IR 05000424/1993005
| ML20035G950 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/13/1993 |
| From: | Barr K, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035G945 | List: |
| References | |
| 50-424-93-05, 50-424-93-5, 50-425-93-05, 50-425-93-5, NUDOCS 9304300214 | |
| Download: ML20035G950 (11) | |
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UNITED STATES
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'fg-WUCLEAR REGULATORY COMMISslON I
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101 MARIETTA STREET, N.W.
' t ATLANTA, GEORGIA 30323
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APR I 51993
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Report Nos.:
50-424/93-05 and 50-425/93-05 l
Licensee: Georgia Power Company Docket Nos.:
50-424, 50-425 License Nos.: NPF-68, NPF-81.
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Facility Name:
Vogtle Electric Generating Plant Inspection Contucted: M rch 22-2, 1993
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$317 tid'
d4M Inspector:
A s
J. L Kre Radiation Specialist Date Signed Approved by:
M dd/3. /773
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P'. Ba'r M hief>
f) ate Sitjned
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Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
This routine, announced inspection was conducted to assess the operational
readiness of the site emergency preparedness program, and. included selective
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review of the following programmatic areas:
(1) Emergency Plan and associated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) training and-(5) independent and internal audits and reviews.
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Results:
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In the areas inspected, no violations or deviations were identified.
Program
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strengths included overall management of the emergency planning effort, t
emergency response training of Shift Superintendents, and maintenance of emergency response facilities and equipment.
9304300214 930415 PDR ADOCK 05000424 G
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REPORT DETAILS
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1.
Persons Contacted Licensee Employees
- J. Beasley, Assistant General Manager, Plant Operations
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- R. Brown, Manager, Training and Emergency Preparedness (Acting)
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- W. Burmeister, Manager, Engineering Support l
P. Burwinkel, Plant Engineering Supervisor (Heating, Ventilation, j
and Air Conditioning; Fire Protection)
- S. Chestnut, Manager, Technical Support
- G. Frederick, Manager, Maintenance
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- K. Holmes, Manager, Operations
- W. Kitchens, Assistant General Manager, Plant Support
- R. LeGrand, Manager, Health Physics and Chemistry
- L. Mayo, Emergency Preparedness Specialist
- J. Roberts, Emergency Preparedness Coordinator
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D. Schreiber, Unit Shift Supervisor
- W. Shipman, General Manager
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- C. Stinespring, Manager, Plant Administration j
- J. Swartzwelder, Manager, Outage and Planning C. Williams, Shift Superintendent
Other licensee employees contacted during this inspection included i
operators, security force' members, technicians,.ind administrative
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personnel..
Nuclear Regulatory Commission
- P. Balmain, Resident Inspector
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- B. Bonser, Senior Resident Inspector
- W. Cline, Branch Chief, Region II
- J. Starefos, Reactor Engineer.(Intern)
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- D. Starkey, Resident Inspector
- Attended exit interview on March 26, 1993 Abbreviations used throughout this report are listed in the last i
paragraph.
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2.
Emergency Plan and Implementing Procedures (82701)
This area was inspected to determine whether significant changes were
made in the licensee's emergency preparedness program since February 1992 (the date of the last such inspection of this area), to assess the
' impact of any such changes on the overall state of emergency
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preparedness-at the facility, and to' determine whether the licensee's actions in response to actual emergencies were in 'accordance with the Emergency Plan and its implementing procedures.
Requirements applicable to this area are found in 10 CFR 50.47(b)(16), 10 CFR 50.54(q),
i Appendix E to 10 CFR Part 50, and the licensee's Emergency Plan.
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The inspector reviewed the licensee's system for making changes to the Emergency Plan and the EPIPs. Through selective review of applicable documents, the inspector confirmed that licensee management approved
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revisions to the Emergency Plan and EPIPs, as required.
Copies of the Emergency Plan, EPIPs, and the VEGP Emergency Response Telephone Directory (latest quarterly revision dated December 10, 1992) were i
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available for use at the CR, TSC, OSC, and EOF, and were found to be current revisions.
The version of the Vogtle Emergency Plan in effect at the time of the
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I current inspection was Revision 17.
Since the aforementioned February
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1992 inspection, the NRC had completed licensing reviews of Revisions 14 and 16. The NRC's reviews of Revisions 15 and 17 were in progress at
the time of the current inspection.
Revision 15, which was a major
change involving conversion of the licensee's EAls to the NUMARC methodology, was required to be submitted for prior approval, and had
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thus not yet been implemented.
During this inspection, the inspector j
did not identify any decrease in the effectiveness of the licensee's
Emergency Plan caused by the changes made in Revision 17 (which was the
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only Plan revision that has been implemented by the licensee but not yet i
reviewed by the NRC).
The NRC's formal review of Revision 17 changes
will be the subject of separate correspondence.
r Revisions to the EPIPs since February 1992 were discussed with the EPC.
M ons miaor modifications were made to upgrade and/or clarify the EPIPs during this period. Completion in September 1992 of the ERDS communications link with the NRC Headquarters Operations Center resulted in the line-item assignment of responsibility for activation of the
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ERDS. This was designated in EPIPs 91103-C, " Duties of the TSC
Manager," and 91111-C, " Duties of the Chemistry Supervisor (TSC)"
f Revisions 10 and 4, respectively, both dated September 25, 1992). The
.actual procedure for ERDS activation was located on the wall in the TSC
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adjacent to the two ERDS terminals. The inspector's review of these and
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other selected EPIP changes disclosed none that decreased the l
effectiveness of the licensee's emergency preparedness program or response capability.
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The inspector reviewed records pertaining to the one emergency declaration made between January 1, 1992 and the date of the current
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inspection. The event was classified at the NOUE level, and is
summarized as follows:
TIME DECLARED /
DATE TERMINATED DESCRIPTION OF EVENT 05/14/92 3:37 a.m./7:45 p.m.
Unidentified Unit 1 RCS leak rate of
2.6 gpm, exceeding the TS limit of I gpm (the unit was ultimately shut down from 100% power to repair the leak caused by a cracked pipe weld)
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The inspector's assessment concluded that the event described above was
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correctly classified based on the licensee's EAls, and that j
notifications thereof to State and local governments and the NRC were j
d made in accordance with applicable requirements. The emergency
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preparedness staff routinely reviewed the response to each emergency
declaration in an effort to identify problems or inconsistencies which
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may have occurred with respect to the requirements of the EPIPs.
i Appendix 2 of the Emergency Plan displayed the letters of agreement
which the licensee maintaired with offsite support organizations, j
including State and local covernment agencies.
Section P of the Plan
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stated that these agreements would be updated as necessary.
Between October 1992 and March 1993, the licensee had renewed all of the subject
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agreements, and planned to incorporate these in Revision 18 of the Plan.
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Between January 1, 1992 and the date of the current inspection, the licensee promulgated 27 revisions to the EPIPs, which were transmitted to the NRC and other copyholders in 15 separate submittals.
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inspector conducted a complete audit of the records of these submittals,
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and determined that each of the referenced EPIP revisions had been
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transmitted to the NRC within 30 days of the implementation date, as
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required.
No violations or deviations were identified.
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3.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
This area was inspected to determine whether the licensee's ERFs and associated equipment, instrumentation, and supplies were maintained in a
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state of operational readiness, and to assess.the impact of any changes
in this area upon the emergency preparedness program.
Requirements I
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applicable to this area are found in 10 CFR 50.47(b)(8) and (9),
10 CFR 50.54(q),Section IV.E of Appendix E to 10 CFR Part 50, and the
licensee's Emergency Plan.
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The inspector toured the licensee's ERFs, which included the CR, TSC,
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Selective examination of emergency equipment, supplies,
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and communications systems located in these facilities identified no
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inoperable or absent components, and indicated that the licensee was l
maintaining a satisfactory level of operational readiness for responding
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to an emergency.
The TSC (described in Section H.1 of the Emergency Plan) was located adjacent to the CR and was relatively small, although the layout made
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efficient use of the available space. The only significant modification made to the TSC since the February 1992 inspection was the installation
of two ERDS terminals in an ancillary equipment room. The licensee i
planned to begin quarterly testing of the ERDS (as required by i
Section VI.1 of Appendix E to 10 CFR Part 50) starting in the second
quarter of 1993.
A description of ERDS had recently been incorporated into the Emergency Plan (Section H.4.3.h).
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The ventilation system for the TSC was separate from that of the CR.
The TSC's ventilation system could be switched to the emergency mode manually and independently of the CR for testing or-any other reason.
l More importantly, actuation of the TSC's emergency ventilation mode was
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" shad" to that of the CR, with actuation of both systems designed to occur automatically upon Safety Injection or when a high radiation level setpoint was exceeded on the CR air intake. As a result of this
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arrangement, the emergency mode of the TSC ventilation system received a
monthly functional test in conjunction with that performed for the CR.
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The EOF (described in Section H.3 of the Emergency Plan) was located in l
the Training Center building, about 1.5 mile from the plant.
It was a
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well-designed facility with ample space for accommodating State, local, and Federal representatives, as has been demonstrated during past
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emergency response exercises.
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The Plan stated that " Normal power to the training center, including the
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EOF, is provided from a reliable offsite source." The inspector discussed this-statement with the EPC in the context of the facility i
design, which did not include a local emergency generator to provide power to the E0F if needed. The EPC stated that this arrangement was based upon an engineering decision regarding the reliability and multiplicity of offsite power sources. Natural-gas-fired peaking units at the licensee's Plant Wilson, located less than 1 mile from the EOF,
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were considered highly dependable sources of backup power for the EOF because of their proximity and inherent reliability.
In addition, a
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backup EOF, located at a licensee office in Waynesboro, Georgia, approximately 16 miles from the VEGP, was available if the primary EOF became uninhabitable or unusable for any reason. The EPC stated that an integrated drill involving use of the backup EOF was planned for the
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near future.
The inspector selectively reviewed completed documentation for each of the following facility / equipment surveillance procedures for the period
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January 1, 1992 through the date of the current inspection:
o 54031-C, " Technical Support Center HVAC System Test" (18-month
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frequency; last performed October 13,1992)
o 54039-C, " EOF Filtration System HEPA Filters Test" (18-month
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frequency; last performed September 30,1992)
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91705-C, " Inventory and Testing of Emergency Preparedness l
Material / Equipment..." -- Data Sheet 7, " Monthly EOF-Ventilation Operational Testing" o
91204-C, " Emergency Response Communications" (monthly, quarterly, and annual test frequencies)
o 91702-C, " Emergency Equipment and Supplies" (quarterly)
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The listed surveillance procedures had been performed at the required frequencies, and the documentation indicated that identified problems
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were corrected expeditiously. The licensee's program for maintenance and inventory of ERFs and associated emergency equipment was very thorough, and was judged to be a strength in the emergency preparedness
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program.
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i The inspector reviewed the operational readiness of the Alert and Notification System, which was described in Appendix 3 to the Emergency Pl an.
The system included 48 fixed sirens and numerous tone-alert
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radios in the 10-mile EPZ around VEGP. The tone-alert radios employed i
the NOAA Alert System and would be activated by the National Weather i
Service at the request of cognizant governmental authorities in the
event of an emergency requiring warning of the public.
Licensee data
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provided to FEMA showed an overall siren availability of 98% in 1992.
This availability factor included results of all siren testing for the i'
year (i.e., silent, growl, and full-cycle modes).
During the annual
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full-cycle test conaucted in conjunction with the exercise on May 19, 1992, all sirens worked properly, according to information obtained from the computerized siren feedback system.
Shortly after the activation of
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the ANS on May 19, the licensee conducted a telephone survey which determined that 91.5% of contacted households reported hearing one or
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both methods of notification.
(This calculation properly excluded those_
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surveyed households which reported that no one was home at the time of
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ANS activation.) The inspector reviewed documentation of the annual
preventive maintenance program for the sirens, which was performed in
accordance with Maintenance Procedure 25722-C, " Emergency Alert Siren
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Performance Check." These records indicated that problems, where identified, were promptly corrected.
Based upon ERF walk-downs, review of changes to the EPIPs, inspection of s
selected emergency equipment and supplies, and statements by licensee representatives, the inspector concluded that no degradation of ERF
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capabilities had occurred since February 1992.
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No violations or deviations were identified.
4.
Organization and Management Control (82701)
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This area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on the emergency preparedness program, and to verify that any such i
changes were properly factored into the Emergency Plan and EPIPs.
Requirements applicable to this area are found in 10 CFR 50.47(b)(1)
and (16),Section IV.A of Appendix E to 10 CFR Part 50, and the
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licensee's Emergency Plan.
The organization and management of the emergency preparedness program
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were reviewed and discussed with licensee representatives. No changes
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in the site organization had occurred which affected the management or
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reporting chain for the emergency preparedness program. Organizational
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changes at the corporate level resulted in the shift of responsibility
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from the corporate office to the site for all interfaces with offsite support agencies, including hospitals.
Emergency preparedness program support for VEGP from the corporate office was reduced to a level of only one part-time individual. The EPC did not view this change as having a rignificant impact upon his ability to manage or execute program responsibilities.
The inspector discussed the status of offsite interfaces with the EPC.
No significant problems existed with these interfaces, according to the EPC.
It is noted here for the record that changes in management personnel for offsite support agencies since the February 1992 inspection included a new (acting) Director of Emergency Management for Allendale County (SC) and a new Director of the Emergency Preparedness Division for the State of South Carolina.
l The inspector reviewed the licensee's management strategy for ensuring compliance with the Emergency Plan requirements addressing the planning
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standard of 10 CFR 50.47(b)(2), which specifies that " timely j
augmentation of response capabilities is available." The only Emergency l
Plan requirements concerning off-hour testing of the licensee's
augmentation capability (as specified in Table B-1 of the Plan) were
contained in Section N.I.2, which stipulated that the annual evaluated exercise would start between 6:00 p.m. and 4:00 a.m. once every six
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years.
In addition, the licensee was conducting quarterly recall tests
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and an annual recall drill (with the latter involving actual travel to the plant) to provide assurance of a continuing capability to activate
.l the ERO in a timely manner during off hours. These tests and drills l
were being performed as part of a licensee initiative, and were not required by the Emergency Plan.
The quarterly recall tests employed a combination of pager and computer-driven telephonic notifications, with
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a real-time telephonic response by the recipient of such a notification'
registering information on that individual's availability. As l
previously indicated, this was a management control strategy which was not required by the Emergency Plan.
The results of these quarterly tests conducted during the past year (most recently on March 2, 1993)
provided the licensee a high level of confidence that personnel would be available to staff ERFs during off-hours in accordance with Emergency Plan commitments.
The last annual recall drill was conducted in
November 1992 and was reviewed during a previous inspection (see
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Paragraph 5 of NRC Inspection Report Nos. 50-424, 50-425/92-29).
- The inspector determined that the following NRC Information Notices
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applicable to emergency planning were received by the licensee since
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February 1992 and distributed to cognizant personnel, and that
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corrective actions, as appropriate, were completed or scheduled:
Problems identified With Emergency Ventilation Systems for Hear-Site (Within 10 Miles) Emergency Operations
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Facilities and Technical Support Centers
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Implementation Date for the Revision to the EPA i
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Manual of Protective Action Guides and Protective Actions for Nuclear Incidents l
Emergency Response Information Requirements for
Radioactive Material Shipments l
o IN No. 93-07: Classification of Transportation Emergencies
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For IN No. 92-38, the licensee had determined a need to develop an action plan to properly address the issues.
No violations or deviations were identified.
5.
Training (82701)
This area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their i
emergency responsibilities.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15),Section IV.E of Appendix E to 10 CFR Part 50, and the licensee's Emergency Plan.
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The inspector reviewed the description of the licensee's emergency
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response training program as contained in Section 0 of the Emergency Pl an.
Also reviewed were the training objectives and associated lesson plans for several key ERO positions. The training material content
appeared appropriate relative to the need to address the duties and responsibilities of each of the selected positions.
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The status of the training program was evaluated by selecting names of six key ERO personnel from the weekly " Duty Call Out Roster" and reviewing individual source records in the Training Department files to verify that applicable training requirements were being implemented.
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This review disclosed that, for the sample of personnel in question, the required training had been provided and was current, based on the criteria contained in the Emergency Plan and EPIPs.
j In an effort to gauge the effectiveness of the emergency response
training program, the inspector conducted an interview with one Shift Superintendent, the position designated as interim ED. This interview was designed to ascertain the (potential) ED's understanding of
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emergency classification, offsite notifications and PARS, site evacuation, emergency worker dose limits, and nondelegable responsibilities of the ED. This 75-minute interview began with technical questions relating to the duties, responsibilities, and functions of the ED during an emergency situation, and then presented six accident scenarios that required event classification and PAR formulation, as appropriate. The inspector delineated the guidelines.
for the interview at the outset, including the "open book" nature of the
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evaluation. The Training and Emergency Preparedness Manager (Acting)
was present during the interview to allow for confirmation and firsthand
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understanding of observations. The Shift Superintendent was judged by
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the inspector to have demonstrated an excellent understanding of his duties and responsibilities in the event of an emergency. All emergency classifications and PARS were timely and correct. No concerns were identified during the interview.
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The inspector reviewed the licensee's assessment and documentation of
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ERO performance during the six emergency response training drills
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conducted since January 1, 1992.
Much of this drill activity was not specifically required by the Emergency Plan, but rather was conducted in order to ensure a continuing high level of ERO response capability. The inspector determined that drill critiques identified substantive issues -
for corrective action and that the licensee was either monitoring the status and' progress of such planned corrective actions or had completed same. The inspector reviewed the critique records for indications of
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repetitive performance problems during 1992. No adverse trends were identified. This schedule of quarterly training drills suggested a high level of dedication of the licensee's resources to maintaining and
improving emergency response capabilities, and was considered indicative of station management's commitment to the emergency preparedness
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program.
No violations or deviations were identified.
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6.
Independent and Internal Reviews / Audits (82701)
i This area was inspected to determine whether the licensee had performed
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an independent audit of the emergency preparedness program, and whether
the emergency planning staff had conducted a review of the Plan and the i
Requirements applicable to' this area are found in 10 CFR 50.54(t) and the licensee's Emergency Plan.
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The inspector reviewed reports documenting the annual independent audits
of the VEGP emergency preparedness program conducted during 1992.
These
audits were conducted by the licensee's SAER Department as follows:
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o Audit No. OP12-92/09, cor. ducted February 25 - March 12, 1992; report dated March 18, 1992 o
Audit No. OP12-92/41, conducted December 7-18, 1992; report dated January 11, 1993 l
o Audit No. 92-3, conducted April 6 - May 9, 1992; report dated i
June 10, 1992 (this audit addressed corporate support to VEGP,
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corporate communications, and interfaces with State and local governments)
l In the aggregate, these audits scrutinized the implementation of the
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Emergency Plan and EPIPs, training, drills and exercises, facilities and
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equipment, interfaces with offsite agencies, and program documentation.
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Among the three audits, one issue was identified as a " finding" (several others were presented as " comments"). The finding concerned failure to
conduct habitability surveys of the primary and alternate PESB during a.
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- February 1992 drill observed by the audit team.
In that this was a
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repeat of a problem which had been identified during the 1991 exercise by both the licensee critique and the SAER observers (Audit
No. OP12-91/18), the inspector questioned the EPC regarding the i
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effectiveness of the corrective actions for the original and the repeat finding. The EPC stated that special training was provided to health:
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i physics personnel to address the original finding, and that the repeat finding resulted from oversight on the part of an individual serving for
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the first time as OSC Manager.
SAER records indicated that this matter
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was considered closed.
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Section P of the Emergency Plan required an annual review of the Plan f
and a biennial review of the EPIPs by the EPC. The most recent annual internal review of the Emergency Plan was completed on December 31, i
1992, according to licensee documentation.
This review identified minor problems which were corrected-in subsequent revisions to the Plan. The
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relatively large number of EPIP revisions suggested that the required
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reviews were effective in identifying procedures in need of correction and/or updating. The EPC used a computer-based system to effectively track the biennial EPIP evaluations, since the review eff'.,rt was
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distributed over the specified two-year cycle.
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No violations or deviations were identified.
7.
Licensee Action on Previous Inspection Findings i
a.
(Closed) IFI 50-424, 50-425/92-29-01:
Revising EPIP 91305-C and
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providing training to ensure consistency in the development of
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PARS.
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The inspector verified completion of the following actions which
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the licensee had agreed to take, as noted in the previous inspection report: (1) a concise " lessons learned" letter was issued to cognizant personnel regarding the minimum PAR for a General Emergency, and (2) EPIP 91305-C (Revision 11, dated March 1,1993) clarified the use of dose assessment results in
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modifying a PAR and added an observable action level to define
"large fission product inventory in containment" by means of a
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containment high-range radiation monitor reading which was calculated as equivalent to 20% gap activity released to
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containment. The inspector had no further questions on this
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matter.
b.
(Closed) IFI 50-424, 50-425/92-29-02:
Verifying licensee actions to address problems with use of default values in dose assessment.
The inspector verified completion of the following actions with-I
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respect to the subject issue: (1) a concise " lessons learned" letter was issued to dose assessment personnel regarding the need'
l to be aware of the conservatism inherent in the VIBRANT computer
code default values, and to appropriately modify the calculational j
results when more realistic input data become available, and
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(2) Training Lesson Plan No. RE-LP-02001-05-C was modified to incorporate the cautionary guidance described above, and will be
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used in this year's annual retraining of Health Physics Foremen.
These actions appeared sufficient to satisfactorily resolve the concern raised by this IFI.
8.
Exit Interview
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The inspection scope and results were summarized on March 26, 1993, with those persons indicated in Paragraph 1.
The inspector described the
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areas reviewed and discussed the inspection results in detail, including the program strengths listed in the " Summary" section of this report and the closures of the two previous inspection findings as delineated in Paragraph 7.
Although proprietary information was reviewed during this inspection, none is contained in this report.
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Abbreviations Used in This Report ANS Alert and Notification System CFR Code of Federal Regulations
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t CR Control Room EAL Emergency Action Level ED Emergency Director E0F Emergency Operations Facility EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure i
EPC Emergency Planning Coordinator
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EPZ Emergency P1anning Zone ERDS Emergency Response Data System ERF Emergency Response Facility
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ERO Emergency Response Organization FEMA Federal Emergency Management Agency gpm gallons per minute HEPA high-efficiency particulate air HVAC heating, ventilation, and air conditioning IFI Inspector Follow-up Item IN Information Notice NOAA National Oceanic and Atmospheric Administration NOUE Notification of Unusual Event NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council OSC Operational Support Center i
PAR Protective Action Recommendation PESB Plant Entry and Security Building RCS Reactor Coolant System SAER Safety Audit and Engineering Review TS Technical Specification
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TSC Technical Support Center VEGP Vogtle Electric Generating Plant i
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