ML15224A267

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Discusses Emergency Plan Rev 92-2 & Forwards Plan Inconsistencies Consisting of Three Changes Inconsistent W/Crisis Mgt Plan
ML15224A267
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 06/22/1993
From: Cline W
NRC Office of Inspection & Enforcement (IE Region II)
To: Hampton J
Duke Power Co
References
NUDOCS 9307120061
Download: ML15224A267 (6)


Text

FORD 1 REGULATEO INFORMATION DISTRIBUTION OSTEM (RIDS)

,ACCESSION NBR:9307120061 DOC.DATE: 93/06/22 NOTARIZED: NO DOCKET #

FACIL:50-269 Oconee Nuclear Station, Unit 1, Duke Power Co.

05000269 50-270 Oconee Nuclear Station, Unit 2, Duke Power Co.

05000270 50-287 Oconee Nuclear Station, Unit 3, Duke Power Co.

05000287 AUTH.NAME AUTHOR AFFILIATION CLINE,W.E.

Region 2 (Post 820201)

RECIP.NAME RECIPIENT AFFILIATION R

HAMPTON,J.W.

Duke Power Co.

SUBJECT:

Discusses emergency plan rev 92-2 & forwards plan inconsistencies consisting of three changes inconsistent w/crisis mgt plan.

D DISTRIBUTION CODE: IE35D COPIES RECEIVED:LTR ENCL /

SIZE:

S TITLE: Emergency Preparedness-Appraisal/Confirmatory Action Ltr/Exercise Re#

F NOTES:

RECIPIENT COPIES RECIPIENT COPIES 0

ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL R

PD2-3 PD 1

1 WIENS,L 1

1 INTERNAL: AEOD/DOA/IRB 1

1 NRR/DRSS/PEPB9D 1

1 D

NRR/PMAS/ILRB12 1

1 NUDOCS-ABSTRACT 1

1 OC B 1

0 OE DIR 1

1 EGFIL 02 1

1 RGN2 FILE 01 1

1 1

EXTERNAL: NRC PDR 1

1 NSIC 1

1 D

0 C

U M

E T

NOTE TO ALL 'RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE! CONTACT THE DOCUMENT CONTROL DESK.

ROOM Pl-37 (EXT. 504-2065) TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED: LTTR 12 ENCL 11

JUNi2 2 1993 Docket Nos. 50-269, 50-270, 50-287 License Nos. DPR-38, DPR-47, DPR-55 Duke Power Company ATTN: Mr. J. W. Hampton Vice President Oconee Site P. 0. Box 1439 Seneca, SC 29679 Gentlemen:

SUBJECT:

OCONEE NUCLEAR STATION EMERGENCY PLAN REVISION 92-2 We have completed our review of the subject submittal.

Based on our review, we have concluded that three of the changes were inconsistent with the previous NRC approved Crisis Management Plan and/or guidance in NUREG-0654.

The items were discussed between C. Jennings of your staff and A. Gooden of the Region II staff during teleconference calls in May 1993. The inconsistencies are discussed in the Enclosure. You should not continue to implement the changes deemed inconsistent. Please modify your Plan to correct the appropriate pages. We request that the corrections be provided to us within 45 days of the date of this letter. It is our understanding that the appropriate changes resolving the inconsistencies will be incorporated into a Plan revision during July 1993. If your understanding on this matter is different from that discussed, please contact this office immediately.

Should you have any questions regarding this letter, please contact Mr. Kenneth P. Barr of our staff at (404) 331-0335.

Sincerely, ORIGINAL SIGNED BY WLLAM E. CLINE William E. Cline,' Chief Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards

Enclosure:

Plan Inconsistencies cc w/encl:

(see page 2) 9307120061 930622 PDR ADOCK 05000269 F

PDR

Duke Power Company 2

cc w/encl:

M. E. Patrick Compliance Duke Power Company P. 0. Box 1439 Seneca, SC 29679 A. V. Carr, Esq.

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 County Supervisor of Oconee County Walhalla, SC 29621 Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MD 20852 J. Michael McGarry, III, Esq.

Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Heyward G. Shealy, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035 G. A. Copp Licensing - ECO50 Duke Power Company P. 0. Box 1006 Charlotte, NC 28201-1006 cc w/encl:

(cont'd on page 3)

Duke Power Company 3

cc w/encl:

(cont'd)

Karen E. Long Assistant Attorney General N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602 bcc w/encl:

L. Wiens, NRR W. Miller, RH M. S. Lesser, RH A. R. Herdt, RH S. J. Vias, RH Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678 RH:, SS RI :D RII:DP AGooden atr

-Wij-e--Lessee, Iltl 9 3V93 lbll9 3

ENCLOSURE PLAN INCONSISTENCIES A.

Onsite Emergency Organization Page B-2, Section B.4, Functional Responsibilities of the Emergency Coordinator The referenced section discussed the role and responsibility of the Emergency Coordinator and EOF Director in making protective action recommendations to the State and county agencies. This responsibility was identified as non-delegatable.

Various sections of the Plan and Emergency Plan Implementing Procedures infer that there are additional responsibilities which are vested solely with the Emergency Coordinator or EOF Director and hence are non-delegatable. Two examples are: 1) Emergency Plan Figures B-5 (Emergency Coordinator Duties) and 8-6 (Emergency Operations Facility Director) states "Escalate, de-escalate, terminate emergency classification." 2) Implementing Procedures RP/O/A/5000/02 thru RP/O/A/5000/05, Section 2 (Immediate Actions) includes "NOTE: Emergency Coordinator shall complete Item 16 when message is approved for transmission." The required approval of the Emergency Coordinator at line item 16 on the Emergency Notification Form signify responsibility for event classification and notification. The aforementioned responsibilities are examples which should be clearly defined to avoid ambiguity regarding who is in charge as various facilities become operational and what responsibilities may not be delegated (e.g.

event classification, event escalation, reduction, or closeout).

Non-delegatable responsibilities were discussed with a member of your staff (C. Jennings) during April and May 1993. A commitment was made to include as non-delegatable responsibilities, in addition to protective action recommendations (PARs), event classification, notification, and event escalation/de escalation/termination in the next Plan revision.

B.

Public Information and Education Page G-1, Section G.1/G.2, Public Information - Public Brochure This section, previously discussed in the Crisis Management Implementing Procedure (CMIP) and the Crisis Management Plan, was transferred to the referenced sections of the site Plan. The previous public information program commitments for the transient population stated: "The public information program for the transient population will include signs or stickers posted in places where the transient population are likely to be found.

This will include motels, hotels, police stations, fire stations, public libraries, post offices, lake access areas and Duke Power Company retail offices." The revised Plan commitment deleted the reference to use of signs as follows: "The public information program for the transient population will consist of several full-

Enclosure size emergency planning brochures/calendars and special transient brochures. They will be located at motels, hotels, police stations, fire stations, public libraries, post offices, marinas and Duke Power local retail offices."

The implementation of a special transient brochure is considered a Plan improvement. However, discontinued use of signs around recreational areas and/or lake access areas is considered a decrease in the effectiveness of your capability to provide appropriate information to the transient population within the EPZ that may be helpful in the event of an emergency. The referenced deletion was discussed with a member of your staff on May 24, 1993, as a decrease in the effectiveness of the transient notification and public information program around recreational areas when compared to NUREG-0654,Section II.G.2, or the previous Plan. A commitment was made to reinstate the previous Plan description regarding the use of signs.

C.

Exercises and Drills Page N-1, Sections N.1a and N.1b, Exercises The previous Plan commitments for exercise st&rting time was found in Section N of the Crisis Management Plan and read as follows:

"The exercises will be initiated at various times of the day, but in every six year period, one exercise at each station will begin between 6:00 P.M. and 4:00 A.M."

The revised Plan does not address the exercise starting time, and is therefore inconsistent in meeting the previous Plan commitment and guidance in NUREG-0654,Section II.N.1.b. The referenced omission/deletion was discussed with a member of your staff on May 25, 1993. A commitment was made to reinstate the appropriate details during the next Plan revision."