ML19326B485
| ML19326B485 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/28/1977 |
| From: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Cavanaugh W ARKANSAS POWER & LIGHT CO. |
| Shared Package | |
| ML19326B479 | List: |
| References | |
| NUDOCS 8004150823 | |
| Download: ML19326B485 (3) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV f
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$11 RYAN PLAZA DRIVE.SulTE 1000 ARLINGTON. TEXAS 76011 4
p*OVj September 28, 1977 Docket No. 50-313 1
Arkansas Power and Light Company ATTN: Mr. William Cavanaugh III Executive Director of Generation and Construction P. O. Box 551 Little Rock, Arkansas. 72203 Gentlemen:
This refers to our letter dated July 1,1977 in response to your letter dated June 22,1977. As mentioned in our July 1 letter, we are' concerned regarding certain aspects of your Emergency Planning Program. These con-cerns were detailed in our letter dated May 16, 1977, with enclosed Notice of Violation and IE Inspection Report No. 50-313/77-08.
i We stated in our July 1,1977 letter that in view of the apparent disagree-ment between our Notice of Violation and y7ur June 22, 1977 resronse, the matter was being forwarded to our Headquarters staff for resolution. The i
following is NRC's position regarding these items:
1.
First Aid Room This item involves Section 4.3.2.a of the ANO-1 Emergency Plan which states:
"A First Aid Room is located near the Unit No. 2 controlled access entrance. The equipment and supplies available in the First Aid Room are listed in Appendix J."
It is not acceptable to have an incorrect statement in the ANO-l Emergency Plan which could lead to confusion and misdirection. You are requested to provide a description of the method to be used to assure that confusion and misdirection are not caused.
Further, you are requested to provide a description of the facilities and equipment which will be provided in the interim until the ANO-2 facilities are available.
It is your position that a verbal agreement was reached between AP&L and NRR at some time prior to issuance of the ANO-1 Operating License which permitted a delay in establishing a First Aid Room until ANO-2 construction was completed.
We have searched our files and reviewed i
the matter with NRR, but were unable to locate any documentation which indicated that any such agreement was ever reached.
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Arkansas Power and Light September 28, 1977 Company A request to changa the ANO-1 FSAR does not appear to be a practical solution since the new facilities would probably be ready before a change to the FSAR would be completed.
2.
Training of Off-Site Support Agencies Our concern regarding this item involved providing training in a timely manner. Your response indicated that you consider " annually" as being any period between two numerical years. For example, if one training session was held on January 1,1975 and the next session on December 31, 1976, this would appear to satisfy your interpretation of " annually" even though the elapsed time involved a 24 month period.
IE normally considers " annually" as being 12 months; however, our legal staff has l
informed us that no legal interpretation of " annually" exists.
Since you indicated that training was accomplished shortly after our inspec-tion, we feel that the inspection program achieved its purpose in assuring that training was provided.
Training requirements will be one of the matters reviewed in Item 3 below.
l No response to this item is required.
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3.
Drill Contents 1'
We are concerned that many of the basic aspects of your Emergency Plan have not been tested during a routine drill.
The scope of your past drills has been rather limited; therefore, we feel that more compre-hensive drill scenarios must be developed in order to test the basic aspects of your Emergency Plan.
Regulatory Guide 1.101 was written to describe a method acceptable to the NRC for complying with the Comission's regulations with regard to the content of emergency plans for nuclear power plants. We recog-nize that Reg. Guide 1.101 was issued after the ANO-1 Emergency Plan was reviewed by NRR.
Consequently, our Headquarters staff advised that the basis for. a deviation against Reg. Guide 1.101 is questionable.
It was initially hoped that by identifying certain aspects of your Emergency Planning Program which we feel are weak, you would make positive comit-ments to improve your program in order to satisfy present acceptable methods.
Since your response indicated that you have no intentions of making such commitments, NRk has been requested to review the ANO Emergency Plan.
This review will include changes necessary in order to correct the apparent weak areas in your Emergency Plan.
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l Arkansas Power and Light September 28,1977 Company No response to this item is required.
Sincerely, i
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[G.L.Madsen, Chief Reactor Operations and Nuclear Support Branch 1
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