ML20028A796

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Public Version of Licensee Response to 821001 Generic Ltr 82-17 Re Inconsistency Between 10CFR50.54(t) Requirements & STS Concerining Reviews/Audits of Emergency Preparedness Programs.Annual Audit Already Required
ML20028A796
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 11/03/1982
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20028A794 List:
References
GL-82-17, LIC-82-359, NUDOCS 8211290042
Download: ML20028A796 (3)


Text

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Omaha Public Power District M' 1823 HAqNEY OMAHA. NESRASNA 68102

  • TELEPHONE 536 4000 AREA CODE 402 November 3, 1982 LIC-82-359 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

Docket No. 50-285 Daar Mr. Eisenhut:

Fort Calhoun Station Emergency Preparedness Program Generic Letter 82-17, dated October 1, 1982, identified an apparent inconsistency between the requirements of 10 CFR 50.54(t) and the Standard Technical Specifications regarding reviews / audits of L^ergency Preparedness Programs. The District has reviewed the requirements of 10 CFR 50.5a(t) and has compared them with the present review / audit provi-sions in the Fort Calhoun Station Technical Specifications (TS) and Radiological Emergency Response Plan (RERP). The subject Code of Federal Regulations (CFP) section states ". . . the licensee shall provide for a review of its emergency preparedness program at least every twelve months by persons who have no direct responsibility for implementation of the emergency preparedness program." RERP Section P.2.2, " Audits of the Emergency Plan", Part 2.2.2 (a copy is attached) requires that this annual independent review be conducted and also details that all reporting and retention requirements of 10 CFR 50.54(t) for this review are felfilled.

The Combustion Engineering Standard Technical Specifications (STS) do indeed stipulate that an independent " audit" of a plant's emergency preparedr.ess progran be conducted every 24 months. Fort Calhoun Station TS Section 5.5.2.8(e) requires the Safety Audit and Review Committee to ensure that an independent audit of the RERP and Implementing Procedures is completed at least once every two years. Thus, the Fort Calhoun Station TS's presently meet the intent of the STS.

The District interprets the terms " audit" and " review" as utilized in the STS and 10 CFR, respectively, as differing in definition and scope. Generic Letter 82-17 utilizes these two terms interchangeably 8211290042 821117 PDR ADOCK 05000295 -

F PDR

Mr. Darrell G. Eisenhut .

LIC-82-359

Page Two and as a result concludes that a plant's TS's should require Emergency Preparedness Program audits every twelve months. By the District's interpretation of these terms, the Fort Calhoun Station presently has in place controls which fulfill the independent " audit" and " review" requirements as defined in their applicable source documents and, as such, no TS changes are necessary for the Fort Calhoun Station.

Si rely, ahW' W. C. Jones fu Division Manager Production Operations WCJ/TLP:jmm cc: LeBoeuf, Lamb, Leiby & MacRae 1333 New Hamoshire Avenue, N.W.

Washington, D.C. 20036 4

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P-2 P- RESPONSIBILITY FOR THE PLANNING EFFORT: DEVE.0PMENT, PERIODIC REVIEW AND DISTRIBUTION (Continued) 2.0 Review and Update of the Emergency Plan (Continued) 2.2 Audits of the Emergency Plan 2.2.1 Safety Audit and Review Committee Audit The Safety Audit and Review Committee (SARC) will conduct an audit of the Emergency Plan biennially, independent of the PRC review. The audit shall be conducted as outlined in EPT-9. The audit shall include the Radiological Emergency Response Plan, implementing procedures and practices, training, readiness testing, and equipment availability and operability. The results of this audit shall be documented and distributed as specified in Technical Specifications 5.5.2.10.c.

2.2.2 Independent Review The Emergency Plan will be reviewed on an annual basis by an independent organization. The Emergency Coordinator will be responsible for assuring that this review is performed. The review shall be con-ducted as outlined in EPT-9. The review will in-clude the Radiological Emergency Response Plan, t'he implementing procedures and practices, training, readiness testing, equipment availability and oper-ability, and interfaces with state and local govern-ments. Results of this audit will be documented, reported to the appropriate plant and corporate management, as well as any involved federal, state and local organizations. The results of this audit shall be retained for a minimum of five (5) years.

2.3 Update of Emergency Telephone Numbers Emergency telephone numbers will be updated on a quarterly basis, in accordance with Emergency Preparedness Test #5 (EPT-5), " Update of Emergency Telephone Numbers." Any changes in phone numbers or organizations will be documented and a revision to the Radiological Emergency Response Plan will be generated.

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