ML20053A955
| ML20053A955 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 02/17/1982 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | John Miller GEORGIA POWER CO. |
| Shared Package | |
| ML20053A914 | List: |
| References | |
| NUDOCS 8205270498 | |
| Download: ML20053A955 (3) | |
See also: IR 05000321/1981030
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FEB 171982
Docket Nos. 50-321 and 50-366
Georgia Power Company
ATTN:
Mr. J. H. Miller, Jr.
Executive Vice President
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
SUBJECT:
Emergency Preparedness Appraisal
To $ 3rify that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals at each power reactor site. These appraisals are being perfomed in
lieu of certain routine inspections normally conducted in the area of emergency
preparedness. The objectives of the appraisal at each facility are to evaluate
the overall adequacy and effectiveness of emergency preparedness and to identify
areas of weakness that need to be strengthened. We will use the findings from
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these appraisals as a basis not only for requesting individual applicant and
licensee action to correct deficiencies and effect improvements, but also for
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effecting improvements in NRC requirements and guidance.
During the period of November 30 to December 11, 1981, the NRC conducted an
appraisal of the emergency preparedness program at the Hatch Nuclear Station.
Areas examined during this appraisal are described in the enclosed report
(50-321/81-30,50-366/81-30). Within these areas, the appraisal team reviewed
selected procedures and representative records, inspected emergency facilities
and equipment, observed work practices, and interviewed personnel. The
appraisal findings were discussed with Mr. J. T. Beckham, Jr., and Mr. M. Manry
at the conclusion of the appraisal.
In addition, Georgia Power Company
management representatives met with Region II management on January 7,1982, to
discuss the status of the emergency preparedness program.
Energency preparedness deficiencies identified during this appraisal, for which
you have made acceptable commitments to resolve, were discussed in our confirma-
tory letter, ( Appendix A) dated December 17, 1981. This is to infom you that if
the deficiencies are not corrected by the commitment dates provided, the
Commission will determine whether enforcement action is appropriate.
The findings of this appraisal also indicate that there are other areas which
should be considered for improvenent in your emergency preparedness program.
These areas are identified in Appendix B, "Prepareaness Improvement Items," and
are discussed in the body of the enclosed report.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendix B may not currently exist.
Notwithstanding this, you are
requested to submit a written statement within thirty (30) days of the date of
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FEB 171982
Georgia Power Company
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this letter, addressing the results of your consideration of each of the items in
Appendix B.
This request is made pursuant to Section 50.54(f) of Part 50, Title
10, Code of Federal Regulations.
Your corrective actions are to be incorporated
into the sita emergency plan and procedures as appropriate.
.
In conjunction with this appraisal, the emergency plan for your facility was
reviewed to insure compliance with applicable regulations. The results of this
review, included as Attachment 2 to the enclosed report, indicate that certain
areas of your plan do not contain sufficient information to demonstrate
compliance with the planning standards of 10 CFR 50.47(b).
Changes to the
emergency plan to correct these areas are to be provided to this office and the
Office of fluclear Reactor Regulation within 30 days of the date of such change in
accordance with 10 CFR 50.54(q).
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will
be placed in the f1RC's Public Document poom unless you notify this office, by
telephone, within ten days of the date of this letter and submit written applica-
tion to withhold information contained therein within thirty days of the date of
this letter.
Such application rust be consistent with the requirements of
2.790(1).
The responses directed by this letter and the enclosures are not subject to the
clearance procedures of the Office of Management and Budget as required by the
Paperwork Reduction Act 'of 1980, PL 96-511.
Should you have any questions concerning this appraisal, we will be pleased to
discuss them with you.
Sincerely,
fr
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James P. O'Reilly
Regional Administrator
Enclosures:
1.
Appendix A, Confirmation of Action
Letter of December 17, 1981
2.
Appendix B, Preparedness Inprovement Items
3.
Inspection Report flos. 50-321, 366/81-30
cc w/ encl:
J. T. Beckham, Vice President and
General flanager-fiuclear Generation
M. Manry, Plant Manager
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C. E. Belflower, Site QA Supervisor
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Georgia Power Company
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NRC Resident Inspector
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Hugh S. Jordan, Executive Secretary
Document Management Branch
State of Georgia
Emergency Preparedness Licensing Branch, IE:HQ
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Appendix A
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NUCLEAR REGUL ATORY COMMISSION
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Georgia Power Company
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ATTN:
J.
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Miller, Jr.
Executive Vice President
P. O. Box 4545
Atlanta, GA 30302
Gentlemen:
Subject: Confinnation of Action
This refers to a telephone conversation on December 16, 1981, between
Mr. W. A. Widner of your staff and Mr. R. C. Lewis of this office concern-
ing our appraisal of the emergency preparedness program at the E. I. Hatch
facility on November 20 to December 11, 1981.
Our findings were also dis-
cussed on December 11, 1981, by Mr. D. L. Andrews of this office with
Mr. J. T. Beckham, Jr. , Vice President and General Manager-Nuclear Genera-
tion, and Mr. M. Manry, Plant Manager.
With regard to matters discussed, it is our understanding that you have
undertaken or will undertake the following actions to resolve apparent
deficiencies in your emergency preparedness program:
1.
Organization
Specify, in the Emergency Plan, the onsite emergency organization
a.
of plant staff personnel for all shif ts and the relationship be-
twden the energency organization and the duties and responsibilities
of the normal staff complement.
This includes specifying by posi-
tion or title the major tasks to be performed by the persons
assigned to the functional areas of emergency activity.
This
action will be completed by March 1, 1982.
b.
Describe, down to the working level, the auginented emergency
organization.
This includes staffing of the energency respense
facilities, identification by name and/or position the plant
and corporate nunagers and alternates who are to take charge
of the emergency response facilities, and identification of
contractor or other non-licensee personnel, if any, who will
augment the emergency organization.
This action will be com-
pleted by March 1,1982.
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2.
Training
Establish an initial training and annual retraining program for all
a.
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per.sonnel with emergency response responsibilities.
Each program
shall include classroom training, practical exercises and, where
appropriate, hands-on demonstration of each individual's ability
to perfonn assigned emergency functions.
The program shall also
include examinations designed to test the individual's knowledge
of assigned functional responsibilities, and established perfor-
mance levels below which innediate retraining shall be required.
Establishment of the training program will be completed by
April 1,1982.
b.
Implement the training program, described in item 2.a. above, and
provide accelerated initial training for members of the emergency
response organization.
Include in the program implementation,
positive means- to insure that training is maintained current and
that replacement personnel are provided appropriate initial train-
ing prior to being assigned functicnal responsibility within the
emgrgcacy organization.
This program will be in progress by
April 1,1982.
3,
Equinment
Provide special equipment, including shielding and sample transport
container, for post-accident (high activity) containment atmosphere
samples.
This action will be coupleted by February 1,1982.
4.
Procedures
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Revise Procedures llNP 4849, liNP 4850, llNP 4851, and ilNP 4852, con-
a.
.
cerning of fsite dose calculations, to provide:
(1) accurate method-
ology for determining offsite doses, (2) a technical basis for such
calculations, (3) a means to modify dose projections based on sampling
and analytical results, and (4) guidelines for protective action
recomendations based on protective action guides for the general
public.
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b.
Develop a procedure for interim post-accident sampling of contain-
ment atmosphere to include use of the special equipment provided in
accordance with item 3 above, precautions and limitations in the use
of the procedure, analytical methods to be employed for such samples,
and dosimetry and other protective equipment required.
Revise Procedure HNp 4725 concerning offsite radiological monitoring
c.
to resolve significant differences in graphical and analytical solu-
tions resulting from the use of that procedure.
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d.
Develop a procedure for repair and corrective action teams to include expo-
sure limitations for various activities within the plant, protective clothing
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and equipment available for use by the teams, provisions for briefing team
members on plant conditions and potential hazards, and a framework for team
organization.
The above procedures will be revised or developed and incorporated into the
training program by March 1,1982.
5.
Initial Dose Assessnent
Develop an initial dose assessment procedure, and provide training to onshift
personnel who may be required to make initial offsite dose projections.
Include
training in initial offsite protective action recommendations when projected
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doses exceed the lower level protective action guides.
This action will be
completed by February 1,1982.
6.
Report
Submit a written report to this office by April 15, 1982, describing actions
taken in the above areas and, for item 2.b., the percent of training completed
and an estimate of when all initial training will be accomplished.
This letter also confims our arrangements for a meeting at the Region II office on
January 7,1982, at 9:00 a.m. with Georgia Power Company management representatives
to discuss the status of your emergency preparedness program.
Please inform this
of fice immediately if your understanding of these matters is different from that
stated above.
The respons!es requested by this letter are not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction Act
of 1980, PL 96-511.
Sincgrely,
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James P. O'Reilly
Regional Administrator
cc:
J. T. Beckham, Vice President
and General Manager
M. Manry, Plant Manager
C. E. Belflower, Site QA Supervisor
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APPENDIX B
PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of tne Hatch Nuclear Station
Emergency Preparedness Program conducted November 30 to December 11, 1981, the
following items should be considered .or improvement:
(References are to
Sections in 0IE Report No. 50-321,366/81-30).
1.
Developing formal selection and qualification criteria for the onsite
Emergency Planning Coordinator (1.0).
2.
Assigning an onsite Emergency Planning Coordinator (1.0).
3.
Providing a staffing chart for the emergency organization (2.1).
4.
Describing augmented emergency organization at emergency response facilities
(2.1).
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5.
Identifying support organizations with which a formal agreement has been
reached (2.2).
6.
Providing up-to-date copies of the Emergency Plan and Implementing Pro-
cedures in the Control Room (4.1.1.1).
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7.
Identifying an alternate location for OSC personnel (4.1.1.3).
8.
Maintaining keys to sampling areas near the Chemistry Laboratory (4.1.1.5).
9.
Providing equipment and procedures for high activity gaseous effluent
samples (4.1.1.5).
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10.
Providing shielding for the reactor building unt and main stack sampling
equipment (4.1.1.5).
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11.
Establishing procedures for counting high activity samples on or near the
site (4.1.1.5).
12.
Identifying alternate assembly areas for site assembly (4.1.2.1).
13.
Providing decontamination procedures in the decontamination kits (4.1.2.3).
14.
Identifying working space and resources for corporate and non-licensee
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augmentation personnel (4.1.3).
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15.
Revising the inventory procedure for emergency kits (4.2.1.1).
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16.
Completing installation of high range monitors (4.2.1.2).
17. Aligning charts and indicator for wind direction (4.2.1.3).
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Appandix B
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Preparedness fmprovement f tems
18.
Revising EAL for seismic events in terms of instrument parameters (4.2.1.3).
19.
Providing labels and proper charts for meteorological instruments (4.2.1.4).
20.
Identifying alternate sources of meteorological information characteristic of
site condi tions (4.2.1.4).
21. Clarifying EALs (5.1).
22. Reviewing appropriate references to emergency procedures in E0P (5.1).
23.
Including emergency classification information in alam and abnormal
occurrence procedures (5.2).
24. i, aciding references to the Emergency Plan and EIP's in appropriate emer-
gency instructions and procedures (5.3).
25.
Improving data sheet infomation for offsite monitoring teams (5.4.2.1).
26.
Revising procedures to include additional guidance for offsite monitoring
teams (5.4.2.1).
27.
Revising procedures to provide additional guidance to inplant monitoring
teams (5.4.2.3).
28. Deleting statements in the emergency procedures that state that high-level
samples will be sent to offsite vendors for analysis and implement onsite or
nearsite capabilities (5.4.2.4-5.4.2.11).
29.
Re-evaluating post-accident sampling procedures with regard to the number of
persons required to obtain each sample (5.4.2.4-5.4.2.11).
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30.
Clarifying the location to which analysis equipment will be moved if the
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analysis lab is not accessible or has a high background (5.4.2.4-5.4.2.11).
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31.
Detemining counting efficiency factors for the counting shields to be used
with high-level charcoal, silver zeolite, and particulate samples (5.4.2.4-
5.4.2.11).
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32.
Establishing proper procedures for the labeling and disposition of all
post-accident samples (including liquid effluent samples) and consider using
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preformatted data sheets when obtaining the samples (5.4.2.4-5.4.2.11).
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33.
Clarifying the method by which reactor building vent and main stack sample
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are transported from the sampling area to the analysis facility and the
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location of shielding for these samples to be used during transport
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(5.4.2.4-5.4.2.11).
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34.
Resolving conflict in exposure guides in emergency procedures (5.4.3.1).
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Appendix B
3
Preparedness Improvement Items
35.
Revising exposure criterion for obtaining emergency stack monitoring reading
or sample in HilP 4350 and HilP 4826 (5.4.3.1).
36.
Resolving conflict in Sections B and J of the Emergency Plan concerning Site
Evacuation (5.4.3.2).
37.
Developing a procedure for accountability during emergencies (5.4.3.3).
38.
Revising security procedures to reference actions required by the emergency
implementing procedures (5.4.4).
39. Developing a procedure which provides guidance to the Repair and Corrective
Action Teams (5.4.5).
40.
Identifying organizational authority for initiating a recovery phase
(5.4.6).
41. Developing coordinated drill and exercise program (5.5.2).
42.
Including rumor control in the Public Information Program (6.2).
43.
Providing implementing procedure for activating public information program
during an emergency (6.2).
44.
Maintaining accountability for drills and corrective actions or drill
deficiencies (7.1).
45.
Providing additional training in evaluation techniques for offsite emergency
teams (7.2).
46. itaking electronic calculators available to offsite monitoring teams (7.2).