ML20058E845
| ML20058E845 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 10/23/1990 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hairston W GEORGIA POWER CO. |
| References | |
| NUDOCS 9011070373 | |
| Download: ML20058E845 (6) | |
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OCT ss a 4
, Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81
. Georgia Power Company ATTN: Mr. W. G..Hairston, III Senior Vice President -
Nuclear Operations P. O. Box'1295 Birmingham, AL 35201 Gentlemen:
SUBJECT:
V0GTLE ELECTRIC GENERATING PLANT EMERGENCY PLAN REVIEW, REVISION 12 AND PROPOSED REVISION 13
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32 We have completed our review of the subject changes and the justification documentation to support the requested changes.
3 Our review indicated that certain changes are not. consistent with ' the provisions; of 10 CFR 50.47(b),Section II of NUREG-0654, Supplement 1 to -
.NUREG-0737,,and Appendix 1 of NUREG-0654. The inconsistencies in Plan changes
.are specified in the Enclosure.
- To. preclude a violation of regulatory requirements, you should not continue to implement the changes deemed inconsistent until additional justification and documentation have. been' provided to NRC for review and. NRC approval (see Enclosure) has been obtained.
Please modify your Plan to correct those pages necessary.to maintain Plan continuity.
We request that the correction or additional justification be provided to us within 60 days of this letter.
'Should there be further questions or discussion regarding this matter, please contact Mr. William H. Rankin of our staff at (404) 331-5618.
Sincerely, y
/s/
J. Philip Stohr, Director Division of Radiation Safety and Safeguards
Enclosure:
Plan Inconsistencies s
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l ENCLOSURE Plan inconsistencies A. Revision 12 1.
Section D Table D-1 (Sheet 2 of 2)
Item 12 states: As an initiating condition, indications or alarms on process or effluent parameters not functional in Control Room to an extent requiring plant shutdown or other signif'. cant loss of assessment (all meteorological instrumentation) or comunication capability.
This change is inconsistent with NUREG-0654, Appendix 1,'Page 1-5, Item 11 and the previous VEGP EAL which stated " indications or alarms on process or effluent ' parameters not functional in Control Room to an extent requiring plant shutdown or other significant loss of assessment or communication cap' ability (e.g. plant computer, safety parameter display system, all meteorological equipment)."
On September 26, 1990. a discussion with Mr. J. Roberts of your staff elicited a t
commitment regarding the aforementioned emergency action level-(EAL) change to ensure either consistency with Item 11 in Appendix 1 of NUREG-0654 or verification that the revised EAL meets the intent of a
"Mr. Roberts agreed that Revision 14 'of the Vogtle h
Emergency Plan would include the loss of both trains of the Plant Safety Monitoring System (PSMS) as an example of a significant loss of assessment capability for satisfying the Notification of Unusual Event category.
Based on our further review of the PSMS as an assessment tool in providing PWR parameter infonnation, the PSMS was considered unacceptable as an example of a significant loss of assessment capability.
We request that you provide a detailed justification for the deletion of the plant computer and Safety Parameter' Display System from the subject EAL, and deve1op an alternative approach which meets the intent of NUREG-0654, 2.
Section 1.5 Field Monitoring. Page 1-7, First Paragraph:
Respirators were deleted from field monitoring kits.
This deletion is inconsistent with 10 CFR 50;47(b)(10) which requires a range of protective actions (consistent witn Federal guidance) be developed for the plume exposure pathway EPZ for emergency workers and the public.
Section 1.6.3.4 of the Environmental Protection Agency, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" states that radiation exposure from inhalation of gaseous or irators.
particulate. radionuclides may be reduced-by the use of resp (b)(10).
Consequently..this change is inconsistent with 10 CFR 50.47 l
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' Enclosure 2
3.
Section 0. Table 0-2 (Sheet 1 of 2):
SCBA training was deleted as required training for several key positions in the Emergency Response Organization.
The deletion of SCBA training for First Aid Team Members was discussed on September 14, 1990 with Mr. J. Roberts of your staff.
This change does not seem appropriate in view of the potential for First Aid Team Members to enter, or traverse, an area of high airborne contamination to administer first aid to a casualty.
Because this change appears to decrease the effectiveness of the Emergency Plan training, it is requested that you provide a detailed justification as to the appropriateness of the First Aid Team not being required to attend SCBA training.
In addition, include in the justification details regarding administration of first aid to casualties in an area ' potentially contaminated with radioactive
. materials.
4 Section P. Responsibility For the Planning Effort, Page P-1, Second Paragraph:
Frequency 1for the Emergency Preparedness Coordinator (EPC) to _ perform EPIPs review was changed from annually to biannually. _This change is inconsistent with NUREG-0654 Section P.
Section P 4 of NUREG-0654 recommends an annual update-of the Emergency Plan.
Section P.9_of NUREG-0654 recon ends an independent I
review of. the emergency preparedness program at least every 12 months and the review shall include EPIPs.
In addition, Section G.2 of the Corporate Emergency Plan requires an annual review of both the Corporate Plan and the implementing procedures.
Consequently, to-ensure consistency between the Plan, impicmenting procedures, and U
NUREG-0654, Section P the annual review shall be reinstated or
. provide more detailed justification to support a biennial review.
5.
Appendix 4-Emergency Equipment Lists, Page 4-5: Same comments as stated in Item 2 above.
5 B.
Revision 13 The proposed changes involving the augmentation staff arrival time and facility activation time are not consistent with the provisions of 10 CFR 50.47(b), NUREG-0654, Table B-1, and Supplement.1 to NUREG-0737,
-Table 2.
The inconsistencies involve the 75-minute staff arrival time, and the 90-minute activation and operation time for emergency response facilities.
The emergency planning regulation of 10 CFR 50.47(b)(2) requires that timely augmentation of response capabilities be available.
The more detailed guidance is contained in NUREG-0654 and NUREG-0737.
In that regard, the NRC has determined that your proposed augmentation and facility activation times are. unacceptable alternatives to the recomended 60-minute augmentation.
As noted in the justification for Revision 13, an evaluation was made in the area of the notification system i
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and geographical location of personnel relative to the site.
However, the
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justification did~not provide insight into the following:
Review of the geographical location and proximity from the plant for 1
various personnel assigned to the. emergency organization for possible reassignment of expertise to satisfy augmentation requirements, p
Summary ' or evaluation report showing the minimum staffing l
requirements-by~ position and function, and the supporting docun+ntation to justify a change in the augmentation time.
Justification. to show that assessment and protective action reconnendations would not be diminished by delaying the augmentation and activation times, s-I b
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