ML20070K564
| ML20070K564 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/21/1994 |
| From: | Mccoy C GEORGIA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| LCV-0334-C, LCV-334-C, NUDOCS 9407260353 | |
| Download: ML20070K564 (4) | |
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Georb>ia Power C. K. McCoy we Prea, two wTe VWW l% S(Uhem oi'TI'C svMem July 21, 1994 LCV-0334-C Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:
VOGTLE ELECTRIC GENERATING PLANT REQUEST FOR SCHEDULAR EXEMPTION ANNUAL RADIOLOGICAL EMERGENCY RESPONSE PLAN EXERCISE Georgia Power Company has received a copy of a letter from the Georgia Emergency Management Agency (GEMA) requesting that the Federal Emergency Management Agency (FEMA) evaluated exercise scheduled for July 27,1994, at the Vogtle Electric Generating Plant (VEGP) be postponed because of GEMA's involvement with the current flood disaster in Georgia. Schedule conflicts with participating agencies including FEMA, GEMA, Georgia Power Company, and the South Carolina Emergency Preparedness Division preclude rescheduling the exercise in calendar year 1994. To accommodate the request from GEMA, Georgia Power Company is requesting that the VEGP 1994 annual emergency exercise be postponed to January 11,1995. Concurrence for this proposed date has been received from FEMA, NRC Region II, and the affected state and local agencies. Delaying the 1994 exercise to January 1995 means that the provisions of 10 CFR 50, Appendix E, Section F.2 that require an annual exercise of the emergency plan cannot be met. The enclosed information supports our request for a schedular exemption for the annual exercise at VEGP in accordance with the provisions of 10 CFR 50.12. To provide adequate time for planning the exercise, we are requesting approval of the postponement request within 60 days.
Sincerely, C. K. McCoy cc: (See next page)
S 9407260353 940721
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f Georgia Power.d U. S. Nuclear Regulatory Commission Page 2 cc:
Mr. Gary McConnell - GEMA Mr. C. Richard Mayson - FEMA Mr. Stan McKinney - South Carolina Emergency Preparedness Division
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Mr. J. E. Porterfield, Director, Burke County EMA Mr. R. T. Powell, Director, Aiken County Emergency Services Ms. N. Walker, Acting Director, Allendale County Emergency Peparedness Agency Mr. J. E. Hair, Jr. Coordinator, Barnwell County Diaster Preparedness Agency U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. B. R. Bonser, Senior Resident Inspector, Vogtle kv434 C
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ENCLOSURE Exemption Request Georgia Power Company (GPC) submits a request for a schedular exemption to 10 CFR 50, Appendix E, Section F.2 in accordance with the provisions of10 CFR 50.12.
The date of the 1994 Annual Radiological Emergency Plan Exercise is proposed to be delayed from July 27,1994, until January 11,1995, to allow the participation of the Georgia Emergency Management Agency (GEMA). This proposed delay will prevent the Vogtle Electric Generating Plant (VEGP) from meeting the annual requirement to exercise the radiological emergency response plan as specified in Appendix E. Therefore, a schedular exemption is requested.
No Undue Risk In accordance with 10 CFR 50.12 (a)(1), GPC demonstrates herein that the requested schedular exemption as authorized by law, will not present an undue risk to the public health and safety, and is consistent with the common defense and security. The delay in the completion of the annual exercise does not represent a degradation in the ability of GPC or off-site organizations to provide protective actions for the public in the event of an emergency at VEGP - Units 1 and 2.
Sp_qqial Justifying Circumstances The special circumstance which justifies the Commission's approval of this schedular exemption request is consistent with the following requirement of 10 CFR 50.12:
The exemption would provide only temporary relief from the applicable regulation and the licensee has made good faith efforts to comply with the regulation.
The granting of a delay in the scheduling of the 1994 exercise provides only temporary relief from the requirements of 10 CFR 50, Appendix E. Georgia Power Company had scheduled, planned, and coordinated the 1994 exercise with participating federal, state, and local agencies for July 27,1994. The scope, objectives, and the final scenario documentation for the 1994 exercise had been properly submitted to the NRC and other agencies, thereby demonstrating a good faith effort to comply with the regulation.
Eyaluation The proposed schedular exemption originated from a request from GEMA to FEMA to postpone the evaluated exercise scheduled for July 27,1994, at VEGP. The request was necessary because GEMA personnel were required to respond to a federally declared flood disaster in South Georgia. The new exercise date was established based on NRC ENCLOSURE (CONTINUED)
Region II, GEMA, FEMA, and South Carolina Emergency Preparedness Division and local availability. The earliest agreeable date was January 11,1995. The proposed delay of the 1994 exercise into 1995 does not meet the literal requirements of 10 CFR 50, Appendix E, Section F.2 which state, "Each licensee at each site shall annually exercise its emergency plan." Since annually is defined as within the calendar year, the rescheduled exercise date does not comply with the regulations. Therefore, a schedular exemption is requested.
The requested delay would not result in a degradation in the response to, or implementation of, any on-site emergency actions or off-site protective measures for the public. Georgia Power Company successfully completed an annual exercise in August 1993. As part of our continuing drill program, two drills have been completed and a tabletop exercise has been completed with the states and counties. Another drill will be conducted in November or December 1994. This date will be coordinated with off-site agencies at a later date. These activities provide assurance that resources necessary for proper emergency response are in place, that personnel are knowledgeable, and needed equipment is in good operating condition to respond to a nuclear emergency at VEGP -
Units 1 and 2.
Conclusion The granting of this schedular exemption is needed to assure the participation of GEMA in the 1994 Annual Radiological Emergency Response Plan Exercise. The requested delay will not result in the degradation of emergency preparedness capabilities for GPC or state and local agencies. Concurrence has been obtained from NRC Region II, GEMA, FEMA, and other affected agencies on the proposed date of January 11,1995. Georgia Power Company has demonstrated good faith efforts in complying with the regulation in that the original exercise date was established in a long-term schedule with affected agencies and that the exercise scope and objectives as well as the final scenario were submitted to the appropriate agencies in suppon of the July 27,1994, exercise date. Therefore, the proposed schedular exemption is warranted under the provisions of 10 CFR 50.12 and does not present an undue risk to the public health and safety.,
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