ML20102B135

FOIA Request for Documents That Formed Basis of NRC from SD Ebneter to Wg Hairston Entitled, Completion of Confirmation of Action Ltr Commitments & Any Internal NRC TIA Review of 900320 Loss of off-site Power at Plant

ML20102B135
Person / Time
Site:	Vogtle
Issue date:	10/22/1991
From:	Lamberski J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-91-468 CAL, NUDOCS 9207280201
Download: ML20102B135 (1)

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- October -- 2 2,: l'991  !

Mr. Donnio n. Grinsley, oirector. FREEDOM OF INFORMATION - ,

l Division of Freedom of Information-  ;

- and Publivations Services [ l ACT MN. REQUEST .

4 office of * 'ainistration /

U. S. Nuclear Regulatory Commission I

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t Washington,-DC.20555- [f dh/8Nhf/ '#

' fLg_qiqa_QL I n f o rma C19IL,1.Lqt_BELufdLt Re:

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Dear Mr. Grimsley:

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I hereby request, pursuant to'the federal Freedom of ,

o Information~Act'("FOIA"), 55U.S.C.LS 552,. as amended, and:-Nuclear

! -Regolatory Commission ("NRC") regulations, 10;C.F.R.- Part 9,-

t- copies of all 'frecords" as defined in 101C.F.R.; S 9.13 which

formed the basis of the NRC's April 12, 1990 letter-from Mr.

1 Stewart D. .Ebneter (NRC RegioniII: Administrator)J to Mr. W. _ George. '

j. Hairston, III (Georgia Power Company): entitled _ " Completion of:

Confirmation if ActionLLetter Commitments '? AdditionaU yl?I request a copy.of all

records, as: defined"above,, constituting?or.-

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relating to any internal NRC Task Interface Agreement (s):

addressing follow-up NRC actions.in connection with

the-NRC!s- i F review.-of the March 20, 1990ilossiof3off-site powersevent:atithe:

i- Vogtle Flectric Generating lPlanti(s~ee attached NRC Staff Guidelines Concerning! Plant-Restart = Approval, datedENovember?23,;

1988, Part I,-item 3).

i i For your:information,-Ilbelieve thatirecordssencompassediby2 l i

[ this FOIA request are or were.inLthe'possessionfoffMr. Stewart D.-

Ebneter _ (Region iII) ,f Mr. Kenneth E. Brockmanf (Region II) ,4Mr. .

Rick'Kendall (NRR) and Mr.sAlfred E. Chaf f ee .l(SegionL V) .--

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I am willing to pay the; applicable charges:for; production 1of b the-requested records in accordance with 10;C.F.R.JPart09 upstofa,. ,

maximum amount'of $1000'.00 and:those-charges:in excess of.. .

$1000.00- of which I am notified, and;which Ifapprove,;inVadvance..

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If you have any questions concerni'ngs this FOIA. request,;  ;

e please feel ~ free to contact me.- l l

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. .i Very truly--yours,-

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y ATLANTA,CEoRotA 33123 APR 121990 o.... . . . .

Docket No. 50-424 License No, NPF-68 Georgia Power Company ATTH: Nr. W. G. Hairston, III Smior Vice President -

.ucicar Operations P. O. 5 1295 .

Birmingnam, AL 35201 ,

Cantlemen:

SUBJECT:

COMPLETION OF CONFIP.MATION OF ACTION LETTER COMMITMENT 5 In a letter from the NRC to Georgia Power Ccupany (GPC), subject "Confinnation of Action letter," dated March 23, 1990, certain matters were agreed to be Additionally, completed prior to Yogtle, Unit 1, reattaining criticality.

pur comitments concerning the needs and requirements of the Incident Investigation Team dispatched to review the March 20, 1990 . loss of vital AC This letter confims the satisfactory power event on Unit 1, were delineated. number 1 and documents the Regional Adm resolution of ittf1 concurrence that appropriate corrective actions have "en taken and the plant can safely return to operation.

On April 9,1990, Georgia Power Company briefed NRC management on their event critique results and the short- and long-term corrective actions they plan to implement. These items were specified in a letter from GPC to the NRC, dated April 9, 1990, and included additional-items which.GPC has committed to submft to the NRC.

Based upon the information provided by GPC and the short-tem actions which have been implemented, Georgia Power Company is authorized to return Unit 1 to Hode 2, attain criticality, and proceed to; subsequent powar operation.

Items 2-5 of the March 23, 1990,- Confinnatica - of Action Letter remain applicable and are not relieved by this letter.

If your understanding differs from that set forth above, please call me irrmediately.

Sincarely, f

Stewart D. Ebneter

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d Regional Administrator &

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1 CAL-50-424/9041 (Seepage 2) y cc:

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, Georgio Power Company 2 APR 121990 cc:  !!T Leader NRC Office Directors Regional Administrators R. P. bcDonald Executive Vice President Nuclear

. Operations

. Georgia Power Company P. O. Box 1295

Birmingham,-AL 35201 .

. C. K. McCoy Vice President-Nuclear Georgia-Power Company P. 0. 1295

Birmingham, AL_ 35201 G. Bockhold, Jr.

l General Manager,- Nuclear Operations

Georgia Power Company _

P. O. 1600 Waynesboro, GA 30830:

J. A. Bailey i

N: nager-Licensing Georgia Power Company

P. O. Box 1295 Binningham, AL 35201 l

! Ernest L. Blake. Esquire.

Shaw, Pittman,-Potts and Trowbridge l 2300 N Street, NW L Washington,-D. C. _20037 4^ -

J. E. Joiner, Esquire Troutman,. Sandersr Lockennan, and

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y, Ashmors -

'6 y 1400 Candler Building

-7 127 Peachtree Street, NE -

Atlanta. GA 30303 D. Kirkland. III Counsel

,  :.- Office of the Consumer's;

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Utility Council

, 1 6 Suite 225 32 Peachtree Street NE

,i ,; Atlanta, FC 30302

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APR 12 990 4 .1 cc: (Continued)

L Office of Planning and Budget Room 6158 270 Washington--Street, SW Atlanta, GA 30334

!' Office of the County Comissioner. >

Burka . County Comissfon l Waynesboro, GA 30830 J. Leonard Ledbetter, Director Environmental Protection Olvision.

! Department of Natural Resources 205 Butler Street, -SE.- Suite 1252 -

Atlanta, GA ' 30334 1

! Attorney General-Law Department 132 Judicial 4 Building Atlanta, GA 30334 State of Georgia i

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. . NOV A 81t88 HDCRANDUM FOR: NRC Office Otrectors NRC Regional Matnistrators FRON: Victor $tello. Jr.:

EJtecutive Of rector for Operations

'$UBJECT: STAFF GUIDE 1,!Nt3 CONC (ItNING Pt. ANT RESTART APPPOVAL, In my menorandum c? July 21,1988 guideltnet regardfrq management of the staff's activities associated with plant restaM approval were issued. The enclosure expands these guidelines to include general criterie G.lthe issues '

i to be considered during the staff's evaluett0H.

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Orighalslot*j/p Vctor Sido,# 4 i

Victor Stelle. Jr.

Executive Director

, for Operations ,

Enclosure:

Plant Rastart Approval Guide'<ines .,4

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$TAFF GU10ELINE5 CONCERNING PLANT RESTART-APPROVAL'

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This paper establishes the framework for the authoritation of'the restart of_ a  ;

nuclear power plant, after a voluntary or involuntary shutdown due to's. _;

! significant event or serious management deficiencies. Ile attempt is made to -- ,

i precisely define thes? terms, and judgement as outlined 4elow is:needed. The-guidelines presented (1)-provide for more effective coordination of IIRC resources betoen Regions and Headquarters. (2) clarify-responsibilities and (3) ensure that there is consistency in-the actions of NRR and. Regional ~

management personnel involved in major hRC decisions-directly affecting Iicenstet. .

Licensed coemercial nuclear-power plants:are shutdown, voluntarily ~or. net.

for.a variety of_ reasons. When aiplant istshutdown for reasons steeming from

• Itcense u nditionsfor. technical specifications, the-licensee normally can- -

develca and:1solement.a clearly' defined: correction plant when the criterf 4 of-- ,

this. plan are net, the plant is allowed to restart without special-authoritation from MRC. Howev*r. plants occasionally _ are in a shutdown -1 condition as a'r6sult of-.a significant event or serious management deffetencias. Thaie are the cases. at which this-' statement.is directed. -

0 Examples of this type of shutdown include planta that were shut down because of---

performance problees- during the-past few yearsnie.g.. Sequoyah.: Browns Terry, -

Rancho Seco. Ptigrim and Peach lottcm.

The- NRC has reacted to these types of. facility shutdowns ~ fnt a variety _of ways depending on the severity of the eventithat led to the shutdown. a H1storically, the NGC-has approached each eventLindividually.iand en ,

j' individual plan of action:has evolved.s The results have been satisfactory _  ;

L but the'processthas:not been apprcached in-a uniform sanner. The guidelines '

presented in this statement will ensureLthat (1)JhRR?and Regions;will be! '

l: appropriately involved In all restart decisions ~andl(2) the-NRC will:present ai unified _ position to'the Itcensees. However, because each plant.-shutdown'..

situation ts =different. a detailed generic procedure for: restart. approvals- :ts-not' appropriate.

The general guidelines for NRC- reaction .to the events'of concern are'.providedi in two parts.- > Part one_' deals- with the' management of the staff's activities ,

associated with the restart reytew efforts and'part' two-dealsLwith the varicus issues that are considered in the reviews.- -

Part I_ i L

1. - When a Region believes-that afparticular situation ~4t a plant represents  ;

a significantievent orc serious; management deficiencies warranting h increased: regulatory attention._-the Region should discuss:the issue with? ,

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NRR. Except for-special circumstances, the inttial discussion should be d between the _ appropriate Region management-and;the NRR Olvision Director for Operational Events-Assessment-(00EA). iThe discusston should= include?a-L l! m

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description of the event or circumstances, as well as= the Reqfon actions -

i already taken. and proposed future actions. Potential NPC reactfMs-could include the estab111,hment of an incident Investigation Team (11T). ,

Augmented inspection Team (AIT) 4_ Regional Assessment Team _(RAT). or-a appropriate, the need for a i- special trispection, and includine. as ~All of these' individual reactions ~

confImatory Action-Letter or Order.  :

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- would be conducted in acccrdance with appropriate; standard. office- -

policies, orecedures, and Manual Chapters._-- Special circumstances involve i strintftcant, rapidly.occueing events, where discussions could be- '

in' tf ated directly at the level of.the Regional Administrator, the Olrector. UR4 or the OEORO.

2. The UR Divistoa Otrector for Operettonal (vents; Assessment will promptly-

- notify the appropriate NRR Projects Olvision Director of the results of the discussf on wIth, the. Re9 t on. The focal-point for discussions within the Nec for follow up actions'will belthe appropriate Projects Division Directors In the Region sed in Net. - They will coordinate participation

- in conference calls and maneceeent discussions to ensure that the Regional-Administrator 5nd the ofrector. NRt. are directly involved .in important dec ts tons. d.e Pro.iect Otvisions wn111coordfrate and carry out'the r actfons prescribed in the follow-up plan.

3. After the Resfon-and kRR decide-on a codrse of action.-includine

notification of the (D0 and Comission at

appropriate. the respective >

Projects Olvisions will-jointly initiate s Task Interface Acreement fTIA) to document the_ essignment of responstbtitty~ for follow up actions - For rapidly occurrfne events leading.:to a evick restart of 4; plant,_ the coordination between the Recton and NRR may be done orally. However, for' 1 events that' take more than about"acweek-to resolve,;a formal TIA should be draf ted. Elements of: the f tA shov1d include the followinei-fte TIA: format must be flentble--to account for the diverse' nature a.

of events. However. all T!A's: should define f1) what must be-

- accomo11shed. as a mintsum.: to authorite plantLrestart, (?! who has - .

lead responsibility for each action, and:f 3) who:hascresponsiblitty- '

for. actual plant restart authoriratfon.

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b. The TIA should fully decmentiall actions that.must be' taken before a plant is autherfred to restart. even if they areinot related to the initicting event.

. c. The' Commission needsnto be kept adequately informed of the staff's

. restart actions on a continuing basis.J The TtA wil1 ~ document lead?  %

responsibility within the agency for interactions withLfhe!

Comission. The lead office:will keep the Ccemission;infomed of

- the sta'f's and'Itcensee's restart _' actions-through the:use of -

Cemf ssion-papers =. daf1v; reports.7and/or, verbal: comunications via the EDO. !8ased on- these staff /Comission fottractfons.:the neednr.

Cometssion brfeffecslwill be determined by the'cfrcumstances and:

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3 Comission desires. HowcVer, the staff should anticipate Comistion briefinns with licerisce participation (a) after a corrective plan is agreed to and implemented, (b) about a raonth before plant restart is anticipated, and (c) a few days prior to the scheduled restart. At the anticipated final briefing, the NRC staff would be required to give the staf' position as to their basis fcf recomending or not recomendine restart. The Comission will express its views concerning restart at any tirne during the process, but normally e formal vote is not taken until tha last briefing.

part !!

4 1. Licensee Restart Plant Root ca.se Idtntified and Corrected First, tDe root cause of the event or condilitns requiring the shutdown must be properly identified. Then the root cause of the event or tunditions requiring the shutdown must be addressed by a cenprehensive

corrective action plan which addresses all applicable issues. The plan

raust carry the issues through their corrective action, implementation and verification phases.

The above actions are taken by the f acility licensee. Tlitt NRC reviews and determines the acceptability of these actions to support stfe operations using any or all of the tools available to it in the regulatory program. These rould include sny or all of the following: 4 Headquarters staff review. SALP, the inspec'. ion procram including regular inspections, spicialist inspections or team inspections and enfortmt conferences.

Resulting settons are set forth in safety evaluations, Ucense amendments, orders, confirmstory action letters, inspection reports, enforcement docenents, etc. The staff's reviev includes the applicable areas outilned below.

2. 1.f centre Han1gement Organintion TF Itcensee's manage w .t organfration is reviewed to ensure that the proper envirotnent and resources are provided to ensure that the problems and their root causes have been rectified. The organization must demonstrate that it can coordinate, integrate and comunicate its otdectives so that they are appropriately priorittred for safety significance and are achieved in a timely manner.

This requires an appreciation on tb; part of that management, of what the safety issues are, coupled with a sositive atsitude toward ensuring that they are resolved. This in turn requires that personnel with adecuate cualifications and experience be prcvided for all key management positions.

or (a) exhibit good tearwork among its The resulting(b)ganization should:-provide strong engineering suoport for plint a subelements; Ic) have the internal abl11ty to recognize ?afety problems, develop adequate corrective actions, and verify the it implementation and effective -

ness; and (d1 have an independent self-assessment capability that can identify situations not suf ficientiv dealt with by the regular functioning of the principal ??Wtation.

40 1

3. planLa,nd _Corporay Staff The rperations staff rust recognize and carry out their responsibilities in .rnsuring pubite health and safety as recuired of them by their individual li'tnses as well as by the fact 11ty Itcense to operate the plant. ihese responsiblitties must be met while working within the envirorment established by the Itcensee's management as discussed above.

This, in turn, requires that an adequate number of formally qualified incensed operators be provided. A positive proactive attitude towards safety issues should be demonstrated across the t.oard in all aspects of ope'etions. In this regarti operators should display attentiveness to duty fitness for duty, a disciplined approach to activities, a sensitivity for trends on what is happening in the plant, security awareness, and an openness of ecemunications and desire for team work which supports effective relations betwcen dif ferent groups (e.g., managtment, operations, health physics, reintenance, security, contractors).

4 f,hysical Stat (of pendiness of the plant This is of brincipal importancu for those cases where the reason for the shutdown was based en a physical event or deficiency but it is also important for other types of events as well.

For cavipment problems the cause should be identified and appropriate corrective actions taken in the manner discussed in (1) above.

These issues will warrant a strong focus on the pre-operational or initial operational testing which verifies that the Droblem is resolved. For cecolex issues this testing program may also he ccrgler and of an extended duration, ,

for other types of probleet, as well as equipment problems the corglete spectrum of pre-optrati:M1 and startup testing programs e.ay need to be expanded to consider the more cceplex types of probit <ns or to consider the effects on plants which have been thut down for extended periods.

The licensee should be able to demonstrate ttat all needed safety equipoent is operations) prior to the restart without exc.essive reliance on the minimum levels of equipment availability permitted by technical specification Limiting Conditions for Operation. Surveillance tests should also be up to date without excessive reliance on the minimum "

level of testing permitted by VS.

The maintenance backlog should be reduced to nominal levels which d, not reflect chronic problems with equipment readiness nor postponement of long unmet needs.

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' of the issue at hand as well as any ertensive long urnet needs, for example, procedures which conflict with other procedures or with the as bu(It plant, procedures which have not undergone their periodic review.

(~ or procedures which do not reflect 'the way it is really dcae" should be i considered for updating.

I The as built detipn of the plant should te knrvn to agree with the safety In some cases, design basis includino analyses, drawinos, etc.

tj@] especially for some of the older plants, fully documented design bases ray not be available. For these Cases, reliance 00 engintzering judgeMnt g may be appropriate, h]'

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f. Other Agencieh overreent C _0roanizations, the Pu_blic_

The decision to restart should consider the need for fortna) action prior to restart as well as the value of effective relations with and c*atives other fed

[L agencies such as FDM, ($J. state and local goverrment repr-interested r: cabers of the public.

for exemple, this fuy include the need for action on the Emegency Plan by h ,

FEM, responses to correspondence to state Governors or rembers of Ml V' l Congress and resoonses to 2.P06 Petitinns.

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j 6. "t.egal' Recujr,coents n

NotwithstanJing all of tb atove the plant and its prospective operation jr is not kncvn to be in conflict with any regulations (GOC etc.) and all requirenents of any document authori:ing restart (Itcerse amendments.

lD orders, etc) are espected to t'e ret, l {!

Restart would not conflict with any natter before a Hearing Board, p

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