ML20205P722
| ML20205P722 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/09/1986 |
| From: | Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Kelly R GEORGIA POWER CO. |
| Shared Package | |
| ML20205P726 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 NUDOCS 8605210543 | |
| Download: ML20205P722 (12) | |
See also: IR 05000424/1986012
Text
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MAY 0 91986
Georg1aj9ower Company
ATTN:v R. J. Kelly
Executive Vice President
P. O. Box 4545
Atlanta, GA 30302
Dear Mr. Kelly:
SUBJECT:
REPORT NOS. 50-424/86-12 AND 50-425/86-18
On March 10-21, 1986, NRC inspected activities authorized by NRC Construction
Permit Nos. CPPR-108, CPPR-109 for your Vogtle facility. At the conclusion of
the inspection, the findings were discussed with those members of your staff
identified in the enclosed inspection report.
Areas examined during the inspection are identified in the report. Within these
areas, the inspection consisted of selective examinations of procedures and
representative records, interviews with personnel, and observation of activities
in progress.
This inspection indicated that there are areas that should be evaluated and
considered for improvement in your emergency preparedness program. These areas
are discussed in Appendix A, " Emergency Preparedness Iraprovement Items."
We
recognize that an explicit regulatory requirement pertaining to each item
identified in Appendix A may not currently exist. Notwithstanding this, you are
requested to submit a written statement addressing the results of your
consideration of each of the items in Appendix A.
During the inspection, several of your program areas were found to be incomplete
and could not be fully evaluated.
These areas are listed in Appendix B, and
designated " Incomplete Emergency Preparedness Items."
In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, a copy of this letter and
the enclosures will be placed in the NRC's Public Document Room unless you notify
this office, by telephone, within ten days of the date of this letter and submit
written application to withhold information contained therein within thirty days
of the date of this letter.
Such applications must be consistent with the
requirements of 2.790(1).
The responses directed 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.
8605210543 860509
ADOCK 05000424
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Goergia Power Company
2
Should you have any questions concerning this letter, please contact us.
Sincerely,
!
Luis A. Reyes, Acting Director
Division of Reactor Projects
Enclosure:
Inspection Report Nos. 50-424/86-12 and
50-425/86-18
cc w/ enc 1:
A . E. Conway, Senior Vice President and
!
j Project Director
v D. O. Foster , Vice President, Project
j Support
VP. D. Rice, Vice President, Project
/. Engineering
R
H. Pinson, Vice President, Project
j Construction
VJ. T. Beckham, Vice President and
General Manager - Operations
A. Thomas, Vice President, Licensing
. W. Hayes, Vogtle Quality Assurance
Manager
. C. Ramsey, Manager - Readiness Review
. B. Bockhold, General Manager, Nuclear
Operations
v/' . T. Gucwa, Chief Nuclear Engineer
pf.H.Googe,ProjectConstructionManager
E. D. Groover, Quality Assurance Site
/ Manager - Construction
pG. F. Trowbridge, Esq. , Shaw, Pittman,. A. Bailey, Project Licensing Manager
j Potts and Trowbridge
-
VB. W. Churchill, Esq., Shaw, Pittman,
f otts and Trowbridge
W. L. Blake, Jr. , Esq. , Shaw, Pittman,
Potts and Trowbridge
/J. E. Joiner, Troutman, Sanders,
Lockerman and Ashmore
- dJ.G.Ledbetter, Commissioner,
Department of Human Resources
. H. Badger, Office of Planning and Budget
. Kirkland, III, Counsel, Office of
the Consumer's Utility Council
.
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Goergia Power Company
3
. C. Teper, Georgians Against Nuclear
d. Energy
Johnson, Executive Director,
"
Educational Campaign for a Prosperous
M. B. Margulies, Esq., Chairman Atomic
j Safety and Licensing Board Panel
J Dr. O. H. Paris, Administrative Judge
j Atomic Safety and Licensing Board Panel
vG. A. Linenberger, Jr. , Administrative
Judge Atomic Safety and Licensing Board
Panel
. P. Garde, Citizens Clinic, Director
Government Accountability Project,
Georgia Power Company
pccw/ encl:
1. Bordenick, ELD
/ ocument Control Desk
RC Resident Inspector
tate of Georgia
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APPENDIX A
l
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Vogtle Electric Generating
Plant (VEGP) Emergency Preparedness Program conducted March 10-21, 1986, the
following items should be considered for improvement (references are to sections -
in NRC Report Nos. 50-424/86-12 and 50-425/86-18).
1.
Determining the responsibility for the annual review of the VEGP Emergency
Plan and correcting NOI-08-052 or Health Physics Procedure 40005-C
accordingly.
(1.1-1.4)
2.
Reviewing the description of emergency staffing by corporate level to ensure
that the staffing assignments are consistent throughout the VEGP and
3
corporate plans and procedures.
(2.1-2.2)
3.
Reviewing the corporate emergency staffing assignments to determine if an
adequate number of individuals are assigned as alternates to key positions
to ensure staffing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day, or as required.
(2.1-2.2)
4.
Correcting Table 3 of EPIP 91101-C to include an Electrical Engineer on the
TSC engineering staff.
(2.1-2.2)
5.
Continuing to develop the computerized record and tracking system for
emergency training, and including its function as a part of the EPIP 91601-C
" Emergency Preparedness Training." (3.1)
6.
Establishing and documenting a provision for conducting appropriate training
{
for non-licensee augmentation personnel (contractors, HPs, vendors, etc.)
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onsite arrival, in response to a request for assistance prior to their
assimilation into the emergency organization.
(3.1)
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7.
Assuring that sufficient HP personnel are available in the OSC to survey an
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acceptable route for RET members between the OSC and the control point (or
other point of plant entry) in the event of onsite radioactive contamina-
tion.
(4.1.1)
8.
Installing a reliable emergency power source to the EOF.
(4.1.1)
9.
Establishing a procedure for transmitting sample analysis results during
emergencies.
(4.1.1)
10. Correcting the kit inventories to include missing items.
(4.2.1)
11.
Calibrating all radiological and air sampling equipment.
(4.2.1)
12.
Providing seals on each SCBA case stored external to a kit to indicate
tampering, and assuring that the spare air cylinders have been charged.
(4.2.1)
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Appendix A
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13. Replacing the KI placebo with actual KI.
(4.2.1)
14. Labeling emergency kits and lockers on the external surface, and sealing
them with a breakaway device so that: (a-) inventory can be controlled; and
(b) continuous access is provided.
(4.2.1)
15. Placing radio charger (s) in the same kit (excluding field team kit) or
locker as the portable radios.
(4.2.1)
16. Equipping the EOF kit with the capability to outfit a limited number of
personnel for a plant entry. This may be necessary in the event of HP area
and Service Building evacuation. Additional equipment should include full
protective clothing, SCBAs, and* extremity dosimetry.
(4.2.1)
.
17. Correcting the discrepancy in either the Plan or Implementing Procedures
regarding the location of the field monitoring kits.
(4.2.1)
18. Assuring that kits dedicated for emergency use are available at their
specified locations on a continuous basis.
(4.2.1)
19. Specifying an averaging period for meteorological data and correcting the
reference to sigma-theta from the 60m level.
(4.2.1)
20. Specifying in the appropriate procedure (s), the expanded affected area of
plume coverage considering uncertainties in wind direction and plume travel
away from the vicinity of the plant.
(A minimum of 67-1/2
is typically
assumed for affected area, with a larger area generally considered for
low-wind speed or unsteady wind situations, or when offsite data sources are
in use.) (4.2.1)
21. Providing a written agreement between GPC and the NWS to document the role
of NWS in emergency response.
(4.2.1)
22. Modi fying procedures to reflect communication protocol in obtaining
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meteorological information (including forecasts) from the NWS and to reflect
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use of NWS information in dose assessment and protective action recommen-
dations.
(4.2.1)
23. Providing an alternate source (e.g. , backup recorders or remote inter-
rogation) of onsite meteorological data available to plant operators in the
vicinity of the Control Room, in the event of failure of the ERF computer
system. (The sending of plant personnel to the meteorological tower and the
verbal transfer of data may not be feasible in the event of severe weather,
seismic activity or hydrologic events.) (4.2.1)
24.
Including fuel tank keys for each emergency vehicle available for field team
use with the ignition key.
(4.2.6)
25.
Reviewing the EPIPs to assure that proper telephone numbers and adequate
references to other procedures are provided.
(5.1)
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Appendix A
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26. Assuring proper documentation of revisions to the EPIPs is made such that
the current version of the procedure is easily identified.
(5.1)
27.
Reviewing and correcting the index of procedures supporting the emergency
program in the VEGP Emergency Plan.
(5.1)
28.
Improving Document Control Procedures to assure that required procedures in
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the controlled document sets are available.
(5.2)
29.
Inclusion in the " Subsequent Operator Actions" sections of all appropriate
off-normal procedures a step similar to that provided in APO 18036-1,
stating " Perform the following: Refer to 91001-C, Emergency Classification
and Implementing Instructions." (5.2)
30. Correcting administrative problems identified in EPIP 91001-C.
(5.3)
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31.
Conducting training and practical drills for persons responsible for
implementing modified EPIPs.
(5.3)
32.
Correcting or modifying EPIP 91002-C, as necessary, to remove administrative
deficiencies.
(5.4.1)
33.
Providing descriptive information of RADDOSE II software and its relation-
ship to VIBRANT code in the Emergency Plan.
(5.4.2)
34.
Specifying the minimum acceptable offsite air sampler flow rates in the
procedure.
(5.4.2)
35.
Resolving the apparent discrepancy between the HP-210 detector iodine
detection efficiencies used for onsite/inplant, and offsite iodine air
activity determination.
(5.4.2)
36.
Including a requirement in EPIP 91304-C that gamma spectrometry determined
radiciodine air activity values be used to update dose projections.
(5.4.2)
37. . Including in EPIP 91303-C a telephone number for calling the TSC or EOF if
radio contact fails.
(5.4.2)
38.
Including a section in EPIP 91303-C on the radiological control of air
sample filters. Both direct radiation exposure and contamination control
should be addressed.
(5.4.2)
'
39.
Correcting data sheets 2 and 3 of EPIP 91303-C. (5.4.2)
40.
Referencing the plant Health Physics Manual in Procedure 91302-C for method
to be used to sample air and calculate air activity.
(5.4.2)
41.
Referencing of the Health Physics Manual Procedures pertinent to protective
actions for facilities and personnel during emergency conditions in
Procedure 91305-C.
(5.4.3)
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Appendix A
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42. Correcting the inventory list in Implementing Procedure 91702-C to include
items in the kits, but not on the inventory listing.
(5.5.1)
43.
Providing a periodic inventory of equipment and supplies used in emergency
response, but not included in the kits (e.g.,
communication devices,
portable or mobile status boards, etc.).
(5.5.1)
44.
Including a prompting statement in Procedure 91702-C to remind persons
performing inventories to turn off electronic instruments at the completion
of the operational check. (5.5.1)
45.
Identifying the specific voltage or type of battery when it is referenced on
an inventory (e.g., D, AA, etc.).
(5.5.1)
46.
Improving communications and training provided for controllers.
(7.1)
47.
Providing a number of alternate players to be available as substitutes if
players are required to leave the exercise team.
(7.1)
48.
Conducting additional training in the use of Alarm Response Procedures,
Abnormal Operating Procedures, Emergency Operating Procedures, and Technical
Specifications to ensure correct and complete interpretation and compliance
with same.
(7.2.1)
49.
Correcting administrative problems as appropriate in EPIPs.
(7.2.3)
50.
Revising EPIP 91305-C, as necessary, to incorporate EPZ maps and other
information as may be appropriate.
(7.2.4)
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APPENDIX B
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INCOMPLETE EMERGENCY PREPAREDNESS ITEMS
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Based on the results of the NRC's appraisal of the Vogtle Electric Generating
Plant (VEGP) Emergency Preparedness Program conducted March 10-21, 1986, the
following areas or items within areas were found to be incomplete and could not
be appraised (references are to sections in NRC Report Nos. 50-424/86-12 and
50-425/86-18).
1.
Completion of the drills necessary to demonstrate that the ERFs can be
,
staffed and operational within one hour after activation.
(2.1-2.2)
2.
Completion of GET training for all personnel onsite to be badged for entry
,
,
into the Protected Area.
(3.2)
1
3.
Comp'ietion of Core Damage Assessment training for all Emergency Response
Organization personnel requiring such training.
(3.2)
,
4.
Completion of In-Plant Monitoring Team training for all Emergency Response
Organization personnel requiring such training.
(3.2)
i
5.
Completion of Field Monitoring Team training for all Emergency Response
1
Organization personnel requiring such training.
(3.2)
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6.
Completion of Offsite Dose Assessment training for all Emergency Response
Organization personnel requiring such training.
(3.2)
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7.
Completion of Communications and Records training for all Emergency Response
.
Organization personnel requiring such training.
(3.2)
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8.
Completion of Repair and Corrective Action training. for all Emergency
Response Organization personnel requiring such training.
(3.2)
9.
Completion of SCBA training for all Emergency Response Organization
j
personnel requiring such training.
(3.2)
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10. Completion of First Aid training for all Emergency Response Organization
personnel requiring such training.
(3.2)
)
11. Completion of Medical Support of Radiation Emergency training for all
Emergency Response Organization personnel required to take the training.
1
(3.2)
1
12.
Completion of planned walk-through and talk-through training and drills for
offsite support organizations.
(3.2)
l
13.
Placement of the appropriate EP material in the OSOS office (prior to fuel
'
load).
(4.1.1)
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Appendix B
2
14.
Placement of adequate and appropriate references, documents, and procedures
in the Control Room (prior to fuel load).
(4.1.1)
15. Completion of the installation and testing of Control Room equipment used in
accident detection / mitigation, classification, notification, and protective
action recommendation formulation.
(4.1.1)
16. Completion of training and qualification for Control Room personnel on all
equipment used in accident detection / mitigation, classification, notifica-
tion, and protective action recommendation formulation, and demonstration of
ability to adequately perform same.
(4.1.1)
17. Completion of the installation and testing of TSC ventilation system, and
qualification of cognizant personnel.
(4.1.1)
18. Completion of the installation and testing of TSC electrical distribution
system, and qualification of cognizant personnel. (4.1.1)
19. Placement of the appropriate documents, referer.ces, and equipment in the TSC
command center and operations satellite document control center.
(4.1.1)
20. Demonstration of the sati sf actory operation, including isolation and
recirculation of the EOF ventilation and HEPA filter system.
(4.1.1)
21.
Installation of 3-h emergency lighting in the E0F as called for in the
(4.1.1)
22. Placement of all b* ue and local emergency plans and the evacuation plan in
the EOF as called for in the Emergency Plan.
(4.1.1)
23. Completion of the installation of the telephone systems.
(4.1.1)
24. Completion of the equipment installation and the determination of
operational and procedural adequacy for post accident gas and particulate
effluent sampling.
(4.1.1)
25. Completion of all the procedures required for post accident liquid effluent
l
sampling.
(4.1.1)
26. Completion of construction modifications of the Unit 1 first aid facility
and the placement of the appropriate material and supplies for its
operation.
(4.1.2)
27. Completion of the VEGP Unit I decontamination facility and placement of the
appropriate material and supplies for its operation.
(4.1.2)
28.
Installation of telephones in the news media room.
(4.1.4)
29.
Installation, calibration, and operational testing of all plant area and
process radiation monitors.
(4.2.1)
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Appendix B
3
30. Determination of the accuracies of meteorological parameters transmitted by
the microwave system and comparing these with the system accuracy
specifications presented in Regulatory Guide 1.23.
(4.2.1)
31.
Display and retrieval of meteorological data through the ERF computer.
(Displayed data should represent 15-minute averaged conditions with
automatic updates.)
32. Assurance that information on severe weather events is provided to plant
operators by the GPC load dispatcher and that procedures are developed to
reflecting availability of other sources of information such as that
provided by NOAA tone-alert radio.
(4.2.1)
33. Completion of the permanent mounting of the SCBAs located at the TSC, OSC,
and HP Control Point.
(4.2.2)
34.
Initiation of the monthly maintenance and inspection of SCBA equipment,
including initial verification that spare air cylinders are fully charged,
and deployment of the appropriate number of SCBAs to the Control Room.
(4.2.2)
35. Completion of the ultimate goal of 100 SCBAs for backup use.
(4.2.2)
36. Completion of the placement of the refilling equipment in the Maintenance
Building, and designation of the specific localities as alternate cylinder
refilling stations.
(4.2.2)
,
37.
Establishment of a constant onsite warehouse inventory of protective
clothing (PCs), at least 4500 sets.
(4.2.2)
38. Completion of communication links with the South Carolina Counties of Aiken,
Barnwell, and Allendale.
(4.2.3)
39. Completion of all communication links specified in the VEGP Emergency Plan,
and assurance of their operability.
(4.2.3)
,
40.
Revision of Appendix 4 of the Emergency Plan to include a listing of
" Emergency Kits."
(4.2.5)
41.
Revision of EPIPs to include reserve emergency supplies and equipment, the
stocking plan for the warehouse, and designation of primary locations.
(4.2.5)
42.
Completion of the procedures for PASS calibrations and verification and
troubleshooting.
(5.4.2)
43.
Completion of PASS training once the system becomes operational, and
updating the tracking system to reflect this.
(5.4.2)
'
44.
Completion of the " flagging" process on the training tracking system for
PASS personnel requiring semi-annual retraining.
(5.4.2)
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Appendix B
4
45. Placement of the designated equipment at the local PASS panel, TSC storage
cabinet, and radiochemistry laboratory.
(5.4.2)
46. Completion of the final PASS operational testing.
(5.4.2)
47.
Revision of Procedure 33016-C to include missing instructions on valve
numbers, activity curves, and data sheets.
(5.4.2)
48. Assurance that the volume of vent air sampled is representative of actual
effluent activity, or development of correction factors to compensate for
sample scavenging mechanisms.
(5.4.2)
49.
Completion of EPIP 33065-C.
(5.4.2)
50. Development and implementation of a procedure for safely and accurately
sampling liquid effluents.
(5.4.2)
51. Development of procedures for safely and accurately analyzing liquid
effluent samples.
(5.4.2)
52. Completion of the Security computer system, detection system, perimeter
protection area barrier, and permanent badge system.
(5.4.3)
53. Revision of EPIP 91308-C to include a RET checklist and inclusion of a
reference in the procedural text.
(5.4.5)
54. Completion of Table 1 of EPIP 91501-C.
(5.4.6)
55. Cc apletion of the emergency preparedness audit plan, schedule and checklists
by the VEGP Quality Assurance Department.
(5.5.4)
56. Dissemination of public-information brochures.
(6.2)
57. Dissemination of emergency radios.
(6.2)
58. Design and installation of an emergency siren system.
(6.2)
59.
Completion of the training, qualification, and integration of remaining
Control Room and other Watch personnel necessary to meet licensing
commitments for number of qualified watch sections.
(7.2)
60.
Performance of additional training and practical drills for Control Room
personnel with notification daties and responsibilities.
(7.2.3)
61.
Performance of a study or drills to verify the ability to meet notification
of offsite agencies criteria in Appendix E to 10 CFR 50, and Saction II.E
and F of NUREG-0654, Rev.1.
(7.2.3)
62.
Performance of a study or driils to verify the ability to meet the minimum
staff augmentation criteria in NUREG-0654, Rev. 1,Section II.8, Table B-1
and activation criteria of Section II.H.
(7.2.3)
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Appendix B
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63. Completion of the training of on-shift HP Foremen in dose-assessment and
protective action recommendation formulation, and integration of this
expertise into the watch section organization.
(7.2.4)
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