ML20207E838
| ML20207E838 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/15/1986 |
| From: | Foster D GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GN-982, NUDOCS 8607220436 | |
| Download: ML20207E838 (16) | |
Text
Georgia Power Company
-s Ebst Office Box 282 Waynesboro. Georgia 30830 Telephone 404 554-9961. Ext. 3360 404 724-8114. Ext. 3360 GeorgiaPower D. O. Foster IN swen &cric sem V U Pr e t July 15, 1986 United States Nuclear Regulatory Commission Region II File: X7M13.3 Suite 2900 Log:
GN-982 101 Marietta Street, Northwest Atlanta, Georgia 30323
Reference:
Vogtle Electric Generating Plant-Units 1 and 2; 50-424, 50-425; Report Nos. 50-424/86-12 and 50-425/86-18 Attention: Mr. J. Nelson Grace Inspection Reports 424/86-12 and 425/86-18 address the results of a detailed appraisal of the Radiological Emergency Preparedness Program at the Vogtle Electric Generating Plant conducted March 10 - 21, 1986.
Inspection results have been placed in two categories,
" Emergency Preparedness Improvement Items" and " Incomplete Emergency Preparedness Items."
The items were listed in Appendix A and B respectively of the report.
A written statement addressing the results of our consideration of Appendix A items was requested and is included as attachment 1.
In addition, attachment 2 is a listing of Appendix B items which are ready for closure.
This response contains no proprietary information and may be placed in the NRC Public Document Room, f
Your t uly, 8607220436 860715 PDR ADOCK 05000424 PDR G
D. O. Foster JNR/D0F/tdm Attachments xc:
U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C.
20555 J. H. Miller R. A. Thomas L. T. Gucwa J. P. O'Reilly D. R. Altman C. W. Hayes G. F. Head P. R. Bemis G. A. McCarley R. E. Conway J. A. Bailey D. S. Read J. T. Beckham O. Batum Sr. Resident (NRC) pfI R. H. Pinson G. Bockhold C. S. McCall (OPC)
P. D. Rice C. E. Belflower J. E. Joiner (TSLA) l B. M. Guthrie J. F. D'Amico D. C. Teper (GANE)
D. E. Dutton E. D. Groover NORMS A
4 A-1 424/86-12-01 425/86-18-01 Determining the responsibility for the annual review of the VEGP Emergency Plan and correcting NOI-08-052 or Health Physics Procedure 40005-C accordingly.
Rasponse The responsibility for the annual review of the VEGP Emergency Plan is the corporate manager responsible for Emergency Preparedness.
A recent organizational change has assigned Emergency Preparedness responsibility to the Manager, Nuclear Training.
Procedures NOI-08-052 and 40005-C will be revised prior to 10/01/86 to reflect this change.
A-2 424/86-12-03 425/86-18-03 Reviewing the description of emergency staffing by corporate level to ensure that the staffing assignments are consistent throughout the VEGP and corporate plans and procedures.
Rasponse The VEGP Emergency Plan and procedures will be revised prior to 10/01/86 to ensure corporate staffing assignments are consistent with the corporate plans and procedures.
A-3 424/86-12-04 425/86-18-04 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.
Rasponse l
The corporate emergency plan will be revised prior to 10/01/86 to ensure that there are adequate alternates in key positions to maintain staffing 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
l A-4 424/86-12-05 425/86-18-05 Correcting Table 3 of EPIP 91101-C to include an Electrical Engineer on the TSC engineering staff.
R2cponse l
Procedure 91101-C has been revised to include an Electrical Engineer on the TSC engineering staff.
i
e A-5 424/86-12-06 425/86-18-06 Continuing to develop the computerized record and tracking system for emergency training, and including its function as part of the EPIP 91601-C " Emergency Preparedness Training."
Rasponse The Training Department is continuing to refine the computerized tracking system used for emergency preparedness training.
This sytem was developed for use within the Department for convenience in scheduling training.
The VEGP records management system (RMS) is the official training records respository.
A-6 424/86-12-07 425/86-18-07 Establishing and documenting a provision for conducting appropriate training for non-licensee augmentation personnel (contractors, HPs, vendors, etc.) onsite arrival, in response to a request for assistance prior to their assimilation into the emergency organization.
Raoponse Site orientation training, to include familiarization with the VEGP Emergency Response Organization, will be provided for non-licensee augmentation personnel as soon as practical upon their arrival at the plant site.
A lesson plan for this training will be available not later than September 30, 1986.
A-7 424/86-12-26 425/86-18-26 Assuring that sufficient HP personnel are available in the OSC to survey an acceptable route for RET members between l
the OSC and the control point (or other point of plant l
entry) in the event of onsite radioactive contamination.
Rasponse Procedure 91110-C, Duties of the Health Physics Supervisor (TSC), will be revised by 08/01/86 to " ensure that sufficient HP personnel are available in the OSC to survey an acceptable route for RET members between the OSC and the control point (or other point of plant entry) in the event of onsite radioactive contamination."
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i p
A-8 424/86-12-31 425/86-18-31 Installing a reliable emergency power source to the EOF.
R3sponse The installation of an emergency power source for the EOF has been evaluated.
A Bechtel Power Corporation study determined that the computed overall availability of the EOF data system is 0.995.
This exceeds the minimum availability of 0.99 that is required by paragraph 1.5 of NUREG-0696.
The data system availability takes into account the availability of the power supply to the EOF which is 0.999855 based on a Georgia Power Company study.
Since the data system availability exceeds that required by NUREG-0696, no emergency power source is required.
In the unlikely event of loss of power to the EOF, the backup EOF in Waynesboro will be utilized.
A-9 424/86-12-34 425/86-18-34 Establishing a procedure for transmitting sample analysis results during emergencies.
Rasponse Georgia Power Company Environmental Affairs Radiochemistry Laboratory Procedure No. PSL-12450.608 will be revised by 10/01/86 to include procedures for transmitting sample analysis results during emergencies.
A-10 424/86-12-38 425/86-18-38 Correcting the kit inventories to include missing items.
Response
Kit inventories have been corrected to include missing items.
A-11 424/86-12-39 i
l 425/86-18-39 Calibrating all radiological and air ssmpling equipment.
l Rauponse Radiological and air sampling equipment for emergency use will be calibrated prior to 10/01/86.
A-12 424/86-12-40 425/86-18-40 Providing seals on each SCBA case stored external to a kit to indicate tampering, and assuring that the spare air cylinders have been charged.
Rasponse Seals on externally stored SCBAs for emergency use by l
Nuclear Operations personnel will be provided prior to 10/01/86.
A-13 424/86-12-41 425/86-18-41 Replacing the KI placebo with actual KI.
Rssponse Emergency Kits designated to contain KI per Procedure 91702-C will be stocked with actual KI and placebo KI will be removed by 10/01/86.
A-14 424/86-12-42 425/86-18-42 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.
Rasponse Emergency kits and lockers have been labeled and sealed.
A-15 424/86-12-43 425/86-18-43 Placing radio charger (s) in the same kit (excluding field team kit) or locker as the portable radios.
Rssponse Battery chargers will be provided at all locations where portable radios are used during an emergency (eg., OSC, Control Room, HP control point).
In some cases these chargers are used on a day-to-day basis and are not part of an emergency kit.
Completion date is 09/01/86.
A-16 424/86-12-44 425/86-18-44 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.
Rosponse The EOF kit contains protective clothing, dosimetry, and respirators with particulate filters.
SCBAs will not be stored at the EOF.
A-17 424/86-12-45 425/86-18-45 Correcting the discrepancy in either the Plan or Implementing Procedures regarding the location of the field monitoring hits.
Response
The VEGP Emergency Plan Section 1.5, Field Monitoring, will be revised to indicate the proper Field Monitoring Kits storage location.
This revision will be accomplished prior to 10/01/86.
A-18 424/86-12-46 425/86-18-46 Assuring that kits dedicated for emergency use are available at their specified locations on a continuous basis.
Rssponse Emergency Kits are now at their specified locations.
The Training Department now has a separate training kit.
A-19 424/86-12-54 425/86-18-54 Specifying an averaging period for meteorological data and correcting the reference to sigma-theta from the 60m level.
Response
Procedure 91304-C will be revised to specify a 15 minute averaging time period for VEGP meteorological data used in dose assessment calculations.
The 60m level sigma-theta reference will be removed.
The revision will be completed by 09/01/86.
A-20 424/86-12-55 425/86=18-55 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 67-1/20 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.)
Rssponse Procedure 91305-C specifies 67-1/20 as the minimum affected area.
A-21 424/86-12-51 425/86-18-51 Providing a written agreement between GPC and the NWS to document the role of NWS in emergency response.
Rosponse The National Weather Service has n->tified Georgia Power Company in writing that a formal written agreement with the NWS is not necessary.
NWS offices have been instructed in FCM-P15-1982, National Plan for Radiological Emergencies at Commercial Nuclear Power Plants, to " provide meteorological information to nuclear power plant officials within available resources."
A-22 424/86-12-52 425/86-18-52 Modifying procedures to reflect communication protocol in obtaining meteorological information (including forecasts) from the NWS and to reflect use of NWS information in dose assessment and protective action recommendations.
Response
i Procedure 91304-C will be revised to designate NWS Augusta as a possible source of meteorological information and the means of obtaining this information.
Procedure 91203-C will be revised to assign the Dose Assessment Manager the responsibility to obtain forecast information from NWS Augusta and the means of obtaining this information.
The Dose Assessment Manager will also consider the forecast information when determining protective action recommendations.
These procedures will be revised by 10/01/86.
A-23 424/86-12-53 425/86-18-53 Providing an alternate source (e.g., backup recorders or remote interrogation) 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 i
and the verbal transfer of data may not be feasible in the event of severe weather, seismic activity or hydrologic events.)
Rssponse The Meteorological Monitoring System meets or exceeds all applicable design and qualification criteria provided in RG 1.97.
This system consists of primary and backup instrumented towers with data displayed at the Meteorological Service Building (MSB) and the ERF Computer terminals located in the Control Room, Technical Support Center, and Emergency Operations Facility.
An uninterruptible power supply to these towers is provided in the HSB.
This system has been designed to provide the
^
required reliable meteorological data.
The ERF computer is also supplied by an uninterruptible power supply backed up by a manual bus transfer to the security diesel.
A-24 424/86-12-65 425/86-18-65 Including fuel tank keys for each emergency vehicle available for field team use with the ignition key.
Rosponse Fuel tank keys are now available for all designated emergency vehicles.
The keys will be kept in the OSC.
A-25 424/86-12-66 425/86-18-66 Reviewing the EPIPs to assure that proper telephone numbers and adequate references to other procedures are provided.
Rasponse The procedures have been reviewed for proper telephone numbers and cross referenced to other procedures and will be revised as necessary by 10/01/86.
A-26 424/86-12-67 425/86-18-67 Assuring proper documentation of revisions to the EPIPs is made such that the current version of the procedure is easily identified.
Rssponse All changes to the procedures now contain a side bar indicating any change since the last revision of the procedure.
A controlled copy of the VEGP Procedure table of contents provides a ready reference for the latest revision number for each procedure.
As the procedures are revised, a controlled copy of the Procedure table of contents is updated and distributed.
A-27 424/86-12-68 425/86-18-68 Reviewing and correcting the index of procedures supporting the emergency program in the VEGP Emergency Plan.
4 Rasponse The VEGP Emergency Plan index of Plant Administrative Procedures, Health Physica Procedures, and Emergency Plan i
Implementing Procedures will be revised in the next revision to ensure consistency between the plan index and the supporting procedures.
This revision will be in place prior to 10/01/86.
A-28 424/86-12-69 425/86-18-69 Improving Document Control Procedures to assure that required procedures in'the controlled document sets are available.
Response
The task of performing monthly audits of the controlled procedures in the Control Room will be added to the Daily Activities Schedule.
The controlled manuals will be compared to the procedure index to ensure the manual is complete.
Any missing procedures will be replaced.
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A-29 424/86-12-70 425/86-18-70 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."
Rosponse All Abnormal Operating Procedures (AOPs) that reflect directly on EAL's have been revised to include references to the applicable emergency procedure, with the exception of AOP 18035-1.
The next revision will incorporate the needed reference and will be completed by 8/01/86.
A-30 424/86-12-71 425/86-18-71 Correcting administrative problems identified in EPIP 91001-C.
Rasponse The administrative problems identified in Procedure 91001-C will be corrected by 10/01/86.
A-31 424/86-12-72 425/86-18-72 Conducting training and practical drills for persons responsible for implementing modified EPIPs.
Rssponse Supplemental training has been conducted for communicator / recorders as a result of changes to procedure 91002-C (Notifications).
The "TRASE" program, as described in VEGP Procedure 60005-C, "' Incorporation of Changes in l
Training Material and Simulator", provides for identification of procedural changes and their impact on t
i training.
Prior to July 31, 1986, this procedure will be I
amended to state more clearly the way in which changes in Emergency Plan Implementing Procedures will be factored into l
applicable training.
As such changes are identified, supplementary training will be conducted in a manner appropriate to the changes in question.
Practical exercises or drills will be incorporated in the training as i
appropriate. -
A-32 424/86-12-73 425/86-18-73 Correcting or modifying EPIP 91002-C, as necessary, to remove administrative deficiencies.
Rasponse Procedure 91002-C will be revised to correct administrative deficiencies by 10/01/86.
A-33 424/86-12-74 425/86-18-74 Providing descriptive information of RADDOSE II software and its relationship to VIBRANT code in the Emergency Plan.
Rasponse RADDOSE II is no longer in use.
All references to RADDOSE II will be deleted from Procedure 91304-0 by 10/01/86.
A-34 424/86-12-75 425/86-18-75 Specifying the minimum acceptable offsite air sampler flow rates in the procedure.
Rasponse Procedure 91303-C has been revised to specify the minimum acceptable offsite air sampler flow rates.
A-35 424/86-12-76 425/86-18-76 Resolving the apparent discrepancy between the HP-210 detector iodine detection efficiencies used for onsite/inplate, and offsite iodine air activity determination.
Rasponse Procedure 43002-C will be revised by 8/15/86 to correct this discrepancy.
A-36 424/86-12-77 425/86-18-77 Including a requirement in EPIP 91304-C that gamma spectrometry determined radiciodine air activity values be l
used to update dose projections.
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Ruaponse l
Procedure 91304-C will be revised to require that gamma spectrometry determined radioiodine air activity values will J
be used to update dose projections.
I A-37 424/86-12-78 425/86-18-78 Including in EPIP 91303-0 a telephone number for calling the TSC or EOF if radio contact fails.
Rosponse Procedure 91303-C will be revised by 10/01/86 to include emergency telephone numbers for transmitting field survey data to the TSC or EOF if a field monitoring team's vehicle radio or the base station radio fails.
5
. A-38 424/86-12-79 425/86-18-79 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.
Rosponse Procedure 91303-0 will be revised to consider both direct radiation exposure and contamination control of air sample filters by 10/01/86.
A-39 424/86-12-80 425/86-18-80 Correcting data sheets 2 and 3 of EPIP 91303-C.
Response
Data sheets 2 and 3 of Procedure 91303-C have been corrected to reflect the proper units.
A-40 424/86-12-81 425/86-18-81 Referencing the plant Health Physics Manual in Procedure 91302-C for method to be used to sample air and calculate air activity.
Rasponse Procedure 91302-0 will be revised by 10/01/86 to include a reference to the Health Physics Manual.
A-41 424/86-12-92 425/86-18-92 Referencing of the Health Physic Manual Procedures pertinent to protective actions for facilities and personnel during emergency conditions in Procedure 91305-C.
l Rasponse l
Procedure 91305-C will be modified by 10/01/86 to reference the Health Physics Manual Procedures (00900 series) for direct radiation monitoring, contamination control, i
personnel dosimetry, and other onsite protective measures.
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A-42 424/86-12-96 425/86-18-96 Correcting the inventory list in Implementing Procedure 91702-C to include items in the kits, but not on the inventory listing.
Rasponse Procedure 91702-C now accurately reflects the iten.s actually in the kits.
A-43 424/86-12-97 425/86-18-97 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.).
Rooponse A surveillance procedure will be developed by 10/01/86 to provide for periodic inventory of emergency equipment and supplies not included in the hits.
A-44 424/86-12-98 425/86-18-98 Including a prompting statement in Procedure 91702-0 tc remind persons performing inventories to turn off electronic instruments at the completion of the operational check.
Rssponse Procedure 91702-C will be revised by 10/01/86 to include a prompting statement to remind persons performing inventories to turn off electronic instruments at the completion of the operational check.
A-45 424/86-12-99 425/86-18-99 Identifying the specific voltage or type of battery when it is referenced on an inventory (e.g., D, AA, etc.).
Rosponse Procedure 91702-0 will be revised to specify the voltage or l
type of battery for all kit inventories by 10/1/86.
A-46 l
424/86-12-104 425/86-18-104 Improving communications and training provided for controllers.
Rospones Training and communications have been improved for controllers.
Controller briefings and training sessions were conducted prior to each major exercise in the months of March and April 1986.
Controller briefings will continue to be held prior to each major drill or exeicise.
Communications among controllers was discussed at each briefing.
'o A-47 424/86-12-105 425/86-18-105 Providing a number of alternate players to be available as substitutes if players are required to leave the exercise team.
Rasponse During exercises and drills all emergency response organization personnel report to their assigned emLrgency response facility (ERF). The ERF managers determine the need for alternates and may dismiss excess personnel to stand-by at their normal work stations until needed for relief of the primary players.
A-48 424/86-12-107 425/86-18-107 Conduct additional training in the use of the Alarm Response Procedures, Abnormal Operating Procedures, Emergency Operating Procedures, and Technical Specifications to ensure correct and complete interpretation and compliance with same.
Rosponse Early training programs had deficiencies in procedure usage training.
However, programs that have been recently developed resolve this deficiency.
Training has been conducted and is scheduled to be conducted utilizing the revised programs.
A-49
'424/86-12-111 425/86-18-111 Correcting administrative problems as appropriate in EPIP 91002-C.
l R3sponse Procedure 91002-C was revised and re-issued 04/24/86 l
correcting the noted administrative deficiencies.
i A-50 424/86-12-113 425/86-18-113 Revising EPIP 91305-C,'as necessary, to incorporate EPZ maps and other information as may be appropriate.
Rasponse An EPZ map will be added to Procedure 91305-C along with a reference to its use by 10/01/86.
l
The following items found to bo incompleto in Report Numbers i
50-424/86-12 and 50-425/86-18, Appendix B, are ready for closure. In some cases we have taken exception to specific items (ie., 35,36,37, and 41).
B-3 424/86-12-09 Completion of Core Damage Assessment training for all Emergency Response Organization personnel requiring such training.
B-4 424/86-12-10 Completion of In-Plant Monitoring Team training for all Emergency Response Organization personnel requiring such training.
B-5 424/86-12-11 Completion of Field Monitoring Team training for all Emergeeny Response Organization personnel requiring such training.
B-7 424/86-12-13 Completion of Communications and Records training for all Emergency Response Organization personnel requiring such training.
B-11 424/86-12-17 Completion of Medical Support of Radiation Emergency training for all Emergency Response Organization personnel required to take the training.
B-14 424/86-12-20 Placement of adequate and appropriate references, documents, and procedures in the Control Room (prior to j
fuel load).
l B-16 i
424/86-12-22 Completion of training and qualification for Control Room personnel on all equipment used in accident detection / mitigation, classification, notification, and protective action' recommendation formulation, and demonstration of ability to adequately perform same.
l
i B-59 424/86-12-106 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.
B-60 424/86-12-108 Performance of additional training and practical drills for Control Room personnel with notification duties and responsibilities.
B-61 424/86-12-109 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 Section II.E and F of NUREG-0654, Rev.1.
B-63 424/86-12-112 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.
I B-22 424/86-12-29 Placement of all State and local emergency plans and the evacuation plan in the EOF as called for in the Emergency Plan.
B-27 424/86-12-36 Completion of the VEGP Unit 1 Personnel decontamination facility and placement of the appropriate material and supplies for its operation.
B-28 424/86-12-37 Installation of telephones in the news media room.
B-35 424/86-12-58 Completion of the ultimate goal of 100 SCBAs for backup use.
B-36 424/86-12-59 Completion of the placement of the refilling equipment in the Maintenance Building, and designation of the specific localities as alternate cylinder refilling staions.
B-37 424/86-12-60 Establishment of a constant onsite warehouse inventory i
of protective clothing (PCs), at least 4500 sets.
B-41 i
424/86-12-64 Revision of EPIPs to include reserve emergency supplies and equipment, the stocking plan for the warehouse, and designation of primary locations.
B-48 424/86-12-88 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.
B-54 424/86-12-95 Completion of Table 1 of EPIP 91501-C.
B-55 424/86-12-100 Completion of the emergency preparedness audit plan, schedule and checklists by the VEGP Quality Assurance Department.
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