ML20207J055
| ML20207J055 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 12/23/1986 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NT-86-0586, NT-86-586, NUDOCS 8701080278 | |
| Download: ML20207J055 (16) | |
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Alabama Power Company NT-86-0587 600 North 18th Street Post Office Box 2641 Birmingham. Alabama 35291-0400 Telephone 205 250-1835 m j "^ " ?.
Pl;79 AlabamaPower nio V ce P sident December 23, 1986 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Region II, Suite 2900 101 Marietta Street, N. W.
i Atlanta, Georgia 30323 Attention: Mr. Roger D. Walker Gentlemen:
Joseph M. Farley Nuclear Plant Radiological Emergency Plan Revision 12 In response to your letter of December 2,1986, provided herein are justification and dacumentation to support the one hour notification time limit utilized for Notification of Unusual Event (N0UE) in revision 12 to the Farley Nuclear Plant Radiological Emergency Plan (REP). Enclosed is a copy of the 10CFR50.59 safety evaluation performed in May 1986 as part of the revision 12 approval process.
The regulatory basis and benefits derived from the extended notification time limit are discussed in section IV of the safety evaluation and in the letters from R. P. Mcdonald to affected state agencies.
Incorporated as part of that safety evaluation are letters from Georgia Emergency Management Agency, Georgia Department of Natural Resources, Alabama Emergency Management Agency and Alabama Department of Public Health concurring with the one hour NOUE notification time limit. Local governments were not contacted by Alabama Power Company since the Company's practice for NOUE is to notify only the state agencies os allowed by the guidance for NOUE in NUREG-0654/ FEMA-REP-1, Revision 1, Appendix 1 (i.e. "Promptly inform State and/or local offsite authorities..." [ emphasis added]). WrittenTEMA concurrance was neither required nor sought in the context of applicable regulations.
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a U. S. Nuclear Regulatory Commission December 23, 1986 Page 2 It is Alabama Power Company's position that Revision 12 to the Farley Nuclear Plant REP was properly processed in accordance with 10CFR50.59 and 10CFR50.54(q) and meets the requirements of 10CFR50.47(b) and 10CFR50, Appendix E.
Pending full resolution of this issue, the Company has revised the applicable emergency implementing procedure to reflect a 15 minute NOUE notification time limit.
In order that the procedure may be returned to the one hour limit consistent with revision 12 of the REP or that the issue may be further pursued as necessary, please notify me regarding the acceptability to Region II of this response.
If there are any questions, please advise.
Very trul y9urs, 6
R. P. Mcdonald RPM /KWMc:maf 1
m 10 CFR 50.59 Safety Evaluation I.
Background Information During a NRC inspection conducted September 24-26, November 8 and November 22, 1985, an alleged violation of NRC requirements was identified. his alleged violation involves FNP's capability to notify State and Local governmental agencies within 15 minutes after declaring an emergency as specified in 10 CrR 50, Appendix E,Section IV.D.3.
In response to the alleged violation, Alabama Power revised the plan to indicate 15 minute notification " consistent with-operational priorities existing during the (emergency class) and the need for off-site emergency actions." APCo indicated that the NOUE notification time would be extended to one (1) hour after written concurrence had been received from the affected state agencies. Attached are letters from the states of Georgia and Alahama stating their concurrence with a one hour notification time frame in the event of a Notification of Unusual Event.
Subsequent to the APCo violation response, NRC Region II i-contacted E. P. Mcdonald and objected to the phrase "and the need for off-site emergency actions." A commitment was made verbally to delete the phrase.
Subsequent to receiving a written NRC response, APCo was contacted by Region II and asked to remove the word "normally" and the phrase " consistent with operational priorities existing during the (emergency class)" for Alert and Site Area. On May i
1, 1986, a conmitment was made verbally to make these deletions.
4 II.
Proposed Procedure Changes Se Emergency Plan will be changed to require notification of State and Local agencies within one hour of the declaration of a Notification of Unusual Event and within 15 minutes of the declaration of an Alert, Site Area Emergency or General Emergency.
III. Reference FSAR, Chapter 13.3 February 3, 1986 letter, R. P. Mcdonald to D. M. Verrelli February 12, 1986 letters from R. P. Mcdonald to affected state agencies requesting concurrence on 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> NOUE time (attached).
1 State agency concurrence letters dated February 20, 21 and 27 and April 3, 1986 (attached).
April 7,1986 letter, J. Nelson Grace to R. P. Mcdonald IV.
Justification for the Proposed Changes he extended NOUE notification time will allow optimum use of resources for responding to the NOUE event. Bis time allowance, imple:nented with state concurrence, is allowable since 10 CFR 50, Appendix E requires that licensees have the
" capability" for a 15 minute notification, not that they utilize the " capability" for all emergency classes. Deletion of the phrase " consistent with operational priorities existing daring the (emergency class) and the need for off-site protective action" and the word "usually" will fulfill verbal commitments to the NRC and commit FNP to utilizing its 15 minute notification capability for the Alert, Site Area and General Emergency classes, t
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V.
Conclusion Since the proposed change includes no changes which would increase the probability or consequences of an accident previously evaluated, no changes which would create the possibility of a new or different kind of accident from any accident previously evaluated and no changes which would involve an unreviewed safety question as defined in 10 CFR 50.59, these changes do not decrease the effectiveness of the Emergency Plan.
Mailing Addrsss Alaca".a F0we* Comcaq 600 North 18tn Street Pest off.ce Box 2641 Birmingham Aiaoama 35291 Teteonone 205 763-6093 R. P. Mcdonald Semo Vice Pres' cent Fhntr.cpe BWorn; AlabamaPower n::
g February 12, 1986 Mr. J. IAonard Ledbetter Cosaissioner Department of Natural Resources State of Georgia 270 Washington Street, S.W.
Atlanta, Georgia 30334
Dear Mr.14dbetter:
As an outgrwth of the 1985 INP Emergency Exercise, Alahama Power Company and the Nuclear Regulatory Commission have had some discussions regarding time limits that must be applied to notifications following declaration of an emergency condition. We NR staff's position is that notification to state governments l
following declaration of a Notification of Unusual Event (NOUE) must be made within approximately 15 minutes unless the agencies involved have agreed to a more liberal time limit, m e pcrpose of this letter is to request your concurrence with a one (1) hour limit on NOUE notifications from Farley Nuclear Plant (ENP).
As you know, the types of events which result in NOUE declaration are of minor significance, are not indicative of a threat to the general public and do not necessitate action by state or local agencies. Alahama Power Company's position is that diverting personnel resources to provide a 15 minute notification of NOUE will reduce our ability to concentrate on stabilizing the plant and mitigating the event without a compensating benefit to the public.
A 15 minute limit would also result in the notification being made by on-shift administrative personnel rather than senior management, as has been our practice to date, and the content of the information conveyed would be reduced. We feel that a notification time limit that will allow senior management to become fully appraised of the situation and concur with planned response actions and then personally to make notifications is the more prudent approach for NOUE. his 4
minimizes the possibility for false notifications and misecumannication and makes complete current and projected status information cvailable to the Egency personnel when the notifications are made.
In discussing this issue with some of the involved agency personnel, the attitude was expressed that a one hour NOUE notification time was reasonable provided that the agency parsonnel were notified before news media began reporting or inquiring about the event. Alabama Power does not routinely make news releases regarding NOUEs and if a news release were made it would not be distributed i
until after the states were notified and informed of the impending news release contents. Were has not been any problem at FNP with media interest in NOUE events within less than one hour after the
Mr. J. Leonard Ledbetter i
February 12, 1986 Page 2 event. We do not anticipate any future problem with off-site agency personnel first learning of an FNP event from the media.
Nevertheless, if snch a situation were to occur, Alabama Power would promptly investigate and take actions as necessary to prevent recurrence.
Based on the above, it would be appreciated if you would provide formal written concurrence with the use of a one (1) hour time limit for notification of the State of Georgia following declaration of a Notification of Unusual Event at Farley Nuclear Plant.
If you have any questions or coments, please advise.
Ve truly rs, l
yp R. P. Mcdonald RPM /EWM:emb cc: Mr. Billy J. Clack Mr. Jim Hardeman file
M Hing Address Alatama Power Company 600 North 18th Street Pos' off.ce Bon 2641 B rmingham. Alaeama 35291 Telephone 205 783-6090 R. P. Mcdonald Semor Vice President Fhntrioge Budde; AlabamaPower t e s:.v r + - : 1.
February 12, 1986 Mr. Aubrey V. Godwin State of Alabama Department of Public Health Bureau of Radiological Health Room 510, state office Building Montgomery, Alabama 36130
Dear Mr. Godwin:
As an outgrowth of the 1985 FNP Emergency Exercise, Alahama Power Company and the Nuclear Regulatory Ccmission have had some discussions regarding time limits that must be applied to notifications following declaration of an emergency condition. We NRC staff's position is that notification to state governments following declaration of a Notification of Unusual Event (NOUE) must be made within approximately 15 minutes unless the agencies ircolved have agreed to a more liberal time limit. he purpose of this letter is to request your concurrence with a one (1) hour limit on NOUE notifications from Farley Nuclear Plant (FNP).
As you know, the types of events which result in NOUE declaration are of minor significance, are not indicative of a threat to the general public and do not necessitate action by state or local agencies. Alab9ma Power Company's position is that diverting personnel resources to provide a 15 minute notification of NOUE will reduce our ability to concentrate on stabilizing the plant and mitigating the event without a compensating benefit to the public.
A 15 minute limit would also result in the notificatim being made by on-shift administrctive personnel rather than senior management, as has been our practice to date, and the content of the information conveyed would be reduced. We feel that a notification time limit that will allow senior management to become fully appraised of the situation and concur with planned response actions and then personally to make notifications is the more prudent approach for NOUE. His minimizes the possibility for false notifications and misecumunication and makes complete current and projected status information available to the agency personnel when the notifications are made.
In discussing this issue with some of the involved agency personnel, the attitude was expressed that a one hour NOUE notification time was reasonable provided that the agency personnel were notified before news media began reporting or inquiring about the event. Alahnma Power does not routinely make news releases regarding NOUEs and if a news release were made it would not be distributed i
until after the states were notified and informed of the impending news release contents. Were has not been any problem at FNP with media interest in NOUE events within less than one hour after the i
Mr. Aubrey Godwin February 12, 1986 Page 2 event. We do not anticipate any future problem with off-site agency 1
personnel first learning of an FNP event from the media.
Nevertheless, if such a situation were to occur, Alahnma Power would promptly investigate and take actions as necessary to prevent recurrence.
f Based on the above, it would be appreciated if you would provide formal written concurrence with the use of a one (1) hour time limit i
for notification of the State of Alnhama. following declaration of a Notification of Unusual Event at Farley Nuclear Plant.
If you have any questions or comments, please advise.
very truly you li' t % -.
R. P. Mcdonald RPWKHM:emb cc: Mr. K. E. Giggy file i
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W MilHng ABCrsss Alaoama Foner Compan) 600 terth 16tn Street Post Office Box 2641 Birmingham. Alabama 35291 Telephone 205 783-6090 R. P. Mcdonald Sesc Vice Presicent Fbntreage Budceg Alabama Power w.y.~
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c February 12, 1986 Mr. Dan Turner Director Alabama Emergency Management Agency Achainistrative Building Montgomery, Alabama 36130
Dear Mr. Turner:
As an outgrowth of the 1985 FNP hergency Exercise, Alabama Power Company and the Nuclear Regulatory Commission have had scae discussions regarding time limits that must be applied to notifications following declaration of an emergency condition. he NRC staff's position is that notification to state governments following declaration of a Notification of thusual Event (NOUE) must be made within approximately 15 minutes unless the agencies involved have agreed to a more liberal time limit. We purpose of this letter is to request your concurrence with a one (1) hour limit on NOUE notifications from Farley Nuclear Plant (FNP).
As you know, the types of events which result in NCUE declaration are of minor significance, are not indicative of a threat to the general public and do not necessitate action by state or local agencies. Alahnma Power Company's position is that diverting personnel resources to provide a 15 minute notification of NOUE will reduce our ability to concentrate on stabilizing the plant and mitigating the event without a compensating benefit to the public. A 15 minute limit would also result in the notification being made by on-shift administrative personnel rather than senior management, as has been our practice to date, and the content of the information conveyed would be reduced. We feel that a notification time limit that will allow senior management to Lecome fully appraised of the situation and concur with planned response actions and then personally to make notifications is the more prudent approach for NOUE. his minimizes the possibility for false notifications and misecumunication arx1 makes complete current and projected status information available to the agency personnel when the notifications are made.
In discussing this issue with some of the involved agency personnel, the attitude was expressed that a one hour NOUE notification time was reasonable provided that the agency personnel were notified before news media began reporting or inquiring about the event. Alabama Power does not routinely make news releases regarding NOUEs and if a news release were made it would not be distributed until after the states were notified and informed of the impending news release contents. Were has not been any problem at FNP with media interest in NOUE events within less than one hour after the
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Mr. Dan Turner February 12, 1986 Page 2 event. We do not anticipate any future problem with off-site agency personnel first learning of an FNP event from the media.
Nevertheless, if such a situation were to occur, Alabama Power would promptly investigate and take actions as necessary to prevent recurrence.
Based on the above, it would be appreciated if you wculd provide formal written concurrence with the use of a one (1) hour time limit for notification of the State of Alahnma following declaration of a Notification of Unusual Event at Farley Nuclear Plant.
If you have any questions or comments, please advise.
Very truly y M
(N R. P. Mcdonald RPM /KWM: erb cc: Mr. A. V. Godwin Mr. K. E. Giggy file
UtiHng Addr ss Atacama Power Company 600 North 18tn Street Post Office Box 2641 Birmingham Alaeama 35291 Telephone 205 783-6093 R. P. Mcoonald l
Senior Vice Pres' cent Fontnoge Budding AlabamaPower
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February 12, 1986 4
Major General Joseph W. Griffin Director Georgia Deergency Management Agency P. O. Box 18055 Atlanta, Georgia 30316-0055
Dear General Griffin:
As an outgrowth of the 1985 FNP Emergency Exercise, Alabama Power Compeny and the Nuclear Regulatory cr==ission have had some discussions regarding time limits that must be applied to notifications following declaration of an emergency condition. We NRC staff's position is that notification to state governments following declaration of a Notification of Unusual Event (NOUE) m st be made within approximately 15 minutes unless the agencies involved have agreed to a more liberal time limit. h e purpose of this letter is to request your concurrence with a one (1) hour limit on NOUE notifications from Farley Nuclear Plant (FNP).
As you know, the types of events which result in NOUE declaration are of minor significance, are not indicative of a threat to the general public and do not necessitate action by state or local agencies. Alabama Power Company's position is that diverting personnel resources to provide a 15 minute notification of NOUE will reduce our ability to concentrate on stabilizing the plant and mitigating the event without a compensating benefit to the public. A 15 minute limit would also result in the notification being made by on-shift administrative personnel rather than senior management, as has been our practice to date, and the content of the information conveyed would be reduced. We feel that a notification time limit that will allow senior management to become fully appraised of the situation and concur with planned response actions and then personally to make notifications is the more prudent approach for NOUE. His minimizes the possibility for false notifications and miscomu nication and makes complete current and projected status information available to the agency personnel when the notifications are made.
In discussing this issue with some of the involved agency personnel, the attitude was expressed that a one hour NOUE notification time was reasonable provided that the agency personnel were notified before news media began reporting or inquiring about the l
l Power does not routinely make news releases regarding event. Alahnma NOUEs and if a news release were made it would not be distributed i
l until after the states were notified and informed of the impending news release contents. W ere has not been any problem at FNP with media interest in NOUE events within less than one hour after the l
l
l Major General Joseph W. Griffin February 12, 1986 Page 2 event. We do not anticipate any future problem with off-site agency personnel first learning of an FNP event from the media.
Nevertheless, if such a situation were to occur, Alabama Power would promptly investigate and take actions as necessary to prevent l
recurrence.
Based on the above, it would be appreciated if you would provide formal written concurrence with the use of a one (1) hour time limit for notification of the State of Georgia following declaration of a Notification of Unusual Event at Farley Nuclear Plant.
If you have any questions or comments, please advise.
Very truly yours, G%
R. P. Mcdonald RPM /10fM:emb cc: Mr. Billy J. Clack Mr. Jim Hardeman
e STATE OF GEORGI A g.,
Bepartment of Defense A
y ecorgia Cmcrgency fHanagement 9gentP un Josses w. onire:N P.O. Box 18055 elLLY J. CLACK
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Atf anta, Georgia 30316 0055 TEL: (404) 656-5500 27 February 1986 Mr. R. P. Mcdonald y Senior Vice President Alabama Power Company Post Office Box 2641 Birningham, Alabama 35291
Dear Mr. Mcdonald:
Peference is made to your letter of 12 February 1986 in which you asked for formal written concurrence with the use of a one hour time limit for notification of the State of Georgia following declaration of Notification of Unusual Event (NUE) at Farley Nuclear Plant.
Based en ycur assurance that news releases regarding NUEs would not Fr distributed by Alabama Power Company prior to notification of the State of Georgia, I have ne cbjection to the one hour tine frane you have proposed.
Accordingly, this letter constitutes formal concurrence by the Georgia Energency Management Agency.
It is my understanding that the Gecrgia Department ef Natural Recources, Environmental Protecticn Division also concurs and will reply by separate correspondence.
Sincerely, 1
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f0SPHW.GR 4G, The Adj tant General 1
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J. Leonard Ledbetter
-- x Commissioner, DNR
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STATE OF ALABAMA EMERGENCY MANAGEMENT AGENCY 560 South McDonough DANTURNEH GEORGE C. WALLACE 261-3318 couasc.
February 20, 1986 7v Mr. R. P. Mcdonald, Vice President (,)
Nuclear Generation Alabama Power Company 600 North 18th Street Birmingham, Alabama 35291 Dear Mr. Mcdonald; This Agency concurs with your request for a one hour limit for notification of the State of Alabama following declaration of a Notification of Unusual Event at the Farley Nuclear Power Plant.
If at any time the news media or general public become aware of a NOUE condition prior to the State and local Emergency Management Agency being notified, the one hour limit will have to be reconsidered.
Sincf)ely, Dan Turner Director DT: KEG: led Aubrey Godwin (RAD Health) cc:
Karyn Gilley (Houston Co. EMA) p.
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Georgia Department of Natural Resources -
-e 270 W:shingt:n Street, S.W., Room 825, Atlanta, Georgb 30334 J. Leonard Le@etter, Commisseonor i
Harold F. Reheis. Asistant Director Environmental Protection Division February 21, 1986 Mr. R.P. Mcdonald, Senior Vice Presiden h Alabama Power Company V
600 North 18th Street Post Office Box 2641 Birmingham, Alabama 35291
Dear Mr. Mcdonald:
This letter is in response to your letter of February 12, 1986 in which you requested our formal concurrence on relaxation of the requirement for notification of state governments following the declaration of an event in the Notification of Unusual Event (NOVE) classification from 15 minutes to one (1) hour. This proposal has been examined by staff of the Environmental Radiation Program, who are responsible both for planning and response to incidents at the Farley Nuclear Plant and I have been advised, based on their analysis, that concurrence with your proposal would be consistent with our concerns for the protection of public health and safety, since, as you stated in your letter, relaxation of the notification requirement would allow you to focus your efforts on plant stabilization and event mitigation.
I hereby grant the concurrence of the Georgia Department of Natural Resources to your request for a one (1) hour notification limit for incidents in the NOUE classification at the Farley Nuclear Plant.
Sincerely,
. L onard Ledb tter Conin ssioner JLL/jhm cc: Major General Joseph M. Griffin, Adjutant General C.234c Georgia Department of Defense j
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DEPARTMENT OF PUBLIC HEALTH i
State Office Buildmg Montgomery, Alabama 36130 IR A L. MYERS. M.D.
STATE HEA1.TH OFFICER April 3, 1986 Mr. R. P. McDonal V Vice President Nuclear Generation Alabama Power Company 600 North 18th Street Birmingham, Alabama 35291
Dear Mr. Mcdonald:
This Agency concurs with your request for a one-hour limit for noti-fication of the State of Alabama following declaration of a Notification of an Unusual Event at the Farley Nuclear Power Plant.
If at any time following the declaration of a Notification of an Unusual Event the event is escalated in classification to an Alert or higher, then we will require immediate (within 15 minutes) notification of the escalation.
Sincerely, b
Aubrey V. Godwin, Director Bureau of Radiological Health Environmental & Facility Standards Administration AVG:J111:mpw K*%n,p sc; s
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