ML20236R459
| ML20236R459 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 11/13/1987 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NT-87-0465, NT-87-465, NUDOCS 8711230293 | |
| Download: ML20236R459 (4) | |
Text
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F-Agbgma Power ompany NT-87-0465 g
Post Office Box 2641 Birmingham, Alabama 35291-0400 Telephone 205 250-1835 -
L Ln'C? e"n.iaen, Nkm@wa the southem electricsystem November 13, 1987
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Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Region II Suite 2900 101 Marietta Street, N.W.
Atlanta, Georgia 30323 Attention: Mr. J. Philip Stohr Gentlemen:
Joseph N. Farley Nuclear Plant NRC Inspection Report Nos. 50-348/87-20 and 50-364/87-20 In response to your letter of October 2,1987, provided herein are planned corrective actions for the items identified as requiring corrective action during the September Emergency Exercise.
i ITEM 1:
"This exercise scenario was not of the quality we have come to expect from your organization." "The lack of a challenging scenario made it difficult to assess the adequacy of the emergency organization in responding to E
a casualty that was neither time demanding and/or esent
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demanding."
CORRECTIVE ACTION: None.
Since this was not addressed or discussed in the exit meeting, even tht,egh a written response was not requested 1
in your October 2 letter, the following comments are
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provided.
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Alabama Power Company takes exception to the characteri-l zation of the exercise scenario quality as requiring
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corrective action due to the level of challenge presented by the scenario.
It would appear that there are only four options available to make a scenario more challenging:
- 1) increase the severity of the accident; 2) include a fire or medical emergency as part of the scenario; 3);
impose unrelated events or failures to distract the staff or 4)' increase the pace of events by time compaction.
Alabama Power does not feel that any of these options are appropriate or necessary.
q 8711230293 871113 f
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U. S. Nuclear Regulatory Commission November 13, 1987 Page 2 With regard to the severity of the scenario accident, the scenario utilized in the 1987 exercise was equivalent in complexity to scenarios used for several previous years and challenged the participants to respond to an accident sequence which went beyond design basis. A design basis l
loss of coolant accident (with leak before break) was simulated and in order to provide a repairable containment leakage path, two normally locked-closed valves were simulated to fail open.
In order to simulate an extended release of radioactive material, a total of six valves were simulated to be incapable of closing and repair of the valves was prevented despite multiple repair party reentries. Alabama Power Company scenario development practices both this year and in prior years have been to make scenarios as realistic as possible, using design basis accidents and going beyond design basis only to the extent necessary to achieve the required emergency classification, off-site dose rate, release duration, i
etc. as dictated by utility, state and local exercise objectives. We do not believe that increasing accident I
severity even further to achieve greater challenge is reasonable or productive.
With regard to option 2, the annual fire drill involving off-site fire department personnel and the annual medical j
I drill involving the local ambulance service and local
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hospital have always been conducted separately so that j
proper attention could be given to the preparation for, l
conduct of and evaluation of those important drills. This is particularly relevant due to the fact that an actual j
fire emergency or medical emergency is much more likely l
to occur than a design basis or beyona design basis accident. Drills designed to ensure preparation for these more likely events deserve the level of attention l
that is possible only by conducting them separately.
l With regard to option 3, unrelated events or failures, the l
chance of random failures of critical equipment is some-what independent of an accident event. Except where prescripting of specific failures has been necessary to i
meet exercise objectives, equipment failures have been accounted for in prior exercises by incorporating unplanned actual equipment f ailures and their subsequent real time repair into the exercise scenario if and when they occur. Thus in past exercises, when a malfunction of the SPING high range stack effluent monitor and the EDCM dose assessment computer occurred, data that would normally be available from that equipment has been with-held from the players until the equipment was fixed.
In this year's exercise, a radio' unit on a plant vehicle and some portable radiation monitoring equipment mal-functioned. Utilization of such actual, unplanned, real-time equipment failures is a realistic approach to
V. S. Nuclear Regulatory Commission November 13, 1987 Page 3 introducing additional challenge into a scenario, allows more realistic response to the failures and is sufficient.
APCo does not believe that prescripted events unrelated to the main scenario are appropriate for an annual exercise.
Finally, with regard to option 4, time compaction, the timing and pace of an exercise scenario as well' as decisions on prestaging of participants, must consider planned federal participation and the objectives and needs of two local governments and two to three state governments. Prestaging by one or more state or federal agencies forces prestaging by the utility to keep l
facility activations and on-site personnel availabilities i
synchronized. This year, as in some past years, APCo has compensated for prestaging by conducting an activation drill the day before the exercise. The pace during an exercise is set to be as realistic as possible and to accommodate fulfilling the objectives of participating agencies within the time available. APCo feels that this year's exercise used realistic event timing except where release path repair was prevented to allow continuation of effluent release.
Increasing the pace significantly would not have been productive and would not have been acceptable to all other involved parties.
In summary, APCo feels that Farley Nuclear Plant exercise scenarios are and should be kept consistent with the regulatory language and intent of exercising the emergency plans.
Increasing the scope of an exercise scenario as described in any of the above four options would detract from reviewing the details of Emergency Implementing Procedures and Emergency Response Procedures and from evaluating personnel response to them.
Alabama Power Company intends to continue its existing practices regarding exercise objective and exercise scenario devel opment.
ITEM 2:
Off-Site Notifications: This area consisted of two sub-items:
ITEM 2-A:
"As a result of the telephone conversation on September 16, 1986, between representatives of your staff and Region II staff we understand you will review your notification procedure to clarify when initial and followup notification information.is to be provided to the States."
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CORRECTIVE ACTION: FNP-0-EIP-26, Offsite Notification, was revised to clarify when the initial and follow-up notification forms are to be utilized in the notification process to the States. This action was completed October 7,1987.
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U. S. Nuclear Regulatory Commission November 13, 1987 Page 4 ITEM 2-B:
"In addition, there was a failure to initially notify the State of Alabama Bureau of Radiological Health as required by your Emergency Plan and Procedures, as well as agreed to by Alabama Power Company and the State of Alabama. This initial notification was made to the Alabama Emergency Management Agency instead."
CORRECTIVE ACTION:
FNP-0-EIP-8, Emergency Communications, was revised October 16, 1987 to clarify which agency should be notified first in Alabama and in Georgia following event declaration. Further instruction on notification will be conducted during 1988 Emergency Plan training.
If there are any questions, please advise.
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R. P. Mcdonald RPM:emb
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cc: Mr. L. B. Long l
Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford t