ML20246L398

Discusses Lack of Generic Emergency Operating Procedure Guidelines.Nrc Suggests Scheduling of Meeting in Near Future to Resolve Concerns Re Continued Reliance Upon Abnormal Transient Operating Guideline Part II as Licensing Basis

ML20246L398
Person / Time
Site:	Arkansas Nuclear
Issue date:	07/12/1989
From:	Hebdon F Office of Nuclear Reactor Regulation
To:	Tison Campbell ARKANSAS POWER & LIGHT CO.
References
TASK-1.C.1, TASK-TM NUDOCS 8907180424
Download: ML20246L398 (5)

Text

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\\j July 12, 1989 Docket No. 50-313 Er. T. Gene Campbell

'Vice President Nuclear Arkansas Power and Light Company P. O. Box 551 Little Rock, Arkansas 72203

SUBJECT:

EMERGENCY OPERATING PROCEDURES GUIDELINES

Reference:

L. J. Callan, "NRC Inspection Report No. 50-313/88-17," Letter from.NRC Director, Division of Reactor Projects, Region 11 to Arkansas Power and Light Company, Docket No. 50-313, License No.

DPR-51, July 25, 1988.

The NRC is inspecting emergency operating procedures (EOPs) at all plants containing B&W Nuclear Steam Supply Systems (NSSSs). At the plants inspected

.so far, including Arkansas Nuclear One, Unit 1 (ANO-1), the most significant deficiency found was the lack of suitable generic guidelines.

As you are aware, the B&W Owners Group (BWOG) is supporting a generic emergency procedures guidelines (EPG) effort that should correct this deficiency. We recommend this generic approach because it is efficient and uses the knowledge of both B&W and the B&W NSSS owners.

It has led to resolution of many of the old openissuesthatremainfromtheAbnormalTransientOperatingGuidelines(ATOG) review. We originally understood that all B&W NSSS owners would use the results of the BWOG program. However, we now understand that ANO-I is not planning to adopt the new EPG program or use the program results.

Our E0P inspection report (see reference) stated that "...ANO had no NRCapproved[ generic]documenttoserveasabasisfordevelopmentofthe ANO-1 specific guidelines." We understand you are continuing to use the Oconee ATOG Part II as the licensing basis for your plant-specific EPGs. This has given the staff cause for concern because:

ANO-1 has made many plant specific changes which are inconsistent with ATOG Part II.

ANO-1 does not use ATOG Part I, and ATOG Part II is not a stand-alone, staff-approved generic document from which procedures may be generated.

This is inconsistent with TMI action Item I.C.I. because ATOG Part II contains no operator guidelines. Further, most of the outstanding issues from ATOG Part I pertain to the bases for the EPGs, and a user of ATOG Part II would have to address each of these issues.

ANO-1 never used certain sections of ATOG Part II.

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Mr. k ' Gene Campbell Additional concerns regarding the plant specific technical guidelines were also noted in the ANO-1 Procedure Generation Package Safety Evaluation Report dated June 23,.1989.

In order to facilitate resolution of our concerns regarding your continued reliance upon the AT0G Part II as the licensing basis for the ANO-1 plant specific technical guidelines, we propose to meet witn you at our office in Rockville, Maryland in the near future. The specific cate and time should be arranged through the ANO-1 NRR Project Manager. At the meeting you should be prepared to address (1) your program for resolution of the generic technical guidelines issues, and (2) your program for long-term maintenance of your plant specific technical guidelines and energency operating procedures.

If your plans have changed, and you intend to adopt the B&W Owners Group EPG program, and use the program results, please inform us in writing immediately.

In that case, a meeting may not be necessary. We believe that the BWOG EPG program will result in a better and more efficient resolution of the generic technical guidelines issue at B&W facilities.

Sincerely,

/s/

Frederick J. Hebdon, Director Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION

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^ Mr. T. Gene Campbell '

l Additional concerns regarding-the plant specific technical guidelines were also noted in the ANO-1 Procedure Generation Package Safety Evaluation Report dated June 23, 1989.

1 In order to facilitate resolution of our concerns regarding your continued reliance upon the AT0G Part II as the licensing basis for the ANO-1 plant specific ttchnical guidelines, we propose to meet with you.at our office in Rockville, Maryland in the near future. The specific date and time should be arranged through the ANO-1 NRR Project Manager. At the meeting you should be preparedtoaddress;(1) guidelinesissues,and(yourprogramforresolutionofthegenerictechnical'2) your progra specific technical. guidelines and eaergency operating procedures.

If your plans have changed, and you intend to adopt the B&W Owners Group EPG program, and use the program results, please inform us in writing immediately.

i In that case, a meeting may not be necessary. We believe that the BWOG EPG program will-result in a better and more efficient resolution of the generic

- technical guidelines issue at B&W facilities.

Sincerely, Frederich.Hebdon, Director Project Directorate - IV Divisica of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION Dc Met File NRC PDR Local PDR PD4 Reading M. Virgilio G.Holahan F. Hebdon P. Noonan C. Harbuck OGC-Rockville E. Jordan B. Grimes w, Rep

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Mr.h.GeneCampbell Arkansas Power & Light Company Arkansas Nuclear One, Unit 1 CC:

Mr. Early Ewing, General Manager Technical Support and Assessment Arkansas Nuclear One.

P. O. Box 608 Russellville,: Arkansas 72801 Mr. Niel Carns, Director Nuclear Operations Arkansas Nuclear One P.-0. Box 608 Russellville, Arkansas 72801

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Mr. Nicholas S. Reynolds Bishop, Cook, Purcell & Reynolds 1400 L Street, N.W.

Washington, D.C.

20005-3502 Mr. Robert B.- Borsum Babcock & 'Wilcox Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, Maryland 20852 Senior Resident inspector U.S. Nuclear Regulatory Connission 1 Nuclear Plant Road Russellville, Arkansas 72801 Regional Administrator, Region IV U.S.. Nuclear Regulatory Commission Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Honorable Joe W. Phillips County Judge of Pope County Pope County Courthoese

'Russellville, Arkansas 72801 Ms. Greta Dicus, Director l

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Division of Environmental Health Protection Arkansas Department of Health 4815 West Markam Street Little Rock, Arkansas 72201 l

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Additional concerns regarding the plant specific technical guidelines were also l

noted in the AND-1 Procedure Generation Package Safety Evaluation Report dated June 23, 1989.

In order to facilitate resolution of our concerns regarding your continued reliance upon the ATOG Part II as the licensing basis for the ANO-1 plant specific technical guidelines, we propose to meet with you at our office in Rockville, Maryland in the near future. The specific date and time should be arranged through the ANO-1 NRR Project Manager. At the meeting you should be preparedtoaddress(1) guidelinesissues,and(yourprogramforresolutionofthegenerictechnical2) your program specific technical guidelines and emorgency operating procedures.

If your plans have changed, and you intend to adopt the B&W Owners Group EPG program, and use the program results, please inform us in' writing issnediately.

In that case, a meeting may not be necessary. We believe that the BWOG EPG program will result in a better and more efficient resolution of the generic technical guidelines issue at B&W facilities.

Sincerely, Frederick J. Hebdon, Director Project Directorate - IV Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation ec: See next page

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