ML20205P722

Forwards Insp Repts 50-424/86-12 & 50-425/86-18 on 860310-21.Listed Emergency Preparedness Program Areas Need Evaluation,Improvement &/Or Completion

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: IR 05000424/1986012 ML20205P722
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

PDR

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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. C. Teper, Georgians Against Nuclear

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Johnson, Executive Director,

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Educational Campaign for a Prosperous

Georgia

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

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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

,

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)

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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

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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

Emergency Plan.

(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

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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)

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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)

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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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