ML20141M416

Partial Response to FOIA Request for Documents.Forwards App F Documents Which Are Being Made Available in PDR

ML20141M416
Person / Time
Site:	Vogtle
Issue date:	12/19/1991
From:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
To:	Lamberski J TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
Shared Package
ML20141J689	List: IA-91-468, Partial Response to FOIA Request for Documents.Forwards App F Documents Which Are Being Made Available in PDR ML20141J684 ML20141J692 ML20141J697 ML20141M416
References
FOIA-91-468 NUDOCS 9208130214
Download: ML20141M416 (2)

Text

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! I) RESPONSE TO FREEDOM OF lt w ] Pet INFORMATION ACT (FOIA) REQUEST o^u  !

L g%.. 'DEC 1 91991 l ooco i er om, m,-,r

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" Mr . John Lamberski PART 1.-AGENCY RLCORDS PELC ASED OR NOT LOCATLD iSee chereedbo7es)

No agency records sub;ttt to the request have been located.

No additional agency records subject to the request have been loc ated.

Requested recedds are areilable through another public distribution prog <am see comments section.

Agency records subject to the request that are identified in Aprwrd ates) are already available for public inspection and copying et the g NRC Pubt;c Document Room,2120 L Street, N.W.. Washington. DC. j Agency.ecords subject to the request that are identified in Append; fesL_f are being made available for public inspection and copying ;j et the NRC Public Docs. ment Roorn. 2120 L Street. N.W., Warbington. DC,in a folder under this FOI A number.

The nonproprietary version of the proposal (s) that you agreed to accept in a telephone conversatch W:th a entmber of rey staf f is noW being ma available i for pubhc inspottien and copying at the NRC Public Docume..t Ronm. 2120 L Street, N W., Washington, DC, in a folder undet this F0l A number. l Agaricy records sutdect to the request that are identified in Appendin(es)_ may be instated and topied at the NRC t ocal Public Document Room identified in the Commente section.

Enclosed is infornution on how you may obtain access to and the c harry

• los tupying records locattd at the NRC Public Document Room,2120 L Street, _- -,

3 N,W , Wavungton, DC. , _

Agency retords subject to the request ere enclosed '

)( , Appendix F Records subject to the request have been te reed to another Feder4: agencybes) for revic* and dirt <t response to you. s rees . .

Yod will be bdled by the NRC for fees totabng $

You will receive a refund frorn the NRC in the amount of $ ,

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I in view of NRC's response to this request, no further action is being taken on appeal !etter dated , No.

I PART 11. A-INFORMATiON WITHHELD FROM PUBLIC DISCDSURh Certain information in the reauested records is being withheid from putdie disclosure pursuant to the exemptions described m and for the reasons stated - ,

in Part II,8, C, and O. Any released portions of the documents for which only part of the record is being withheld are being made available for public inapecticn and copying in the NRC Public Docurnent Room 2120 L Street. N W., Washington, DC in a folder under tnis FOI A number.

COMMENTS ,

'This is a partial-response. The review offot'.ier' relevant documentation-is ongoing.

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Res FOIA-91-468 APPliNDIX P RT&QBDS DiCI&fiED liUMBER DATE IlliSCRII7IOJi

1. 4/3/90 Memo to A. Chaffee from G. G. Zech re Lessons Learned: Vogtle Site Area Emergency (3 pages)

2. 6/4/90- Note to E. Jordan from F. Ingram re s.

draft-public announcement.(4 pages)

- 3. :7/12/90 Memo to T. B. Kellam from E. W. Weiss re Telecommunications Problomm During _

Vogtle Event (1 page) 4.: 8/8/90- Memo tr Chairman Carr, et al., from J.

M. Taylor ro Staff Actions Resulting form the Vogtle Unit 1 Incident Investigation with annotated enclosure (12 pages) 3

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October 22, 1991 Mr. Donnie H. Grimsley, Director UffDM Of lHf0RMATl0N Division of Freedom of Information ACT REQUEST

" and Publications Serfices f' office of Administration / O ' 7/ '96 I' U. S. Nuclear Regulatory Commission n Washington, DC 20555~ VJi'dgd7#//

Re: EILqdp_m OLlDiolaa1L9.n_A.gt Feauo31

Dear Mr. Grimsley:

I hereby request, pursuant to the federal Freedom of Information Act_("FOIA"), 5 U.S.C. S 552, as amended, and Nuclear

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Regulatory Commission ("NRC") regulations, 10 C.F.R. Part 9, copies of all " records" as defined in 10 C.F.R. 5 9.13 which formed ' the bas.ts of the NRC's April 12, 1990 letter from Mr.

Stewart D. Ebneter-(NRC Region II Administrator) to Mr. W. George Nairston,-III (Georgia Power Company) entitled " Completion of Confirmation'of Action. Letter Commitments." Additionally, I request a_ copy _of all records, as defined above, constituting or relating to any internal-NRC Task Interface Agreement (s) addressing-follow-up NRC_ actions in connection with the NRC's review of the March 20, 1990_ loss-of off-site power event at the

.Vogtle Electric Generating Plant (see attached NRC Staff Guidelines Concerning Plant Restart Approval, dated November 23,

.1988, Part-I, itemL3),

' t- For your.Information, I believe that records encompassed by this FOIA request are or were in the poscession of Mr. Stewart D.

b Ebneter (Region II), Mr. Kenneth E. Brockman (Region II), Mr.

Rick Kendall (NRR)-and Mr. Alfred'E. Chaffee (Region-V).

g .I am'willing_to pay the applicable charges for prcduction_of i~ the. requested records in accordance_with 10 C.F.R. Part 9 up to a maximum amount _of $1000.00 and those charges in excess of

$1000.00Lof which I am notified, and which I approve, in advance.

If you have any questions concerning this'FOIA request, p,'. ease feel free to contact me.

Very truly yours, Q- . .

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R? a; y 7-utttTto sTJ2Tua gt yMsg{ NUCLEAR HEGULATORY c0MMissiON RE0loN il

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Docket No. 50-424 License No. NPF-68 i

Georgia Power comsany-ATTH: Mr. W. G. l4airston, !!!

Senior Vice President -

Nuclear Operations P. O. Box 1295- ,

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. Bimingham, AL 35201 ,

Gent 1 men:

SUBJECT:

COMPLETION OF CONFIRMATION OF ACTION LETTER COMMITMENTS In a letter from the NRC- to Georgia Power Company (GPC), subject "Confirv.ation of Action 8,etter," ' dated March 23, 1990, certain matters were agreed to be Additionally, completed prior to Yogtle, Unit 1, reattaining criticality.

your connitments concerning the needs and requirements ofloss 20, 1990, the Incident of vital AC

-Investigation Team dispatched to review the MarchThis letter confirms the satisfactory power event on Unit 1, were delineated. resolution. of L item number 1 and do concurrence that appropriate corrective actions have been taken and the plant can safely return to operation.

Georgia Power Company briefed NRC management on their On eventApril 9, ,1990, critique resu lts and the short- and long tern corrective actions they plan to implement. These items were specified in a letter from GPC to the NRC, dated April 9,1990, and included additional itwns which GPC has ccernitted to submit to the NRC.

' Based upon the:infomation provided by GPC and the short-term actions'which have been implemented, Georgia Power Company is authorized to return Unit 1 to

_ Hede 2. . attain criticality, and proceed to subsequent power operation.

J Items 2-5 of the March 23, '~ 1990, Confirmation of Action Letter remain applicable and are not relieved by this letter.

If your understanding; differs from that set forth above, please call me in.tediately.

Sincerely,

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Stewart D. Ebneter '

gN Bf Regional Ad:ninistrator G GEtw08 KP, 8

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NRC Office Ofrectors Regional Administrators R. P. Mcdonald L- - - . Executive Vice President-Nuclear  !

Operations Georgia: Power Company k P. O. Box 1295; -

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n; General Manager, Nuclear Operations-Georgia 1 Power; Company-P. ; 0. /1600 '- -. - -i

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..C Office of Planning and Budget

Room 6158 270 Washing' ton Street, SW

. Atlanta, GA 30334-Office of the County Comissioner l Burke County Comission e Waynesboro, GA- 30830 JJ Leonard Ledbetter, Director

-Environ .artal Protection Division -

Department of Natural Resources 205' Butler Street, _SE, Suite 1252

Atlanta, GA 30334 Attorney Generai

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l M(NORANDUM FOR: hRC Office Otrectors 1

NRC Reitonal Aestnistrators FROMt Victor Stello. Jr.

Executive Director for Operations l

'$UBJECT: STAFF GUIDELINES CONCERNING PLANT RESTART APPROYAt. (

i in my memorandum of July 21. 1988 guidelines regarding management of the staff's activities associated with plant restart approval were issued. The enclosurs expands these guidelines to include general criteria on the issues to be considered during the staff's tvaluettori.

Orighals%ned W y.ctof S14110.8/s Victor Stallo, Jr.

, . . Docutive Otttctor for Oparations

Enclosure:

Plant Restart Approval Guidelines DI ten $TAIBUT' Te* ONtral I 6 dinn Stello P01 2 Read'ng Taylor J81aha PDR TMurley ,

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$TAFF GUIDEllNES CONCERNING PLANT RESTART APPROYAl.

This paper estabitshes the frantwork for the duthoritation of the restart of a nuclear power plant, af ter a voluntary or involuntary shutdown due to a significant event or serious management deficiencies. No attempt is made to precisely define these terms, and judgexnt as outilned below is needed. The guidelines presented (1) brovide for more effective coordination of NRC resources between Regions and Headouarters, (?) clarify responsibilttles. and

- (3)ensurethatthereisconsistencyintheactionsofHRRandRegional manageeent personnel involved in major NRC decisions directly affecting Itcensees.

Licensed ccmercial nuclear power plants ar4 shutdown, voluntarily or not.

for a variety of reasons. When a plant is shutdown for reasons steming from 11 cense conditions or technical specifications, the Itcensee normally can develop and tr91ennt a clearly defined correction plan) when the criteria of this plan ire met, the plant is alleved to restart without special authoritation from HQC. However. plants occasionally are in a shutdown condition as a result of a significant event or serious managteent deficiencies. These are the cases at which this stetteent is directed.

Exangles of thLs type of shutdown include plants that were shut down because of performance problems during the past few yearst e.g., Sequoyah, Browns Ferry, Rancho Seco. Pflgrim and Peach Bottom.

The NRC has reacted to these types of facility shutdowns in a variety of ways depending on the severity of the event that led to the shutdown.

Historically. the NRC has approached each event individually, and an individual plan of action has evolved. The results have been satisfactory.

but the process bas not been approached in a untform canner. The guidelines presented in this stattinent all) ensure that (1) NRR and Regions will be appropriately involved in all restart decisions and (2) the NRC will present a untfled position to the Itcensees. However. because each plant shutdown

situation is different. 4 detailed generic procedure for restart approvals is l not appropriate.

The general guidelines for NRC reaction to the events of concern are provided

! in two parts. Part one deals with the management of the staff's activities associated with the restart review efforts and part two deals with the various issues that are considered in the reviews.

Part 1_

1. When a Region believes that a particular situation at a plant represents a significant event or serious managecent deficienclea warranting increased regulatory attention, the Region should discuss the issue with NRR. Except for special circumstances, the initial discussion should be between the appropriate Region managernent and the NRR Division Of rector for Operational Events Assessment (00EA). The discussion should include a

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7 description nf the event or circumstances, as well as the Region actions already-t d en, and proposed future actions. Potential NPC reactinns l could include the estabitshment of an Incident Investigation Teen (11T). .

Augmented Inspection Team (AIT) s Regional Assessment Team IRAT). or a special inspection, and includine, as appropriste the need for a Confirmatory ActionTetter or Order.- All of these individual reactions  :

.wccid be conducted in accordshce with appropriate standard office l policies, procedures. and Manual Chapters. Special circumstances involve i significent rapidly occurring events, where discussions could be intt1sted direct 1/ at the level of the Regional Administrator, the  ;

Otrector NRR or the.DIDRO.

2. The NRR.Divistoa Director for Operational tvents Asses ment will promptly .

notify the appron*Me NRR Projects Olvision Ofrector of the results of f

- the df *M; ion with.the N9 f on. The focal point for discussions within ,

the NLC for. follow.up actio1s will be the appropriate Projects Ofvision ,

Directors in the Region and in NER. They will coordinate participation ',

in conference calls and menacement discussions to ensure that the Regional '

Administrator and the Olrector NRe. are directly involved. in important.

dec t s f t,ns. : The Pro,tect Olvisfont wn11 coordinate'and carry out the  ;

actions prescribed in the follow.up plan.-  ;

3. After tho'Reefen and MRR decide on a cowrse of action, including nettffcation of the (00 and Coretssion as appropriate. the respective -

projects Olvisions will-jointly initiate a Task Interface Agreement fila) to document the assignment of responsibility for follow up actions. For >

rapidly occurrine eventt leading to a-outek restart of a plant, the coordination between the Reefon and.NAR may be done orally. Mcnrever, for events-that' take. acre than about a weak to resolve, a formal TIA should-be drafted. Eleeents.of the T1A should foclude the followino:  ;

a. The TIALformat must be flexit,1e to account for the diverse nature of events. However.'all T!A's- should define-II) what Pust be accomplished, as a sinteum. to authorite plant = restart. 170 who has-lead responsibility lfor each action, and f 3) who has responstbflity ,

for actual plant restart authortration.

b. .The' TIA should fully document all actions that must be taken before-  :

'a-plant is authortred to restart, even if ~ they are not related tn  !

the inttlating event.

c.; LThe Consatssion needs; to be.tept adeoustely Inforwed of the staff's restart 1 actions on:ascentinuing basis.. The TIA wl11' document lead-  ;

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.responsiblitty within the agency for interactions with the

' Comet 55fon, The lead offfce w111 keep the Commission-inforved nf ,

the sta"'s and Itcensee's restart actions through the use of . ,

Comission papers, defly reports.- and/N-verbal'ccmunications via the.E00.:: 8ased on these staff /Corestssion interactions,. the need 'nr Commission 6rfeffecs will be determined by the cf rcumstances and p'

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3 Comission desires. However, the staff should anticipate Comission  ;

briefings with licensee participation (a) af ter a correctivo plan is I l

agreed to and implemented, (b) 4. bout a munth before plant restart it antfripated, and (c) a few days prior to the scheduled restart. At '

the anticipated final briefinn, the NRC staff would be required to I

give the staf' position as to their basis for recoernending or not recoernendino restart. The Comission will express its views  !

concerning restart at any time during the process, but normally 4

. formal vote is not taken until the last briefing, l l Part _11.

l. t.icensee Restart Plan! Root Cause Identiffed and Corrected First, the root cause of the event or conditions requiring the shutdown must be properly identified. Then the root cause of the event or conditions requiring the shutdc+n must be addressed by a comprehensive corrective action plan which addresses all applicable issues. The plan oust chry the issues through their corrective action, implementation and verification phases.

The above actions are tauen by the facility Ifeensee. The NRC reviews and detennines the acceptability of these actions to support safe operations using any or all of the tools available to it in the reculatory orocram. These could include any or all of the following: a Headquarters staff review. SALP, the inspection procram including regular inspections, specialist inspections or team inspections and enforcement conferences.

Resulting actions are set forth in safety evaluations, license amendments, orders, confirmatory action letters, inspection reports, enforcement documents, etc. The staff's review includes the applicable areas outlined below.

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'2,-lycenseeManagementOrganiration-The licensee's managen. era orgenf ration is reviewed to ensure that the proper envircrrnent and resources are provided to ensure that the problems

.and their root causes have been rectified. The organfration must demonstrate that it can coordinate. integrate and comunicate its

=4= ob.lectiver so that they are appropriately prioritized for safety-significance and are achieved in a timely manner.

This requires an appreciation on the part of that management, of what the u

safety issues are, coupled with a positive attitude toward ensuring that they are resolved. This in turn requires that personnel with adequate cualifications and experience be provided for all key management positions.

The resulting or (a) exhibit good teamwork among itt.

subelements; (b)ganization should: provide strong engineering support for plan (c1 have.the internal ability to recognize safety problems, develop adequate Corrective actions, and verify their implementation and effective-ness; and (d) have an independent self-assessment capability that can identify situations not sufficient 1v deelt with by the regular functioning of the principal organf ration.

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3. Plant and Corporate Staff The operations staff nJst recognize and carry out their responsibilities l in ensuring public health and safety as recuired of them by their individual licenses as well as by the factitty license to operate the plant. These responsibilities must be met while working witnin the env' *onment established by the ifcensee's management as discussed above.

This, in turn, requires that an adequate number of fomally qualified licensed operators be provided. A positive proactive attitude towards safety issues should be demonstrated across the board in all aspects of operations. In this regard operators should display attertiveness to duty, fitness for duty, a disciplined approach to activities. A sensitivity for trends on what is happening in the plant, security awareness, and an ,

openness of corwanications and desire for team work which supports i effective relations between dif ferent groups (e.g., management, operations, l health physics, maintenance, security, contractors).

4 Physical Stge of pf adiness_ of the plant

' Thlstis of principal importance for those cases where the reason for the shutdown was based on a physical event or deficiency but it is also important for other types of events as well.

For_ equipment problems the cause should be identified and appropriate corrective actions taken in the manner discussed in (1) above.

These issues will warrant a strong focus on the pre. operational or initial operational testing which verifies that the problem is resolved. For complex issues this testing program may also he cernplex and of an extended duration.

For other types of problems as well as equipment problems the complete spectrum of pre-operational and startup testing programs may need to be exoandeo to consider the more complex types of problems or to consider the effects on plants which have been shut down for extended periods.

The licensee should be 0ble to demonstrate ttat all needed safety equipment is operation,a1 prior to the restart without excessive reliance on the minimum levels of eculpment availability pemitted by technical specification Limiting Conditions for Operation. Survelliance tests should also be up to date without excessive reliance on the minimum level-of testing pemitted by TS.

The maintenance backlog should be reduced to nominal levels which do not  :

reflect chronic problems with equipment readiness nor postponement of long

. umet ' needs.

1

. 5-1 Procedures should be updated and plant staff trafned to reflect resolutfon of the issue at hand as well as any extensive tono unnet needs. For exampic, procedures which conflict with other procedures or with the as-built plant, procedures which have not undergone their periodic review, or procedures which do not reflect "the way it is really done" should be l considered for 9pdating.

The as-built defign of the plant should be known to agree vith the safety In some cases, design basis includino analyses, drawinas, etc.

especf A11y for some of the older plants, fully documented design bases ,

may not be available. For these cases, reliance on engineering judgement may be appropriate.

5. Other Agencies, _Goverraent Oroanizations, the Puh11e t

The decision to restart should consider the need for fomal action prior to restart as well as the value of effective relations with other reder agencies such as TEMA, D0J, state and local government representatives an interested members of the public.

For example, this may include the need for action on the Emergency Plan by FEMA. responses to correspondence to state Governors or members of Congress and resoonses to 2.706 Fetitinns.

6.- "tegal' Renuirements Notwithstanding all of the above. the plant and its prospective operation is not known to be in conflict with any regulations (GDC, etc.) and all requirerents of any document authorizing restart (license amendments, orders, etc) are expected to be met.

Restart would not conflict with any matter before a Hearing Board.

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,+ . . -.

MEMORANDU;4 FOR: Al Chaffee, Team Leader Vogtle Ir.cident Investigation Team FROM: Gary G. Zech, Chief Incident Response Branch Division of Operational Assessment Office for Analysis and Evaluation of Operational Data

SUBJECT:

LESSONS LEARNED: V0GTLE SITE AREA EMERGENCY On March 20, 1990, Vogtle Unit 1 declared a Site Area Emergency due to a loss of offsite power when a truck hit a tower in the switchyard and the concurrent loss of onsite .imergency diesel generator capability when the one operable diesel generator tripped after starting. Unit I had been in a refueling outage since February 2,4, 1990, and as a result of the electrical pcwer

-failure, lost RHR coali'ng. The RCS heated up from 90 F to 136*F before Emergency Diesel Generator (EDG) power was restored about h hour lLter. Unit 2,' which was at 100% power at the time of the event, tripped and all of its  !

emergency systems functioned normally.-

1he NRC's response to the event, both in Headquarters and the region went well, although a number of lessons learned were identified and were discussed in a critique held on March 22, 1990. Enclosed is a list of the major lessons '

learned and recommended responses, as appropriate, to those items requiring action. Several other items are being tracked separately.

If you have any questions or comments, please let me know.

Original signed by:

Gary G. Zech, Chief Incident Response Branch Division of Operational Assessment Office-for Analysis and Evaluation of Operational Data

Enclosure:

As stated cc: E. La Jordan, AE00 '

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ENCL 0SURE !

1. Even though there appeared to be a valid basis for the licensee having declared a Site Area Emergency (loss of offsite power with a concurrent lo*s of the onsite EDG supply) these were several discussions between the Regional Administrator, the AE0D DeMty Director and the Emergency Officer regarding whether to put tN agency into the Standby mode. The AE00 Deputy Director pursued this m the Regional Administrator (RA) recognizing it was primarily the i ~ decision to make according to NUREG-0728. The RA-elected to defe that decision and see if the EDG (which had subsequently been started) would stay on the line and whether the licensee's predictions for restoring offsite power (about 10 minutes) were accurate. Those predictions proved to be optimistic and when the EO advised the AEOD Deputy Director and then the RA that the one operable EDG was started only after manually bypassing a low water jacket pressure trip, the RA decided to place the agency in the Standby mode.

This delay-(about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from initial notification) in entering the Standby mode could have impacted the agency's response to the event in terms of timely notifications and call out of response team members. The NRC is much better able to handle inquiries, liaison functions and notifications if in a response and proceduralized response mode.

Cecommendation: For valid declarations of an Alert or SAE by a licensee, v the decisionmaking process for placing the agency in an elevated response

. mode should be reviewed to ensure that the decisionmakers understand the potential impacts that can result from delaying a decision to elevate the response mode.

i- 2. Although.three H00's were assisting in the response, they still had trouble keeping-up-with the-flow of telephone traffic. Part of this was attributed to the bridge failures (had to be reestablished for the Commissioner f.ssistants Briefing when it crashed at noon). Also a new way of establishing the first bridge with the licensee and NRC was tried during the response (connect two bridges together to form one large bridge and disconnect NRC from it when they needed to discuss upgrading NRC's response) but did not urk much better than the old way (all on the same bridge with NRC people dropping off and reestablishing another bridge).

Recommendation: Suggestions from the H00's involved will be solicited and then a proposed plan developed to correct these problems.

3. -The problems with the conference bridges will be coirected with the upgraded Emergency Telephone System (ETS). Some of the phone problems could be attributed to the Vogtle ENS which has caused problems in the past. ' Also, it was agreed that if ERDS had been available, the information and data that would have been transmitted would have significantly improved the RST's understanding and ability to handle the o event.

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4. RCT notification calls were made inla timely fashion. The Federal agencies were contacted twice at the beginning of the' response; once by the H00 (per his procedures for a Site Area Emergency) and once by the RCT when the NRC went into Standby Mode. The Standby Team members (primarily AE00 personnel) were contacted early on in the event and arrived quickly. The Protective Measures Team will train more AE00 technical staff to become members of the team so that the PMT can be quickly staffed (similar te the RST). An Assistant Status Officer will be added to the Standby Team to keep the chronology in the ET Room for bringing late arrivals up to date on the event.

5. Consideration will be given to adding a Safeguards Team member to the

-Standby Team. This event could have had safeguards implications and no one at Headquarters looked at it from this standpoint. The Region II Base Team did _ cover this aspect.

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