IR 05000261/1985032
| ML20137E199 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/14/1985 |
| From: | Cunningham A, Decker T, Kreh J, Simonds G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137E191 | List: |
| References | |
| 50-261-85-32, NUDOCS 8511270217 | |
| Download: ML20137E199 (11) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
. y REGION 11
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j 101 MARIETTA STREET.N.W.
ATLANTA. GEORGIA 30323
o ReportYo.:
50-261/85-32 NOV 2 01985 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name:
H. B. Robinson Inspection Condu ted:
October 20-23, 1985
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J. f/ Kreh Date Signed
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[r-G. y Simonds Date Signed Accompanying Personnel:
B. C. Haagensen, J. A. MacLellan, A. L. Smith, J. M. Will, Jr.
p T. R. Decker, Ch'ief
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O ~/D D Approved by:
Date Signed Emergency Preparedness Section Division of Radiation Safety and Safeguards SUMMARY Scope: This routine,' announced inspection entailed 174 inspector-hours onsite in the area of an emergency preparedness exercise.
Results:
No violations or deviations were identified.
I 0511270217 e51120
PDR ADOCK 0500
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REPORT DETAILS l
1.
- Persons Contacted Licensee-Employees
- R.-E. Morgan, Plant General Manager
- J. M. Curley, Director, Regulatory Compliance
- H. J. Young, Director, Corporate QA/QC
- H. S. Zimmerman, Director, Planning & Scheduling
- R..M. Smith, Manager, Environmental and Radiation Control
- A. R. Wallace, Manager, Technical Support
- R. C. Black, Jr., Manager, Emergency Preparedness (Corporate)
- H. R. Goodwin, Senior Specialist, Emergency Preparedness (Corporate)
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- M. ' C. Morrow, Specialist, Emergency Preparedness
- J. F.. Benjamin, Operations Support Supervisor l
- C. L. Wright, Senior Specialist, Regulatory Compliance
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- B. W. Morgan, Senior Specialist, Health Physics
- D. L. Erickson, Radiation Control Supervisor l
- L. N. Williams, Security Supervisor
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- R. L. Barnett, Maintenance Supervisor (I&C)
W. T. Gainey, Jr., Maintenance Supervisor (Mechanical)
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Other licensee -employees contacted included engineers, technicians, operators,. mechanics, security force members, and office personnel.
NRC Resident Inspectors
- H. E. P. Krug
- H. C. Whitcomb
- Attended exit interview 2.
Exit Interview (30703)
The inspection scope and findings were summarized on October 23, 1985, with those persons. indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the findings presented below.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
3..
Licensee Action on Previous Enforcement Matters (92702)
(Closed) Unresolved Item 261/84-20-01: Adequacy of emergency communications from Control Room. The licensee augmented the Control Room's communications capability through the addition of an emergency telephone system (with 20
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trunk lines) and an automatic ringdown (" hot line") to the State Warning
' Point.- Although the automatic ringdown was not yet operable at the time of
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the exercise, the. licensee stated that declaration of operability was imminent. On the basis of this major upgrading of communications capability in the Control Room, this item is closed.
4.
Exercise Scenario (82301)
The scenario for the emergency exercise was reviewed to assure that provisions were made to test the integrated capability and a major portion of the. basic elements defined in the licensee's emergency plan and
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organization pursuant to 10 CFR 50.47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, and specific criteria defined in Section II.N of NUREG-0654, Revision 1.
The scenario was reviewed in advance of the exercise and was discussed in detail with licensee representatives on October 21, 1985. While no major problems with the scenario were identified, some inconsistencies became apparent during the exercise.
The inconsistencies, however, failed to detract from the overall performance of the licensee's emergency organization.
The scenario developed for this exercise was detailed, and fully exercised the onsite emergency organizations.
The scenario also provided sufficient information to the State and local government agencies consistent with the scope of their participation in the exercise.
No violations or deviations were identified.
5.
Drill Scenarios (82301)
Scenarios for the fire and medical emergency drills were reviewed to assure that provisions were 'made to test specific functions in the licensee's emergency plan pursuant to 10 CFR 50.47(b)(14), paragraph IV.F of Appendix E to 10 CFR 50, and specific criteria defined in Section II.N of NUREG-0654, Rev. 1.
The scenarios developed for the drills were detailed and adequately exercised the participating licensee organization and offsite local emergency agencies. The scenarios provided sufficient information to local support agencies consistent with the scope of their participation in the drills. No significant problems were disclosed regarding the scenarios for the subject drills.
No violations or deviations were identified.
6.
Assignment of Responsibility (82301)
This area was observed to assure that primary responsibilities for emergency response by the licensee were specifically established, and that adequate staff was available to respond to an emergency pursuant to 10 CFR 50.47(b)(1), paragraph IV.A of Appendix E to 10 CFR 50, and specific criteria defined in Section II.A of NUREG-0654, Revision '
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The inspectors observed that specific assignments were made for the licensee's emergency response organization, and that adequate staff was available to respond to the simulated emergency. One shift turnover was demonstrated at each of the emergency response facilities; however, because of the scenario scope and conditions, long-term or continuous staffing of the emergency response organization was not required.
Discussions with licensee representatives indicated that sufficient technical staff was available to provide for continuous staffing of the augmented emergency organization if needed.
The inspectors also observed the activation, staffing and operation of the emergency organization in the Technical Support Center (TSC), Emergency Operations Facility ( EOF), and Operations Support Center (OSC).
At each response center, the required staffing and assignment of responsibility appeared to be consistent with the licensee's approved procedures.
No violations or deviations were identified.
7.
Onsite Emergency Organization (82301)
The licensee's onsite emergency organization was observed to assure that the following requirements were implemented pursuant to 10 CFR 50.47(b)(2),
paragraph IV.A of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.B of NUREG-0654, Revision 1:
(1) responsibilities for emergency response were unambiguously defined; (2) adequate staffing was provided to assure initial facility accident response in key functional areas at all times; (3) onsite and offsite support organizational interactions were specified.
The inspectors observed that the initial onsite emergency organization was adequately defined and that staff was available to fill key functional positions. The on-duty Shift Foreman assumed the duties of Site Emergency Coordinator promptly upon initiation of the simulated emergency and directed the response until relieved by the Plant General Manager.
Required interactions between the licensee's emergency response organization and State and local support agencies were adequate and consistent with the scope of the exercise.
No violations or deviations were identified.
8.
Emergency Response Support and Resources (82301)
This area was observed to assure that arrangements for requesting and effectively using offsite assistance resources were made pursuant to 10 CFR 50.47(b)(3), paragraph IV. A of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.D of NUREG-0654, Revision 1.
Licensee contact with offsite organizations was conducted in accordance with approved procedures and was consistent with the scope of the exercise.
Assistance resources from State and local agencies were available to the licensee.
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No violations or deviations were identified.
9.
Emergency Classification System (82301)
This area was observed to assure that a standard emergency classification and' action level scheme was in use by the licensee pursuant to 10 CFR 50.47(b)(4), paragraph IV.C of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.D of NUREG-0654, Revision 1.
An emergency action level matrix was used to promptly identify and properly classify the emergency and escalate to more severe emergency classifications as the simulated emergency progressed.
Licensee actions in this area were considered adequate.
An inspector observed that the emergency classification system used was consistent with the Radiological Emergency Plan (REP) and implementing procedures. The system appeared to be adequate for classification of the simulated accident.
The respective emergency procedures provided for initial and continuing mitigating actions during the simulated emergency.
No violations or deviations were identified.
10.
Notification Methods and Procedures (82301)
This area was observed to assure that procedures were established for notification of State and local response crganizations and emergency personnel by the licensee, and that the content of initial and follow-up messages to response organizations was established.
This area was further observed to assure that means to provide ea~ly notification to the populace r
within the plume exposure pathway were established pursuant to 10 CFR 50.47(b)(5), paragraph IV.D of Appendix E to 10 CFR 50, and specific criteria defined in Section II.E of NUREG-0654, Revision 1.
An inspector observed that notification methods and procedures were established and available for use in providing information concerning the simulated emergency conditions to Federal, State, and local response organizations, and to alert the licensee's augmented emergency response organizations.
Notification of the State of South Carolina and local offsite organizations was completed in a timely manner following declaration of each emergency classification.
The NRC was notified within one hour following declaration of each emergency classification.
The prompt notification system (PNS) for alerting the pubif e within the plume exposure pathway was in place; however, consistant with the scope of the exercise, this system was not actuated. A full-cycle test of the system is scheduled for November 21, 1985, as pa-t of an Alert and Notification
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System demonstration under the auspices of the Federal Emergency Management Agency (FEMA).
No violations or deviations were identifie '
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11.. Emergency Communications (82301)
This area was. observed to. assure that provisions existed for prompt communications among -principal response organizations and emergency personnel pursuant to 10 CFR 50.47(b)(6), paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.F of NUREG-0654, Revision 1.
The inspector observed communications within and between the licensee's emergency response facilities (Control Room, TSC, OSC), between the licensee and offsite agencies, and between the offsite environmental monitoring teams
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and the TSC.
The inspector also observed information flow among various groups within the licensee's emergency organization.
Emergency communications were. generally adequate and consistent with the scope of the exercise. However, several minor problems were noted.
Fi rst, communications between Post-Accident Sampling System (PASS) team members were degraded because of the failure of several voice amplifiers in the respirators. This contributed to confusion and delay on the part of the PASS team members.
In addition, in plant radio communications between the PASS ' team and the OSC were frequently unintelligible. This contributed to confusion over radiation levels and the status of the simulated emergency.
The licensee agreed to implement improvements in this area.
-Inspector Follow-up Item (261/85-32-01):
Improving. the quality and reliability of the respirator-associated. ccmmunications equipment used by the PASS team.
The second area in which communications problems arose was related to information transmission between the licensee and the State of South Carolina.
The. State's - Forward Emergency Opera'tions Center (FEOC) was officially activated at 10:00 a.m.
At that time, the licensee should have begun directing information (e.g., emergency class declarations, protective action recommendations, etc.) to the FEOC in lieu of the State EOC in Columbia.
However, the TSC continued to transmit information to the Columbia E0C until 10:48 a.m.
The licensee agreed to review this problem and implement appropriate corrective action.
Inspector Follow-up Item (261/85-32-02):
Insuring that information transmission to - the State is directed to the FEOC immediately upon activation of that facility.
No violations or deviations were identified.
12.
Public Education and Information (82301)
This area was observed to assure that information concerning the simulated emergency was made available for dissemination to the public as required by 10 CFR 50.47(b)(7), paragraph IV.D of Appendix E to 10 CFR 50, and specific criteria defined in NUREG-0654,Section I _ _ - -
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i Information was provided to the media and the public in advance of the exercise.
The information included details on how the public would be
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' notified and what initial actions they should take in an emergency. A Plant Media Center was established and was well equipped and coordinated.
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inspector had no further questions in this area.
No violations or deviations were identified.
13.
Emergency Facilities and Equipment (82301)
This area was observed to assure that adequate emergency facilities and
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equipment to support an emergency response were -provided and maintained
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pursuant to 10 CFR 50.47(b)(8), paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria defined in Section II.H of NUREG-0654, Revision 1.
The inspectors observed the activation, staffing, and operation of the emergency response facilities, and evaluated the equipment provided for emergency use during the exercise. Emergency response facilities activated
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during the exercise included the Control Room, TSC, OSC, and E0F.
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Control Room - The inspector observed that Control Room operations personnel acted promptly to initiate required responses to the simulated emergency.
Emergency procedures were readily available, routinely followed, and factored into accident assessment and mitigation exercises.
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- The Shift Foreman and Control Room operators were cognizant of their duties, responsibilities,-
and authorities.
These personnel demonstrated an understanding of the emergency classification system
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and the proficient use of specific procedures to determine and declare the proper classification.
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The inspector observed that the exercise log maintained in the Control Room was informal and contained some inaccuracies. The log was written in pencil on loose tablet paper; as such, it would not be considered a legal record had the emergency been actual instead of simulated. A similar practice was observed in the OSC (see paragraph 13.c below).
- The licensee agreed to implement appropriate corrective action.
Inspector Follow-up Item (261/85-32-03): Maintaining exercise logs in a manner consistent with the requirements for a legal record.
b.
Technical Support Center (TSC) - The TSC was activated and promptly staffed following notification by the Site Emergency Coordinator of the simulated emergency conditions leading to the Alert classification.
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The facility staff appeared to be knowledgeable concerning their
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emergency duties, authorities, and responsibilities, and the required operation appeared acceptable.
This facility was provided with adequate equipment for support of the assigned staff.
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Status boards were strategically located to facilitate viewing by the TSC staff.
Status boards were updated as required for chronicle changes in plant status, accident assessment, and mitigation throughout the exercise.
c.
Operations Support Center (OSC) - The OSC was promptly staffed following activation of the REP by the Site Emergency Coordinator. An inspector observed that teams were assembled and deployed in a timely manner.
However, numerous shortcomings in OSC operations were noted during the course of the exercise.
Briefings of OSC emergency teams (including the PASS sample team) were judged excessively informal and generally inadequate to prepare the teams for their tasks.
Briefings typically failed to include information on plant conditions (including radiological release status)
and tools required to perform the assigned tasks. The licensee agreed to consider the applicability of this finding.
Inspector Follow-up Item (261/85-32-04):
Thorough preparatory briefings for OSC emergency teams.
As was the case in the TSC (see paragraph 13.b above), the OSC exercise log was kept on loose sheets of paper, a practice inconsistent with the requirements for a legal record.
The following problems were identified in relation to the location and configuration of the OSC:
facility located within 300 feet of plant stack; no established step-off pad; no radiological control points; no staging for OSC personnel and equipment; OSC Leader isolated from OSC personnel. Although many of these findings were identified during the licensee's controller / evaluator critique, they were reiterated during the exit meeting, and the licensee was urged to reevaluate the OSC location. The licensee agreed to undertake such a review. This matter will be reviewed during a future exercise.
Inspector Follow-up Item (261/85-32-05): Reevaluation of OSC location and configuration, d.
Emergency Operations Facility (EOF) - The EOF is colocated with the TSC in a new hardened onsite structure.
The facility was adequately designed, equipped, and staffed to support the response to the simulated emergency.
The inspector had no further questions in this area.
No violations or deviations were identified.
14. Accident Assessment (82301)
This area was observed to assure that adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite
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consequences of a radiological emergency condition were in use as required by 10 CFR 50.47(b)(9), paragraph IV.B of Appendix E to 10 CFR 50, and specific criteria promulgated in Section II.I of NUREG-0654, Revision 1.
The accident assessment program included an engineering assessment of plant status and an assessment of radiological hazards to onsite and offsite personnel. During the exercise, the engineering accident assessment team functioned adequately in analyzing the plant status to provide recommendations to the Site Emergency Coordinator concerning mitigating actions required to reduce damage to plant equipment, prevent releases of radioactive materials, and terminate the emergency condition.
Radiological assessment activities involved several groups. A TSC group was effective in estimating the radiological impact within the plant based on in plant monitoring and onsite measurements.
Offsite radiological monitoring teams were dispatched to determine the level of radioactivity in those areas within the path of the plume.
Radiological effluent data was received in the TSC.
The offsite dose assessment calculations were consistent with scenario values.
No violations or deviations were identified.
15.
Protective Response (82301)
This area was observed to assure that guidelines for protective actions, consistent vith federal guidance, were developed 'and in place, and protective actions for emergency workers, including evacuation of nonessential personnel, were implemented promptly as required by 10 CFR 50.47(b)(10) and specific criteria promulgated in Section II.J of NUREG-0654, Revision 1.
The inspector observed the licensee's program for personnel accountability.
The inspector noted that upon sounding of the site evacuation alarm, personnel appeared to proceed promptly to designated assembly points.
Initial accountability appeared to be completed in about 15 minutes.
Accountability was continued, however, until all personnel were accounted
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for.
This test was completed 30 minutes af ter the site evacuation alarm was sounded.
The protective measures decision-making process was observed by the inspector. Recommendations issued by the TSC and EOF were timely, adequate, and consistent with the above criteria. Protective measures recommendations were provided by the licensee to the State of South Carolina and local offsite organizations consistent with the scope of the exercise scenario.
No violations or deviations were identified.
16.
Radiological Exposure Control (82301)
This area was observed to assure that methods for controlling radiological exposures in an emergency were established and implemented for emergency
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workers, and that such methods included exposure guidelines consistent with EPA recommendations as required by 10 CFR 50.47(b)(11) and specific criteria defined in Section II.K of NUREG-0654, Revision 1.
An inspector noted that radiological exposures were controlled throughout the exercise by issuing supplemental dosimeters to emergency workers and by conducting periodic radiological surveys in the emergency response facilities.
Exposure guidelines were in place for various categories of emergency actions, and adequate protective clothing and respiratory protection were available for use as required.
Health Physics control of radiation exposure, contamination, and radiation area access appeared adequate, except as described in paragraph 13.c above.
Dosimetry was available and was used. High-range dosimeters were available if needed.
No violations or deviations were identified.
17.
Medical and Public Health Support (82301)
This area was observed to assure that arrangements were made for medical services for contaminated injured individuals as required by 10 CFR 50.47(b)(12), paragraph IV.E of Appendix E to 10 CFR 50, and specific criteria in Section II.L of NUREG-0654, Revision 1.
A7 inspector observed the emergency medical rescue activities at the accident scene, movement of the victim from the scene to the Lake Robinson Rescue Squad ambulance, and treatment by the staff at Byerly Hospital. In general, appropriate judgment was displayed with regard to first-aid practices, decontamination of the patient, and contamination control. The inspector had no further questions in this area.
No violations or deviations were identified.
18.
Exercise Critique (82301)
The licensee's critique of the emergency exercise was observed to assure that shortcomings identified as part of the exercise were brought to the attention of management for corrective action, as required by 10 CFR 50.47(b)(14), paragraph IV.F. of Appendix E to 10 CFR 50 and the specific criteria in Section II.N of NUREG-0654, Revision 1.
A formal critique was held on October 23, 1985, with exercise controllers and evaluators, licensee management, and NRC representatives. Weaknesses identified during the exercise and plans for corrective actions were discussed. Licensee action on identified weaknesses will be reviewed during a subsequent inspection.
Observatior of the licensee controller / evaluator critique, held prior to the exit critique, was included as part of the exercise evaluation.
Observation disclosed that the licensee conducted a detailed critique of the exercise and operation of the emergency response facilities.
The critique included identification and discussion of
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weaknesses and required improvements, documentation thereof, and required corrective actions. Those NRC findings not also identified by the licensee were summarized during the exit critique.
No violations or deviations were identified.
19.
Inspector Follow-up (92701)
(Closed) Inspector Follow-up Item 261/83-31-06:
Improve tracking of doses to Health Physics personnel.
Exercise observation confirmed the implementation of an improved system in the subject area.
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