IR 05000261/1991026
| ML14182A244 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 12/30/1991 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 9201270122 | |
| Download: ML14182A244 (39) | |
Text
Docket No. 50-261 License No. DPR-23 EA 91-176 Carolina Power and Light Company ATTN: Mr. Lynn W. Eury Executive Vice President Power Supply P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT: ENFORCEMENT CONFERENCE SUMMARY (NRC INSPECTION REPORT NO. 50-261/91-26)
This letter refers to the Enforcement Conference held at our request on December 20, 199 This meeting concerned activities authorized for your H. B. Robinson facilit The issues discussed at the conference related to:
the apparent failure to implement adequate corrective actions for previously identified exercise weaknesses regarding emergency classification; the other 1991 exercise weaknesses and issues; and the license's self assessment of exercise performance as well as associated corrective action A list of conference attendees and a copy of your handouts are enclose In addition, subsequent to the Enforcement Conference you requested clarification of selected issues presented in the subject Inspection Report. These areas were further discussed with your staff on December 23, 1991, and are addressed in detail in Enclosure 3 to this lette We have completed our review of the apparent misclassification issue identified during the 1991 Emergency Exercise. After consideration of the information you provided during the Enforcement Conference, we concluded that the emergency classification related to the simulated fire was appropriate based on the limited information available and the communications protocol implemented during the scenari As a result, the apparent failure to correct previous exercise weaknesses regarding emergency classification does not warrant enforcement action and no Notice of Violation will be issued. However, during the Enforcement Conference you presented several factors which contributed to the circumstances surrounding the unanticipated emergency classification including scenario development and execution and Emergency Action Level specificit Based on your commitments for corrective actions, we will evaluate these areas for effectiveness during future emergency exercise In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Roo PDR ADOCK 05000261
Carolina Power and Light Company
Should you have any questions concerning this matter, please contact u
Sincerely, J. Philip Stohr, Director Division of Radiation Safety and Safeguards Ehclosures:
1. List of Attendees 2. Licensee Handouts 3. Inspection Report Clarifications cc w/encls:
C. R. Dietz, Vice President Robinson Nuclear Project Department H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 R. H. Chambers, Plant General Manager H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 Heyward G. Shealy, Chief Bureau of Radiological Health Dept. of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 McCuen Morrell, Chairman Darlington County Board of Supervisors County Courthouse Darlington, SC 29535 cc w/encls:
(Cont'd on page 3)
Carolina Power and Light Company
(cc w/encls:
cont'd)
Mr. H. Ray Starling Manager -
Legal Department Carolina Power and Light C P. 0. Box 1551 Raleigh, NC 27602 H. A. Cole Special Deputy Attorney General State of North Carolina P. 0. Box 629 Raleigh, NC 27602 Robert Gruber Executive Director Public Staff -
NCUC P. 0. Box 29520 Raleigh, NC 27626-0520 J. D. Kloosterman, Director Regulatory Compliance H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 bcc w/encls:
J. Johnson, RII H. Christensen, RII R. Lo, NRR J. Lieberman, OE G. Jenkins, RII Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 RII:DRSS RII:'DRSS RII:DRSS RII:DRSS RII:DRSS
.
ABoland:er WRankin WCline HChristensen GJenkins 12/
/91 12/
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- See previous concurrence
Car ol in PUwer dud Light ouipany
Robert Gruber Executive Director Public Staff - NCUC P..
Box 29520 Ralegh, NC 27626-0520 J. D. loosterman, Director Regulat ry Compliance H. B. Ro inson Steam Electric Plant P. 0. Box 7 0 Hartsville,
.29550 bcc w/encls:
J. Johnson, RII H. Christensen, RI
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R. Lo, NRR Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Co ission Route 5, Box 413 Hartsville, SC 29550 1I 0I
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RII:DRSS RII:DRSS RII:D~
uABoland:er C WRankin WClie H hristensen ek' s 12/30/91 12/30/91 12/</91
- 12/00/91 12/3) 91
ENCLOSURE 1 LIST OF ATTENDEES U. S. Nuclear Regulatory Commission S. Ebneter, Administrator, Region II (RH)
L. Reyes, Director, Division of Reactor Projects (DRP)
P. Stohr, Director, Division of Radiation Safety and Safeguards (DRSS)
G. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS)
C. Evans, Regional Counsel, RII E. Adensam, Project Directorate, II-1, Office of Nuclear Reactor Regulation (NRR)
D. Verrelli, Chief, Reactor Projects BraTch 1, DRP, RII W. Cline, Chief, Radiological Protection and Emergency Preparedness Branch (RPEP), DRSS, RII H. Christensen, Chief, Reactor Projects Section 1A, DRP, RHI W. Rankin, Chief, Emergency Preparedness Section, RPEP, DRSS, RH R. Rosano, Enforcement Specialist, Office Of Enforcement D. Dorman, Interim Project Manager, NRR A. Boland, Radiation Specialist, RPEP, DRSS, RH E. Fox,.Senior Emergency Planning Specialist, NRR L. Garner, Senior Resident Inspector - Robinson B. Uryc, Senior Enforcement Coordinator, EICS, RII Carolina Power and Light Company R. Watson, Senior Vice. President Nuclear Generation C. Dietz, Vice President, Robinson Nuclear Project Department (RNPD)
G. Vaughn, Vice President Nuclear Services R. Chambers, Plant General Manager; RNPD W. Flanagan, Jr., Manager, Operations, RNPD S. Floyd, Manager, Nuclear Licensing B. McFeaters, Group Analyst, Nuclear Generation R. Indelicato, Manager, Corporate Emergency Planning W. Storer, Shift Supervisor Nuclear, RNPD D. Hollar, Associate General Counsel
ENCLOSURE 2 CAROLINA POWER & LIGHT COMPANY ROBINSON NUCLEAR PROJECT ENFORCEMENT CONFERENCE EMERGENCY PREPAREDNESS ISSUES
-
DECEMBER 20, 1991
CAROLINA POWER & LIGHT COMPANY ROBINSON NUCLEAR PROJECT CE TR us'
ORMAIAO ENFORCEMENT CONFERENCE EMERGENCY PREPAREDNESS ISSUES DECEMBER 20, 1991
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS *...........
C. R. DIETZ E.A.L. CLASSIFICATION ISSUE
- EVENTS REVIEW **********
......... *****.. STOVER
- MANAGEMENT
.
WM.J.FLANAGAN EXPECTATIONS"""""*******...MJ.LAGN
- NRC QUESTIONS OTHER EXERCISE...
ISSUES
.
.
- ........*..................
R. H. CHAMBERS
- NRC QUESTIONS ROBINSON EMERGENCY................... R. DIETZ PREPAREDNESS ASSESSMENT
- NRC QUESTIONS CONCLUDING REMARKS..******........... *..**.........
G. E. VAUGHN/
R. A. WATSON
ENFORCEMENT CONFERENCE DECEMBER 20 1991 OBJECTIVES
ADDRESS APPARENT INEFFECTIVE CORRECTIVE ACTIONS ASSOCIATED WITH EMERGENCY ACTION LEVEL CLASSIFICATIONS ADDRESS APPARENT ROOT CAUSES & RELATED CORRECTIVE ACTIONS IN RESPONSE TO PERFORMANCE WEAKNESSES EXHIBITED DURING 1991 ANNUAL EMERGENCY EXERCISE SUMMARIZE RESULTS OF AN INTERNAL ASSESSMENT OF ROBINSON
- EMERGENCY PREPAREDNESS PROGRAM
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 OPENING REMARKS PRESENTATION FORMAT
Two PHASES
RESPONSE TO APPARENT VIOLATION
-
EMERGENCY PREPAREDNESS ISSUES
DIRECT CONTINUITY OF COMPLEX ISSUES
-
CLARIFICATION OF UNDERSTANDING Q & A
To ILLUSTRATE OR CONVEY THAT:
-
ISSUES AND WEAKNESSES BEING DISCUSSED ARE THE PRODUCTS OF SELF-ASSESSMENT
-
CP&L MANAGEMENT IS TOTALLY COMMITTED TO CORRECTING THE CAUSAL FACTORS WHICH CONTRIBUTED TO PERFORMANCE DEFICIENCIES
-
INVESTIGATIVE PROCESSES TO ASSESS ROOT CAUSE ARE PARTIALLY COMPLETE; HAVE CONFIDENCE THAT APPARENT ROOT CAUSES ARE COMPLETE AND COMPREHENSIVE CORRECTIVE ACTIONS ARE AGGRESSIVE, TIMELY, AND COMPREHENSIVE TO PRECLUDE REPETITION
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 OPENING REMARKS (CONTINUED)
OVERVIEW OF EAL DETERMINATION HISTORICAL REVIEW OF PREVIOUS OCCURRENCES DETAILED REVIEW OF 1991 EAL
-
"SEC AND ERM" AWARENESS
CONCLUSION
-
ACKNOWLEDGE E.A.L. CLASSIFICATION WEAKNESS
-
"POTENTIAL" VS. SCENARIO EXPECTATIONS
-
JUDGEMENT IS REQUIRED
-
ACTIONS IN RESPONSE TO PREVIOUS PERFORMANCE
-
COMPREHENSIVE
-
NOT REASONABLY EXPECTED TO PRECLUDE THE ISSUE BEING DISCUSSED TODAY PERFORMANCE DURING 1991 EXERCISE
-
CONSERVATIVE BASED UPON KNOWN INFORMATION
-
SAFETY SIGNIFICANCE
-
NO THREAT TO HEALTH AND SAFETY OF PUBLIC
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS
...............................
C. R. DIETZ E.IA.L. CLASSIFICATION ISSUE
- EVENTS REVIEW ***********.
WM. STOVER
MANAGEMENT
- ..............
...........
WM. J. FLANAGAN EXPECTATIONS
- NRC QUESTIONS OTHER EXERCIS...................................R. H. CHAMBERS ISSUES
- NRC QUESTIONS ROBINSON EMERGENCY.................................. C. R. DIETZ
.PREPAREDNESS ASSESSMENT
- NRC QUESTIONS CONCLUDING REMARKS *****..............
................ G. E. VAUGHN/
R. A. WATSON
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 SEQUENCE OF EVENTS 0846
- INITIAL ALARM ON FIRE COMPUTER 0847
- FIRE TECHNICIAN ON SCENE --
COMMUNICATION ESTABLISHED
- PERCEPTION:
FIRE ON "A" COMPONENT COOLING WATER Pump 0850
- FIRE BRIGADE DISPATCHED
- "B" COMPONENT COOLING WATER PUMP STARTED
- SHIFT SUPERVISOR BEGAN REVIEWING EAL FLow CHART
- SENIOR CONTROL OPERATOR REVIEWING FIRE PRE-PLAN FOR Room 0853
- "A" COMPONENT COOLING WATER PUMP POWER SUPPLY DE-ENERGIZED 0854
- FIRE BRIGADE TEAM MEMBERS ENTER ROOM
- COMMUNICATION ESTABLISHED INSIDE ROOM 0855
- SPRINKLER SYSTEM ACTUATED 0857
- ADDITIONAL FIRE BRIGADE TEAM MEMBERS ENTER VIA ALTERNATE ROUTE 0858 e No DETERIORATION REPORTED FROM FIRE SCENE
- UNUSUAL EVENT DECLARED 0900
- FIRE EXTINGUISHED
ENFORCEMENT CONFERENCE DECEMBER 20A l991 ASSIFICATION FIRE NOT ON SAFETY-RELATED EQUIPMENT KNOWLEDGE OF ROOM
-
SMALL FIRE HAZARD
-
PHYSICAL SEPARATION
-
PROTECTION COMMUNICATIONS
-
VERBAL FROM FIELD
-
NON-VERBAL FROM FIELD
"B" COMPONENT COOLING WATER PUMP OPERATING
ENERGY SOURCE ELIMINATED
SUPPRESSION ACTIVATED
CONSULTATION WITH SENIOR CONTROL OPERATOR
ENFORCEMENT CONFERENCE DECEMBER 20.,1991 CCW ROOM LAYOUT FDAP-AI P-29 L?-26
BORIC ACID LP-33 TRN UT F
BORIC A CID TANKS FDA-I1 COLfIX COMPONENT COOLING FIRE UT'tNUISMM
.. CAI-ROPICS RABDWf? STATION 8MANULL PULL STATION
AL..RCIPTACE 0 OSI STATION
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS
............................
C. R. DIETZ E.A.L. CLASSIFICATION ISSUE
- EVENTS REVIEW.........
- .*****....................
WM. STOVER
- MANAGEMENT...
- .*.
... WM. FLANAGAN EXPECTATIONS
- NRC QUESTIONS OTHER EXERCISE..........................
....... R. H. CHAMBERS ISSUES
- NRC QUESTIONS ROBINSON EMERGENCY............ **....
- ....
...... C. R. DIETZ PREPAREDNESS ASSESSMENT
- NRC QUESTIONS CONCLUDING REMARKS..........
................... G. E. VAUGHN/
R. A. WATSON
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 CLASSIFICATION EXPECTATIONS
- PROMPT ENTRY IN EAL PROCEDURES
- EVALUATE INITIAL INFORMATION -
"MUST THINK!"
- FIELD PERSONNEL PROVIDE FREQUENT, DESCRIPTIVE STATUS UPDATES
- SRO's COMMUNICATE ANY AND ALL STATUS CHANGES
- CIRCLE INFORMATION NEEDS
- PROCEED TO UNUSUAL EVENT MATRIX
- RETURN TO CIRCLED DECISION BLOCKS
- CONSULT CONTROL ROOM STAFF
- EXERCISE JUDGEMENT BASED ON KNOWLEDGE AND EXPERIENCE
- CLASSIFY PROPERLY
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 CLASSIFICATION CONCLUSIONS
- CORRECTIVE ACTION FOR PREVIOUS EXERCISE WEAKNESSES WERE EFFECTIVE
- CORRECTIVE ACTION FOR PREVIOUS EXERCISE WEAKNESSES WOULD NOT HAVE CHANGED 1991 EXERCISE CLASSIFICATION
- EXERCISE CLASSIFICATION IS NOT A RECURRING PROBLEM
- EXERCISE CLASSIFICATION WAS A WEAKNESS
- ESCALATED ENFORCEMENT IS NOT WARRANTED
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS...................................... C. R. DIETZ E.A.L. CLASSIFICATION ISSUE
- EVENTS REVIEW................................. M. STOVER MANAGEMEN............................ Wm. J. FLANAGAN EXPECTATIONS
- NRC QUESTIONS OTHER EXERCISE **
....
. CHAMBERS ISSUES
- NRC QUESTIONS ROBINSON EMERGENC R. DIETZ PREPAREDNESS ASSESSMENT
- NRC QUESTIONS CONCLUDING REMARKS ******...........*.........
....
G. E. VAUGHN/
R. A. WATSON
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ISSUE: 50-261/91-26-01 INSPECTOR FOLLOW-Up ITEM Improve exercise scenario control and coordination including the length and complexity. (Paragraph 2)
APPARENT ROOT CAUSE REASONS CORRECTIVE ACTIONS Failure to adequately support
- Incomplete verbal
- Enhance the training of scenario development process communications to the controllers/evaluators, to controllers include emphasis on contingency messages and
- Work practices their use Validation & Verification
- Scenario to be reviewed by
- Scenario development development team within two resources weeks of exercise
- Formulate a scenario development guideline
- Establish priority for scenario development effort
ENFORCEMENT CONFERENCE DECEMBER-20, 1991 ISSUE: 50-261/91-26-03 EXERCISE WEAKNESS Failure to provide complete information regarding the simulated emergency to State and local governments, as required. (Paragraph 6)
APPARENT ROOT CAUSE REASONS CORRECTIVE ACTIONS
- Teamwork/command and
- Training based on data being
- Implement Technical and control in the EOF available and correct Teamwork Training for Item
- Comuncaton:91-26-06 on dose projection
- Communication:
- Dose projection data not Enhance Emergency provided to every group Communicator training to
- Checking of messages to address:
State and Counties
- Unavailable data
- Use of drill contingency
- Incorrect data messages Message quality
- Posting of data on plant commensurate with status incomplete timeliness-Effective review
- Training stressed "timeliness" of messages
- Implement Controller Training for Item 91-26-01 on rill Contingency Messages
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ISSUE: 50-261/91-26-04 EXERCISE WEAKNESS Failure to demonstrate the ability to conduct damage control activities in a timely manne (Paragraph 8.c)
APPARENT ROOT CAUSE_
REASONS CORRECTIVE ACTIONS Command and control by
- No emphasis by OSC &
- Enhance training to OSC Leader to get the damage control team leaders emphasize the need for teams into the field to expedite critical missions command and control by the team leaders
- Excess time spent on ALARA considerations for critical
- Train on the role of ALARA missions versus protecting the public health and safety during an
- Evaluator/Controller emergency event delayed team members leaving OSC to check respirators
- Pre-drill controller briefing should include instructions concerning the interactions between controllers and players
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ISSUE: 50-261/91-26-05 INSPECTOR FOLLOW-UP ITEM Evaluation of the resources available to media personnel in the media work area as well as the potential impact of the media work area location on the conduct of press briefing (Paragraph 8.e)
APPARENT ROOT CAUSE REASONS J CORRECTIVE ACTIONS
- Human factors analysis not
- Change location of media properly applied to Joint phones within the Joint Information Center Information Center
- Erect sound barrier * Evaluate the need for a contract with communications company to provide additional telephone lines for an emergency
ENFORCEMENT CONFERENCE DECEMBER 20. 1991 ISSUE: 50-261/91-26-06 EXERCISE WEAKNESS Failure to demonstrate adequate assessment of the radiological consequences of the simulated accident/dose assessment. (Paragraph 9)
APPARENT ROOT CAUSES REASONS CORRECTIVE ACTIONS Communications between Dose * Dose Assessment calculated
- More extensive technical Assessment and other PORV flow incorrectly when training for dose assessment emergency response functional they did not get a response personnel areas from Accident Assessment
- Enhance teamwork and
- Accident Assessment team
- Procedure required the use knowledge of requirements interactions with other of dose projection even for various emergency emergency response functions though other data such as functions environmental data showed 0 Training on developing dose different conclusions
- Evaluate procedure for the calculations use of other types of data
- Dose projection personnel were in the assessment process unfamiliar with State and NRC information requirements
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ISSUE: 50-261/91-26-07 EXERCISE WEAKNESS Failure to fully demonstrate the formulation of protective action recommendations (Paragraph 10).
APPARENT ROOT CAUSE REASONS CORRECTIVE ACTIONS
- Persons using the procedure
- Communication of critical
- Enhance training of failed to properly use the information did not support personnel on the use of Protective Action accurate decision making Protective Actions Recommendation chart Recommendation Chart and
- Ineffective training on the in position Protective Action responsibilities/needs Recommendation flow chart for EOF personnel
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS **********............***....
- ...
.........
C. R. DIETZ E.A.L. CLASSIFICATION ISSUE
- EVENTS REVIEW.................................... WM. STOVER
- MANAGEMENT ****................................ WM. J. FLANAGAN EXPECTATIONS
- NRC QUESTIONS OTHER EXERCIS.....................................R. H. CHAMBERS ISSUES
- NRC QUESTIONS ROBINSON EMERGENCY....
...
C. R. DIETZ PREPAREDNESs AsSESSMENT
- NRC QUESTIONS CONCLUDING REMARKS................................. G. E.VAUGHN/
R. A. WATSON 0II
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
HISTORICAL PERFORMANCE
- CORRECTIVE ACTIONS
- CONCLUSIONS
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
- HISTORICAL PERFORMANCE YEAR WEAKNESS IFI 1987
3 1988
1 1989
3 1990
0 1991
2
ASSESSMENT
-
PERFORMANCE IS CYCLIC WITHOUT CONSISTENT GOOD PERFORMANCE 0II
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT CORRECTIVE ACTION TARGET RESPONSIBILITY COMPLETION DATE
- ORGANIZATION
- Reassessment of Staffing Levels and assignments 3/1/92 Dietz/Vaughn
- Reassign Emergency Preparedness accountability to Robinson 2/1/92 Dietz Dep Manager
- TRAINING Dietz, Vaughn & Line
- Position Responsibility and Interfaces 3/1/92 Management
- Dose Projection/Assessment 3/1/92 McFeaters
- Table Top Exercises Monthly Dietz & Line Management
- SCENARIO DEVELOPMENT & DRILL CONTROL
- Scenario Development Guidelines 3/1/92 Dietz & Vaughn
- EMERGENCY ACTION LEVEL DETERMINATION
- Comprehensive Assessment of Current Emergency 4/1/92 Dietz & Vaughn Action Level Flow Chart
- MANAGEMENT Dietz & Line
- Improve Accountability & Ownership of ERO Organization 2/1/92 Management
- Assess "Good Practices" and utilize to improve RNP ERO 3/1/92 Dietz & Vaughn
- Comprehensive reassessment of ERO functions 4/1/92 Dietz & Vaughn
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON MERGENCY PRE EDNESS ASSESSMENT
- CORRECTIVE ACTIONS
- ORGANIZATION
-
COMPLETE A REASSESSMENT OF STAFFING LEVELS AND ASSIGNMENTS TO ASSURE AN APPROPRIATE LEVEL OF COMMITMEN TARGET COMPLETION 3/1/92 DATE RESPONSIBILITY:
DIETZ/VAUGHN REASSIGN THE EMERGENCY PREPAREDNESS ACCOUNTABILITY TO THE DEPARTMENT MANAGER ON AN INTERIM BASIS (12 TO 18 MONTHS) PENDING A DETERMINATION OF APPROPRIATE REASSIGNMEN TARGET COMPLETION 2/1/92 DATE RESPONSIBILITY:
DIETZ
ENFORCEMENT CONFERENCE DECEMBER 20 1991 ROBINSON EMERGENCYPREPAREDNESS ASSESSMENT
- CORRECTIVE ACTIONS (CONTINUED)
- TRAINING
-
POSITION RESPONSIBILITY AND INTERFACES COMPLETE THE DEVELOPMENT OF A TRAINING PROGRAM THAT REFLECTS FUNCTIONAL ACCOUNTABILITY AND THE APPLICATION OF DERIVED INFORMATION AND SERVICE TARGET COMPLETION DATE:
MODULE DEVELOPMENT 3/1/92 PERSONNEL TRAINING 4/1/92 RETRAINING ANNUAL RESPONSIBILITY:
DIETZ, VAUGHN, AND LINE MANAGEMENT
ENFORCEMENT CONFERENCE DECEMBER 20 1991 ROBNSON EMERGENCY PREPAREDNESS ASSESSMENT
- CORRECTIVE ACTIONS (CONTINUED)
- TRAINING (CONTINUED)
-
DOSE PROJECTION/ASSESSMENT IMPROVED TRAINING MODULES FOR INCREASED LEVEL OF UNDERSTANDING IN BOTH TECHNICAL PROCESSES AND THE UTILIZATION OF THAT DATA. THIS ACTIVITY WILL ALSO INCLUDE ENHANCEMENTS TO THE TECHNICAL PROCESS TO FACILITATE IMPROVED HUMAN FACTOR TARGET COMPLETION 3/1/92 DATE RESPONSIBILITY:
MCFEATERS
-
TABLE Top EXERCISES IMPLEMENT MONTHLY TABLE TOP EXERCISES TO SUPPORT IMPROVEMENTS IN PERFORMANCE. THIS WILL CONTINUE UNTIL DETERMINED BY RNP DEPARTMENT MANAGER THAT SUBSTANTIVE, SUSTAINED IMPROVEMENT HAS BEEN DEMONSTRATE TARGET COMPLETION MONTHLY DATE RESPONSIBILITY:
DIETZ AND LINE MANAGEMENT
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
- CORRECTIVE ACTIONS (CONTINUED)
- SCENARIO DEVELOPMENT AND DRILL CONTROL
-
CONSISTENT WITH CORPORATE INITIATIVES, SCENARIOS WILL BE DEVELOPED IN ACCORDANCE WITH GUIDELINES THAT SUPPORT APPROPRIATE SCENARIO CONTENT, CONTROL, EXECUTION, AND MONITORIN TARGET COMPLETION 3/1/92 DATE:
RESPONSIBILITY:
DIETZ AND VAUGHN
- A DETAILED ACTION PLAN WILL BE DEVELOPED FOR THE FUTURE UTILIZATION OF ROBINSON'S PLANT SPECIFIC SIMULATO TARGET COMPLETION 4/1/92 DATE:
RESPONSIBILITY:
VAUGHN
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
- CORRECTIVE ACTIONS (CONTINUED)
- EMERGENCY ACTION LEVEL DETERMINATIONS
-
PERFORM A COMPREHENSIVE ASSESSMENT OF THE CURRENT EMERGENCY ACTION LEVEL FLOW CHART FOCUSING ON EACH.OF THOSE ACTIONS DERIVED FROM SEC JUDGEMENT. DEVELOP ADDITIONAL INSTRUCTIONS/GUIDANCE TO FACILITATE THIS JUDGEMENT AND ENSURE CONSISTENCY BASED UPON SIMILAR OPERATING SITUATION TARGET COMPLETION 2/1/91 DATE:
li0 RESPONSIBILITY:
DIETZ AND VAUGHN
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
- CORRECTIVE ACTIONS (CONTINUED)
- MANAGEMENT
-
DEVELOP IMPROVED ACCOUNTABILITY AND OWNERSHIP WITHIN THE ERO BASED UPON MORE SPECIFIC STATEMENTS OF EXPECTATION AND SUPPORTIVE FORMAL ASSESSMENTS OF PERSONAL PERFORMANCE CAPACIT TARGET COMPLETION 2/1/92 DATE:
RESPONSIBILITY:
DIETZ AND LINE MANAGEMENT
-
COMPLETE AN ASSESSMENT OF "GOOD PRACTICES" THROUGHOUT THE INDUSTRY AND LEARN FROM THE EXPERIENCE OF OTHER UTILIZE THIS INFORMATION IN THE STUDIES NOTED BELO TARGET COMPLETION 3/1/92 DATE:
RESPONSIBILITY:
DIETZ AND VAUGHN
-
COMPLETE A COMPREHENSIVE REASSESSMENT OF THE ERO FUNCTIONS AND INFORMATION FLOW PATHS TO IMPROVE THE OVERALL "OPERABILITY" OF THOSE PROCESSES. DEVELOP RE-ENGINEERED PROCESSES AS APPROPRIATE AND COMPLETE THE TRAINING TO SUPPORT IMPLEMENTATIO TARGET COMPLETION 4/1/92 DATE:
RESPONSIBILITY:
DIETZ AND VAUGHN 0II
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 ROBINSON EMERGENCY PREPAREDNESS ASSESSMENT
- CONCLUSIONS
-
THE 1991 EXERCISE WEAKNESSES REQUIRE MANAGEMENT ATTENTION To RESOLVE
-
OUR ACTIONS COMMENCED IMMEDIATELY AND ARE INTENDED TO BE COMPREHENSIVE AND TIMELY; PROGRESS WILL BE MONITORED AND REPORTED ROUTINELY TO SENIOR EXECUTIVE MANAGEMENT CHALLENGES ARE NOT NEW TO THE ROBINSON STAFF AND WE ARE CONFIDENT THAT THE RESULTS WILL BE AS SUCCESSFUL AS OTHER INITIATIVES...AS JUDGED BY OUT RESULTS
-
IN THE INTERIM, REMAIN CONFIDENT THAT THE ROBINSON ERO STAFF HAS THE CAPABILITY TO RESPOND EFFECTIVELY TO ANY EMERGENCY SITUATION AND IF WE DEFAULT, THE ACTIONS WILL BE CONSERVATIVE AND STRUCTURED TO SUPPORT THE HEALTH AND SAFETY OF THE PUBLIC 011
ENFORCEMENT CONFERENCE DECEMBER 20, 1991 AGENDA OPENING REMARKS....................... *......
C. R. DIETZ E.A.L. CLASSIFICATION ISSUE
- EVENTS REVIEW.**...................................
WM. STOVER MANAGEMENT WM. J. FLANAGAN EXPECTATIONS
- NRC QUESTIONS OTHER EXERCIS..........
.
.
.
.
R. H.CHAMBERS ISSUES
- NRC QUESTIONS ROBINSON EMERGENC............................ C.R.DIETZ PREPAREDNESS ASSESSMENT
- NRC QUESTIONS CONCLUDNG REMARKS......... G. E. VAUGHN!
R. A. WATSON
ENCLOSURE 3 CLARIFICATION TO INSPECTION REPORT NO. 50-261/91-26 Subsequent to the Enforcement Conference the licensee. requested clarification of selected issues identified in the Inspection Repor These areas were discussed further by A. Boland of the Region II staff and J. Kloosterman and M. Gann of the Robinson staff on December 23, 199 Although these areas are being addressed to assure completeness and accuracy, the additional information provided by the licensee does not affect the specific weaknesses and concerns identified in the original Inspection Repor The following items are referenced by topical section, page and paragraph number from Inspection Report No. 50-261/91-26, dated December 4, 199.
Exercise Scenario, Page 2, Paragraph 2:
Licensee representatives stated that their internal investigation of data flow during the exercise revealed no examples where scenario data was injected into play at the inappropriate tim The inspector had previously identified that the "A" Steam Generator Low-Low Level alarm was injected at 10:30 a.m. rather than 10:45. Emergency Classification, Page 6, Paragraph 3:
The complete quotation from Site Emergency Coordinator Training Module, EP-LP-02, related to the Alert Fire Emergency Action Level is as follows:
"It is generally interpreted that if a fire is in the same fire zone (room)
as a safety related component, then it has the potential to effect the equipment, The SF/SEC should use judgement. A smoldering fire in a trash can probably would not have the potential to effect equipment."
3. Notification Methods and Procedures, Page 7, Paragraph 4:
The specific emergency messages of concern which did not appropriately contain radiological release information and dose projections were No. 5, No. 6, and No. 7. As noted in the Inspection Report, these omissions resulted in a two hour and five minute period in which the State/locals were not officially provided this informatio Licensee representatives further clarified, however, that the State/locals were officially without this information for one hour and 22 minutes after radiological conditions change. Notification Methods and Procedures, Page 8, Paragraph 2:
The Inspection Report noted that the transmission times-were not annotated on NRC Messages No. 3, No. 4, and No. On December 23, 1991, the licensee provided copies of the original notification forms maintained by the inspecto The copied version indicated clearly the dispatch time of the messages to NR Licensee representatives stated the reason for the discrepancy in the forms was a result of the process used for generation, approval, and dispatch of emergency messages during the exercis Specifically, after generation.and approval, a copy is made. The original is maintained for information by the originator and the, copy is given to the phone talker for transmission who then completes the transmittal time
Enclosure 3
III information. In addition, the licensee clarified that State/local message No. 7 did not contain reactor status because this information had not changed, and therefore, was not required to be on the for. Operational Support Center, Page 11, Paragraph 1:
The report noted that the licensee was planning to move the OSC into the Protected Area following completion of the new Maintenance Shop projected for 199 Licensee representatives clarified that the relocation of the OSC was not considered a formal licenseee commitmen. Operational Support Center, Page 12, Paragraph 2:
Licensee representatives stated that their internal investigation revealed that 20 minutes of the one hour and ten minute delay observed for the PORV Team was due to demonstration of respirator usag No further information was provided for the other four teams discussed in the repor. Joint Information Center, Page 14, Paragraph 1:
The inspector was informed that the CP&L District Office in Florence is appropriately the CP&L Division Offic. Accident Assessment, Pages 16 and 17:
The Inspection Report attributed the dose assessment problems observed during the exercise to the failure of dose assessment personnel to recognize actual plant conditions as well as inadequate interactions between health physics and accident assessmen Licensee representatives stated that the dose projection inaccuracies resulted from the miscalculation of PORV flow rates by Dose Assessment personne Further, these calculations were performed by Dose Assessment due to the repeated failure of Accident Assessment personnel to respond to requests for the PORV flowrate informatio. Exercise Critique, Page 19, Paragraph 3:
The licensee's self-identified critique item (not observed by NRC) involving the improper removal of the fire hose from the CCW Pump Room was found to be invalid as a result of the licensee's post exercise investigation process.