IR 05000261/1994020
| ML14181A596 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/06/1994 |
| From: | Barr K, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A595 | List: |
| References | |
| 50-261-94-20, NUDOCS 9409160258 | |
| Download: ML14181A596 (9) | |
Text
UNITED STATES
Ro NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 SEP 06 1994 Report No.:
50-261/94-20 Licensee: Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DRP-23 Facility Name: H. B. Robinson Inspection Conduct d:
Au ust 8-12, 1 Inspector:
2--/6 G. W. Sal s
/Date Signed Approved by:
,
K. P. Barr,GlTief ate Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY Scope:
This routine, announced inspection was conducted to assess the operational readiness of the site emergency preparedness program, and included selective review of the following programmatic areas:
(1) Emergency Plan and associated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3)
organization and management control; (4)
training and (5) independent and internal audits and review Results:
In the areas inspected, no violations or deviations were identified. The program appeared to be receiving management support and previously noted weak areas appears to be improving. Scheduling of required activities should be more consistent between intervals (Paragraph 5).
Drill reports and critiques needed more detail so as to convey what drills and objectives were actually accomplished (Paragraph 5).
Tracking of less significant issues, improvement items, needs improvement (Paragraph 6).
9409160258 940906 PDR ADOCK 05000261 a
REPORT DETAILS Persons Contacted Licensee Employees
- R. Arrnett, Project Management
- D. Bacir, Senior Specialist, Emergency Preparedness
- C. Baucom, Manager, Shift Outage
- G. Bowen, Senior Specialist, Emergency Preparedness Training
- M. Brown, Manager, Design Engineering
- H. Carter, Manager, Operator Training
- M. Gann, Emergency Preparedness
- J. Harding, Emergency Preparedness Training
- R. Howell, Nuclear Assurance Department
- P. Jenny, Manager, Emergency Preparedness
- K. Jury, Manager, Licensing/Regulatory Programs
- R. Kirch, Manager, Regulatory Affairs
- F. Lowery, Manager, Work Control
- T. Lucas, Emergency Preparedness
- J. Moyer, Manager, Site Assessment
- M. Pearson, Manager, Robinson Plant
- R. Reynolds, Nuclear Assessment Department
- L. Woods, Manager, Technical Support Other licensee employees contacted during this inspection included operators, security force members, technicians, and administrative personne Nuclear Regulatory Commission
- C. Ogle, Resident Inspector
- J. Starefos, Project Engineer, Region II
- Attended exit interview on August 12, 1994 Abbreviations used throughout this report are listed in the last paragrap.
Emergency Plan and Implementing Procedures (82701)
This area was inspected to determine whether significant changes were made in the licensee's emergency preparedness program since the last inspection in this area, to assess the impact of any such changes on the overall state of emergency preparedness at the facility, and to determine whether the licensee's actions in response to actual emergencies were in accordance with the Emergency Plan and its implementing procedure Requirements applicable to this area are found in 10 CFR 50.47(b)(16), 10 CFR 50.54(q), Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla )
The inspector reviewed the licensee's system for making changes to the Emergency Plan and the PEPs. The inspector selected twelve of the approximately fifty changes to the PEPs since April 1993, the last inspection, and concluded that the changes were in agreement with the Plan. All changes were approved and distributed in accordance with the licensee's procedures. The NRC was notified within 30 days of all changes as required in 10 CFR 50 Appendix The inspector reviewed the licensee's event declarations to verify that the events were properly classified in accordance with the EALs, and that the applicable PEPs were properly implemented. Six emergency declarations were made by the licensee since April 199 *
NOUE, August 2, 1994 - Failure of the Pressurizer PORV to close
Alert, June 6, 1994 - Fire "A" EDG
NOUE, March 19, 1994 - RCS leakage greater than 10 gpm
NOUE, January 17, 1994 - Loss of both Emergency Diesel Generators
Alert, August 16, 1993 - Fire on "A" EDG
Noue, May 12, 1993 - RCS leakage greater than 10 gpm The inspector concluded that the events were properly classified and the notifications were made in a timely manne No violations or deviations were identifie.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
This area was inspected to determine whether the licensee's ERFs and associated equipment, instrumentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes in this area upon the emergency preparedness progra Requirements applicable to this area are found in 10 CFR 50.47(b)(8)
and (9), 10 CFR 50.54(q),Section IV.E of Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla The inspector toured the Control Room, EOF, TSC, and OSC. The inspector observed the EOF and TSC was being maintained in a state of operational readiness. The OSC had the capability to be made operationally ready in an efficient manner in the event of an emergency declaratio PEP-652, "Emergency Facilities and Equipment", Section 5.1 listed equipment and facilities to be tested, their test frequencies, and identified the responsible work group PEP-003, "Emergency Preparedness Periodic Tests" implemented portions of PEP-652. Section 3.1 of PEP-003 "listed" periodic tests and their required test frequencies which the EP staff was responsible for performin RST-003, "Emergency Kit Inventory", Attachment 8.2 contained the inventory list for the emergency kits in the OSC, Back-up OSC, EOF, TSC, CR, Byerly Hospital, and Wilson Hospita The inventories were performed by the Radiation Control grou The inspector reviewed documentation for the required task identified in PEP-652, PEP-003, and RST-003 since April 1993. All tests and inventories were performed at the specified frequency and all test results indicated the tests were satisfactor Scheduling of the required task was tracked on a magnetic "White Board."
The calendar year was on the horizonal axis and the task was identified in the left margin. A moveable magnetic marker represented the scheduled task date with a band width of plus or minus twenty-five percent. This method of scheduling assured that the tasks were completed within the permissible "band" but not completed at concise interval The inspector tested communication equipment and computers in the EOF and TSC. The equipment tested satisfactorily. The inspector observed the quality and quantity of the emergency supplies in the TSC and OSC and noted that the emergency supplies were neatly organized and of adequate quantit The ENS consisted of 45 fixed sirens (four in Lee County, 13 in Chester County, and 28 in Darlington County). Testing was performed under the jurisdiction of the respective counties emergency management agencies, with test results forwarded to the license The licensee made two 10 CFR 50.52 notifications to the NRC associated with the PNS:
April 12, 1994 - Twelve of forty-five sirens inoperable
January 5, 1994 -
Nine out of twenty-eight sirens inoperable in Darlington county The inspector reviewed documentation of bi-weekly silent tests, quarterly growl tests, and annual full activation tests. Documentation indicated the test results were satisfactory and timely corrective actions were taken when necessary. The inspector reviewed a letter to FEMA that state the licensee's sirens exceeded the annual 90 percent capability criteri The inspector concluded that the ERO facilities and emergency equipment was appropriately maintained. No violations or deviations were identifie.
Organization and Management Control (82701)
This area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems in the emergency preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and PEP Requirements applicable to this area are found in 10 CFR 50.47(b)(1)
and (16),Section IV.A of Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla The organization and management of the emergency preparedness program were reviewed with licensee representatives. Although there had been management changes at the site and corporate levels, and personnel changes within the site emergency preparedness organization, no changes had occurred to the reporting chain for the site or corporate emergency preparedness organization since the last EP inspectio No violations or deviations were identifie.
Training (82701)
This area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities. Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15),Section IV.E of Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla Initial and annual retraining of Emergency Preparedness Training was conducted in a classroom environment. Two full time training instructors were assigned to EP training. Classroom training sessions consisted of a formal presentation using detailed instructor lesson plans, a basic student handout, and test The emergency preparedness training program was structured by "TI" procedures. The emergency preparedness training program had undergone three revisions since the last inspection. In:
May 1993, (TI-305), initial training and annual retraining requirements consisted of classroom and self-stud *
July 1993, (TI-305), was revised to a added qualification checklist, and added recent industry events and drill feedback to the annual retrainin *
May 1994, (TI-305), was revised to separate training and qualification. Qualifications were placed in PEP-00 *
July 1994, (TI-305) was rewritten and retitled as TI-21 TI-216 (305), Radiological Emergency Preparedness Training, described the H. B. Robinson EP training program. The document contained a matrix which related ERO positions to required training courses. The inspector
reviewed the matrix, the courses (lesson plans and exams) identified in the matrix, for the Site Emergency Coordinator and PARs. The inspector concluded that the matrix, lesson plans, and exams were satisfactor The inspector reviewed the licensee's newly developed "Initial Qualification Checklist" and "Annual Qualification Review Checklist".
The "Qualification Checklist" were detailed and organized. As an overview statement, the checklist required prerequisites, training, and performance activities and evaluations. The checklist appeared to cover the major elements necessary for an effective training program. The inspector concluded that the "Qualification Checklist" was a program improvemen The status of the classroom training program was reviewed by selecting positions in the ERO and reviewing the training records of personnel qualified to fill the positions. Because of the evolution of the training program and the practice of "grand-fathering" ERO members into the new TI-216 program, it was difficult for the inspector to verify that an individual ERO members training was current. The inspector did conclude that the EP training had improved, and that the ERO training records examined were curren The inspector reviewed documentation of training of offsite support groups as required in Section 5.6.1.1 of the RE Except for the fire department, the course outline or subject material was not available for review. The documentation of offsite training consisted of a letter from the offsite support group stating that they had received the training. The licensee could not provide documentation of offsite training for Byerly Hospital in 1993. The inspector reviewed a fax from the hospital stating that they had received the training. The inspector also interviewed the individual that conducted the Byerly Hospital training in 1993, and reviewed the individuals experience and qualifications. The inspector concluded that Byerly Hospital had received training in 1993 and the instructor was satisfactorily qualified to conduct the trainin The inspector verified that the licensee had performed the required drills in accordance with Section 5.6.1.2.1 and 5.6.1.2.2 of the REP, Drills and Exercises, by reviewing documentation of their drill From April 1993, through July 1994, H. B. Robinson performed the following ERO drills:
June 14, 1993, combined functional drill
November 15, 1993, off-hours drill
January 15, 1994, combined functional drill o
March 26, 1994, combined functional drill
May 21, 1994, combined functional drill
July 13, 1994, combined functional drill Section 5.6.1.2.2 of the REP states that the graded exercise will test each of the elements or objectives within a five year period. In response to a NAD audit comment, the licensee had formally documented the major elements of their plan. The document listed thirty eight elements or objectives. The licensee also developed a six year matrix of the thirty eight objectives. The inspector concluded from reviewing
"Robinson Nuclear Plant 5 Year Objectives Plan" that the licensee had exercised each of the major objectives within the past five year The licensee combined drills, as an example: medical drill and quarterly drill, radiological monitoring drill and graded exercise. The licensee's critiques and drill reports did not clearly state what drills or objectives were performed, therefore, verifying the licensee's compliance with their commitment was difficult. This was brought to the licensee's attention. With the licensee's assistance in identifying objectives and mini-scenarios within the documentation, the inspector verified that the licensee had met their drill commitment in Section 5.6.1.2.1 and 5.6.1.2.2 of the RE The inspector concluded that the licensee continued to maintain the REP classroom training of the ERO and training of offside support groups in accordance with Section 5.6.1.1 of the REP and-PEP-653, Performance of Training, Exercises and Drills. No discrepancies were found by the inspecto No violations or deviations were identifie.
Independent and Internal Reviews/Audits (82701)
This area was inspected to determine whether the licensee had performed an independent audit of the emergency preparedness program, and whether the emergency planning staff had conducted a review of the Plan and the PEPs. Requirements applicable to this area are found in 10 CFR 50.54(t)
and the licensee's Emergency Pla The inspector reviewed the report for the 1994 annual independent audi The audit report reviewed was NAD audit number R-EP-94-01 dated February 18, 1994. The report contained three issues and one weakness. The report was comprehensive and met the respective requirement Issue two of the audit was: The Emergency Preparedness Unit has not effectively utilized the CAP to evaluate and correct deficiencie The EP program currently utilizes the CAP system but, CAP only tracked level three or higher issue Improvement items are not tracked by the CAP system. The inspector asked the licensee if they tracked
"improvement" items from drill and exercises. The licensee provided the inspector a computer print out of forty eight item The list did not identify whether the item was open or closed, its' status, or identify an individual responsible for the issue. When asked by the inspector,
the licensee could not readily provide information on the status of the listed issue The inspector also confirmed that the maintenance of the Emergency Plan and the PEPs was being reviewed by the licensee during the audit progra Documentation indicated that the REP was initially presented to the PNSC for review on October 27, 1993. At that time, members of the PNSC were not prepared to discuss REP changes that had occurred since the previous review. The review was rescheduled and documented on January 28, 199 No violations or deviations were identifie.
Licensee Action on Previous Inspection Findings (Closed) IFI 50-261/93-09-01:
Correct decision block A-13 to provide a proper response to RCS barrier questio The inspector reviewed Revision 7 to the EAL flow-charts. In Revision 7, the original block A-13, listing the S/G blowdown radiation monitor was replaced with the steam line radiation monito (Closed) IFI 50-261/93-09-02: Review of corrective actions to findings identified in NAD Audit repor The EP organization provided the inspector with documentation that indicated R-EP-93-01-W1, W2, and W3 had been responded to and closed. The documentation indicated NAD's approval by a closure date of February 18, 199 (Open) IFI 50-261/93-09-03: Review Corrective Action Program for EP related deficiencie The inspector concluded that there was insufficient data histor.
Exit Interview The inspection scope and results were summarized on August 12, 1994 with those persons indicated in Paragraph 1. The inspector described the areas reviewed and discussed the inspection results in detail, including the program strengths and areas for improvement listed in the "Summary" section of this report. The closure of the two previous inspection findings as delineated in Paragraph 7 were discussed. No proprietary information was reviewed during this inspectio Item Number Status Description and Reference 50-261/93-09-01 Closed Correct decision block A-13 to provide a proper response to RCS barrier question (Paragraph 7).
50-261/93-09-02 Closed Review of corrective actions to findings identified in NAD Audit report (Paragraph 7). Abbreviations Used in This Report CFR Code of Federal Regulations CR Control Room EAL Emergency Action Level EDG Emergency Diesel Generator EOF Emergency Operations Facility EP Emergency Preparedness ERF Emergency Response Facility ERO Emergency Response Organization FEMA Federal Emergency Management Agency gpm gallons per minute IFI Inspector Follow-up Item NOUE Notification of Unusual Event NAD Nuclear Assessment Department NRC Nuclear Regulatory Commission OSC Operational Support Center PAR Protective Action Recommendation PNS Prompt Notification System PORV Power Operated Relief Valve RCS Reactor Coolant System TI Training Instruction TSC Technical Support Center