IR 05000261/1995011
| ML14181A683 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/02/1995 |
| From: | Barr K, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A682 | List: |
| References | |
| 50-261-95-11, NUDOCS 9505110063 | |
| Download: ML14181A683 (8) | |
Text
64, REGcGi UNITED STATES NUCLEAR REGULATORY COMMISSION REGION 11 101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 May 3, 1995 Report No.:
50-261/95-11 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 Steam Electric Plant, Unit 2 Inspection Conducted:
April 3-7, 1995 Inspector: 6?.
-44-
2-9 J. L. Kreh adiation Specialist Date Signed Approved by:
.12 K..'Barr th ef Dite Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This special, announced inspection was conducted to assess the operational readiness of the site emergency preparedness prpgram through selective review of the following programmatic areas:
(1) emergency response training, (2) emergency notifications and communications, and (3) protective action decision-makin Results:
In the areas inspected, no violations or deviations were identified. Program strengths included very good performance in walk-throughs with individuals designated as Site Emergency Coordinators and Emergency Communicators, and significant upgrades in the ergonomics and equipment capability of the Technical Support Center and Emergency Operations Facility. Areas for potential improvement included addressing the following items: (1) inclusion in the Emergency Plan of the scheme for developing protective action recommendations (see Paragraph 2 for details); (2) unfamiliarity of Emergency Communicators with a particular aspect of the 10 CFR 50.72 requirement for NRC notification of an emergency declaration (Paragraph 3); and (3) inconsistencies between the Emergency Plan implementing procedures and 9505110063 950503 PDR ADOCK 05000261
some instructional material used in the training of nonlicensed emergency response personnel (Paragraph 4).
Appropriate 'corrective actions for items (2) and (3) were completed by the licensee after the onsite phase of the inspection, with suitable confirmatory documentation provided to the inspecto REPORT DETAILS Persons Contacted Licensee Employees D. Akers, Senior Reactor Operator
- D. Baur, Senior Specialist, Emergency Preparedness
- B. Clark, Manager, Maintenance
- H. Curry, Senior Specialist, Training Department
- M. Gann, Acting Manager, Emergency Preparedness
- D. Gudger, Senior Specialist, Regulatory Programs G. Healey, Auxiliary Operator W. Hensley, Senior Training Specialist
- C. Hinnant, Vice President, Robinson Plant
- P. Jenny, Manager, Emergency Preparedness
- K. Jury, Manager, Licensing/Regulatory Programs
- R. Krich, Manager, Regulatory Affairs
- F. Lowery, Manager, Work Control
- J. Lucas, Manager, Technical Training
- B. Meyer, Operations Manager
- G. Miller, Manager, Robinson Engineering Support Section
- R. Moore, Manager, Outages
- P. Musser, Manager, Plant Operations Assessment S. Poteet, Senior Specialist, Requalification Training Program
- R. Steele, Manager, Shift Operations
- G. Walters, Manager, Support Training
- D. Whitehead, Manager, Plant Support Services
- T. Wilkerson, Manager, Environmental and Radiation Control D. Young, Plant General Manager Other licensee employees contacted during this inspection included operators, engineers, security force members, and administrative personne Nuclear Regulatory Commission
- W. Orders, Senior Resident Inspector
- Attended exit interview on April 7, 1995 An index of abbreviations used throughout this report will be found in the last paragrap.
Protective Action Decision-Making (82202)
This area was inspected to determine whether the licensee was maintaining a continuous capability to (a) assess emergency conditions, (b) make appropriate recommendations to governmental officials to protect the public, and (c) take appropriate measures to protect onsite workers in the event of an emergency. Regulatory bases applicable to this area are found in 10 CFR 50.47(b)(9) and (10),Section IV.D.3 of Appendix E to 10 CFR Part 50, and Section 5.4.4 of the Emergency Pla *
The inspector determined through review of the Emergency Plan and PEPs that authority and responsibility for accident assessment and protective action decision-making were clearly assigned and were available on a 24-hour basi Interviews conducted by the inspector disclosed that ERO personnel understood their authorities and responsibilities with respect to accident assessment and protective action decision-makin Walk-through evaluations involving protective action decision-making were.conducted with two teams (see Paragraph 4 for details of the conduct of these evaluations). The Site Emergency Coordinator for each team was aware of the range of PARs available for protection of the public and was cognizant of appropriate onsite protective action During review of the Emergency Plan, the inspector noted a significant discrepancy in that the methodology for developing a PAR in the event of a General Emergency declaration was not contained in the Pla The Plan simply referenced PEP-105, "General Emergency", for the details of the decision-making process for deriving a PAR to evacuate or shelter the public. However, 10 CFR 50.47(b)(10) specifies that an Emergency Plan must provide "guidelines for the choice of protective actions during an emergency, consistent with Federal guidance."
Exclusion of the licensee's PAR methodology from the Plan placed the scheme outside the framework of the NRC's formal licensing process for evaluating changes to the Emergency Plan. With this understanding of the NRC's position in the matter, licensee management planned to revise the Emergency Plan by May 31, 1995 to incorporate the details of the method for deriving a PA No violations or deviations were identifie.
Notifications and Communications (82203)
This area was inspected to determine whether the licensee was maintaining a capability for notifying and communicating with plant personnel, offsite support agencies and authorities, and the population within the 10-mile EPZ. Regulatory bases applicable to this area are found in 10 CFR 50.47(b)(5) and (6),Section IV.D of Appendix E to 10 CFR Part 50, and Section 5.5 of the Emergency Pla The inspector reviewed the licensee's notification procedure PEP-171,
"Emergency Communicator and Staff".
That procedure contained emergency notification message forms (one for State and county officials, another for the NRC) and specified when to notify and activate the onsite emergency organization, corporate support organization, and offsite agencies. The procedure was consistent with the emergency classification scheme used by the licensee. The "Emergency Notification Form", used in transmitting information to State and local emergency management officials, was consistent with the guidance in NUREG-0654, Sections II.E.3 and II. *
Interviews with two Site Emergency Coordinators, each assisted by an Emergency Communicator (see Paragraph 5 for details regarding the conduct of these interviews), verified that each team understood the requirements for notifying State and local authorities and the NRC in the event of a declared emergency. During walk-through evaluations, each of the Emergency Communicators performed satisfactorily and helped facilitate the timely implementation of the applicable PEP Interviewees demonstrated sensitivity and responsiveness to the time limitations for notifications of offsite authorities. However, it was not clear from these interviews that the Emergency Communicators were aware of the requirement in 10 CFR 50.72(a)(3) to "notify the NRC immediately after notification of the appropriate State or local agencies and not later than one hour after the time the licensee declares one of the Emergency Classes" [emphasis added].
The Emergency Communicators appeared to be familiar only with the "one hour" aspect of the requirement. Subsequent to the closing date of the onsite inspection, the licensee provided the inspector with a copy of an April 22, 1995 internal memorandum (received on April 26, 1995) to designated Emergency Communicators which reminded the subject personnel of the NRC notification requirement quoted above. This action, together with the licensee's intention of henceforth addressing the notification issue during training for Emergency Communicators, satisfactorily resolved the matter under discussio The inspector reviewed records of weekly and monthly surveillances of communications equipment which were conducted in accordance with PEP-103, "Emergency Preparedness Periodic Tests". This equipment included the Selective Signaling System, Local Government Radio System, FTS 2000 (ENS), and radio pagers used for off-hours notification of the ERO. These records indicated that communications problems, when identified, were expeditiously corrected. The inspector conducted operability checks of selected communications equipment at the Control Room, TSC, and EOF. No problems were note The management control program for the public notification system (sirens) was reviewed. According to documentation and discussions with a licensee representative, the system consisted of 45 sirens located within the 10-mile EPZ in the counties of Darlington, Lee, and Chesterfield. Licensee documentation prepared for the Federal Emergency Management Agency on the results of siren tests (full cycle, silent, and growl) for calendar year 1994 indicated an overall system availability of 98.2%.
No violations or deviations were identifie.
Knowledge and Performance of Duties (Training) (82206)
This area was inspected to determine whether ERO personnel understood their response roles and could perform their assigned function Regularity bases applicable to this area are found in 10 CFR 50.47(b)(15), Section ILV.F of Appendix E to 10 CFR Part 50, and Section 5.6 of the Emergency Pla *
In an effort to gauge the effectiveness of the emergency response training program, the inspector conducted separate interviews with two teams, each of which included a Site Emergency Coordinator (a Senior Reactor Operator and the Plant General Manager, respectively) and an Emergency Communicato Each 90-minute interview began with technical questions relating to the duties, responsibilities, and functions of the individuals during an emergency situation, and then presented two accident scenarios that required classification, preparation of a notification message, and formulation of a PAR. The inspector delineated the guidelines for the interview at the outset, including the
"open book" nature of the evaluation. The Acting Emergency Preparedness Manager was present during each of the interviews to allow for confirmation and firsthand understanding of observations. From an overall perspective, each of the two teams demonstrated excellent understanding of their duties and responsibilities in the event of an emergency. The only issue arising from these interviews was the timeliness requirement for notification to the NRC of an emergency declaration, as discussed previously in Paragraph The inspector reviewed detailed outlines and lesson plans used in the training of selected ERO positions. Generally, the training materials were comprehensive and accurate. However, factual discrepancies were noted during this review with respect to lesson plans that apparently had been used in classroom training without appropriate modifications to account for revisions such as those involving EALs and emergency worker dose limits. A licensee representative informed the inspector of a mechanism already in place to insure that the Training Department promptly received revisions to the PEPs when issued so that training modules could be corrected as necessary. The licensee was in the process of rectifying the existing discrepancies, but completion of this task was at least several months away. In reaction to the inspector's expressed concern regarding this situation, the licensee undertook a near-term effort to revise those lesson plans for ERO training which had not been appropriately updated at the time of the inspectio Subsequent to the closing.date of the onsite inspection, the licensee provided the inspector with revised instructor lesson plans for 23 modules used in ERO training (received on April 26, 1995).
Based upon selective review of this material, the inspector determined that the licensee's action satisfactorily resolved the matter under discussio No violations or deviations were identifie.
Licensee Action on Previous Inspection Findings (Closed) IFI 50-261/93-09-03:
Reviewing Corrective Action Program for emergency preparedness-related deficiencie The controls and timeliness for corrective actions in emergency preparedness appeared to have been improved through use of the plant-wide Corrective Action Program. The Emergency Preparedness
- staff was no longer using its own internal program to track items for corrective actio (Closed) URI 50-261/94-19-01:
Review respiratory equipment qualification for ERO personne In response to concerns raised by the Resident Inspectors, the licensee generated ACR No. 94-01204 on August 15, 1994. This ACR resulted in an extensive evaluation of the need for respiratory qualification on a position-specific basis. These efforts resulted in improvements to PEP-004, "ERO Qualification",
Revision 2, effective February 16, 1995, which appeared to satisfactorily resolve this issu No violation or deviation of regulatory requirements was foun.
Exit Interview The inspection scope and results were summarized on April 7, 1995 with those persons indicated in Paragraph 1. The inspector described the areas assessed and discussed the inspection results in detail, including the three areas for improvement reported in the "Results" section at the beginning of this report. The plan to implement corrective action as delineated in Paragraph 2 was confirmed by licensee management. No violations or deviations were identified, and no new items will be formally tracked by the NRC. Dissenting comments were not received from the licensee. Although proprietary information was reviewed during this inspection, none is contained in this report. The following list summarizes the status of items being tracked by the NRC in the area of emergency preparedness:
Type Number Status Description and Reference IFI 50-261/93-09-03 Closed Reviewing Corrective Action Program for emergency preparedness-related deficiencies (Paragraph 5.a)
URI 50-261/94-19-01 Closed Review respiratory equipment qualification for ERO personnel (Paragraph 5.b)
1 Index of Abbreviations Used in This Report ACR Adverse Condition Report CFR Code of Federal Regulations EAL Emergency Action Level ENS Emergency Notification System EOF Emergency Operations Facility EPZ Emergency Planning Zone ERF Emergency Response Facility ERO Emergency Response Organization
FTS Federal Telecommunications System IFI Inspector Followup Item NRC Nuclear Regulatory Commission OSC Operational Support Center PAR Protective Action Recommendation PEP Plant Emergency Procedure TSC Technical Support Center URI Unresolved Item