IR 05000261/2006008
| ML062640103 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/15/2006 |
| From: | Brian Bonser NRC/RGN-II/DRS/PSB2 |
| To: | Walt T Carolina Power & Light Co |
| References | |
| IR-06-008 | |
| Download: ML062640103 (15) | |
Text
ber 15, 2006
SUBJECT:
NRC INSPECTION REPORT NO. 05000261/2006008
Dear Mr. Walt:
On August 14-18, 2006, the U. S. Nuclear Regulatory Commission (NRC) conducted an inspection at your H. B. Robinson Steam Electric Plant, Unit 2. The enclosed inspection report documents the inspection findings, which were discussed on August 18, 2006, with you and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed personnel.
Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this letter, please contact us.
Sincerely,
/RA/
Brian R. Bonser, Chief Plant Support Branch 2 Division of Reactor Safety Docket No. 50-261 License No. DPR-23
Enclosure:
(See page 2)
CP&L 2 Enclosure: NRC Inspection Report 0500261/2006008 w/Attachment: Supplemental Information
REGION II==
Docket Nos: 50-261 License No: DPR-23 Report No: 05000261/2006008 Licensee: Carolina Power & Light Company Facility: H. B. Robinson Steam Electric Plant, Unit 2 Location: 3581 West Entrance Road Hartsville, SC 29550 Dates: August 14-18, 2006 Inspector: J. Kreh, Emergency Preparedness Inspector Approved by: Brian R. Bonser, Chief Plant Support Branch 2 Division of Reactor Safety Enclosure
SUMMARY OF FINDINGS
IR 05000261/2006008; 08/14-18/2006; H. B. Robinson Steam Electric Plant, Unit 2;
Emergency Preparedness Baseline Inspection This report covers an announced inspection conducted by a Region II emergency preparedness inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
Licensee-Identified Violations
.
None
REPORT DETAILS
REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System (ANS) Testing
a. Inspection Scope
The inspector evaluated the adequacy of licensee methods for testing the alert and notification system in accordance with NRC Inspection Procedure 71114, 02, Alert and Notification System Testing. The applicable planning standard 10 CFR 50.47(b)(5) and related requirements contained in Section IV.D of Appendix E to 10 CFR Part 50 were used as reference criteria. The evaluation criteria contained in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1; and Federal Emergency Management Agency (FEMA) Report REP-10, Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants were also applied. This inspection activity represents one sample on a biennial cycle.
The inspector reviewed various documents which are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
1EP3 Emergency Response Organization (ERO) Augmentation
a. Inspection Scope
The inspector reviewed the ERO augmentation staffing requirements and the process for notifying ERO personnel to ensure the readiness of key staff for responding to an event and the capability for timely facility activation. The results of periodic ERO communications drills were reviewed. The inspector examined the provisions for a backup notification system. A sample of problems identified from augmentation drills and ERO pager system tests was reviewed to assess the effectiveness of corrective actions.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, 03, Emergency Response Organization Augmentation. The applicable planning standard 10 CFR 50.47(b)(2) and related requirements contained in Appendix E to 10 CFR Part 50 were used as reference criteria. This inspection activity represents one sample on a biennial cycle.
The inspector reviewed various documents which are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
The inspector reviewed the Emergency Plan changes for Revisions 59 and 60 (the latter was the version in effect at the time of the inspection). The EAL modifications made in Revision 60 to address NRC Bulletin 2005-02 were reviewed in detail.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, 04, Emergency Action Level and Emergency Plan Changes. The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria.
This inspection activity represents one sample on an annual cycle.
The inspector reviewed various documents which are listed in the Attachment to this report.
b. Findings
Introduction.
The inspector determined that there were several inconsistencies between the EALs in PLP-007, Robinson Emergency Plan, Revision 60, and the EAL guidance provided in NUREG-0654, Appendix 1, Revision 1, which nominally comprises the basis for the licensees emergency classification scheme. Further NRC review and internal agency discussions will be required to determine whether the changes made over time have resulted in a blending of NUREG-0654 and NUMARC/NESP-007 EAL schemes in the licensee's emergency classification methodology, and to determine whether such changes constitute decreases in the effectiveness of the licensees Emergency Plan.
This is categorized as an unresolved item (URI) pending completion of further NRC staff review.
Description.
The inspector noted differences between the formally approved and the current versions of the NUREG-0654-based emergency classification scheme or EALs contained in the Robinson Emergency Plan. The inspector preliminarily determined that most of the differences appeared to be attributable to changes based on the NRC staff guidance contained in EPPOS [Emergency Preparedness Position] -1, dated June 1, 1995. EPPOS-1 was intended to provide guidance to the NRC staff regarding the acceptability of incorporating selected NUMARC/NESP-007 EALs (including both deletions and changes allowed by the NUMARC/NESP-007 methodology) into a NUREG-0654-based classification scheme. The NRC's intention was that licensees wishing to adopt changes listed in EPPOS-1 would request prior NRC approval for such changes. Further NRC review will be required to determine the extent of condition and how to disposition this potential finding.
Analysis.
This potential finding affects the Emergency Preparedness Cornerstone and is considered to be more than minor because the Emergency Preparedness attribute of procedure quality was affected. This, in turn, affects the Emergency Preparedness objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Due to the nature of this issue (affecting the regulatory process), traditional enforcement would be applied instead of the Significance Determination Process (SDP).
Enforcement.
10 CFR 50.54(q) states, in part, that the licensee may make changes to emergency plans without Commission approval only if the changes do not decrease the effectiveness of the plans, and the plans, as changed, continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.Section IV.B of Appendix E states, in part, that a revision to an EAL must be approved by the NRC before implementation if the licensee is changing from one EAL scheme to another EAL scheme (e.g., a change from an EAL scheme based on NUREG-0654 to one based on NUMARC/NESP-007 or NEI 99-01).
Proposed changes that decrease the effectiveness of the approved Emergency Plan may not be implemented without application to and approval by the Commission. The licensee made changes to its Emergency Plan which appeared to reduce the effectiveness of the Plan and appeared to be inconsistent with NUREG-0654 EAL scheme, and to utilize an alternative EAL scheme. These changes were not submitted to the NRC for approval prior to implementation. Pending further NRC review necessary to provide the proper scope regarding the significance of the blending of the EAL schemes and EAL changes that were made to the Robinson Emergency Plan, this finding is identified as URI 05000261/2006008-001, Blending of EAL Schemes.
1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies
a. Inspection Scope
The inspector reviewed the corrective actions identified through the emergency preparedness program in an effort to ascertain the significance of the issues and to determine whether repetitive problems were occurring. The facilitys self-assessments and audits were reviewed to assess the licensees ability to be self-critical, thus avoiding complacency and degradation of its emergency preparedness program. In addition, the inspector reviewed the licensees self-assessments and audits to assess the completeness and effectiveness of a sample of emergency preparedness-related corrective actions. Documentation of all emergency declarations since the December 2004 inspection was reviewed in detail.
The inspection was conducted in accordance with NRC Inspection Procedure 71114, 05, Correction of Emergency Preparedness Weaknesses and Deficiencies. The applicable planning standard 10 CFR 50.47(b)(14) and related requirements contained in Appendix E to 10 CFR Part 50 were used as reference criteria. This inspection activity represents one sample on a biennial cycle.
The inspector reviewed various documents which are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors reviewed the licensees procedure for developing the data for the Emergency Preparedness PIs, which are:
- (1) Drill and Exercise Performance (DEP);
- (2) ERO Drill Participation; and
- (3) Alert and Notification System (ANS) Reliability. The inspectors examined data reported to the NRC for the five-quarter period April 1, 2005 to June 30, 2006. Procedural guidance for reporting PI information and records used by the licensee to identify potential PI occurrences were also reviewed. The inspectors verified the accuracy of the PI for ERO DEP through review of a sample of drill and event records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO.
The inspectors verified the accuracy of the PI for ANS reliability through review of a sample of the licensees records of periodic system tests.
The inspection was conducted in accordance with NRC Inspection Procedure 71151, Performance Indicator Verification. The applicable planning standard 10 CFR 50.9 and NEI 99-02,Regulatory Assessment Performance Indicator Guidelines, Revisions 3 and 4, were used as reference criteria. This inspection activity represents three samples on an annual cycle.
The inspectors reviewed various documents which are listed in the Attachment to this report.
b. Findings
No findings of significance were identified.
4OA6 Meetings, including Exit
On August 18, 2006, the inspector presented the inspection results to Mr. T. Walt, Vice President, and other members of his staff who acknowledged the findings. The inspector stated that additional information may be requested relative to the URI discussed in Section 1EP4.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- C. Baucom, Licensing Supervisor
- B. Clark, Manager, Nuclear Assessment Section
- E. Kapopoulos, Plant General Manager
- J. Lucas, Manager, Support Services - Nuclear
- G. Ludlam, Manager, Training
- W. Noll, Director, Site Operations
- T. Tovar, Radiation Control Superintendent
- T. Walt, Vice President
- S. Wheeler, Supervisor, Emergency Preparedness
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
- 05000261/2006008-01 URI Blending of EAL Schemes.
(Section 1EP4)
Closed
None
Discussed
None