IR 05000335/1988031
| ML17222A673 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/28/1988 |
| From: | Kreh J, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17222A672 | List: |
| References | |
| 50-335-88-31, 50-389-88-31, NUDOCS 8901300305 | |
| Download: ML17222A673 (6) | |
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UNITEO STATES NUCLEAR REGUI ATORY COMMISSION
REGION II
101 MARIETTAST., N,W.
ATLANTA,GEORGIA 30323
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Report Nos.:
50-335/88-31 and 50-389/88-31 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-335 and 50-389 License Nos;:
OPR-67 and NPF-16 Facility Name:
St.
Lucie Plant, Units 1 and
t Inspection Conducted:
. December 5-.9, 1988 Inspector:
J.
L. Kreh
,i:. W.
H. RankiJI, Acting Section Chief Division of Radiation Safety and Safeguards Date Signed Date Signed C'-'UMMARY Scope:
This routine, unannounced inspection was conducted in the area of emergency preparedness, and included review of the following programmatic elements:
( 1) Emergency Plan and its implementing procedures; (2) emergency facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) training; and (5) independent reviews/audits.
Results:
In the areas inspected, one violation was identified involving failure to properly maintain controlled copies of the Emergency Plan Implementing Procedures ( see Paragraph 2).
The emergency preparedness program was determined overall to be well managed despite the temporary lack of a
full-time site Emergency Planning Coordinator.
Training of the emergency response organization was judged to be very effective.
The findings of this inspection indicated that the licensee was adequately prepared to respond to an emergency at the St.
Lucie Plant.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- G. Boissy, Plant Manager
'H. Buchanan, Health Physics Supervisor G. Casto, Emergency Planning Senior Analyst (Corporate)
"P. Fincher, Training Superintendent
"K. Harris, Site Vice President J. Maisler, Emergency Planning Manager (Corporate)
- H. Mercer, Health Physics Technical Supervisor
- D. Miller, Emergency Planning Analyst (Corporate)'R.
Parks, Project Manager
- M. Shepherd, Operations Training Program Supervisor
"R. Sipos, Services Manager R. Storke, Nuclear Plant Supervisor Other licensee employees contacted during this inspection included operators, security force members, technicians, and administrative personnel'uclear Regulatory Commission
- G: Paulk, Senior Resident Inspector
"M. Scott, Project Engineer, Region II
"Attended exit interview 2.
Emergency Plan and, Implementing Procedures (82701)
Pursuant to
CFR 50.47(b)( 16),
CFR 50.54(q),
Appendix E
to
CFR Part 50, and Section 7 of the licensee's Emergency Plan, this area was inspected to determine whether significant changes were made in the.
licensee's emergency preparedness program since the last unannounced inspection (December 1987),
and to assess the impact of any such changes on the overall state of emergency preparedness at the facility.
The inspector reviewed the licensee's program for making changes to the Emergency Plan and the Emergency Plan Implementing Procedures (EPIPs).
The inspector verified that changes to these documents were reviewed and approved by the Facility Review Group and licensee management.
A review of records showed that all such changes since December 1987 were submitted to the NRC within 30 days of the effective date, as required.
Copies of the EPIPs were examined in the Control Rooms and Technical Support Center (TSC) and found to contain some procedures which had been superseded by later revisions.
Specifically,,
controlled copy no. 81, located in the Health Physics (HP)
emergency equipment cabinet on the
periphery of the Unit 1 Control Room, contained Revision 38 (instead of Revision 39, dated December 26, 1988) of EPIP 3100023E and Revision
(instead of Revision 7,
dated October 15, 1988)
of EPIP 3100027E.
Controlled copy no.
6, which was the only controlled version of the EPIPs in the Unit 1 Control Room, contained the second of the two above-listed discrepancies.
Licensee representatives were informed that this situation represented a
failure to adequately maintain controlled copies of procedures as required by Technical Specification 6.8. l.e, which stated that "Written procedures shall be established, implemented and maintained covering.
.
.
Emergency Plan implementation."
The licensee determined that copies of the Emergency Plan and EPIPs in the Control -Rooms and TSC had been maintained personally by the site Emergency Planning Coordinator prior to his departure from that position about October 1,
1988.
Apparently, turnover of that responsibility was overlooked.
The licensee immediately updated the documents in question and made the Acting Emergency Planning Coordinator fully aware of his responsibility for maintaining designated copies of the Emergency Plan and EPIPs.
In consideration of the NRC's recently'evised Enforcement Policy, a Notice of Violation is not being issued in connection with the subject noncompliance because ( 1) the licensee initiated appropriate corrective action prior to the end of the inspection, and (2) the finding was determined to be an isolated Severity Level V violation.
This item (50-335, 389/88-31-01) is closed:
Through review of Emergency Plan/EPIP revisions and discussions with licensee representatives, the inspector concluded that no major programmatic changes were made in the subject area since the December 1987 inspection.
Prior to the current inspection, a
formal review of Revision 18 (dated March 9, 1988) to the Emergency Plan was completed in the Regional Office.
None of the changes in that revision were found to decrease the effectiveness of the Plan; however, several minor discrepancies were identified in a July 8, 1988, letter to the licensee.
Change No.
1 to Revision 18 was issued on July 26, 1988, to correct these problems.
One emergency declaration was made since the last inspection.
A telephone call to the local 911 emergency service alleged the presence of a bomb in the Unit 1 Control Room, resulting in a Notification of Unusual Event classification.
Reyiew of the licensee's documentation of this occurrence disclosed no problems with respect.to implementation of the Emergency Plan.
One violation was identified.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to
CFR 50.47(b)(8)
and (9),
CFR 50.54(q),
and Section IV.E of Appendix E to
CFR Part 50, this area was inspected to determine whether the licensee's emergency response facilities and other essential emergency 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 program.
The inspector toured the licensee's emergency response facilities (ERFs),
including the Control Rooms for both units, TSC, and Operations Support Center (OSC).
All facilities and emergency equipment'therein appeared to be maintained in an appropriate state of readiness.
According to observations by the inspector and statements by licensee representatives, no significant ERF changes were made since the last inspection.
The inspector selectively reviewed documentation of the monthly emergency equipment inventory and communications tests conducted from Oecember 1987 through November 1988, in accordance with procedure HP-90,
"Emergency Equipment."
The records indicated that problems and deficiencies identi.fied during the monthly audits were resolved expeditiously.
The inspector discussed the St.
Lucie Alert and Notification System (ANS)
with licensee representatives, and reviewed the biweekly siren patrol procedures.
The licensee's records indicated that availability of the ANS sirens, calculated for each month as a
simple average of the previous 12 months'ata, was 98+0.5%
throughout the period November 1987 to November 1988.
No violations or deviations were identified.
Organization and Management Control (82701)
Pursuant to
CFR 50.47(b)(1)
and (16)
and Section IV.A of Appendix E to
CFR Part 50, this area was inspected to determine the effects of any changes in the licensee's emergency response organization and/or
'management control systems on the emergency preparedness program and to
.verify that such changes were properly factored into the Emergency Plan and EPIPs.
The organization and management of the emergency preparedness program were reviewed and discussed with licensee representatives, with one significant change noted.
The position of site Emergency Planning Coordinator (EPC)
was assigned on October 1,
1988, as a temporary collateral. responsibility of the Health Physics Technical Supervisor
.
The individual who had filled the EPC role since February 1986 transferred to another position in the licensee's organization.
Licensee management representatives informed the inspector that they were endeavoring to find a
suitable replacement candidate at the earliest possible date.
According to licensee representatives, there were no significant changes in the organization and staffing of the offsite support agencies since the inspection of Oecember 1987.
Discussions with licensee representatives revealed that no program was in place to periodically demonstrate that the capability for emergency staff augmentation, as claimed in Table 2-2b of the Emergency Plan, actually
existed during nonregular working hours.
The licensee agreed to develop. a system whereby this capability would be verified on a regular basis.
Inspector Follow-up Item ( IFI) 50-335, 389/88-31-02:
Implementing a program for periodically testing the off-shift augmentation capability of the emergency response organization.
No violations or deviations were identified.
Training (82701)
Pursuant to
CFR 50.47(b)(2)
and ( 15),
Section IV.F of Appendix E to
CFR Part 50, and Section 7.2 of the licensee's Emergency Plan, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
The'nspector reviewed documentation of the emergency response training program, including training procedures and selected lesson plans, and interviewed members of the instructional staff.
Based on these reviews and interviews, the inspector determined that the licensee had established a formal emergency training program.
The inspector conducted a walk-through in the Control Room with a Nuclear Plant Supervisor (NPS) during his duty hours.
The NPS was given several hypothetical sets of emergency conditions and plant data and was asked in each case to talk through the response he would provide as Emergency Coordinator if such an emergency actually existed.
The individual exhibited exceptional familiarity with emergency procedures and equipment.
No significant problems were observed in the areas of emergency classification, protective action decision-making, and notification of offsite authorities.
No violations or deviations were identified.
6.
Independent Review/Audits (82701)
Pursuant to
CFR 50.47(b)(14)
and (16)
and
CFR 50.54(t), thi s area was inspected to determine whether the licensee had performed an independent review or audit of the emergency preparedness program, and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercises and drills.
Records of emergency preparedness program audits were reviewed.
The records showed that independent audits of the program were conducted by the plant Quality Assurance Oepartment.
These audits separately reviewed the Emergency Plan and EPIPs (Report No. QSL-OPS-88-605, dated July 20, 1988),
and the annual emergency response exercise (Report No. QSL-OPS-88-627, dated October 24, 1988).
The audits appeared to have been thorough, and each produced two significant findings for which
corrective actions were either planned>> or completed.
The audit records showed that state and local government interfaces with the licensee were evaluated.
Audit findings and recommendations were formally presented to plant and corporate management.
The licensee's program for follow-up action on audit, drill, and exercise findings was reviewed.
The licensee had established a
Regulatory Commitment Tracking System, also known as CTRAC, as a management tool in following up on actions taken in deficient areas.
The inspector noted that CTRAC listed
open items in the emergency preparedness area as of December, 9, 1988.
. No violations or deviations were identified.
7.
Exit Interview The inspection scope and results were summarized on December 9,
1988, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Although proprietary information was reviewed during this inspection, none is contained in this report.
Dissenting comments were not received from the licensee.
Item Number Descri tion 50-335, 389/88-31-01 50-335, 389/88-31-02 Violation:
Failure to properly maintain controlled copies of the Emergency Plan Implementing Procedures (Paragraph 2).
Inspector Follow-up Item:
Implementing a
program for regularly testing the off-hours augmentation capability of the emergency response organization (Paragraph 4).