IR 05000335/1995003
| ML17228B074 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 03/13/1995 |
| From: | Barr K, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17228B073 | List: |
| References | |
| 50-335-95-03, 50-335-95-3, 50-389-95-03, 50-389-95-3, NUDOCS 9503270103 | |
| Download: ML17228B074 (14) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 303234199 March 16, 1995 50-335/95-03 and 50-389/95-03 Licensee:
Florida Power and Light Company 9250 West Flagler Street Miami, FL 33102 Docket Nos.:
50-335 and 50-389 Facility Name:
St.
Lucie Nuclear Plant Inspection Conduc
February 13-17, 1995 License Nos.:
J.
L. Kreh, adiation Specialist
. Approve by:
K.
P.
arr, Emergency Preparedness Section Radiological Protection and Emergency Preparedness Division of Radiation Safety and Safeguards SUMMARY Date Signed f3 Date Signed Branch Scope:
This routine, announced inspection was conducted to assess the operational readiness of the site emergency preparedness program through selective review (with an emphasis on changes since the last such inspection) of the following programmatic areas:
(1) Radiological Emergency Plan and associated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3) organization and management control systems; (4) training; (5) independent and internal audits and reviews, and (6) effectiveness of controls in identifying, resolving, and preventing problems.
Results:
In the areas inspected, no violations or deviations were identified.
In general, the emergency preparedness program was found to be very well managed and implemented.
Two improvement items were identified:
weaknesses in the process for notifying the State of Florida within 15 minutes of an emergency declaration (Paragraph 5),
and discrepancies in equipment and supplies located in emergency response facilities (Paragraph 3).
9503270103 950316 PDR ADOCK 05000335 GI PDR
REPORT DETAILS Persons Contacted Licensee Employees
- C. Burton, Plant General Manager
- R. Dawson, Licensing Manager
- J. Dyer, guality Control Supervisor
- K. Heffelfinger, Protection Services Supervisor
- J. Holt, Licensing Engineer
- D. Mothena, Manager, Nuclear Emergency Preparedness (Corporate)
S.
Nye, Licensed Operator Requalification Training Instructor J. Revell, Emergency Preparedness Coordinator
- L. Rich, Operations Requalification Training Supervisor
". R. Walker (Richard),
Emergency Preparedness Coordinator R. Walker. (Roger),
Licensed Operator Requalification Training Instructor J. -'Walls, guality Assurance Auditor
- D. Whitwell, Emergency Preparedness Specialist (Corporate)
- C. Wood, Operations Supervisor k'ther licensee employees contacted during this inspection included operators, engineers, security force members, and administrative personnel.
. Nuclear Regulatory Commission
- H. Hiller, Resident Inspector
- R. Prevatte, Senior Resident Inspector
- Attended exit interview on February 17, 1995 An index of abbreviations used throughout this report will be found in the last paragraph.
Emergency Plan and Implementing Procedures (82701)
The Radiological Emergency Plan and Implementing Procedures were inspected with a focus upon the adequacy and acceptability of significant changes which were made in the licensee's emergency preparedness program since July 1992, when the last such inspection of this area was performed.
The inspection also evaluated whether the licensee's actions in response to actual emergencies were in accordance with the REP and EPIPs.
The inspector reviewed this area of the licensee's emergency preparedness program relative to the following requirements:
(a)
CFR 50.54(q),
which stipulates that changes to an emergency plan may be made without prior NRC approval if regulatory planning standards continue to be met and if the changes do not'decrease the effectiveness of the plan; (b)Section IV.B of Appendix E to
CFR Part 50, which specifies that the licensee's EALs shall be reviewed and agreed on with State and local governmental authorities prior to implementation and on an annual basis; (c)Section V of Appendix E to
CFR Part 50, which states that changes to the emergency
plan or implementing procedures shall be submitted to NRC within 30 days of such changes; (d) Section 3 of the licensee's REP, which delineated emergency classification criteria and required actions in response to an emergency declaration; and (e) Section 7.3. 1 of the REP, which described the processes for developing, approving, and distributing changes to the REP and the EPIPs.
The inspector reviewed the licensee's system for making changes to the REP and the EPIPs.
Through selective review of applicable documents, the inspector confirmed that licensee management approved revisions to the REP and EPIPs as required.
Selected copies of the REP and EPIPs which were available for use at the Control Room, TSC, OSC, and EOF were checked and found to be current revisions.
The inspector reviewed all licensee records regarding the transmittal of EPIP revisions to the NRC between January 1,
1993 and the date of this inspection.
The records verified that each of the 72 revisions made to
'he EPIPs during that period had been transmitted to the NRC within 30 days of the changes, as required, with three apparent exceptions.
A letter to the NRC dated June 6,
1994 transmitted a group of three revised EPIPs:
3100021E, '"Duties and Responsibilities of the Emergency Coordinator," Revision 33, approved 4/19/94; HP-90,
"Emergency Equipment," Revision 24, approved 4/19/94; and HP-202,
"Environmental Honitoring During Emergencies,"
Revision 18, approved 4/29/94.
These EPIP revisions were transmitted to the NRC more than 30 days after the changes were approved by licensee management (namely, 48, 48, and 38 days, respectively).
Self-identification of this apparent discrepancy by the emergency preparedness staff in June 1994 led to the generation of a Problem Report-entitled,
"Failure to Process a Procedure Change to EPIP 3100021E Within a 30 Day Time Period."
The root cause of this event was determined by the licensee to be a lack of pertinent knowledge by Information Services personnel of the specific commitment to word-process and issue EPIP changes within 30 days of approval.
This situation apparently had not arisen before because Information Services had previously been able to consistently process and issue EPIP changes (in spite of the routine-priority status of the work) within a few days after approval by plant management.
The licensee's position, as discussed with the inspector, was that the EPIPs are not considered
"changed" until they can be used by a member of the plant staff.
Until that point, they are approved for use but not implemented.
The inspector noted that the procedures in question were transmitted to the NRC within 10 days of issuance to the plant staff.
The licensee's corrective action involved addition of the EPIPs to an Information Services database which will provide for priority processing of revisions.
Since the previously referenced June 1992 inspection, the NRC has formally reviewed and approved five revisions (Revisions 22 through 26)
of the REP.
The version of the Plan in effect at the time of the current inspection was Revision 27, dated November 1,
1994.
This revision has been formally submitted to the NRC, but not yet reviewe Changes made since July 1992 to the REP and EPIPs were discussed with the Emergency Preparedness Coordinator.
The major modifications were determined to be in the following areas:
Numerous changes were necessary to implement the modified Federal guidance promulgated in EPA 400-R-92-001,
"Manual of Protective Action Guides and Protective Actions for Nuclear Incidents,"
and regulatory changes in 10 CFR Part 20.
The scheme for formulating PARs for the public was revised to eliminate the need to evaluate containment status.
The focus of the PAR development process was more properly placed on evaluation of core damage.
The new scheme also eliminated the need to consider whether a puff release was occurring or anticipated.
Using draft NUMARC guidance, the licensee developed shutdown EALs with applicability to Operating Modes 5 and 6.
Also, limited mode applicability was added to certain EALs in the event category of
"Abnormal Primary Leak Rate."
The licensee also adopted the provisions of an NRC Branch Position Paper (dated July 11, 1994) which promulgated the acceptabil,ity of certain deviations from the archetypal NUREG-0654 example initiating conditions.
This change resulted in the elimination of several EALs from the licensee's classification procedure.
Review of the Plan and EPIPs confirmed that the changes described above were incorporated into the EPIPs.
The last two of the four modifications listed above were contained in REP Revision 27, not yet formally reviewed by the NRC.
The inspector verified that current letters of agreement existed between the licensee and the 19 offsite support organizations listed in Appendix B to the REP.
Also verified through documental examination was the licensee's conduct of the required annual review of EALs with State and local governmental authorities for both 1993 and 1994.
These reviews were accomplished by means of letters, sent to the four cognizant agencies, in which the licensee solicited evaluation and comments regarding the EALs (a reply was requested of those agencies only if EAL concerns arose).
For both reviews, no dissenting observations were received from those agencies, according to the licensee representative.
Between the July 1992 inspection and the ending date of the current inspection, two emergency declarations were made by the licensee, both at the NOUE level.
These emergency declarations were as follows:
August 23, 1992, based on issuance at 7:00 a.m. of a Hurricane Warning for south Florida, including the location of the St.
Lucie Plant.
The declaration was made at 7: 15 a.m. that day and terminated at 9:20 a.m, the following day, after Hurricane Andrew had passed over the State.
A postevent review identified a need
to clarify the EALs associated with emergency classifications higher than NOUE for a hurricane.
The inspector noted that appropriate revisions were subsequently made.
Hay 30, 1993, because of initiation of 'a Technical Specification-required shutdown resulting from an unlatched Control Element Assembly which could not be raised from the bottom of the core during routine start-up physics testing.
The declaration was made at 10:49 a.m.
and terminated at 10:58 a.m.
when Hot Standby was reached (this evolution involved only a transition from Node 2 to Node 3).
No significant problems were identified through the licensee's review of this event.
The inspector's examination of licensee documentation of the events discussed above concluded that each was correctly classified based on the EALs, and that notifications to the State were made in accordance with applicable requirements.
The inspector's assessment of this program area concluded that changes to the REP and EPIPs since July 1992 were appropriate and acceptable (excluding changes made in Revision 27, which has not yet been formally reviewed by the NRC),
and that the licensee's actions in response to actual emergencies were fully in accordance with the REP and EPIPs.
No violations or deviations were identified.
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 program.
The inspector reviewed this area of the licensee's emergency preparedness program relative to the following REP requirements:
(a) Section 2.4, which described the licensee's ERFs and their functional capabilities; (b) Section 4.6, which described emergency communications systems; and (c) Sections 7. 1 and 7.4, which delineated the testing and maintenance program for emergency facilities and equipment.
The inspector toured the Control Rooms, TSC, OSC, and EOF.
Selective examination of equipment, instrumentation, and supplies therein indicated that a satisfactory state of operational readiness was being maintained for these ERFs, Only minor changes and refinements had been made in the ERFs since the July 1992,inspection.
Selected communications equipment was checked and found to be functional.
Radiological kits were examined and found to be properly maintained, with survey instruments, air-sampling equipment, and self-reading pocket dosimeters available as specified and in conformance with calibration requirements.
However, several minor discrepancies of an administrative nature were identified during the inspector's walkdown of the ERFs.
Contained in the TSC document cabinet (which was secured with a padlock)
was a noninventoried volume of the EPIPs which was labeled as
"Copy 10" on the spine and "Controlled Copy 37" on the cover sheet.
This volume
appeared to have been last updated in Harch 1994 (numerous EPIP revisions were issued since that date).
The Emergency Preparedness Coordinator's immediate corrective action wa's to remove the noninventoried book for disposal.
It was also noted that five complete and current copies of the EPIPs were available in the TSC document cabinet, as specified by the inventory. list.
At the OSC, the inspector found an orange soft-cover manual entitled,
"FPL Interoffice Telephone Directory", dated February 1987.
This noninventoried item was also removed for disposal by the Emergency Preparedness Coordinator.
Some components in the OSC equipment cabinets were difficult to locate (e.g.,
silver zeolite air-sampling cartridges),
with informal shelf labels not helpful because they were mostly inaccurate.
The discrepancies cited above suggested a need for improvements and possible management oversight of this area.
The licensee initiated an Action Report (identified as STAR No. 950171) to ensure that appropriate corrections are implemented, The inspector reviewed commitments and documentation related to the licensee-maintained Alert and Notification System.
The ANS for the St. Lucie Plant consisted of 85 electronic sirens with public-address capability.
The program of routine quarterly maintenance included verification of both airhorn and voice sound production (at less than full volume).
The annual full-cycle ANS test verified both siren and public-address functions.
An upgrade of the siren electronic components to improve reliability was completed in summer 1994, according to a, licensee representative.
Licensee data indicated that ANS availability during the period 1992-1994 was consistently 97-99 percent as calculated on a 12-month rolling average.
The inspector selectively reviewed completed documentation of facility/equipment surveillances for the period January 1,
1993 through November 30, 1994 performed in accordance with procedure HP-90,
"Emergency Equipment".
Records indicated that these surveillances were performed at the required frequencies, and the completed procedural documentation indicated that identified problems were corrected expeditiously.
Based upon ERF walkdowns, review of changes to the EPIPs, inspection of completed surveillance procedures, and statements by licensee representatives, the inspector concluded that no degradation of capabilities with respect to the ERFs and their associated equipment had occurred since the NRC inspection of this program area in July 1992.
An area for improvement was detected, as discussed above, but no violations or deviations were identified.
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 on the emergency preparedness program, and to verify that any such changes were properly factored into the REP and EPIPs.
The inspector reviewed this area of the licensee's emergency preparedness program relative to
the following requirements:
(a) Section 2.2 of the REP, which defined the positions, minimum staffing, and functions of the ERO; and (b) Section 7.3 of the REP, which delineated the authority and responsibility for the emergency planning function.,
The organization and management of the emergency preparedness program were reviewed and discussed with licensee representatives.
A plant reorganization in November 1993 significantly affected the emergency planning function.
The EPC formerly reported to the Health Physics Supervisor through another level of management.
The emergency planning function was transferred to a new Protection Services Department, with the EPC reporting directly to the Protection Services Supervisor, who reported to the Services Manager.
This reorganization effectively removed one layer of management between the EPC and the Site Vice President.
This fact, combined with the statements from the EPC and the Protection Services Supervisor during discussions of this subject, strongly suggested that this recent reorganization would improve the
"visibility"of emergency preparedness at the St.
Lucie Plant.
In addition, as of January 1,
1995, a second EPC joined the staff, and the two EPCs have evenly divided the emergency planning responsibilities.
The inspector discussed the status of offsite interfaces with the Emergency Planning Manager, In Martin County, there was recently a
change in assignment of the position of Radiation Safety Officer (the licensee's working-level contact),
who reported to the Chief of the
'De+rtment of Public Safety.
There was also a recent change of assignment of the position of Director of the State of Florida's Division of Emergency Management.
The licensee representative stated that these changes had not adversely affected the interfaces with St.
Lucie County and the State of Florida in the area of emergency preparedness, and,that other offsite-agency interfaces continued to be maintained as amicable working relationsh'ips.
The inspector reviewed the licensee's management strategy for ensuring compliance with the REP requirements addressing the planning standard of
CFR 50.47(b)(2),
which specifies that "timely augmentation of response capabilities is available."
The applicable Emergency Plan requirements were contained in REP Table 2-2a, "Shift Staffing Augmentation and Emergency Capabilities," which delineated the ERO positions required to be filled within either 30 or 60 minutes.
A
"Note" in Table 2-2a stated,
"Augment staffing capabilities are routinely tested to ensure timely response is maintained with respect to the goals identified in NUREG-0654."
The procedural requirement that implemented this commitment was contained in EPIP 3100050E,
"Maintaining Emergency Preparedness
- Emergency Exercises, Drills, Tests, and Evaluations" (Appendix A, Checklist 2, Item 6).
In fulfillment of this commitment, the licensee conducted an annual, unannounced, off-hour augmentation drill involving notification of personnel and their responses to the automated calling/paging system (which included estimated travel times) to determine whether required ERO positions at the TSC, OSC, and EOF could be filled within the specified time regimes.
The licensee had actually conducted four augmentation drills during the
past year (on May 5, August 17, and December 14, 1994; and on January 5,
1995).
The December 14 drill was unsuccessful because of technical problems with the automated calling system.
A remedial drill on January 5 was successful and resolved the referenced technical problems.
The documented results of these drills indicated that the ERO could be augmented in a timely manner, and in accordance with the referenced REP commitments.
The inspector determined that the following NRC Information Notices applicable to emergency planning were received by the licensee and distributed to cognizant personnel, and that any corrective actions deemed appropriate by the licensee were completed or scheduled:
Revised Protective Action Guidance for Nuclear Incidents IN No. 92-32:
Problems Identified With Emergency Ventilation Systems for Near-Site (Within 10 Miles) Emergency Operations Facilities and Technical Support Centers'+
=
'
Implementation Date for the Revision to the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents IN No. 93-07:
Classification of Transportation Emergencies IN No. 93-47:
Unrecognized Loss of Control Room Annunciators IN No. 93-53:
Effect of Hurricane Andrew on Turkey Point Nuclear Generating Station and Lessons Learned IN No. 93-81:
Implementation of Engineering Expertise on Shift IN No. 93-94:
Unauthorized Forced Entry into the Protected Area at Three Mile Island Unit
on February 7,
1993 No violations or deviations were identified.
5.
Training (82701)
This area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
The inspector reviewed this area of the licensee's emergency preparedness program relative to the following REP requirements:
(a) Section 7. 1, which delineated the licensee's agenda of required exercises and drills; and (b) Section 7.2, which described the emergency response training program.
In an effort to gauge the effectiveness of the training program, the inspector observed a training drill conducted in the Control Room simulator on February 15.
This drill was a routine component of the Licensed Operator Requalification Training Program, and involved REP
implementation to the extent of appropriately classifying the off-normal condition and completing the State of Florida Notification Hessage Form.
The scenario for the observed training drill involved a steam generator tube rupture with a loss of offsite power.
The initial classification of the event was promptly and correctly determined to be Site Area Emergency.
Appropriate onsite protective actions were simulated to have been implemented.
However, the Nuclear Plant Supervisor, serving as EC, became too involved in operational particulars to adequately fulfillhis primary responsibility during the immediate period following an emergency declaration.
As a result, the EC finished the State notification message 27 minutes after the emergency declaration instead of within 15 minutes as required by the REP and the EPIPs.
In addition, there were several minor discrepancies in the completed message form.
Following the drill critique, a 30-minute interview with the simulator crew was conducted by the inspector in the areas of duties, responsibilities, and actions under emergency conditions; no further problems were disclosed during that interview.
On February 16, in an attempt to determine whether a generic problem
" "~;- existed with regard to the licensee's capability to promptly notify the State of an emergency declaration, the inspector observed another simulator training drill involving different personnel and a different scenario (steam generator tube rupture with a steam line break).
The.
t initial classification of the event was again promptly and correctly determined, this time at the NOUE level.
The EC almost immediately began completing the State notification message, but discontinued this effort when plant conditions seriously degraded about 7 minutes after the NOUE declaration.
By the time a Site Area Emergency was declared and the State message form was completed, 26 minutes had elapsed since the NOUE declaration.
As with the first drill, the licensee failed to notify the State within 15 minutes of an emergency declaration, although for somewhat differing reasons.
The inspector concluded that the licensee's training program may not be placing appropriate emphasis on the 15-minute notification requirement.
Following detailed discussions of this matter, the licensee decided to initiate an Action Report (STAR No. 950172) to ensure appropriate follow-up and corrective action for this issue.
Aside from the notification issue discussed above, the training activities observed by the inspector indicated that licensee. personnel were properly trained and understood what response actions were required in the event of an emergency.
No violations or deviations were identified.
6.
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 an annual review of the REP and the EPIPs.
The inspector reviewed this area of the licensee's
emergency preparedness program relative to the following requirements':
(a) Section 7.3.4 of the REP, which required an annual independent audit of the license's emergency preparedness program by the licensee's QA Department; and (b) Section 7.3. 1 of the REP, which required a
comprehensive annual internal review of the REP and EPIPs by the emergency preparedness staff.
In the period since the previously referenced July 1992 inspection, the licensee's QA organization conducted four,independent audits in 1993 and 1994.
The inspector reviewed detailed documentation associated with the following audits:
QAS-EMP-93-2, conducted by the corporate QA group from June 29 to August 5, 1993 QSL-OPS-93-08, conducted by the site QA group from March 17 to July 29, 1993 QAS-EHP-94-1, conducted by the corporate QA group from February
to March 3, 1994 QSL-OPS-94-06, conducted by the site QA group from March 8 to Hay 25, 1994 The audit checklists were detailed and thorough.
No significant negative findings were disclosed by these audits.
The inspector reviewed records of the annual internal reviews of the REP and EPIPs for 1993 and 1994, These were performed and documented in accordance with EPIP 3100050E,
"Maintaining Emergency Preparedness-Emergency Exercises, Drills, Tests, and Evaluations" (Appendix A, Checklist 5).
The reviews adequately assessed program accomplishments and needed corrective actions.
In each of these two years, the REP and most of the EPIPs were revised as a result of the review process.
No violations or deviations were identified.
Effectiveness of Licensee Controls (82701)
This area was inspected to assess the adequacy of the licensee's controls in identifying problems and in implementing appropriate corrective actions.
The inspector reviewed this area of the licensee's emergency preparedness program relative to the following requirements:
(a)Section IV.F.5 of Appendix E to 10 CFR Part 50, which specifies that weaknesses or deficiencies that are identified through training critiques shall be corrected; and (b) Section 7. 1.3 of the REP, which required the recommendation of corrective measures for all deficiencies identified during exercises and drills.
The inspector reviewed the STAR system, used universally at the station to develop corrective actions and to track open items.
The inspector selected two closed STAR items derived from drill critiques and reviewed
the details of the process from item origination to closure with the EPC.
The STAR system appeared to be effective as a management tool for ensuring the completion of corrective action for identified problems in emergency preparedness.
No violations or deviations were identified.
Licensee Action on Previous Inspection Findings (Closed)
IFI 50-335, 50-389/94-04-01:
Reviewing the definition of
"containment failure" as it relates to emergency classifications and PARs.
A revised PAR scheme (promulgated in Revision 26 of the REP and Revision 32 of EPIP 3100021E)
deleted (in favor of an alternate methodology)
the requirement to evaluate whether containment failure had occurred or was.imminent; therefore, the concern of this IFI was no longer applicable.
The EPC'tated that this change was developed from Federal guidance in EPA 400 and NUREG/BR-0150 (the NRC's Response Technical Manual),
and was previously reviewed and approved by the NRC's licensing process, Exit Interview The inspection scope and results were summarized on February 17, 1995 with those persons indicated in Paragraph 1.
The inspector described the areas assessed and discussed the inspection results in detail, including the two issues described in the "Results" section at the beginning of this report.
These two issues will be tracked and corrected through the licensee's STAR system.
No violations or deviations were identified, and no new items will be tracked by the NRC.
The inspector commended the licensee's proactive efforts in identifying and resolving the discrepancy associated with providing EPIPs to the NRC within 30 days'issenting 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:
~Te Number IFI 50-335, 389/94-04-01 Status Closed Descri tion and Reference Reviewing the definition of.
"containment failure" as it relates to emergency classifications and PARs (Paragraph 8).
Index of Abbreviations Used in This Report ANS CFR EAL EC Alert and Notification System Code of Federal Regulations Emergency Action Level Emergency Coordinator
EOF EPC EP IP ERF ERO FPL IN NOUE NRC NUMARC OSC PAR REP STAR TSC Emergency Operations Facility Emergency Preparedness Coordinator Emergency Plan Implementing Procedure Emergency Response Facility Emergency Response Organization Florida Power and Light Company'nformation Notice Notification of Unusual Event Nuclear Regulatory Commission Nuclear Management and Resources Council (now known as the Nuclear Energy Institute)
Operational Support Center Protective Action Recommendation Radiological Emergency Plan St.
Lucie Action Request Technical Support Center