IR 05000400/1987030
| ML18004B910 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/24/1987 |
| From: | Decker T, Tabaka A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B909 | List: |
| References | |
| 50-400-87-30, NUDOCS 8708310234 | |
| Download: ML18004B910 (13) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
ATLANTA,GEORGIA 30323 AIJRS b IM'f Report No.:
50-400/87-30 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602
'ocket No.:
50-400 Facility Name:
Shearon Harris License No.:
NPF-53 Inspection Conducted:
August 3-7, and 11, 1987 Inspector:
a a
a Approved by:
T.
R.
Dec er, Section ie Division of Radiation Safety and Safeguards ate igne te Signed SUMMARY Scope:
This routine, unannounced inspection was conducted to evaluate selected areas of the emergency preparedness program.
Results:
Within the areas inspected, no violations or deviations were identified.
8708310234 870825 PDR ADQCK 05000400
REPORT DETAILS Persons Contacted Licensee Employees
- J. Willis, Plant General Manager
- H. Bowles, Director, Onsite Nuclear Safety
- C. Gibson, Director, Plant Programs and Procedures
- D. Tibbitts, Director-; Regulatory Compliance
- J. Thompson, Operations Supervisor
- G. Forehand, Director, QA/QC
- J. Sipp, Manager, Environmental and Radiation Control
- R. Indelicato, Corporate Emergency Preparedness
- A. Garrou, Senior Specialist, Emergency Preparedness
- M. Wallace, Specialist, Regulatory Compliance
- C. McKenzie, Principal QA Engineer J. Blocker, Emergency Preparedness Technician H. Lippa, Chemistry Coordinator D. Elkins, Radiation Control Foreman K. Pace, Senior Reactor Operator D. Walker, Senior Reactor Operator E. Bean, Director, News Programs T. Dunn, Writer L. Ratliffe, Senior Specialist-Harris Energy and Environmental Center T. Neufang, Radiation Control Technician Other licensee employees contacted included engineers, technicians, operators, security office members and office personnel.
Nuclear Regulatory Commission
- G. Maxwell, Senior Resident Inspector S. Burris, Resident Inspector
- Attended exit interview 2.
Exit Interview (30703)
The inspection scope and findings were summarized on August 7, 1987, with those persons indicated in Paragraph I above.
The inspector described the areas inspected and discussed in detail the inspection findings.
The inspector identified two unresolved items* concerning the timeliness of emergency declaration and the status of a commitment to the NRC concerning TSC positive pressure.
On August 11, 1987, Mr. J.
L. Willis of the
~
'
unreso ve stem is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviatio licensees staff was notified that the unresolved item relating to emergency classification and declaration would be identified as a licensee identified violation.
Licensee representatives did not take exception to any of the findings presented during the exit.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
Unresolved Items One unresolved item was identified during the inspection and is discussed below.
During the June 1986 Emergency Preparedness Appraisal Followup Inspection, licensee representatives made a commitment to the NRC regarding a periodic maintenance program on the TSC door seals.
This commitment was made in response to concerns regarding the integrity of the TSC door seals due to frequent use of the access doors and the effect that the door seal adjustments had on the positive pressure in the facility.
During pre-operational testing of the ventilation system, startup engineers stated that the door seals had to be'djusted in order to maintain the required pressure.
Based on direct observation of system operation and the licensee's commitment to provide a periodic check on the door seals, Inspector Followup Item 50-400/85-46-02 (Verification of TSC positive pressure)
was closed.
The commitment was documented in NRC Inspection Report No. 50-400/86-45 as well as in an internal licensee memorandum to C. Gibson, dated June 19, 1986.
During the course of this inspection',
the inspector attempted to followup on the licensee's action on this commitment; however, the licensee was not able to confirm that such a
program had or had not been implemented.
Because individuals with the Technical Support group who are responsible for the system were not available, this item will be identified as an Unresolved Item pending licensee clarification.
Unresolved Item 50-400/87-30-01:
Evaluation of licensee action on an NRC commitment concerning a periodic check of TSC door seals.
Notification and Coomunication (82203)
Pursuant to
CFR 50.47(b)(5)
and (6);
CFR Part 50, Appendix E,Section IV.D; and Section 3.8 of the licensee's Emergency Plan, this area was examined.to
- determine whether the licensee was maintaining a
capability for notifying and communicating (in the event of an emergency)
among-its own personnel, offsite supporting agencies and authorities, and the population within the 10-mile EPZ.
The inspector reviewed the licensee's notification procedures.
The procedures were consistent with the emergency classification and EAL scheme used by the licensee.
The inspector determined that the procedures made provisions for message authenticatio The inspector determined by'eview of the Plant Emergency Procedures and the Corporate Emergency Plan Implementing procedures that adequate procedural means existed for alerting, notifying, and activating emergency response personnel.
The procedures specified when to notify and activate the onsite emergency organization, corporate support organization, and offsite agencies.
Emergency telephone numbers listed in the Plant General Order for emergency response support organizations were reviewed quarterly by the licensee to determine whether the listed numbers were current and correct.
The content of emergency messages was reviewed.
The message appeared to meet the guidance of NUREG-0654, Sections II.E.3 and II.E.4.
The message format and content was identical to that found in Annex F to the State Radiological Emergency Plan.
The licensee's management control program for the prompt notification system was reviewed.
According to licensee documentation and discussions with licensee representatives, the system consisted of 79 fixed sirens within the 10-mile EPZ and tone-alert radios for all residents within a 5-mile radius of the plant.
The system installed appeared consistent with the description contained in Section 4.5.3 of the Emergency Plan.
Maintenance of the system had been provided for by Corporate Communications.
The inspector reviewed the siren test records for the period December 1986 to July 1987.
The records showed that silent tests were conducted every two weeks and growl tests quarterly.
Two full cycle tests were performed in 1987 and February 28 and July 14.
The inspector also reviewed licensee documentation of overall system operability during the period March 1986 to February 1987.
For the year, operability was 96.9 percent with 3 months falling below 90 percent.
Communications equipment in the Control Room, Technical Support Center, and the Emergency Operations Facility was inspected.
Provisions existed for prompt communications among emergency response organizations and to emergency personnel.
The available communications in these facilities were consistent with the Emergency Plan and Implementing Procedures with one exception.
Attachment 3 to PEP-302,
"Communications Activities,"
still referred to the primary notification method to the State and local warning points as the Automatic Ringdown rather than the selective signaling system that is installed.
The licensee had identified this and was in the process of revising the procedure.
The inspector conducted operability checks on the Emergency Notification System and the Selective Signaling System.
No problems were observed.
The inspector reviewed licensee records for the period July 1986 to July 1987 which indicated that 'monthly communications tests were conducted a'
required by Section 5.3.1 of the Emergency Plan.
Redundancy of offsite and onsite coranunication links was also reviewed.
The inspector verified that the licensee had established diverse and redundant communication systems which made use of Public Address, VHF LLEA radio, 'Private Branch Exchange, Microwave System, commercial telephones,
sound powered telephones, various inter-facility ringdowns, selective signaling system, and the two NRC dedicated networks.
No violations or deviations were identified.
Changes to the Emergency Preparedness Program (82204)
Pursuant to
CFR 50.47(b)(16);
CFR 50.54(q);
and
CFR Part 50, Appendix E, Sections IV and V; this area was reviewed to determine whether changes were made to the program since receiving an operating license in January 1987, and to note how these changes affected the overall state of emergency preparedness.
The inspector discussed the licensee's program for making changes to the Emergency Plan and'mplementing Procedures.
The inspector reviewed Section 5. 1.2 of the Emergency Plan, Administrative Procedure AP-006,
"Procedure Review and Approval,"
and PEP-001,
"Administration of Plant Emergency Procedures,"
which govern the review and approval of changes to the Plan and procedures.
The inspector verified that changes to the Plan and procedures were reviewed by management as required.
In addition to routine revisions to the Plan and Implementing Procedures, the licensee had made one temporary change to PEP-101, dated March 23, 1987.
The change was made in accordance with Administrative Procedure-007,
"Temporary and Advance Changes to Plant Procedures,"
and an advance change was made within the twenty-one days as required.
Since January 1987 several revisions were made to both the Emergency Plan and Implementing Procedures.
Revision 10 and Revision 11 of the Emergency Plan (dated May 28, 1987, and July 29, 1987)
had not yet been reviewed and approved by the NRC.
Discussions concerning the effect of these changes on the emergency preparedness program will be forwarded to the licensee at a later date.
The inspector did review, however, the numerous changes made to the Implementing Procedures which had not been evaluated by the NRC.
No changes to these documents were'identified which would degrade the Plan's effectiveness.
In addition, it was noted that the changes to both the Plan and Procedures made since January 1987 were submitted to the NRC within 30 days of the effective date as required.
The inspector reviewed licensee documentation to determine tha't the licensee had performed an annual review of the Emergency Plan.
The records indicated that the Plant Nuclear Safety Committee (PNSC)
had performed the last such review in May 1987.
Although the PNSC minutes for May 1986 did not explicitly show that the annual review was performed, they did show that Revision 7 to the Plan was approved.
Since this time the licensee had implemented a
PNSC meeting checklist to ensure that the annual review was documented.
This documentation was available for the 1987 review.
The inspector reviewed the licensee's program for distribution of changes to the Emergency Plan and Implementing Procedures.
Document Control
records for the period January 1987 to present showed that appropriate personnel and organizations were. sent copies of the Plan and Procedures.
In addition, the inspector reviewed several controlled and select copies of the Plan and Procedures and found them to be current.
Although no controlled or select copies of Plan and Procedures were found to be out-of-date, the inspector did observe that old, non-controlled emergency procedures were present in the TSC dose projection equipment cabinet and were available for use by emergency response personnel.
The procedures (PEP-341 and 343) were improperly contained in a reference notebook with various other documents and procedures whose validity was also questionable.
The licensee did remove the documents from the cabinet during the course of the inspection; however, discussions were continuing on what course of action was going to be taken concerning the maintenance of such reference documents in this area.
Inspector Followup Item 50-400/87-30-02:
Failure to remove or maintain uncontrolled procedures and reference material in the TSC dose projection supply cabinet.
Discussion with licensee representative indicated that no significant modifications to facilities, equipment, or instrumentation were made since this area was last reviewed in February 1987 during the full scale exercise.
The organization and management of the emergency preparedness program were reviewed.
Recent changes in the site emergency preparedness organization included the departure of all contractors assisting the plant staff, and the replacement of the emergency preparedness technician.
In general, these personnel shifts.should not have any adverse affect on the program in that contracted personnel were primarily used for program and procedure development during the pre-licensing process.
Organization and personnel changes for the Corporate staff were discussed and documented in NRC Inspection Report No. 50-325, 324/87-23 for your Brunswick facility.
The inspector's discussion with licensee representatives also disclosed that several changes had taken place in the offsite emergency organization.
These included:
(1)
a new Wake County Emergency 'Preparedness Coordinator appointed in late 1986; and (2) the replacement of Apex Volunteer Fire Department as the primary fire support group for the site.,
(Fuqua-Varina is now the primary with Holly Springs Volunteer Fire Department as a
back-up).
In addition to organizational changes, the inspector also discussed recent changes in responsibility for the emergency preparedness program.
Although no significant changes were made, one item is of note.
Recently the Emergency Operations Facility was turned over from the Corporate to the Plant staff.
This includes maintenance of equipment, management of the facility, and eventually an increased percentage of Plant personnel manning the response functions during EOF activation.
Formal documentation was available outlining the turnover, and designating these responsibility specifically.
The overall effect of this turnover will be observed during future inspection No violations or deviations were identified.
Shift Staffing and Augmentation
{82205)
Pursuant to
CFR 50.47(b)(2)
and
CFR Part 50, Appendix E, Sections IV.A and IV.C, this area was inspected to determine whether shift staffing for emergency was adequate in both numbers and in functional capability, and whether administrative and physical means were available and maintained to augment the emergency organization in a timely manner.-
The inspector reviewed the shift staffing levels and functional capabilities for the emergency response organization.
The commitments made in Table 2.2-1 of the licensee's Emergency Plan were consistent with the guidance of Table B-1 of NUREG-0654.
The inspector verified that backshift staffing was adequate'o assure minimum required staffing levels.
Specifically, during the midnight shift on August 3-4, 1987, security accountability records showed that the backshift staff was adequate to support an emergency and met the minimum goals for both numbers and functional capability.
The licensee had established an "on-call" system to assure that essential off-shift personnel were available if needed.
This system made use of pagers for key emergency organization personnel which included individuals for the positions of Site Emergency Coordinator, TSC Management, Team Leaders, and key corporate responders.
Call-in of individual emergency team members was achieved through maintained departmental call-outs.
The call-in procedure, PEP-321,
"Notification of SHNPP Emergency Response Personnel,"
appeared to be effective in meeting the 'augmentation goals.
The inspector discussed staff augmentation times with licensee representatives.
Licensee documentation indicated that on May 21, )986, an unannounced drill was conducted to verify that augmentation times could be met.
The results indicated that response times were consistent with the goals of Table 2.2-1.
In addition, as part of the Saturday, February 28, 1987, annual exercise, the licensee adequately performed off-normal staff
, augmentation as documented in NRC Inspection Report No. 50-400/87-11.
No violations or deviations were identified.
,
Dose Calculation and Assessment (82207)
Pursuant to
CFR 50.47(b){9), this area was inspected to determine whether there was an adequate method for assessing the consequences of an actual or potential radiological release.
r The inspector reviewed the following dose assessment procedures:
PEP-104, Protective Action Recommendations PEP-341, Manual Dose Calculation PEP-343, Automation of Dose Projection - IBM P The procedures had provisions for calculating doses for ground releases, monitored and unmonitored pathways such as containment leakage, steam releases, the plant stack, and building vents.
The procedures called for verification of dose projection through environmental monitoring and for timely incorporation of dose assessment results into the offsite protective action decision-making process.
The inspector discussed the dose projection models used by the licensee and the State of North Carolina with representatives of the Harris Energy and Environmental Center.
These discussions indicated that an internal verification of the CPSL and Sta'te models had been performed.
Some differences between the models were identified.
In general, the most significant difference being in sigma-Z beyond 1000 meters.
With this exception, the two models compared within a few percent for the test cases examined.
The licensee was continuing to formulate its assessment of the models with formalization of conversion factors (for standard validation problems) in the near future.
An inspection and operability check was made on selected equipment and support items used for dose assessment at the Control Room and Technical Support Center.
No problems were observed.
The inspector requested and observed dose assessment walk-throughs by selected licensee personnel.
These individuals included two Senior Reactor Operators who are responsible for providing initial dose projections and a Radiation Control Technician designated as an alternate Dose Assessment Team member in the Technical Support Center.
In general, these individuals were familiar with the procedures to be implemented and the basic calculations to be performed; however, the proficiency was minimal.
Although familiarity was demonstrated; calculations were typically slow, and two of the three individuals evaluated calculated incorrect doses using the manual method.,
These errors were attributable to mathematical error and incorrect extraction from the X/g table.
In a telephone conversation on August 11, 1987, between Mr. Douglas Collins of the NRC and Mr. James Willis of Shearon Harris, the licensee agreed to evaluate the dose assessment area for improvement.
Inspector Followup Item 50-400/87-30-03:
Review proficiency of individuals performing dose assessment calculations.
The inspector reviewed the backshift availability of personnel qualified to make dose calculations.
As stated earlier, Control Room operators are responsible for initial dose assessment; therefore, such personnel are available onshift at all times.
The inspector conducted a comparison between the licensee's computerized dose assessment model and the NRC Interactive Rapid Dose Assessment Model ( IRDAM).
.Whole body and thyroid dose comparisons were performed for both gross and isotopic releases.
Typically, the doses differed by a factor of two to three.
The licensee had also performed a comparison for IRDAM
similar to that discussed previously for the State.
Specific areas of differences had been identified and documented.
No violations or deviations were identified.
Public Information Pursuant to
CFR 50.47(b)(7)
and
CFR Part 50, Appendix E,Section IV.D.2, this area was inspected to determine whether basic emergency planning information was disseminated to the public in the plume-exposure-pathway emergency planning zone (EPZ)
on an annual basis.
The licensee had developed an emergency response information brochure for use by the public residing in or frequenting the 10-mile emergency planning zone (EPZ).
This information was disseminated in the form of a calendar.
Section 5.2.5 of the Emergency Plan requi red a coordinated review and annual update of the public information calendar.
Informal documentation indicated that the 1987 calendar had been coordinated with the State and that comments had been solicited from all parties for the 1988 brochure.
The inspector evaluated the current calendar and verified that it included the information specified by NUREG-0654,Section II.G.
According to licensee representatives and Section 5.2.5 of the Emergency Plan, several means are used to inform the transient population of appropriate emergency response measures.
These methods included:
posted notices at public areas; information decals on telephone booths; distribution of the, calendars to motels (one within the EPZ)
and commercial establishments; and distribution of calendars to fire, police, libraries, and local CP&L offices.
The inspector observed the placement of several information decals on public telephones as well as the permanent information signs.
One item should be noted.
The inspector visited the Holleman's Crossing boat ramp and observed the information sign to be missing.
Discussions with licensee representative indicated that the sign had been missing since sometime prior to July 14, 1987; however, this information had not been related to plant personnel so that it could be replaced.
The licensee stated the sign would be replaced.
Inspector Followup Item 50-400/87-30-04:
Replacement of the public informat'ion sign for transients at Holleman's Crossing.
A review of licensee documentation that the calendar was updated and distributed (September 1985 and September 1986) to residents within the 10-mile EPZ.
In 1986 the distribution was accomplished by "Program Outreach" where residents were personally visited by CP8L representatives.
Approximately 97K of the 10-mile EPZ were contacted; and those who were not contacted by this means were given the calendars by mail.
Licensee documentation also showed that area business and industry were also provided calendars.
The public information calendar provided several points of contact for obtaining additional information.
The contacts were the vari'ous county
4'
Emergency Management Agencies, the State of North Carolina, and the Harris Visitor's Center.
In addition to the required information calendar, licensee representatives indicated that the on-going public information program included the following:
an annual media education day last held on February 27, 1987; distribution of special emergency information brochures to school children; periodic newsletters to CPSL consumers; numerous speaking engagements to civic organizations; and the formulation of topical brochures on such subjects as Chernobyl.
Based on a
review of the Emergency Plan and interviews with licensee personnel, the inspector determined that the licensee's public information program met the applicable regulatory requirements.
No violations or deviations were identified.
Followup on licensee Events (93700)
The inspector reviewed licensee documentation of actual events which had occurred at the facility since November 1986.
In general, for the thirteen Notifications of Unusual Events reviewed it appeared the events were properly classified and the required notifications to offsite organizations were made in a timely manner; however, two items of concern are noted.
For three of the twelve declared events, it was not evident that PEP-321,
"Notification of SHNPP Emergency Response Personnel,"
was properly implemented.
No documentation was available in the incident records to indicate that all the required notifications were made.
Although some contacts were documented in the Shift Log, all those required were not included.
It was not apparent whether this was a failure to document or to perform these notifications in accordance with the procedure.
Inspector Followup Item 50-400/87-30-05:
Lack of documentation supporting the implementation of PEP-321.
On February 10, 1987, the licensee declared a Notification of Unusual Event based on plant shutdown as a result of exceeding a Technical Specification Limiting Condition of Operation.
Examination of the event records by the inspector revealed that classification of the incident did not occur until 25 minutes after exceeding the EAL (51 minutes after entrance into the Technical Specification Action Statement),
and offsite notifications were not initiated for 36 minutes after the EAL was exceeded (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after entrance into the Action Statement).
This failure to promptly classify and provide offsite notifications was identified to the licensee as an unresolved item with the potential for being a violation.
However, after review of the licensee's Plant Incident Summary, discussion with Regional staff, and the implementation of corrective action by the licensee, this failure to implement the Emergency Plan was identified as a
Licensee Identified Violation.
Because prompt classification and offsite
notification can be important in the protection of the public health and safety, prompt implementation of the Emergency Plan is critical.
The adequacy of the implemented corrective actions to preclude recurrence will be evaluated during future inspections.
Licensee Identified Violation 50-400/87-30-06:
Failure to promptly classify and provide offsite notifications during a Notification.of Unusual Event.
10.
Inspector Followup (92701)
a ~
(Closed)
Inspector Followup Item 50-400/86-45-02:
Completion of alarm audibility testing in high noise areas.
As documented in NRC Inspection Report 50-400/86-45 the licensee had completed PA testing for the Control Block during February/March 1986.
The inspector reviewed pre-operational Test Procedure 81-6036-P-02 which indicated that successful completion of the remaining PA units was completed by July 1986.
The areas reviewed included Security Building and Yard areas, areas D8E (Service Building, Administration Building, Cooling Tower, etc.),
and the Diesel Generator Building (during operation of the diesels).
Problems were noted and subsequent maintenance was documented.
It should be noted that several exterior areas of the site remain isolated from the PA/alarm system; however, the licensee had administrative controls in place to alert personnel in these areas if necessary (Security Procedure-015,
"Emergency Plan Support" ).
b.
(Closed)
Offsite Medical Services.
The inspector discussed medical arrangements for the treatment of contaminated/overexposed members of the public.
Representatives indicated that Wake County Hospital was designated as the primary facility for the public while Rex hospital was the primary for site employees.
At the time of the inspection, the State of North Carolina was in the process of formulating an agreement with Wake County.
Completion is expected soon.