IR 05000400/1988019
| ML18005A555 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 08/05/1988 |
| From: | Decker T, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A554 | List: |
| References | |
| 50-400-88-19, NUDOCS 8808230318 | |
| Download: ML18005A555 (12) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
~Up Q 8 1988 Report No.:
50-400/88-19 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris Inspection Conducted:
July 11-15, 1988 Inspector:
h.
oo en Approved by: gS~
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Dec er, Section Chief Division of Radiation Safety and Safeguards License Nos.:
NPF-63, Date Signed Date Signed SUMMARY Scope:
This routine, unannounced inspection was to assess the operational readiness of the site emergency preparedness program; and to determine if changes to the emergency preparedness program since the September 1987 inspection meet NRC requirements, commitments, and the affect of changes on the overall state of emergency preparedness.
In addition, the adequacy of licensee actions taken on previously identified NRC inspection findings were reviewed.
Results:
Within the areas inspected, no apparent programmatic breakdowns or major weaknesses were noted.
The licensee's emergency preparedness program appears to be maintained in a state of operational readiness.
Following the exit interview on July 15, 1988, the licensee conducted an internal audit of the Plant Emergency Procedures (PEPs)
distribution program, a violation was identified - failure to submit PEPs within 30 days of the approval date in accordance with 10 CFR 50.54(q),
Paragraph 3.
8808230318 880808 e
PDR ADQCK 05000400
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REPORT DETAILS Persons Contacted Licensee Employees Bailey, Shift Foreman Black, Jr., Corporate Manager - Emergency Preparedness Blocker, Engineering Technician Brooks, Shift Foreman Byrd, Communications Foreman Evans, Project Specialist Health Physics, Harris Energy and nvironmental Center Forehand, Director, Quality Assurance/Quality Control Garrou, Senior Specialist-Emergency Preparedness Gibson, Director, Program and Procedures Hinnant, Plant General Manager Hutchinson, Sub-Station Operator Indelicato, Project Specialist-Emergency Preparedness Keisler, Senior Specialist-Document Services Olexi k, Jr., Operations Supervisor Rausch, Senior Specialist-Technical Training Stafford, Specialist-Operator Training Stanley, Project Specialist-Training Tibbitts, Director, Regulatory Compliance Wallace, Senior Specialist-Regulatory Compliance Watson, Vice President Harris Project K.
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Nuclear Regulatory Commission
- G. Maxwell, Senior Resident Inspector
¹A. Cunningham, Senior Radiation Specialist, RII
- Attended exit interview
¹Participated in Conference Call on July 18, 1988
¹¹Participated in telephone exit interview on July 19, 1988 Other licensee employees contacted during this inspection included engineers, operators, security personnel and administrative personnel.
2.
Licensee Action On Previous Enforcement Matters 3.
This subject was not addressed in the inspection.
Emergency Plan And Implementing Procedures (82701)
Pursuant to
CFR 50.47(b) (16),
CFR 50.54(q),
and
CFR 50, Appendix E, this area was reviewed to determine whether changes were made to the program since the last routine inspection (September, 1987) and,.to
assess the impact of these changes on the overall state of emergency preparedness.
The inspector reviewed the licensee's program governing the review, approval and distribution of changes to the Plan and PEPs.
The inspector verified that changes to the Plan and Procedures were done in accordance with Section 5.0 of the Emergency Plan and Procedure RNP-002.
It was also noted that changes were being distributed to copy holders in a timely manner, as evidenced by the dates on the transmittal letters, and a
review of the dates reflected on the computerized printout distribution history for the Emergency Plan.
The licensee maintains a computerized distribution system for distributing changes to the various copy holders, with the exception of transmittals to the NRC (Document Control Desk and Regional Office) which are generated by Regulatory Compliance personnel assigned a control. copy of the Plan and Procedures.
A licensee contact demonstrated the effectiveness of the computerized distribution system by obtaining a distribution history printout for the most recent revision to the Emergency Plan.
The printout showed the following information:
document number, number of copies sent, date distributed, control copy number, transmittal number, revision number, and the acknowledgement or notification date.
The inspector reviewed documentation for the following selected Plan and Implementing Procedure changes to verify that submittals were made to the NRC within 30 days of the approval date:
PEP-001, Rev. 2, Approved 10/21/87, mailed to NRC 11/20/87 PEP-102, Rev. 5, Approved 12/08/87, mailed to NRC 12/23/87 PEP-104, Rev. 2, Approved Ol/18/88, mailed to NRC 02/03/88 PEP-203, Rev.
3, Approved 12/08/87, mailed to NRC 12/23/87 PEP-204, Rev.
6, Approved 01/15/88, mailed to NRC 02/03/88 PEP-212, Rev. 4, Approved 03/03/88, mailed to NRC 03/23/88 PEP-220, Rev. 4, Approved ll/19/87, mailed to NRC 12/09/87 PEP-223, Rev. 4, Approved ll/11/87, mailed to NRC ll/20/87 PEP-341, Rev. 4, Approved 11/19/87, mailed to NRC 12/09/87 PEP-381, Rev. 3, Approved 12/29/87, mailed to NRC Ol/19/88 Emergency Plan Rev.
10, Approved 5/28/87, mailed to NRC 06/ll/87 Emergency Plan Rev.
11, Approved 7/24/87, mailed to NRC 08/13/87 Emergency Plan Rev.
12, Approved 2/22/88, mailed to NRC 03/15/88 Emergency Plan Rev.
13, Approved 6/02/88, mailed to NRC 06/23/88 The inspector noted that the above-referenced submittals were all made within 30 days of the approval date.
However, on July 18, 1988, two members of the licensee's staff phoned to advise Region II that subsequent to the NRC exit (conducted July 15, 1988),
licensee personnel had discovered that several PEPs were not submitted to the NRC within 30 days of the approval date.
Consequently, a decision was made to conduct an internal audit of all procedural changes and submittals to the NRC (from September 1986 to present),
to determine if there were other examples where transmittals were not submitted within 30 days of the approval date.
According to licensee personnel, the audit disclosed that
PEPs had not been submitted in accordance with 10 CFR 50.54(q).
The licensee contact further stated the following:
A non-conformance report was issued by Regulatory Compliance on July 15, 1988.
Administrative corrective actions have been documented and implemented to preclude recurrence.
A letter is being drafted to the NRC detailing the finding, corrective action implementation, and includes the appropriate PEP changes.
On July 19, 1988, the inspector discussed in detail with the Senior Specialist, Emergency Preparedness, the above finding.
The inspector informed the licensee contact that based on a review of the audit details (as presented above)
performed on July 15, 1988, this matter was considered a Licensee Identified Violation, and will be tracked as an Inspector Followup Item (IFI) for review during a subsequent inspection.
The licensee contact acknowledged this finding and stated that corrective action to prevent recurrence had already been implemented.
IFI 50-400/88-19-01:
Licensee Identified Violation - failure to submit changes to the Plant Emergency Procedures within 30 days after the change is approved.
No viol ati ons or devi ati ons were identi fied.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Discussions were held with a
licensee representative concerning modifications to facilities, equipment, and instrumentation since the last inspection.
The inspector was informed that no changes had been made to any of the emergency facilities since the last routine inspection.
In addition, there were no major equipment purchases since the last inspection.
An inspection and operability check was performed on selected equipment and support items used for emergency response in the Control Room, Technical Support Center (TSC),
and Emergency Operations Facility (EOF).
The inspector conducted a communications check from the Control Room using the Emergency Notification System (NRC Operations Center)
and observed a
communications check of the Selective Signaling System in-the Control Room and TSC by personnel designated as Emergency Coranunicators.
No problems were noted with any of the communications equipment that was tested.
In assessing the operational status of the emergency facilities, the inspector verified that reference documents, protective equipment, and supplies were operational and inventoried on a periodic basis.
Emergency kits and/or cabinets from the Control Room, TSC, EOF, and Operational Support Center were inventoried and randomly selected equipment was checked for operability.
Selected equipment operated properly and displayed current calibration sticker By review of applicable procedures and documentation for the period of June 1987 to May 1988, the inspector determined that emergency equipment (e.g.
communication equipment and emergency kits) was being checked in accordance with procedures governing such tests (PEP-402, APT-0100, APT-0102, and PGO-041).
The inspector also verified that current copies of the Emergency Plan and Plant Emergency Procedures were available in the emergency response facilities (Control Room, TSC, and EOF).
No problems were noted.
The licensee's management control program for the Public Notification System (PNS)
was reviewed.
According to discussion with a member of the licensee's staff, the current system consisted of 79 sirens located inside the 10 mile EPZ, and tone alert radios which were distributed within the
mile radius of Harris.
The licensee provided siren test records for the period October 1987 to July 1988.
The records showed that silent tests, growl tests, and full-cycle tests were being conducted in accordance with NUREG-0654.
A Public Alerting System Siren Test and Inspection Form (Form 2000)
was used for documenting the test results and/or actions taken as a followup to siren problems.
During the review of siren test records, the inspector noted that periodically the documentation on Form 2000, in response to siren failures, did not include the corrective actions and the time and date of the successful retest.
The Nuclear Plant Public Alerting Systems Operation and Maintenance Procedure states that "anytime a siren or associated equipment is out of service, a Form 2000 is completed which details the following:
siren location, nature of failure, time and date of fai lure, the resulting corrective action, and the time and date of the successful retest."
This matter was discussed with a
licensee representative to review the inconsistency on the part of maintenance personnel in documenting the results of siren tests in accordance with the procedure governing such tests.
Just prior to the NRC exit, the personnel assigned the responsibility for verification of the system operability provided copies of the Operations and Maintenance Section Form 2000 documentation which appeared to include the details stated above, The inspector performed a very limited spot check of the aforementioned documentation.
A member of the licensee's staff was questioned regarding the inconsistency in documentation included on the Form 2000s transmitted to the Senior Specialist, Emergency Preparedness.
According to maintenance personnel, Form 2000s may have been transmitted to the Senior Specialist, Emergency Preparedness, prior to followup or corrective action input regarding the siren failure.
Consequently, once the sirens were restored to an operational status, maintenance personnel provided verbal notification to the plant emergency preparedness contact.
However, a
completed Form 2000 detailing the reason for siren failure and the corrective actions taken to restore the unit to service was not always done.
The licensee was informed that the procedure governing the testing requires that a
completed Form 2000 be distributed to the Senior Specialist, Emergency Preparedness.
The inspector indicated that this matter was considered an IFI for review during a subsequent inspectio IFI 50-400/88-19-02:
Verify that appropriate documentation for the Prompt Notification System testing is provided to the Senior Specialist Emergency Preparedness.
No violations or deviations were identified.
5.
Organization And Management Control (82701)
The inspector's discussion with licensee representatives disclosed that key administrative changes had been made to the plant emergency organization since the September 1987 inspection.
Personnel filling the Plant General Manager's Position (also serves as the Site Emergency Coordinator)
had been replaced on two different occasions since the last inspection.
The most recent assignment was effective July 9, 1988.
Training records for the individual most recently assigned to this position was reviewed, and the inspector noted that all training required for the Site Emergency Coordinator's role had been completed prior to the position assignment.
The individual previously assigned Site Emergency Coordinator responsibility had served as an alternate Site Emergency Coordinator in the emergency organization, and past duties assigned in the normal plant organization had included the position of Assistant Plant Manager.
Therefore, in both cases, there were no problems noted with training for the Site Emergency Coordinator's role.
Although key reassignments had been made, there were no key management positions to the emergency organization not being covered by an individual who was trained, and in some instances, the individual who was reassigned may have previously served as an alternate to the primary.
For example, the individual currently assigned as the Manager of Maintenance with responsibility in the emergency organization as the Emergency Repair Director had maintained the previous position of Electrical Maintenance Supervisor with responsibility as the alternate Emergency Repair Director.
Regarding changes to the offsite emergency organization, the inspector was informed that no changes had been made to the corporate organization nor key offsite support agencies.
A licensee representative further stated that no changes had been made in agreement letters with offsite support groups other than 10 year contractual agreements which had been executed with offsite fire and rescue groups.
No violations or deviations were identified.
6.
Training (82701)
Pursuant to
CFR 50.47(b)(15)
and
CFR Part 50, Appendix E,Section IV.F, this area was inspected to determine whether emergency response personnel understood their emergency response roles and could perform their assigned functions.
The inspector reviewed Section 5.2 of the Emergency Plan, PEP-403, and TI-302, for a description of the training program and training procedures.
In addition, selected lesson plans were reviewed and members of the training staff were interviewed.
Based on
'hese reviews and interviews, the inspector determined that the licensee had established a formal emergency training program.
In response to IE Information Notice No. 85-80, "Timely Declaration of an Emergency Class, Implementation of an Emergency Plan, and Emergency Notifications," the inspector interviewed two Auxiliary Operators who may be designated as communicators for the. Control Room, and two members of the Regulatory Compliance staff with responsibility as communicators in the TSC.
The inspector interviewed communicators regarding various communications systems available from the Control Room or TSC for making notifications, their responsibility as a
communicator, backup communications systems, etc.
No problems were noted.
The interviewees demonstrated familiarity with the communications emergency procedures and equipment, and no problems were observed in the areas of equipment use, message forms (initial and followup), or responsibility as communicators.
The inspector conducted walk-through evaluations with two Shift Foremen, who may be designated as Interim Site Emergency Coordinators, and one Control Room Operator who may be called upon to perform the initial dose projection from the Control Room.
During these walkthroughs, individuals were presented hypothetical emergency conditions and data and asked to respond as if an emergency actually existed.
Both Shift Foremen demonstrated familiarity with Plant Emergency Procedures, equipment, non-delegatable responsibilities, and emergency exposure limits.
One of the interviewees, when questioned regarding the time limit for completing notifications to State and local governments, indicated that notifications must be initiated within 15 minutes as opposed to completed within 15 minutes.
This matter was discussed between the inspector and the Senior Specialist, Emergency Preparedness and was identified as requiring clarification in that the notification completion time is to be within 15 minutes as opposed to initiating the notification within 15 minutes of event declaration.
No problems were noted with the results from the dose projections and/or protective action recommendations.
The licensee maintained a
system for tracking training known as the
"Nuclear Education Tracking System (NETS)."
According to training records, all training for a small sample of key members of the emergency organization were consistent with approved procedures.
It was noted that with the exception of dose projection and operations personnel, most other emergency response personnel were satisfying the annual training by reviewing the appropriate material and succ'essfully completing the examination.
Should personnel be unsuccessful in challenging the exam, formal classroom attendance followed by a
successful exam score was required.
The inspector reviewed training for the period April 1987 to June 1988.
No problems were noted.
No violations or deviations were identifie.
Independent Review/Audits (82701)
Pursuant to
CFR 50.47(b)(14)
and (16)
and
CFR 50.54(t), this area was inspected to determine whether the licensee had performed an independent review or audit of the emergency preparedness program.
Records of audits of the program were reviewed.
According to documentation provided to the inspector, independent audits of the program were conducted by the Corporate guality Assurance Department on the following dates:
September 21-25, 1987 (documented in Audit Report No. gAA/0022-87-06),
and February 8-12, 1988 (documented in Audit Report No. gAA/0022-88-01).
The aforementioned audits fulfilled the 12-month frequency requirement for such audits.
No nonconformances were identified during either audit.
During the September audit, four recommendations were presented to plant and corporate management for consideration.
A further review regarding the actions taken in response to those recommendations disclosed that all four items had been reviewed and resolved.
The licensee's program for followup action on audit, drill, and exercise findings was reviewed.
Licensee procedures required followup on deficient areas identified during audits, drills, and exercises.
The licensee had established a tracking system known as the "Corrective Action Program (CAP)" for use as a management tool in following up on actions taken in deficient areas.
The inspector reviewed a printout from the Emergency Preparedness Action Items list which is a part of the plant-wide tracking system
"CAP,"
and noted that items were prioritized and assigned to various departments or individuals with a tentative completion date.
No violations or deviations were identified.
8.
Action On Previous Inspection Findings (92701)
a ~
(Closed)
IFI 50-400/87-30-02:
Failure to remove or maintain uncontrolled procedures and reference materials in the TSC dose projection supply cabinet.
A review of the subject cabinet disclosed that all procedures and documents not included on the cabinet inventory list had been removed.
Further, all reference material was audited; and out-of-date material was removed, and non-controlled information was stamped
"For Information Only" then placed in a reference notebook stored elsewhere.
b.
(Closed)
IFI 50-400/87-30-03:
Review of proficiency of individuals performing assessment dose calculations.
Personnel assigned dose projection responsibility were provided sample problems, and instructions for completing problems, in addition to required attendance at a formal classroom training session involving dose projection.
As part of the 1988 requal training, personnel were required to complete three sample problems using the manual and computerized methodology prior to class attendanc C.
(Closed)
IFI 50-400/87-30-06:
Failure to promptly classify and provide offsite notifications during a Notification of Unusual Event.
The inspector reviewed event notification forms and emergency communications logs for three events declared as NOUE's since the last inspection.
With each event, the licensee appeared to be prompt in making the event classifications and offsite notifications.
d.
(Closed)
IFI 50-400/87-35-01:
Resolution of discrepancy between PEP-102 and PEP-381 concerning the criteria for evacuation of non-essential plant personnel.
The inspector was provided for review a
copy of PEP-381 and PEP-102.
It was noted that Revision 3 to PEP-381 (dated December 12, 1987) included a change to Section 5.0 to reflect identical protective action levels for personnel exposure as shown in PEP-102 (Rev. 5, dated December 8, 1987, Section 9.4.3.b).
e.
(Closed) IFI 50-400/87-35-02:
Ensure that all first aid team members are trained as required (followup on licensee commitments).
The inspector reviewed training records for 12 of the 24 individuals assigned to the first aid team.
Of the randomly chosen names, all training was current and in accordance with procedures governing training.
9.
Exit Interview The inspection scope and findings were summarized on July 15, 1988, with those persons indicated in Paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection finding listed below.
On July 18, 1988, as stated in Paragraph 3 above, licensee representatives telephoned Region II Emergency Preparedness personnel to discuss the discovery of Plant Emergency Procedures which had not been submitted to NRC within 30 days of the approval date.
On July 19, 1988, additional details were obtained from a licensee representative regarding the failure to submit changes in accordance with 10 CFR 50.54(q)
and the actions taken to prevent recurrence.
The inspector informed the Senior Specialist, Emergency Preparedness that, based on a review of the information provided subsequent to the inspection, the Licensee Identified Violation (discussed in Paragraph 3) will be tracked as an Inspector Followup Item.
The licensee contact acknowledged this item and advised that corrective actions had already been taken on this matter.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
Item Number 50-400/88-19-01 Descri tion and Reference IFI - Licensee Identified Violation for failure to submit changes to the Plant Emergency Procedures within 30 days after the change approva /88-19-02 IFI - Verify that appropriate documentation for the Prompt Notification System testing is provided to the Senior Specialist, Emergency Preparednes