IR 05000400/1989012
| ML18005A975 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/21/1989 |
| From: | Kreh J, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18005A974 | List: |
| References | |
| 50-400-89-12, NUDOCS 8907070029 | |
| Download: ML18005A975 (10) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JUH 3~ 1989 Report No.:
50-400/89-12 L'icensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris Nuclear Power Plant License No.:
NPF-.63 Inspection Con ucted:
May 22-26, 1 89 I
Inspector:
Kre Approved bye~
W..
an in; C ie Emergency Preparedness Section Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards C'4-2-i-te Date igne 4-~ -8 ate Signe SUMMARY Scope:
This routine, unannounced inspection was conducted to assess the operational readiness of the site emerqency prepar edness program, and included review of the following programmatic elements:
(1) Emergency Plan and associated implementing procedures; (2) emergency facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) training; and (5) independent reviews/audits.
Results:
The licensee's emergency preparedness program appeared to be well organized and effectively managed.
Emergency facilities and equipment were properly maintained.
The training program for emergency response personnel appeared to be effective.
One Inspector Follow-. up Item was identified and is discussed in Paragraph 2.
No violations or deviations were identified.
The findings of this inspection indicated that the licensee was adequately prepared to respond to an emergency at the Shearon Harris Plant.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees E. Brooks, Shift Foreman
- J. Collins, Manager, Operations
- G. Forehand, Director, Quality Assurance/Quality Control
- A. Garrou, Senior Specialist, Emergency Preparedness
- C. Gibson,.Director, Programs and Procedures
- R. Indelicato, Project Specialist, Emergency Preparedness
- T. Norton, Manager, Maintenance (representing Plant General Manager)
E. Schuler, Senior Control Operator
- J. Sipp, Manager, Environmental and Radiation Control
- N. Wallace, Senior Specialist, Regulatory Compliance Other licensee employees contacted during this inspection included operators, security force members, technicians, and administrative personnel.
NRC Resident Inspector
- M. Shannon
- 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 5.1 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 inspection in July 1988, to assess the impact. of any such changes on the overall state of emergency preparedness at the facility, and to determine whether the licensee's actions in response to actual emergencies were in accordance with the Emergency Plan and its implementing procedures.
The inspector reviewed the licensee's system for making changes to the Emergency Plan and the Plant Emergency Procedures (PEPs).
The inspector verified'hat licensee management approved all revisions to the PEPs and the one revision (Revision 14)
to the Emergency Plan issued since July 1988 (see also Paragraph 7.b, below).
The changes in Revision 14 to the Emergency Plan were primarily concerned with the Emergency Action Levels (EALs),
used in determining the classification of an emergency.
The EAL Flowpath (a logic diagram)
was redesigned using the same human-factoring as was previously applied to the licensee's Emergency Operating Procedures Flowpath.
This and all other
changes in Revision 14 were evaluated in a Region II licensing review, and a letter to the licensee dated December 13, 1988, certified the acceptability of the Emergency Plan as modified by Revision 14.
The inspector reviewed records pertaining to the emergency declarations which had occurred since July 1, 1988.
All of these declarations were at the Notification of Unusual Event level except for the one on August 12, 1988, which was classified as an Alert.
The following is a compendium of the referenced events.
Date Descri tion of Event August 12, 1988 October 6, 1988 October 20, 1988 Loss of more than half of annunciator panels on Main Control Hoard (event duration was nine minutes)
Unidentified Reactor Coolant System (RCS) leakage exceeding Technical Specifications (1,.0 gpm)
Leakage of approximately 28 gallons from RCS to Pressurizer Relief Tank November 17, 1988 The Emergency Response Facility Instrumentation System (ERFIS)
unavailable for more than
minutes December 1,
1988 December 16, 1988 March 13, 1989 Unidentified RCS leakage exceeding 1.0 gpm High-level radiation alarm for a liquid release from the treated laundry and hot shower ERFIS unavailable for more than 60 minutes The documentation of these events showed that notifications to State and local governments and the NRC were made in accordance with applicable requirements.
Each of the listed events appeared to have been classified correctly.
The emergency preparedness staff routinely reviewed the response to each declared emergency in order to identify problems or inconsistencies which may have occurred with respect to the requirements of the PEPs.
The inspector's review of selected PEPs disclosed a
problem with the instructions in Section 7.2 of PEP-101,
"Emergency Classification and Initial Emergency Actions,"
and Section 9.1 of PEP-102,
"Site Emergency Coordinator
-
Control Room."
Guidance in those sections drew a
potentially confusing distinction between (1) actual declaration of an W
R I
h an EAL was exceeded but was exite e ore a declaration could be made.
The inspector advised licensee representatives that the NRC expects emergency classifications previously handled by the second method to be
declared and terminated with one telephone call to each cognizant agency.
The licensee agreed to consider the applicability of this finding.
Inspector Follow-up Item (IFI) 50-400/89-12-01:
Elimination of the procedural distinction between
"declaration" and
"reporting" of an emergency.
No violations or deviations were identified.
3.
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 (ERFs)
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 following ERFs:
Control Room, Technical Support Center (TSC), Operations Support Center (OSC),
and near-site Emergency Operations Facility.
Selective examination of emergency equipment and supplies therein indicated that an adequate state of readiness was being maintained.
PEP-402,
"Maintaining Readiness of Emergency Facilities," was a governing procedure which was implemented by Plant General Order PG0-041,
"Emergency Equipment Inventory Checklist."
The inspector reviewed records of the surveillances performed under PGO-041 for the third and fourth ouarters of 1988 and the first quarter of 1989.
The records were complete, and indicated that problems were corrected expeditiously.
At the time of the current inspection, the licensee was in the process of installing communi'cations equipment in the NRC room at the TSC so that room could be used as the simulated Control Room for drills and exercises.
In this mode of operation, the actual Control Room would be uninvolved in drills and exercises with the sole exception of the responsibility for activating the site assembly alarm, if.directed.
Although this change would not affect the licensee's response to a real emergency, it was deemed desirable because of the tendency for the Control Room to become overcrowded during drills and exercises.
No other significant ERF changes had occurred since the July 1988.inspection.
No violations or deviations were identified.
4.
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 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'mergency Plan and PEPs.
The organization and management of the emergency preparedness program were reviewed.
Since the last inspection of this area (July 1988),
no significant changes in the management or organization of the program had occurred.
Similarly, no significant changes in the management of, or methods of coordination with, key offsite support agencies had occurred since July 1988, according to licensee representatives.
The inspector reviewed rec'ords of pager drills conducted on November 22, 1988 and February 14, 1989, to test the capability to augment the emergency response organization during off-hours.
The results of these
"call-back" drills indicated that all required emergency roles could have been filled in a timely manner.
The licensee was conducting such drills on approximately a quarterly basis, although not required or committed to do so, and the inspector encouraged the continuation of this practice.
No violations or deviations were identified.
5.
Training (82701)
Pursuant to
CFR 50.47(b)(2)
and (15),Section IV.F of Appendix E to
CFR Part 50, and Section 5.2 of the Emergency Plan, this area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
To determine the effectiveness of the emergency response training program, an extensive interview was conducted with one Senior Control Operator (SCO), who'as chosen at random by the inspector.
This position was designated as alternate for the Site Emergency Coordinator (SEC) role if the Shift Foreman were unavailable or incapacitated during an emergency.
The interview examined the SCO's general knowledge of emergency response as well as his specific understanding of such matters as emergency classification, onsite and offsite protective actions, notification, and nondelegated responsibilities of the SEC.
The interviewee was given several sets of hypothetical emergency conditions and plant data, and was asked for each case to talk through the response he would provide as SEC if such conditions actually existed.
Classification by means of the EAL Flowpath typically required 5 -
7 minutes.
The interviewee demonstrated an exceptionally through understanding of the concept and the specifics of the emergency response program.
No problems were observed during the course of the interview.
No violations or deviations were identifie.
Independent Reviews/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, and whether the licensee had a corrective action system for deficiencies and weaknesses identified during exercises and drills.
Licensee records showed that the required independent audit was accomplished as part of a review of the entire Harris Operations program conducted by a
team of seven gA auditors during the period December 2-16, 1988, and documented in Audit Report No. gAA/0022-88-06, dated January 9,
1989.
The audit of the emergency preparedness program appeared to have been thorough, and included an evaluation of the interfaces with State and local government agencies by means of personal interviews with cognizant officials of those agencies.
Audit findings and recommendations were presented to plant and corporate management.
Deficiencies identified during audits, drills, and exercises were tracked for follow-up on a
computer-based file entitled Emergency Preparedness Action Items.
The inspector noted that this file contained 52 findings from the May 1988 exercise, all of which had been closed following the
.completion of suitable corrective action.
The more significant findings identified during audits, drills, and exercises were entered into the plant-wide Corrective Action Program tracking system to ensure upper-management attention.
The inspector determined that the licensee was effectively using the aforementioned tracking systems as tools for ensuring the completion of corrective actions for problems in emergency preparedness, No violations or deviations were identified.
7.
Action on Previous Inspection Findings (92701)
a.
(Closed)
IFI 50-400/88-12-03:
Development of a
procedure for periodic functional testing of the TSC power supply switch.
Preventive Maintenance Procedure PM-E0038,
"TSC Transfer Switch," was developed to address the subject finding.
This procedure was performed (with successful results)
on July 5 and November 19, 1988,
~ and will henceforth be scheduled for performance in October of each year.
b.
(Closed)
Licensee-Identified Violation 50-400/88-19-01:
Failure to submit changes to the Plant Emergency Procedures to NRC 'within 30 days after approval.
The inspector reviewed the licensee's nonconformance report and corrective actions implemented in response to this finding.
Due to the departure last year of a particular Regulatory Compliance clerk, the licensee's system for issuing PEP revisions malfunctioned.
A
system which appeared to be much more reliable was implemented.
Records of the
PEP revisions made since July 14, 1988 showed that each was forwarded to the NRC within.30 days of the effective date.
c.
(Closed) IFI 50-400/88-19-02:
Providing appropriate documentation on testing of the offsite siren system to the Senior Specialist, Emergency Preparedness.
The licensee's maintenance staff was trained that the documentation in question, known as Form 2000, was to be submitted as a record of the corrective action for each discrepancy identified during siren testing.
The inspector reviewed records of the biweekly silent tests and the quarterly growl tests of the siren system for the period August 1988 through April 1989, and found that all required documentation had been submitted to the Senior Specialist.
8.
Exit Interview The inspection scope and results were summarized on May 26, 1989, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below.
Proprietary information is not contained -in this report.
Dissenting comments were not received from the licensee.
Item No.
50-400/89-12-01 Descri tion and Reference Inspector Follow-up Item:
Elimination of the distinction in PEP-101 between "declaration" and
"reporting" of an emergency classification (Paragraph 2).
Licensee management was informed that the three previous findings listed in Paragraph 7 were considered close I