IR 05000400/1991014
| ML18010A355 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/24/1991 |
| From: | Rankin W, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18010A349 | List: |
| References | |
| 50-400-91-14, NUDOCS 9108120039 | |
| Download: ML18010A355 (9) | |
Text
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+n +y*de4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 JUL 24 59l Report No.:
50-400/91-14 Licensee:
Carolina Power 'and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris Inspection Conducte:
June 10-14, 199 Inspector:
G.
W.
Sa yers License No.:
NPF-63 D t Si ned Accompanying Personnel:
W. Rankin Approved by:
W. H.
Ran sn, C ief Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards Date Signed SUMMARY Scope:
This routine, unannounced inspection was conducted in the area of emergency preparedness, and included review of the.following programmatic elements:
1) Radiological Emergency Response Plan and its implementing procedures; (2) emergency facilities, equipment, instrumentation, and supplies;
organization and management control; (4) training; and (5) independent reviews/audits.
Results:
In the area inspected, one violation and two non-cited violations were identified:
Failure to maintain Control Room equipment (Paragraph 3).
Failure to maintain EOF equipment (Paragraph 3).
Failure to maintain ERF qualification current (Paragraph 6).
9108120039 9l0724 PDR ADDCK 05000400 ":
The emergency preparedness program appeared to be receiving adequate management support.
Emergency response facilities, equipment, and supplies were properly maintained.
Training of emergency response personnel appeared to be effective.
The requirements and commitments addressed by the emergency preparedness program were effectively managed by the licensee's staff.
Records of program activities were maintained and readily auditable.
The findings of this inspection indicated that the licensee was adequately prepared to respond to a radiological emergency at the Shearon Harris Nuclear Plan REPORT DETAILS Persons Contacted Licensee Employees
- R. Bassett, Senior Specialist, Emergency Preparedness
- D. Batton, Manager, Outage Plant Scheduling
- J. Collins, Manager, Operations
- C. Gibson, Manager, Programs and Procedures
- P. Hadol, Manager, Projects
- C. Hinnant, General Manager
- B. Meyer, Manager, Environmental and Radiation Control
- R. Morgan, Manager, Project Assessment
- C. Olexik, Manager, Regulatory Compliance
- R. Pasteur, Senior Specialist, Technical Training
- A. Powell, Manager, Harris Training Unit
- J. Rausch, Manager, Technical Training R. Richey, Vice President, Harris Nuclear Projects
- M. Staton, Power Agency Site Representative
- F. Streble Jr., Manager, guality Assurance Engineering
- M. Wallace, Senior Specialist, Regulatory Compliance
- E. Willett, Manager, Outages and Modifications
- W. Wilson, Manager, Spent Nuclear Fuel
- L. Woods, Manager, System Engineering Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
NRC Resident Inspector
- M. Shannon
- Attended exit interview Emergency Plan and Implementing Procedures (82701)
Pursuant to
CFR 50.47(b)(16),
CFR 50.54(q),
and Appendix E to
CFR Part 50, this area was reviewed to determine whether changes were made to the program since the last routine inspection (March 1990),
and to assess the impact of these changes on the overall state of emergency preparedness at the facility.
The inspector reviewed the licensee's program for making changes to the Emergency Plan and the Plant Emergency Procedures (PEPs).
A review of selected licensee records confirmed that all changes to the Emergency Plan and PEPs since March 1990 were approved by management and submitted to the NRC within 30 days of the effective date, as require Controlled copies of the Emergency Telephone Directory, Emergency Plan, and PEPs were audited in the Control Room, Technical Support Center (TSC),
and the Emergency Operations Facility (EOF).
The inspector reviewed three emergency declarations made by the licensee since March 1990.
All three declarations were NOUEs.
Review of the Emergency Action Level (EAL) Classification procedure and conditions prompting the classifications indicated that the classifications were made promptly, correctly, and timely offsite notifications conducted.
The inspector reviewed the memorandum to Mr. C. Gibson from Mr. R. Indelicato discussing the quarterly meeting on October 26, 1990 of the Harris Plant Task Force composed of State, county, and CPKL Emergency Preparedness personnel where the EALs were presented and reviewed.
Neither the State nor the county made recommendations for EAL changes at that time.
No violations or deviations were identified.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
Pursuant to
CFR 50.47(b)(8)
and (9),
and
CFR 50.54(q),
and Section IV.E of Appendix E to
CFR 50, this area was inspected to determine whether the licensee's 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 licensee's ERFs, including the Control Room, TSC, OSC, and offsite EOF.
While touring the Control Room, the inspector observed that the failed fuel detector was out of service.
The three fission barrier concept for EAL classification is utilized by Shearon Harris.
Information from the failed fuel detector is used in a decision block in the EAL Flowchart for identifying the first boundary failure, failed fuel.
Also, the availability of the failed fuel detector was used as a bases for removing back-up information for identifying failed fuel in Revision 16 of the EAL Flowchart and is defined in Section 3.2.3.h of the Emergency Plan as Control Room equipment to be maintained.
Review of work request
ANMM1 indicated the failed fuel detector was removed from service August 7, 1989.
Summarizing from the action necessary to correct the excess flow problem, installing a restricting orifice, and a new control valve with a different throttling characteristic, the equipment had not functioned properly since initial operation.
The inspector informed licensee representatives during the exit, that failure to maintain the operability of the fail fuel detector was a violation of the requirements of Section 3. 1 of the Emergency Plan.
Violation 50-400/91-14-01:
Failure to maintain Control Room equipment (Failed Fuel Detector Section 3.2.3.h)
as defined in Section 3. 1 of the Shearon Harris Emergency Pla While touring the,EOF, the inspector requested a demonstration of the Emergency Response Facility Information System (ERFIS) terminals; While attempting to ready the system, 2 of the
ERFIS terminals failed to function on command, and required technical assistance to activate.
The licensee produced in'formation confirming a work request was on ERFIS terminal
"2" to correct a scrolling screen, and a plant mod removing a
fourth terminal had caused operability problems affecting the ERFIS "3" terminal.
In addition display "Blocks" of RMS instruments on the ERFIS terminal indicated alternately GREEN (GOOD)
and then RED (BAD) on a two and half minute cycle.
This was explained as a bad data link between one of the two RMS computers and the two ERFIS computers.
A work request had been issued attempting to identify the RMS/ERFIS data link problem.
Also, the VISC 80 printer had an alarm light and would not print.
The inspector
'nformed licensee representatives during the exit, that failure to maintain the operability of the three ERFIS terminals was a violation of the requirements of Section 3. I of the Emergency Plan.
Since all criteria as specified in 10 CFR Part 2, Appendix C, Section V of the NRC Enforcement Policy were satisfied, the licensee was informed that this finding was considered a noncited violation (NCV).
(Closed)
NCV 50-400/91-14-02:
Failure to maintain EOF equipment (ERFIS terminals Section 3.5.3.b)
as defined in Section 3. 1 of the Shearon Harris Emergency Plan.
The remainder of the facilities and emergency equipment therein appeared to be maintained in an appropriate state of readiness.
According to observations by the inspector and,statements by licensee representatives, no significant changes in the facilities other than removing the fourth ERFIS terminal were made since the last inspection.
The Emergency Ventilation System for the EOF was tested in the emergency mode.
The system actuated flawless and indicated a positive pressure of 0.13 inches of water.
The acceptable pressure is 0.125 inches of water.
The system appeared well maintained and in a state of operational readiness.
An operational test of the Emergency Diesel Generator (EDG) supplying the EOF was observed.
The EDG is rated at 175 KW, with all EOF loads being supplied by the EDG, the EDG was only carrying approximately
KW.
The inspector reviewed the maintenance and testing records of the EDG since March 1990.
By all indications, the EDG appears to be receiving proper maintenance and testing.
The inspector and licensee performed an inventory check of the emergency kit located in the TSC, Control Room and Environmental Monitoring Kits and found the inventory complete.
The inspector reviewed the inventory records of the various emergency kits since March 1990.
The records indicated that the emergency kits are being properly maintaine The inspector verified the availability of emergency vehicles for the environmental monitoring teams in case of an emergency.
The licensee stated and demonstrated access to (keys and logs of) seven laboratory vehicles, twelve fleet cars, one passenger training van, and one 4X4 Suburban for the'nvironmental laboratory as accessible emergency vehicles.
Given the licensee is equipped to field five environmental monitoring teams and only plans to field three teams of two persons each, the inspector determined the availability of vehicles at any given time was adequate.
The inspector verified the operability of two site vehicles by requesting the licensee start the vehicles.
Both started and ran satisfactorily.
Visual inspection of the vehicles indicated that the vehicles were ready to respond.
The inspector reviewed the licensee's documentation of required communications tests for the period of March 1990 to June 1991, including the following:
I)
EOF communications system functional tests, performed bi-weekly; (2 monthly communications drills involving message transmission from the Control Room to the State Warning Point via the Automatic Ring-Down; and (3) tests of the Emergency Notification System (ENS).
According to the records, prompt corrective actions were undertaken when equipment deficiencies were identified.
The Early Warning Notification System (EWNS) consisted of 79 fixed sirens located in Chatham, Sanford, Lee, Harnett, and Wake Counties.
Silent testing was performed bi-weekly under the jurisdiction of the respective county emergency management agencies, with test results forwarded to the licensee.
Actual live testing with a
person standing by to actually witness the actuation was performed annually.
This provides on-line activation and operability testing of the EWNS system.
One violation and one NCV was identified.
Organization and Management Control (82701)
Pursuant to
CFR 50.47(b)(1)
and (16) and Section IV.A of Appendix E to
CFR Part 50, this area was inspected to determine the effects of any changes in the licensee's emergency response organization and/or management control systems in the emergency preparedness program and to verify that such changes were properly factored into the EP and EPIPs.
The inspector discussed site working relationship, in Emergency Preparedness, with the Emergency Coordinator for Chatham, Harnett, Lee, and Wake Counties, the State Emergency Management, and the Fuquay Fire Department.
The relationships were described as open and responsive.
No problem areas or concerns were identified by offsite officials.
The organization and management of the emergency preparedness program was reviewed and discussed with licensee representatives.
Management changes in the program had occurred since March 1990, of particular interest was the Site Emergency Preparedness Coordinator.
This change did not affect the 1'icensee ability to respon The inspector reviewed Section 5 of the licensee's Emergency Plan.
"Maintaining Emergency Preparedness."
This section addressed the performance of a variety of required activities, including testing of communication systems, training for licensee and offsite emergency response personnel, shift augmentation drills, and other program maintenance activities.
Documentation of these activities was determined to be appropriately maintained.
Records were reviewed in the following areas:
Emergency Communications Test Early Warning System Siren Activation Monitoring Emergency Plan Augmentation Callout Emergency Plan Radiation Instruments and Emergency Kit Inspection and Checks All of the required records were found satisfactory.
No violations or deviations were identified.
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 has performed an independent review or audit of the emergency preparedness program, and whether the licensee has a corrective action system for deficiencies and weaknesses identified during exercises and drills.
The most recent independent audit of the Emergency Preparedness Program (Audit Report gAA/0022-90-05 90-1795 dated December 18, 1990) conducted in accordance with CP&L's Corporate guality Assurance Department Procedure CRAU 80-1 was reviewed.
The Audit was an integrated performance-based audit involving Operations, Security, and the Emergency Preparedness Program.
Although acceptable, the audit report and the requirements of the audit as identified in
CFR 50.54(t)
was discussed with the licensee's Emergency Coordinator.
The inspector reviewed the qualifications of the technical expert assigned to the emergency preparedness portion of the audit.
The auditor's emergency preparedness background was satisfactory.
The licensee's program for follow-up on findings from audits, drills, and exercises was reviewed.
The licensee had established a facility-wide computer-based system called Action Item Tracking List for tracking deficient areas of the program.
In addition, the emergency preparedness group has a
computerized tracking system for managing their personal follow-up actions.
Review of a sample of completed corrective actions indicated that findings were satisfactorily addressed and appropriate corrective actions had been completed.
No violations or deviations were identifie Training (82701)
Pursuant to 10 CFR 50.47(b)(2)
and (15),
and Section IV.
F of Appendix E
to
CFR Part 50, this area was inspected to determine whether the licensee's key emerg'ency response personnel were properly trained and understood their emergency responsibilities.
One Senior Reactor Operator (SRO),
and one individual from upper management were interviewed.
During the interviews, licensee personnel were given scenarios out of NUREG-0654, Appendix 1.
The inspector noted that the licensee personnel classified the events in accordance with the Harris EAL flowcharts, but that in multiple cases the emergency classifications were different than the classifications would have been utilizing NUREG-0654 Appendix 1.
The bases for the flowcharts decision blocks are complex and require significant effort to effect a correct classification.
The licensee representative stated he believed the indications given orally for the scenarios were complete, although, some information may have been missing which would have allowed the flowcharts to classify the scenarios in agreement with NUREG-0654.
The inspector suggested scenarios be developed and run on the simulator for verification of the flowcharts.
This would remove the "ambiguity" of oral scenarios.
It was noted by the licensee that the EALs had received NRC approval.
The discrepancy between classifications will be reviewed in a future inspection.
This finding will be tracked as Inspector Follow-up Item 50-400-91-14-04.
The inspector reviewed the training records of selected members of the Emergency Response Facility (ERF) roster.
Training for the ERF staff is divided into and performed by three separate training groups:
(1) Corporate, (2) licensed operator training, and (3) non-licensed operator training.
Corporate training performs the training and maintains the records of the Corporate members of the ERF staff.
The Site Training Department maintains a computerized personnel history of all the training for ERF personnel stationed at the site.
In addition to identifying past training, an attention date identifies the date current training is to expire two months prior to the actual training expiration date.
The inspector reviewed the training records of various members of the ERF staff and identified one member with expired training.
The member was listed as current in training and as an active member on the ERF roster.
The individual also participated in the June 5,
1991 emergency drill.
Contrary to the roster, the member's qualification had expired in February 14, 1990.
This went undetected by approximately four quarterly audit reviews and an annual review per PEP 403, Section 5.7.
This was brought to the licensee's attention.
The licensee took prompt corrective action by removing the individual from the roster and retraining the individual.
Since all criteria as specified in 10 CFR Part 20,
Appendix C,Section V of the NRC Enforcement Policy were satisfied, the licensee was informed that, this finding was considered a
NCV.
(Closed)
NCV 50-400/91-14-03:
Failure to maintain ERF qualification current as defined in Section 5.2. 1 of the Shearon Harris Emergency Plan.
One NCV was identified.
Actions on Previous Inspection Findings (92701)
(C'losed)
Inspector Follow-up Item (IFI) 50-400/88-12-01:
Evaluate Dose Assessment Meteorological Data.
IFI 88-12-01 was opened to track completion of TMI Action Item III A.2.2, Atmospheric Transport and Diffusion Assessment.
Subsequent to this inspection, the NRC had concluded that inspection of licensee's ERFs beyond that done during the observation of emergency exercises is not required, (reference Russell to Murley Memo dated October 2, 1990 closeout of TMI Action Items III A. 1.2 and III A.2.) therefore this IFI is closed.
Exit Interview The inspection scope and results were summarized on June 14, 1991, with those persons indicated in Paragraph 1.
Although proprietary information was reviewed during this inspection, none is contained in this report.
Licensee management was informed that the previous IFI is considered closed as described in Paragraph 7.
The IFI listed below was initially a discussion with your staff during the inspection.
However, review and discussion by Region II Management and staff subsequent to the onsite inspector determined that this matter warranted an IFI, as described in Paragraph 6.
Licensee management representatives were telephonically informed of this determination on July 18, 1991.
Item Number Descri tion and Reference 50-400/91-14-01:
50-400/91-14-02:
50-400/91-14-03:
50-400/91-14-04 Violation - Failure to maintain Control Room equipment (Failed Fuel Detector Section 3.2.3.h)
as defined in Section 3.1 of the Shearon Harris Emergency Plan (Paragraph 3).
NCV - Failure to maintain EOF equipment (ERFIS terminals Section 3.5.3.b)
as defined in Section 3. 1 of the Shearon Harris Emergency Plan (Paragraph 3).
NCV - Failure to maintain ERF qualification current as defined in Section 5.2. 1 of the Shearon Harris Emergency Plan (Paragraph 6).
IFI - Discrepancy in classification between Harris EAL flowchart and NUREG-0654 Appendix 1.