ML14181A237
| ML14181A237 | |
| Person / Time | |
|---|---|
| Site: | Harris, Brunswick, Robinson  |
| Issue date: | 07/07/1994 |
| From: | Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | Habermeyer H Carolina Power & Light Co |
| References | |
| NUDOCS 9407290095 | |
| Download: ML14181A237 (24) | |
Text
Docket Nos. 50-325, 50-324, 50-400, 50-261 License Nos. DPR-71, DPR-62, NPF-63, DPR-23 Carolina Power & Light Company ATTN:
Mr. H. W. Habermeyer, Jr.
Vice President Nuclear Services Department P. 0. Box 1551 - Mail OHS7 Raleigh, NC 27602 Gentlemen:
SUBJECT:
MANAGEMENT MEETING
SUMMARY
This letter refers to the Management Meeting held at your request on June 1, 1994. The meeting concerned activities at your Brunswick, Harris, and Robinson facilities. The issues discussed at the meeting included an update of your Emergency Preparedness Initiatives and an overview of your self assessment program. We believe the meeting was beneficial to our understanding of your progress in these areas.
A list of attendees and a copy of your handout are enclosed.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, please contact us.
Sincerely, ORIGiN.L IG T 1 William E. Cline, Chief Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
Enclosures:
- 1. List of Attendees
- 2. -Handout cc w/encls:
(See page 2) 9407290095. 940707 PDR ADOCK 05000261 F
Carolina Power & Light Company 2
cc w/encls:
J. P. Cowan Director Site Operations Brunswick Steam Electric Plant P. 0. Box 10429 Southport, NC 28461 W. Levis Plant Manager Unit 1 Brunswick Steam Electric Plant P. 0. Box 10429 Southport, NC 28461 C. C. Warren Plant Manager Unit 2 Site Operations Brunswick Steam Electric Plant P. 0. Box 10429 Southport, NC 28461 Mark S. Calvert Associate General Counsel Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Commerce & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 Karen E. Long Assistant Attorney General State of North Carolina P. 0. Box 629 Raleigh, NC 27602 Robert P. Gruber Executive Director Public Staff - NCUC P. 0. Box 29520 Raleigh, NC 27626-0520 Public Service Commission State of South Carolina P. 0. Box 11649 Columbia, SC 29211 cc w/encls:
(Cont'd on page 3)
Carolina Power & Light Company 3
(cc w/encls:
cont'd)
Mayor City of Wilmington P. 0. Box 1810 Wilmington, NC 28402 Mayor City of Southport 201 East Moore Street Southport, NC 28461 Mr. W. S. Orser Executive Vice President Carolina Power and Light-Company Shearon Harris Nuclear Power Plant P. 0. Box 1551 - Mail Code CPB 12 Raleigh, NC 27602-1551 David McCarthy, Manager Regulatory Affairs Harris Nuclear Project P. 0. Box 165 New Hill, NC 27562 H. Ray Starling Manager - Legal Department Carolina Power and Light Co.
P. 0. Box 1551 Raleigh, NC 27602 Admiral Kinnaird R. McKee 214 South Morris Street Oxford, MD 21654 Robert D. Martin 3382 Sean Way Lawrenceville, GA 30244 M. P. Pearson Plant Manager H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 R. Krich, Manager Regulatory Compliance H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 cc w/encls:
(Cont'd on page 4)
Carolina Power & Light Company 4
(cc w/encls:
cont'd)
Max Batavia, Chief Bureau of Radiological Health Dept. of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 bcc w/encl s:
H. Christensen, RH B. Mozafari, NRR N. Le, NRR P. Milano, NRR Document Control Desk NRC Resident Inspector U. S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 NRC Resident Inspector U.S. Nuclear Regulatory Commission Star Route 1, Box 208 Southport, NC 28461 NRC Resident Inspector U. S. Nuclear Regulatory Commission 5421 Shearon Harris Road New Hill, NC 27562-9998 SEND OFC RII:
RII:DRP TO NAME Ka CChristensen_
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EFFECTIVENESS OF IMPLEMENTATION OF OFFSITE EMERGENCY PREPAREDNESS PROGRAM "OFFSITE EVALUATED DRILL / EXERCISE" Performance last 4 evaluations 4th previous 3rd previous 2nd previous last Performance this evaluation Justification Documentation Rting Criteria Green FEMA Exercise Report identifies no "Deficiencies" and no more than 1 "Area Requiring Corrective Action" for any individual offsite agency involved Yellow FEMA Exercise Report identifies no "Deficiencies" and no more than 2 "Areas Requiring Corrective Action" for any individual agency involved Red FEMA Exercise Report identifies a "Deficiency" or greater than 2 "Areas Requiring Corrective Action" for any individual agency involved
EFFECTIVENESS OF ADMINISTRATION OF MAINTENANCE OF THE STATION'S EMERGENCY PREPAREDNESS PROGRAM "STAFFING" Performance last 4 quarters 4th qtr. 93 1st qtr. 94 2nd qtr. 94 3rd qtr. 94.
Performance this quarter Justification Documentation Rating Criteria Green All critical ERO positions are staffed 4 deep and no ERO position is less than 3 deep and less than 5% of ERO members requal. has lapsed Yellow All critical ERO positions are staffed 3 deep and no position is less than 2 deep and less than 10% of ERO members requal. has lapsed Red Any critical ERO position less than 3 deep or any ERO position less than 2 deep or greater than 10% of ERO members requal. has lapsed
EFFECTIVENESS OF ADMINISTRATION OF MAINTENANCE OF THE STATION'S EMERGENCY PREPAREDNESS PROGRAM "EMERGENCY RESPONSE EQUIPMENT & FACILITIES" Performance last 4 quarters 4th qtr. 93 1st qtr. 94 2nd qtr. 94 3rd qtr. 94 Performance this quarter Justification Documentation Criteria Green Required inventories / equipment testing completed within scheduled times. No inventory / equipment testing overdue. No ACR's or MAC's identified during inventories / equipment testing. Any repairs are completed within two weeks. Back-up equipment to the primary system out of service is fully operational.
Yellow.:
No ACR's identified during inventories / equipment testing. Any repairs are completed within two weeks. Back-up equipment to the primary system out of service is fully operational.
Red ACR's identified during inventories / equipment testing. Primary and associated back-up equipment is out of service simultaneously.
Process for Unification of Emergency Plans CP&L proposes a two step process for review:
CP&L would submit the draft package to the Region Station for it's review concurrent with station PNSC reviews CP&L would submit a final / formal submittal after Emergency Plans resolution of comments from PNSC's & NRC Region Transition Process:
Commitment table
-Conduct search I capture T
i D
m Transition Document all known commitments
- make determination of applicabilityC to E. Plan vs. Procedures of three Station E. Plans CP&L ubmlttal kage to unified E. Plan
- Development of Station E. Plans vs. NUREG 0654I Appx. E matrix
- Development of draft unified E.Plan in 0654 format CP&L NGG Emergency Plan
-Development of unified E. Plan vs.
NUREG 0654/ Appx. E matrix
Procedure Structure Under Consideration AII Sites Of
- e soDose Code Defines Policy and Responsibility for Off 1
NGG EP Program Administration
>~
All Sites Sii ar
- Site X
Defines Attachments format &
- e EOF revision Activation process BNP 1
ANP Unique.
n ne EAo
Self-Assessment Program Overview Effectiveness Emergency Preparedness Assessment Act Suioirtini Proirams Verification Program Components and frequency of conduct Drill on form Drill & Exercise Program Drill conduct - quarterly CorTective Action Program
. ERO performance trending -annual Corrective Action Program
- Event response investigation - as occurs Corrective Action Program Actual Events crnques Emergency Response Operability testing - per proc'ds Corrective Action Program Facilities & EIuipment Inventories -per proc'ds Corrective Action Program Performance trending - annual Corrective Action Program
! Repair timeliness -semiannual Corrective Action Program
- ERF tours -weekly Corrective Action Program CAP database Emergency Plan 50.54 (t) review - annual NAD Program Revision trending - annual Corrective Action Program Procedures review - annual EP NGG Directive Response Procedures
-Revision timeliness - semi-annual Corrective Action Program ERO Training effectiveness review-annual Station Training Program Trainin Pro ram ERO classroom audits - quarterly EP Self-Assessment Guide Training revision timeliness - semi-annual Corrective Action Program BENCHMARKING Preparedness Program CP&L NGG EP Program FAIM & MAPS Programs Cost Effectiveness Review O&M / LaborPeer Group Comparison -annual Industry Peer Comparison FAIM & MAPS Programs of EP O&M / Labor Costs - annual Industry Issues
- CP&L NGG event critiques - (all below are as occurs / as issued) and NUREG reviews Events Review Operating EVerience reviews INPO information reviews Industry EP meetings (SEUEPG & NE)
..Key EP Program elements are EP Self-Assessment Guide Performance Measures measured and reported - quarterly Program
ENCLOSURE 1 Management Meeting Attendees Carolina Power & Light Company R. Varley, Director, Corporate Emergency Preparedness, Carolina Power & Light (CP&L)
B. Houston, Manager, Emergency Preparedness, Brunswick Nuclear Plant P. Jenny, Manager, Emergency Preparedness, Robinson Nuclear Plant B. McFeaters, Manager, Emergency Preparedness, Harris Nuclear Plant R. Rogan, Manager, Nuclear Licensing and Regulatory Affairs, CP&L Nuclear Requlatory Commission H. Christensen, Acting Chief, Reactor Projects Branch No. 1, Division of Reactor Projects W. Cline, Chief, Radiological Protection and Emergency Preparedness (RPEP)
Branch, Division of Radiation Safety and Safeguards (DRSS)
K. Barr, Chief, Emergency Preparedness Section (EPS), RPEP, DRSS W. Sartor, Senior Radiation Specialist, EPS, RPEP, DRSS A. Gooden, Radiation Specialist, EPS, RPEP, DRSS
ENCLOSURE 2 Carolina Power & Light Company Emergency Preparedness Program.
Initiatives Update June 1, 1994
Emergency Preparedness Initiatives Discussed During Our 11/17/93 Meeting Emergency Preparedness Program Vision Statement Emergency Preparedness Program Performance Measures Consolidation of Emergency Plans Standardization of Implementing Procedures
Emergency Preparedness Initiatives Progress Since Our 11117/93 Meeting Emergency Preparedness Program Vision Statement each site has the capability to be self-sufficient for the first twenty four hours of an incident each site ERO is staffed "three deep" in critical positions and has ongoing efforts to achieve "four deep" staffing (BNP staffing goal is "five deep")
standard ERO structure for all three sites has been developed and will be integrated into current initiatives implementation schedules implementation of Performance Measures program occurred on 2/9/94
Emergency Preparedness Initiatives Progress Since Our 11/17/93 Meeting Emergency Preparedness Program Performance Measures implemented on 2/9/94 last quarter '93 & first quarter '94 measures issued (see enclosed graphs)
Consolidation of Emergency Plans development of unified CP&L Nuclear Generation Group Emergency Plan underway (see enclosed diagram)
Standardization of Emergency Preparedness Procedures development of standardized Implementing and Administrative procedures underway (see enclosed diagram)
New Emergency Preparedness Initiatives Undertaken Since Our 11/17/93 Meeting Emergency Preparedness Self - Assessment Program undergoing final refinements I reviews (RNP Pilot Program in progress)
Offnormal Events Response Evaluation / Procedures draft procedures being reviewed 50.54 ( t) Annual Audit - Peer Involvement EP Unit Manager and EP Trainer were members of the recent BNP Annual Audit Team Director, Corporate EP acted as an advisor to the BNP Audit Team
Station Specific Emergency Preparedness Program Topics Brunswick Station Emergency Response Facilities Enhancements INPO Drills & '94 Exercise Scope Robinson Station Siren System Root Cause Analysis November '94 Exercise - specific objectives selection
Carolina Power and Light Company - Emergency Preparedness Vision The Emergency Preparedness Program at Carolina Power and Light Company will be structured and conducted in a manner which will be recognized as a "World Class" Program, respected as a leader in innovative initiatives, demonstrating consistently high quality activities and will be a model for cost effective operation for multi-station utilities.
The Emergency Preparedness Program will provide strong assurance that the health and safety of the public will be adequately protected in the unlikely event of an incident at any Carolina Power and Light Company nuclear facility.
The response of Carolina Power and Light Company to any offnormal event will reflect the technical competence and management skills necessary to mitigate the onsite aspects of the event, protecting the welfare of it's employees while providing adequate support and timely, forthcoming communications to satisfy the needs of the offsite response organizations and governmental agencies responsible for protecting the health and safety of the public.
Traits of the Carolina Power and Light Company Emergency Preparedness Program Each site Emergency Response Organization will have the capability for self - sufficient response to the event at the plant site for the first twenty four hours of the incident Each site Emergency Response Organization will have sufficiently trained personnel to staff it's critical positions "three deep" at all times and strive to achieve "four deep" staffing. Emergency Response Organization members will be assigned on a weekly rotating basis, will remain within the required response time vicinities of the site and adhere to the Company's fitness for duty policies while on assignment.
- The Emergency Response Organization alignment, as well as response procedures and equipment at each site, will be structured with sufficient similarity to maximize cost effective implementation of the preparedness program and where feasible provide backup interchangability of certain key Emergency Response Organization members and equipment between site locations.
Carolina Power and Light Company communications with all external parties in support of decision making and public information needs during an event will be timely, accurate and forthright. Moreover, the communications will be structured to support the response needs of senior corporate management.
The working relationships with affected offsite government, private and volunteer agencies will be professional, supportive, responsible and cooperative. This relationship will include a clearly articulated Company policy for providing any necessary financial support.
The response equipment and facilities at each site will be maintained at the highest levels of readiness at all times. Inventories will be maintained full and surveilled on a frequent basis.
The preparedness program at each site will have a system of performance standards measures, visible to senior site and corporate management, assuring adequate levels of preparedness are being maintained. Line management will be held accountable to ensure assigned staff attend training and drills to maintain their Emergency Response Organization position qualifications. Emergency Response Organization personnel assignments will be integrated with the Companys' employee performance appraisal program.
As reflected by the signatures on this page, the Emergency Preparedness program at Carolina Power and Light Company will be fully supported at the highest levels of management at each Company location.
Vice President, Nuclear e ces epartment Vice President, Shearon Harris Nuclear Plant Vfce! President, Brunswick Nuclear Plant Vice President,' H. Br--kobinson Nuclear Plant
EMERGENCY PREPAREDNESS PERFORMANCE MEASURES PROGRAM EMERGENCY PREPAREDNESS "ACTUAL EVENTS" PERFORMANCE MEASURES PROGRAM "DRILL RESPONSES" 1st Quarter - 1994 ist Quarter -194 MAIN BRUNSWICK ROBINSON HARRIS CP&L (avg)
BRUNSWICK ROBINSON M ARIS CP&L (Avg.)
EMERGENCY PREPAREDNESS EMERGENCY PREPAREDNESS PERFORMANCE MEASURES PROGRAM PERFORMANCE MEASURES PROGRAM "EVALUATED EXERCISES" "OFFSITE EVALUATED DRILL / EXERCISE" 1st Quarter - 1994 1st Quarter*1994
- am weameme emR~mghmemeIaatgaQumamtmrraem1pa4 BRUNSWbIC ROBINSON4 HARRIS CPA).(avg.)
BRUNSICK ROBINSON KHRRIS CPA).(ovg)
EMERGENCY PREPAREDNESS PERFORMANCE MEASURES PROGRAM EMERGENCY PREPAREDNESS PERARM NC A
PERFORMANCE MEASURES PROGRAM "EMERGENCY RESPONSE EQUIPMENT & FACILITIES" 1st Quarter
- 1994 1st Quarter -1994 cam GRUNSWICK ROGINSON HARRIS CPAs).
(a4 BRUW RONSON CPA) (avg.
F
.asm esmGRNAIK DAAN ARI C
ag
EMERGENCY PREPAREDNESS EMERGENCY PREPAREDNESS EMREC REAENS MERORMANCY EAREDNSSP PERFORMANCE MEASURES PROGRAM PERFORMANCE MEASURES PROGRAM.PRRATENNG "COMPOSITE RATINGS" "PROGRAMTRENDING" Green ist Quarter - 1994 Yenow VILLOW
- e e
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satSM&CK ADSON KMA CP&
EFFECTIVENESS OF IMPLEMENTATION OF STATION S EMERGENCY PREPAREDNESS PROGRAM "ACTUAL EVENTS" Performance last 4 quarters 4th qtr. 93 1st qtr. 94 2nd qtr. 94 3rd qtr. 94 Performance this quarter Justification Documentation Rating Criteria Green Effective response timely & accurate classification / notification, facility activation within requirements, effective mitigation, - no adverse conditions or minor adverse conditions identified Yellow:
Effective response with less than 5 minor adverse conditions identified Red :
Marginal response with one or more adverse conditions or greater than 5 minor adverse conditions identified
EFFECTIVENESS OF IMPLEMENTATION OF STATION'S EMERGENCY PREPAREDNESS PROGRAM "DRILL RESPONSES" Performance last 4 quarters 4th qtr. 93 1st qtr. 94 2nd qtr. 94 3rd qtr. 94 Performance this quarter Justification Documentation Rating Criteria Green Effective response timely & accurate classification / notification, facility activation within requirements, effective mitigation, - no adverse conditions or minor adverse conditions identified Yellow Effective response with less than 5 minor adverse conditions identified Red Marginal response with one or more adverse conditions or greater than 5 minor adverse conditions identified
EFFECTIVENESS OF IMPLEMENTATION OF STATION'S EMERGENCY PREPAREDNESS PROGRAM "EVALUATED EXERCISE" Performance last 4 evaluations 4th previous 3rd previous 2nd previous last Performance this evaluation Justification Documentation Rating -
Criteria-:
Green No NRC identified weaknesses or inspector followup items Yellow No more than 1 NRC identified weakness and / or 5 or less inspector followup items Red More than 1 NRC identified weakness and / or greater than 5 inspector followup items