ML18019A245

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Forwards Insp Rept 50-400/85-09 on 850304-15.Apps Re Emergency Preparedness Deficiencies,Improvement Items & Incomplete Items from Insp Also Encl.Corrective Actions Requested
ML18019A245
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 04/22/1985
From: Walker R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Utley E
CAROLINA POWER & LIGHT CO.
Shared Package
ML18019A246 List:
References
NUDOCS 8506210427
Download: ML18019A245 (11)


See also: IR 05000400/1985009

Text

0

APR 2 2

1985

Carolina

Power

and Light Company

ATTN:

Mr. E.

E. Utley

Executive Vice President

Power Supply and Engineering

and Construction

411 Fayetteville Street

Raleigh,

NC

27602

Gentlemen:

SUBJECT:

REPORT

NO. 50-400/85-09

On

March 4-15,

1985,

NRC

inspected

activities

authorized

by

NRC Construction

Permit

No.

CPPR-158 for your Shearon

Harris facility.

At the conclusion of the

inspection,

the

findings

were

discussed

with those

members

of your

staff

identified in the enclosed

inspection report.

Areas

examined during the inspection

are identified in the report.

Within these

areas,

the

inspection

consisted

of selective

examinations

of procedures

and

representative

records,

interviews with personnel,

and observation of activities

in

progress'he

findings of this

inspection

indicate

that

a deficiency exists

in your

emergency

preparedness

program.

This is discussed

in Appendix A,

"Emergency

Preparedness

Deficiencies."

This deficiency identified in Appendix A must

be

corrected prior to operation

above

5% reactor

power.

You are requested

to notify

this office in writing as

soon

as possible after corrective actions for this

deficiency have

been

completed.

This inspection also indicated that there

are areas that should

be evaluated

and

considered for improvement

in your

emergency

preparedness

program.

These

areas

are

discussed

in Appendix B,

"Emergency

Preparedness

Improvement

Items."

We

recognize

that

an explicit regulatory

requirement

pertaining

to

each

item

identified in Appendix

B may not currently exist.

Notwithstanding this, you are

requested

to submit

a written statement

addressing

the results of your considera-

tion of each of the

items in Appendix B.

This statement

should

be submitted in

conjunction with your notification of completion of corrective

actions for the

deficiencies identified in Appendix A.

During the inspection,

several

of your program areas

were found to be incomplete

and could not

be evaluated.

These

areas

are listed in Appendix C, "Incomplete

Emergency

Preparedness

Items."

In accordance

with

10 CFR 2.790(d)

and

10 CFR 73.21,

a copy of this letter and

the enclosures will be placed in the NRC's Public Document

Room unless

you notify

this office, by telephone,

within ten days of the date of this letter and submit

written application to withhold information contained therein within thirty days

of the

date

of this letter.

Such

applications

must

be consistent

with the

requi rements of 2. 790(1) .

850Mf0427 850422

PDR

ADOCK 05000400

9

PDR

M~d/

I(~

Carolina

Power

and Light Company

The responses

directed

by this letter are not subject to the clearance

procedures

of the Office of Management

and Budget

as required

by the Paperwork Reduction Act

of 1980,

PL 96-511.

Should you have

any questions

concerning this letter,

please

contact

us.

Sincerely,

Enclosure:

Inspection

Report

No. 50-400/85-09

cc w/encl:

R. A. Watson,

Vice President

Harris Nuclear Project

R.

M. Parsons,

Project General

Manager

bcc w/encl:

NRC Resident

Inspector

Document Control

Desk

State of North Carolina

Original Signed by

Roger D. Walker

Roger

D. Walker, Director

Division of Reactor

Projects

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APPENDIX A

EMERGENCY PREPAREDNESS

DEFICIENCIES

Based

on the results

of the

NRC's appraisal

of the Shearon

Harris Nuclear Plant

Emergency

Preparedness

Program

conducted

March 4-15,

1985,

the

following

deficiency was identified (see

Section

5.3 of NRC Report

No. 50-400/85-09):

The

Unusual

Event Matrix of Attachment

1 to

PEP-101

is inconsistent

with

NUREG-0654, Appendix 1, Notification of Unusual

Event examples.

APPENDIX B

EMERGENCY PREPAREDNESS

IMPROVEMENT ITEMS

Based

on the results

of the

NRC's appraisal

of the Shearon

Harris Nuclear

Power

Plant

(SHNPP)

Emergency

Preparedness

Program

conducted

March 4-15,

1985,

the

following items should

be considered for improvement (references

are to sections

in

NRC Report

No. 50-400/85-09).

1.

Including specific procedural

requirement for training

on

new or modified

emergency

preparedness

(EP) equipment.

(3. 1)

2.

Including

a procedural

method for training augmentation

personnel

who may be

requested

to assist

the applicant

in the

event of an

emergency condition."

(3.1)

3.

Including in the training program specific cautions to emergency

personnel

regarding safety during unusual

plant conditions.

(3. 1)

'

4.

. Placing adequate

numbers of plant procedures

in the Control

Room

so that all

operators

having

access

requirements

may easily

accomplish

their tasks.

(4.1.1)

Providing portable radio unit for Operations

Support Center

(OSC) leaders

in

the

OSC storage

cabinets.

(4. 1. 1)

6.

Providing status

board for tracking repairs,

damage,

and monitoring teams.

(4.1.1)

7.

Providing

a

minimum of one

sound-powered

phone

and cord in the

OSC storage

cabinet.

(4.1.1)

8.

Providing dosimeters with a range sufficient to monitor the limits set forth

in the emergency

plan for emergency

workers.

(4. 1. 1)

9.

Using

consistent

terminology

for "Site

Evacuation"

in

the

plan

and

procedures.

(4. 1. 1)

10.

Providing

a written agreement

between

Carolina

Power

and Light Company

and

the

National

Weather

Service

(NWS) to

document

the role of the

NWS in

emergency

response.

(4.2. 1)

11.

Eliminating

the

reference

to

mixed-mode

release

calculations if not

applicable,

or substantiation

of the

use of mixed-mode release

assumptions

(4.2.1)

12.

Standardizing

the wording

and

placement

in procedures

PEP-102

and

PEP-103

relating to the specific nondelegable

responsibilities

of the Site

Emergency

Coordinator

(SEC). (5. 1)

Appendix

B

13.

Including in the

SEC

nondelegable

responsibilities,

request

for Federal

assistance.

This responsibility

may shift to the

Emergency

Recovery

Manager

when the Emergency Operations Facility is activated.

(5.3)

14.

Completing Attachment

2 to the emergency

phone list (PSO-85-002)

to include

an introduction,

names of contact

persons for State

and local agencies,

and

NRC phone

numbers.

Consider providing pager

numbers

in Attachment

1 when

available.

( For

SHNPP emergency

response

personnel).

(5.4. 1)

15.

16.

17.

Dating

issues

of

PSO-85-002

so that

emergency

personnel

may

make timely

reviews

and assure

themselves

that current

copies

are

in use.

Consider

numbering

pages

in attachment

for easy

reference

and

assurance

that all

pages

are present

in the document.

(5.4. 1)

Providing

a checklist in PEP-102 to assist

the Site

Emergency Coordinator in

using the procedure

(5.4.2)

Modifying Attachment

2 to

PEP-104

to include

a reference

to procedure

step

9.6 which recommends

sheltering for a zone unless

the plume is

a result of a

continuous .release

of duration greater

than the evacuation

time for a given

zone. (5.4.2)

Modifying PEP-104,

Paragraph

5.3,

to

include

mention

of Attachment 4.

(5.4.2)

Reviewing Attachment

1 to PEP-104

from a

human factors standpoint.

(5.4.2)

20.

21.

22.

23.

Providing

a copy of CRC-828

and the Westinghouse

Core

Damage

Document in the

Technical

Support

Center

(TSC)

and

Emergency

Operations

Facility (EOF)

as

reference

sources.

(5.4.2)

Defining frequency of dose projection updates

in PEP-216.

(5.4.2)

Reviewing PEP-207

and

PEP-208 with aim of reducing

redundancy

and confusion.

Consider either

incorporating

PEP-208

into

PEP-207,

or making

PEP-208

a

procedure

which directs

and controls emergency

chemistry activities. (5.4.2)

Developing

a checklist of priorities for support functions'5.4.3)

24.

Developing

a checklist of priorities for performing radiological functions.

(5.4.3)

25.

26.

Reviewing

routine

procedures

that are

referenced

in PEP-371

for applica-

bility and

those

which are

not applicable

be deleted

from the reference

list. (5.4.3)

Incorporating into PEP-406,

a provision that defines precisely which manager

or director,

by title,

shall

be

responsible

for corrective

actions

identified during drills or

exercises.

Consider

identifying

in

the

procedure

the method

by which deficiencies will be documented

and including

a system that provides for corrective action deadlines.

(5.5.2)

e

Appendix

B

27.

Placing administrative

checklists

in operation for

EP unresolved

items

and

recurring requirements

to assure

timely accomplishment.

(5.5.3)

28.

Modifying emergency

plan

to reflect that distribution of Plant Operating

Manuals

(POM) is in accordance

with PGO-014. (5.5.3)

29.

Considering

engineering

design

change

to include

main control board annun-

ciator alarm for the Gross Failed

Fuel Detector

System

(GFFDS). (7.2. 1)

30.

Preparing off-normal response

procedure for alarm

on

GFFDS.

(7.2. 1)

31.

Ensuring

that

procedural

changes

are

promptly

entered

into

in-use

procedures.

(7.2.2)

32.

Ensuring that

any procedural

changes

are promptly brought to the attention

of the

cognizant

personnel,

and that

appropriate

training is ultimately

conducted.

(7.2.2)

33.

Demonstrating

the capability to perform staff augmentation within applicable

time frames with procedures

in use

or considering

acquisition of equipment

=-=- that will permit such performance.

(7.2.3)

34.

Conducting

additional

training for control

room personnel

as appropriate

when all emergency

communication circuits are installed.

(7.2.3)

APPENDIX

C

INCOMPLETE EMERGENCY PREPAREDNESS

ITEMS

Based

on the results

of the NRC's appraisal

of the Shearon

Harris Nuclear

Power

Plant

Emergency

Preparedness

Program

conducted

March 4-15,

1985,

the following

areas

or items within areas

were

found to

be

incomplete

and

could

not

be

appraised

(references

are to sections

in

NRC Report

No. 50-400/85-09).

1.

Completing respiratory protection

program training for required

personnel.

(3.2)

2.

Completing necessary

and scheduled training for State

and local agencies

as

outlined in SHNPP

Emergency

Plan Training drill and exercise

schedule

dated

3/4/85. (3.2)

3.

Completing

emergency

response facility information

system

(ERFIS) training

upon completion

and startup of the system.

(3.2)

Completing training for onsite

warning signals,

personnel

muster/assembly

and training for assembly

area

leaders.

(3.2)

Completing

emergency

personnel

makeup classes.

(3.2)

Completing

planned

walk-through

and talk-through training

and drills for

on-site

and off-site support organizations.

(3.2)

7.

Completing training for augmentation

personnel

and nonbadged

site personnel.

(3 2)

8.

Completing

general

employee training

(GET) for all personnel

on site to be

badged to enter the Protected

Area. (3.2)

9.

Completion of installation

and testing of communication

systems

(4. 1. 1)

10,

Completing installation

and testing

of accident

detection

and mitigation

equipment,

such

as

the Radiation

Monitoring System

(RMS),

ERFIS,

and

Main

Control Boards.

(4.1.1)

11.

Completing training

and qualification for Control

Room Personnel

upon all

equipment

used

in

the

detection,

classification,

notification,

and

protecti.ve

acti on

r ecommendati on.

preparati on,

and

demon str ating

the

capability to adequately

perform

same.

(4.1.1)

12.

Completing construction

items in the

TSC such

as

power systems,

ventilation,

radiation monitoring,

and facility integrity. (4.1.1)

13.

Completing installation

and testing of communication

systems.

(4.1.1)

14.

Completing stocking of emergency kits and finalizing inventories.

(4.1.1)

0

Appendix

C

15.

Completing installation/testing of ERFIS and all supporting

systems.

(4. 1. 1)

,16.

Completing training and qualification of Technical

Support

Center personnel

upon all equipment

used in the classification, notification, and protective

action

recommendation

preparation,

and

demonstrating

the

capability

to

adequately

perform

same.

(4. 1. 1)

17.

Completing

and testing the

ERFIS in the

EOF. (4. 1. 1.)

18.

19

'quipping Turbine Building first-aid room

and

assembling

and distributing

onsite

ambulance kit.

(4. 1.2)

Finishing construction of and equipping the Turbine Building decontamination

facility, and

equipping

the

waste

processing

building

and

TSC deconta-

mination facilities. (4. 1.2)

20 'ompleting

the

supplemental

procedure

PEP-402

to reflect all the emergency

equipment

and

supplies.

Supplemental

specific

information,

such

as

the

proposed

Plant Special

Order 85-014,

is

needed

and

should

include

main-

tenance responsibilities.

(4.2. 1)

21.

22.

Verifying operability

and

accuracy

of in-plant capabilities for detecting

airborne iodine in the presence

of noble gases.

(4.2. 1)

Performing operability

and calibration

procedures

after final inventories

have

been established

(4.2. 1)

23.

Completing installation

and testing of area

and process

radiation monitors.

(4.2.1)

24.

Completing

installation

and

testing

of nonradiation

process

monitors.

(4.2.1.)

25.

26

'ompleting refill-storage

area

on the

261 level of the Turbine Building.

(4.2.1)

Completing the security radio system installation. (4.2.3)

27.

28.

29.

30.

31.

Completing the onsite operations

radio repeater

system.

(4.2.3.)

Completing

the onsite public address

system

(needs full functional check).

(4.2.3)

Completing the automatic ring down phone

system (additional

remote tie-ins).

(4.2.3.)

Completing final--operational testing

on all communications

systems.

(4.2.3)

Completing stocking of reserve

emergency

equipment

and supplies.

(4.2,5)

Completing the emergency

alarm and abnormal

occurrence

procedures;

(5.2)

Appendix

C

33.

Describing in PEP-342

the dose projection method using

ERFIS. (5.4.2)

34.

Completing offsite radiological

survey procedures.

(5.4.2)

35.

Completing

procedures

for on-site

(out-of-plant)

radiological

surveys.

(5.4.2)

36.

Changing

section

2.3 of PEP-231 to reflect the deletion of HPP-805

and the

addition of HPP-060.

(5.4'.)

37.

Completing the printing and distribution of survey forms in the appropriate

procedures.

(5.4.2)

38.

Providing

primary

orientation

and

training

on

Emergency

Signals

and

Procedures.

(5.4.2)

39 'Providing

equipment

training

and

demonstrating

personnel

accountability.

(5.4.3)

40.

Completing the security system.

(5.4.4)

41.

Completing

Shearon

Harris

site

specific

training for corporate

public

information personnel.

(5.4.7)

42.

Completing public education

on the Shearon

Harris plant. (5.4.4)

43.

Completing procedures

for inventorying, operationally checking

and

calibrating emergency

equipment, facilities, and supplies.

(5.5. 1)

44.

Completing training for State

and county agencies.

(6. 1)

45.

Completing the emergency kits for both hospitals.

(6. 1)

46.

Submitting the final issue of the public information brochure for review of

FERA/NRC. (6.2)

47.

Completing placing public notices for transients.

(6.2)

48.

Initiating the drill and exercise

program.

(7. 1)

49.

Completing

procedures

for dose calculation

and protective action decision-

making. (7.2.4)