IR 05000261/2006008
| ML062640103 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 09/15/2006 |
| From: | Bonser B R NRC/RGN-II/DRS/PSB2 |
| To: | Walt T D Carolina Power & Light Co |
| References | |
| IR-06-008 | |
| Download: ML062640103 (15) | |
Text
September 15, 2006
Carolina Power & Light Company ATTN:Mr. T. D. WaltVice PresidentH. B. Robinson Steam Electric Plant, Unit 2 3581 West Entrance Road Hartsville, SC 29550
SUBJECT: NRC INSPECTION REPORT NO. 05000261/2006008
Dear Mr. Walt:
On August 14-18, 2006, the U. S. Nuclear Regulatory Commission (NRC) conducted aninspection at your H. B. Robinson Steam Electric Plant, Unit 2. The enclosed inspection report documents the inspection findings, which were discussed on August 18, 2006, with you and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.
The inspector reviewed selected procedures and records, observed activities, and interviewed personnel.Based on the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and itsenclosure will be available electronically for public inspection in the NRC Public DocumentRoom or from the Publicly Available Records (PARS) component of NRC's document system(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).Should you have any questions concerning this letter, please contact us.
Sincerely,/RA/Brian R. Bonser, ChiefPlant Support Branch 2 Division of Reactor SafetyDocket No. 50-261License No. DPR-23
Enclosure:
(See page 2)
CP&L 2
Enclosure:
NRC Inspection Report 0500261/2006008
w/Attachment:
Supplemental Informationcc w/encl:William G. Noll Director, Site Operations Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionErnest J. Kapopoulos, Jr.Plant General Manager Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionChris L. Burton, ManagerPerformance Evaluation and Regulatory Affairs CPB 9 Electronic Mail DistributionC. T. Baucom, SupervisorLicensing/Regulatory Programs Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionJ. F. Lucas, ManagerSupport Services - Nuclear Carolina Power & Light Company H. B. Robinson Steam Electric Plant Electronic Mail DistributionHenry J. Porter, DirectorDiv. of Radioactive Waste Mgmt.
Dept. of Health and Environmental Control Electronic Mail DistributionR. Mike GandyDivision of Radioactive Waste Mgmt.
S. C. Department of Health and Environmental Control Electronic Mail Distribution(cc w/encl cont'd - See page 3)
CP&L 3(cc w/encl cont'd)Beverly Hall, Acting Director Division of Radiation Protection N. C. Department of Environment, Health and Natural Resources Electronic Mail DistributionDavid T. ConleyAssociate General Counsel - Legal Dept.
Progress Energy Service Company, LLC Electronic Mail DistributionJohn H. O'Neill, Jr.Shaw, Pittman, Potts & Trowbridge 2300 N. Street, NW Washington, DC 20037-1128Chairman of the North Carolina Utilities Commission c/o Sam Watson, Staff Attorney Electronic Mail DistributionRobert P. GruberExecutive Director Public Staff - NCUC 4326 Mail Service Center Raleigh, NC 27699-4326Public Service CommissionState of South Carolina P. O. Box 11649 Columbia, SC 29211Distribution w/encl
- C. Patel, NRR RIDSNRRDIRS PUBLIC
_________________________OFFICERII:DRPRII:DRSRII:DRSSIGNATURERARARANAMEDESAIBONSERKREHDATE9/15/20069/15/20069/15/20069/ /20069/ /20069/ /20069/ /2006 E-MAIL COPY? YESNO YESNO YESNO YESNO YESNO YESNO YESNO EnclosureU. S. NUCLEAR REGULATORY COMMISSIONREGION IIDocket Nos:50-261 License No: DPR-23 Report No:05000261/2006008 Licensee:Carolina Power & Light Company Facility:H. B. Robinson Steam Electric Plant, Unit 2 Location:3581 West Entrance RoadHartsville, SC 29550Dates:August 14-18, 2006 Inspector:J. Kreh, Emergency Preparedness Inspector Approved by:Brian R. Bonser, ChiefPlant Support Branch 2 Division of Reactor Safety
SUMMARY OF FINDINGS
IR 05000261/2006008; 08/14-18/2006; H. B. Robinson Steam Electric Plant, Unit 2;Emergency Preparedness Baseline InspectionThis report covers an announced inspection conducted by a Region II emergency preparednessinspector. The NRC's program for overseeing the safe operation of commercial nuclear powerreactors is described in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000.A.
NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
B.Licensee-Identified Violations
.
None
REPORT DETAILS
1.REACTOR SAFETYCornerstone: Emergency Preparedness 1EP2 Alert and Notification System (ANS) Testing
a. Inspection Scope
The inspector evaluated the adequacy of licensee methods for testing the alert andnotification system in accordance with NRC Inspection Procedure 71114,Attachment 02, "Alert and Notification System Testing." The applicable planning standard 10 CFR 50.47(b)(5) and related requirements contained in Section IV.D of Appendix E to 10 CFR Part 50 were used as reference criteria. The evaluation criteria contained in NUREG-0654, "Criteria for Preparation and Evaluation of RadiologicalEmergency Response Plans and Preparedness in Support of Nuclear Power Plants,"
Revision 1; and Federal Emergency Management Agency (FEMA) Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants" were also applied. This inspection activity represents one sample on a biennial cycle.The inspector reviewed various documents which are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified.1EP3 Emergency Response Organization (ERO) Augmentation
a. Inspection Scope
The inspector reviewed the ERO augmentation staffing requirements and the processfor notifying ERO personnel to ensure the readiness of key staff for responding to an event and the capability for timely facility activation. The results of periodic EROcommunications drills were reviewed. The inspector examined the provisions for abackup notificati on system. A sample of problems identified from augmentation dr illsand ERO pager system tests was reviewed to assess the effectiveness of correctiveactions. The inspection was conducted in accordance with NRC Inspection Procedure 71114,Attachment 03, "Emergency Response Organization Augmentation." The applicable planning standard 10 CFR 50.47(b)(2) and related requirements contained in Appendix E to 10 CFR Part 50 were used as reference criteria. This inspection activity represents one sample on a biennial cycle.The inspector reviewed various documents which are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified.1EP4 Emergency Action Level (EAL) and Emergency Plan Changes
a. Inspection Scope
The inspector reviewed the Emergency Plan changes for Revisions 59 and 60 (the latterwas the version in effect at the time of the inspection). The EAL modifications made in Revision 60 to address NRC Bulletin 2005-02 were reviewed in detail.The inspection was conducted in accordance with NRC Inspection Procedure 71114,Attachment 04, "Emergency Action Level and Emergency Plan Changes." The applicable planning standard 10 CFR 50.47(b)(4) and related requirements contained in 10 CFR 50.54(q) and Appendix E to 10 CFR Part 50 were used as reference criteria.
This inspection activity represents one sample on an annual cycle.The inspector reviewed various documents which are listed in the Attachment to thisreport.
b. Findings
Introduction.
The inspector determined that there were several inconsistencies betweenthe EALs in PLP-007, Robinson Emergency Plan, Revision 60, and the EAL guidance provided in NUREG-0654, Appendix 1, Revision 1, which nominally comprises the basisfor the licensee's emergency classification scheme. Further NRC review and internalagency discussions will be required to determine whether the changes made over timehave resulted in a "blending" of NUREG-0654 and NUMARC/NESP-007 EAL schemesin the licensee's emergency classification methodology, and to determine whether such changes constitute decreases in the effectiveness of the licensee's Emergency Plan. This is categorized as an unresolved item (URI) pending completion of further NRC staffreview.Description. The inspector noted differences between the formally approved and thecurrent versions of the NUREG-0654-based emergency classification scheme or EALscontained in the Robinson Emergency Plan. The inspector preliminarily determined that most of the differences appeared to be attributable to changes based on the NRC staffguidance contained in EPPOS [Emergency Preparedness Position] -1, dated June 1, 1995. EPPOS-1 was intended to provide guidance to the NRC staff regarding theacceptability of incorporating selected NUMARC/NESP-007 EALs (including bothdeletions and changes allowed by the NUMARC/NESP-007 methodology) into a NUREG-0654-based classification scheme. The NRC's intention was that licenseeswishing to adopt changes listed in EPPOS-1 would request prior NRC approval for suchchanges. Further NRC review will be required to determine the extent of condition andhow to disposition this potential finding.
5Analysis. This potential finding affects the Emergency Preparedness Cornerstone andis considered to be more than minor because the Emergency Preparedness attribute of procedure quality was affected. This, in turn, affects the Emergency Preparedness objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Due to the nature of this issue (affecting the regulatory process), traditional enforcement would be applied instead of the Significance Determination Process (SDP).Enforcement. 10 CFR 50.54(q) states, in part, that the licensee may make changes toemergency plans without Commission approval only if the changes do not decrease the effectiveness of the plans, and the plans, as changed, continue to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.Section IV.B of Appendix E states, in part, that a revision to an EAL must be approved by the NRC before implementation if the licensee is changing from one EAL scheme to another EAL scheme (e.g., a change from an EAL scheme based on NUREG-0654 to one based onNUMARC/NESP-007 or NEI 99-01).Proposed changes that decrease the effectiveness of the approved Emergency Planmay not be implemented without application to and approval by the Commission. The licensee made changes to its Emergency Plan which appeared to reduce the effectiveness of the Plan and appeared to be inconsistent with NUREG-0654 EALscheme, and to utilize an alternative EAL scheme. These changes were not submittedto the NRC for approval prior to implementation. Pending further NRC review necessaryto provide the proper scope regarding the significance of the blending of the EAL schemes and EAL changes that were made to the Robinson Emergency Plan, this finding is identified as URI 05000261/2006008-001, Blending of EAL Schemes.1EP5 Correction of Emergency Preparedness Weaknesses and Deficiencies
a. Inspection Scope
The inspector reviewed the corrective actions identified through the emergencypreparedness program in an effort to ascertain the significance of the issues and to determine whether repetitive problems were occurring. The facility's self-assessmentsand audits were reviewed to assess the licensee's ability to be self-critical, thus avoidingcomplacency and degradation of its emergency preparedness program. In addition, the inspector reviewed the licensee's self-assessments and audits to assess the completeness and effectiveness of a sample of emergency preparedness-related corrective actions. Documentation of all emergency declarations since the December 2004 inspection was reviewed in detail.The inspection was conducted in accordance with NRC Inspection Procedure 71114,Attachment 05, "Correction of Emergency Preparedness Weaknesses and Deficiencies." The applicable planning standard 10 CFR 50.47(b)(14) and related requirements contained in Appendix E to 10 CFR Part 50 were used as reference criteria. This inspection activity represents one sample on a biennial cycle.
6The inspector reviewed various documents which are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified.4.OTHER ACTIVITIES 4OA1Performance Indicator (PI) Verification
a. Inspection Scope
The inspectors reviewed the licensee's procedure for developing the data for theEmergency Preparedness PIs, which are:
- (3) Alert and Notification System (ANS) Reliability. Theinspectors examined data reported to the NRC for the five-quarter period April 1, 2005to June 30, 2006. Procedural guidance for reporting PI information and records used by the licensee to identify potential PI occurrences were also reviewed. The inspectors verified the accuracy of the PI for ERO DEP through review of a sample of drill andevent records. The inspectors reviewed selected training records to verify the accuracy of the PI for ERO drill participation for personnel assigned to key positions in the ERO. The inspectors verified the accuracy of the PI for ANS reliability through review of asample of the licensee's records of periodic system tests. The inspection was conducted in accordance with NRC Inspection Procedure 71151,"Performance Indicator Verification." The applicable planning standard 10 CFR 50.9 and NEI 99-02,"Regulatory Assessment Performance Indicator Guidelines," Revisions 3 and 4, were used as reference criteria. This inspection activity represents three samples on an annual cycle.The inspectors reviewed various documents which are listed in the Attachment to thisreport.
b. Findings
No findings of significance were identified.4OA6Meetings, including ExitOn August 18, 2006, the inspector presented the inspection results to Mr. T. Walt, VicePresident, and other members of his staff who acknowledged the findings. The inspector stated that additional information may be requested relative to the URI discussed in Section 1EP4.ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- C. Baucom, Licensing Supervisor
- B. Clark, Manager, Nuclear Assessment Section
- E. Kapopoulos, Plant General Manager
- J. Lucas, Manager, Support Services - Nuclear
- G. Ludlam, Manager, Training
- W. Noll, Director, Site Operations
- T. Tovar, Radiation Control Superintendent
- T. Walt, Vice President
- S. Wheeler, Supervisor, Emergency Preparedness
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000261/2006008-01URIBlending of EAL Schemes. (Section 1EP4)
Closed
- None
Discussed
None
2Attachment
LIST OF DOCUMENTS REVIEWED
Section 1EP2: Alert and Notification System TestingProceduresEPPRO-2, Maintenance and Testing, Revision 24EPPRO-7, Operation and Maintenance of the Alert and Notification System Revision 1Records and DataDocumentation of 2005 Telecom preventive maintenance (per Attachment 10.3 of
- EPPRO-7)Documentation of 2005-2006 siren mechanical and electrical preventive maintenance
(per Attachment 10.4 of EPPRO-7)
- Siren system availability test records for January 2005 through July 2006
Section 1EP3: Emergency Response Organization (ERO) Augmentation ProceduresEPPRO-2, Maintenance and Testing, Revision 24Records and DataDocumentation of
- ERO Communications Drills conducted 01/25/2005, 04/26/2005, 0728/2005,
- 11/10/2005, 02/
- 07/2006, 05/23/2006
Section 1EP4: Emergency Action Level (EAL) and Emergency Plan Changes Plans and ProceduresRobinson Emergency Plan, Revision 59Robinson Emergency Plan, Revision 60
- EPCLA-02, Emergency Action Level User's Guide, Revision 14Records and Data10
- CFR 50.54(q) Emergency Preparedness Program Evaluation for Revision 5910
- CFR 50.54(q) Emergency Preparedness Program Evaluation for Revision 60
- CFR 50.54(q) Emergency Preparedness Program Evaluation for
- EAL-1 (Rev. 14) and EAL-2
(Revision 20)
- 3Attachment
Section 1EP5: Correction of Emergency Preparedness Weaknesses and Deficiencies ProceduresCAP-NGGC-0200, Corrective Action Program, Revision 17Audits and Self-AssessmentsNAS Report File No.
- R-EP-05-01, Robinson Nuclear Plant Emergency Preparedness
- Assessment Report
- NAS Report File No. R-EP-06-01, Robinson Nuclear Plant Emergency Preparedness Assessment Report Self-Assessment Report No.
- 141652, RASCAL Implementation at Robinson Nuclear Plant Self-Assessment Report No.
- 141648, Cross-Functional Self-Assessment of the Robinson Emergency Plan and Implementation Procedures Self-Assessment Report No.
- 176155, Emergency Plan and Implementing ProceduresRecords and DataDocumentation packages (scenario/time line/drill notification forms/critique report) for ERO drill on 11/08/2005
- Documentation packages (Control Room log/event time line/event notification forms/critique report/NCRs) for Notification of Unusual Event declaration on 12/27/
- 2004Nuclear Condition Reports (NCRs)147116, KPI for ANS is Red147577, 2004 DEP Performance Indicator rollup
- 148132, Dialogic modem failure
- 153054, DEP Performance Indicator data
- 154529, Drill press release deficiencies154999, Accident monitoring protocols for failed fuel indications
- 155072, Misinterpretation of
- EAL-1 by drill partici pants155074, Problems with preparation of emergency notification forms
- 155075, Training on
- EPPRO-7, Revision 0
- 155885, Radiation Control/Operations interface in the Operational Support Center156492, Alert declaration not made during the 04/12/2005 drill
- 159007, Confirmation received on inadvertent siren activation
- 175529, Emergency notification form errors during drill
- 195550, Call collisions during 05/23/2006 communications drill195551, ERO personnel called to fill more than one ERO position198228, ERO communications and equipment failures and alarms
- 198661, Siren system alarm increase198849, Communication between the met tower and siren computer lost
- 4Attachment
Section 4OA1: Performance Indicator (PI) VerificationRecords and DataSiren System Availability Test Records for April 2005 - June 2006Documentation (scenario/time line/event notification forms/critique report) for
- ERO drill on
- 11/08/2005
- Documentation of DEP Opportunities from Operations Simulator evaluations on 04/04/2005,
- 11/17/2005, 11/22/2005, 11/30/2005, 12/07/2005, 03/01/2006, 05/31/2006Records of drill and exercise participation by selected key ERO personnel in 2005
- 5Attachment
LIST OF ACRONYMS
- AND [[]]
INITIALISMSANSAlert and Notification System DEPDrill and exercise performanceEALEmergency Action Level
EPPOEmergency Preparedness Position
EROEmergency Response Organization
FEMAFederal Emergency Management Agency
NASNuclear Assessment Section
PIPerformance Indicator
SDPSignificance Determination Process