IR 05000155/1986002

Insp Rept 50-155/86-02 on 860106-09.No Violations or Deviations Noted.Major Areas Inspected:Changes to Emergency Preparedness Program,Knowledge & Performance of Duties, Licensee Audits & Actions on Previously Identified Items

ML20140F108
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	01/29/1986
From:	Phillips M, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140F095	List: IR 05000155/1986002 ML20140F089
References
50-155-86-02, IEB-80-15, NUDOCS 8602040244
Download: ML20140F108 (7)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/86002(DRSS)

Docket No. 50-155 License No. OPR-6 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Big Rock Point Plant Inspection At: Big Rock Point Site, Charlevoix, MI Inspection Conducted: January 6-9, 1986 Inspectors: W. Sne b d E d 1/ 2>/hc Lead Inspector Date it ; /k-WfSL

, Date Approved By: .

h@lps, Chief, 29/

Emergency Preparedness Date Section Inspection Summary Inspection on January 6-9, 1986 (Report No. 50-155/86002(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program: changes to the emergency preparedness program; knowledge and performance of duties (training); licensee audits; activations of the emergency plan; and licensee actions on previously-identified item The inspection involved 52 inspector-hours by two NRC inspector Results: No violations or deviations were identified, hhj2040244060129 G ADOCK 05000155 PDR

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DETAILS Persons Contacted

• D. Hoffman, Plant Superintendent

• R. Abel, Production and Performance Superintendent

• L. Monshor, NAD and QA Superintendent

• J. Beer, Chemistry and Health Physics Superintendent

• R. Alexander, Technical Engineer

• J. Werner, Senior Nuclear Emergency Planning Coordinator G. Petitjean, Planning and Administrative Superintendent R. Scheels, Shift Supervisor G. Sonnenberg, Shift Supervisor D. Staton, Shift Supervisor M. Hobe, Nuclear Trainer II L. Oostemeyer, Administrative Supervisor

• Denotes those present at the exit interview on January 9, 198 . Licensee Actions on Previouly-Identified Notices of Violation Related to Emergency Preparedness (Closed) Open Item No. 155/84014-01, Notice of violation for failure to include an evaluation for adequacy of interfaces with the State and local governments in the March 19-23, 1984 annual audi The corrective action taken to avoid further noncompliance was examined by the inspector. Corrective action included working out a Letter of Agreement between Consumers Power Company and the Detroit Edison Company (dated November 26, 1984) to provide the necessary independent review of the Big Rock Point Emergency Preparedness Program and ensure compliance with 10 CFR Part 50.54(t). The criteria by which Consumers Power Company / Detroit Edison reviews are conducted was formalized and included examining the sixteen planning standards of 10 CFR Part 50.47b. The inspector reviewed the Detroit Edison Company independent review of the Big Rock Point Emergency Preparedness Program conducted May 18-25, 1985. This review included an evaluation of the adequacy of interfaces with the State and Local governments in accordance with 10 CFR Part 50.54(t). This item is close (Closed) Open Item No. 155/84014-02, Notice of Violation for failure to perform semiannual Health Physics drills as required by the Site Emergency Plan. A review of the licensee's records determined that semi-annual Health Physics drills were performed in December 1984, May 1985 and December 1985. To ensure that these drills are performed in the future, the licensee established a computerized tracking system that was examined by the inspector. This system should be adequate to ensure the performance of drills when required. This item is close )

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3. Licensee Actions on Previously-Identified Open Items Related to Emergency Preparedness (Closed) Open Item No. 155/840XX-01, Backup Communications Capability: As a result of a loss of significant communications capability due to a loss of power at the Palisades Plant, an examination was made of the backup communications capability at the Big Rock Point Plant in the event of a loss of power at the Big Rock Point facilit CFR Part 50, Appendix E., IV.E.9 requires that the licensee's have "At least one onsite and one offsite communications system; each system shall have a backup power source." In addition, IE Bulletin No. 80-15 dated June 18, 1980 required licensee's to provide adequate backup power for the Emergency Notification System

_(ENS). In a response to IE Bulletin No. 80-15, the licensee determined that the ENS was powered from the safeguards instrumentation bus 1Y which receives power from the emergency diesel generator upon loss of offsite power. The Health Physics Network (HPN) was not connected to bus 1Y, but the licensee committed to add it to bus 1 During the January 6-9, 1986 inspection, the licensee reconfirmed that both the ENS and HPN were on the safeguards instrumentation bus 1 Backup notification capability to State and local authorities is available via a State Police radio installed in the Security Buildin The inspector determined that in the event of a loss of power at the Big Rock Point Plant, backup communications capability should be adequat This item is close (Closed) Open Item No. 155/84003-02, Shift Augmentation: During the May 22, 1984 annual exercise, one of the objectives was to demonstrate the capability to augment the onshift staff within 30 and 60 minute timeframes as specified in the Big Rock Point Plant Site Emergency Plan. The licensee failed to demonstrate this objective during the exercise, and it was not an objective of the May 1985 exercis Initial corrective actions taken by the licensee to address this item included a review of shift augmentation procedures resulting in changes in training and the Emergency Plan Implementing Procedures. These actions were acceptable to close out Open Item No. 155/84003-0 However, over 19 months have elapsed since the last attempt to demonstrate an acceptable level of shift augmentation capabilit CFR Part 50, Appendix E, IV.F.5 states that "All training, including exercises, shall provide for formal critiques in order to identify weak or deficient areas that need correctio Any weaknesses or deficiencies that are identified shall be corrected."

Since there has been no redemonstration of the licensee's 30 and 60 minute shift augmentation capabilities since the May 1984 exercise, a drill to verify this capability should be conducte In addition, the Site Emergency Plan should be revised to specify that shift augmentation drills be conducted semi-annually to demonstrate this capability on an ongoing basis. This will be tracked under a new Open Item No. 155/86002-0 . . (Closed) Open Item No. 155/85001-XX, Unusual Event Declared January 1, 1985: On January 1, 1985 an Unusual Event was declared based on exceeding a Limiting Condition of Operation. This event was properly classified as discussed in IE Report No. 155/84017. An examination of the event determined that offsite notifications to State and local authorities were within the required 15 minute time period after classificatio Notifications to the NRC were discussed in IE Report No. 155/84017. This item is close (Closed) Open Item No. 155/85002-XX, Loss of Telephone Capability on July 13, 1985: On July 13, 1985, the Big Rock Point Plant experienced a partial loss of offsite communications as a result of Michigan Bell Telephone inadvertently cutting a toll cabl An examination was made of the events to ensure that it was properly handled from an emergency preparedness standpoint. The licensee did not and was under no obligation to classify this event per the Site Emergency Pla However, the local and State authorities and the NRC were notified of the event The licensee's actions were appropriat This item is close . Licensee Actions Related to Unusual Event Declared May 31, 1985 On May 31, 1985, an Unusual Event was declared due to exceeding a Limiting Condition of Operation. An examination of this event determined that it was appropriately classified according to the Big Rock Point Site Emergency Plan Implementing Procedures. In addition, notifications to all offsite authorities were completed within the required time limit . Changes to the Emergency Preparedness Program (82204)

Chapter 10, Section 6.0, of the Big Rock Point Plant Technical Specifications specifies that written procedures shall be established, implemented and maintained for all systems, structures, components and safety actions at the Big Rock Point Plant. The Plant Review Committee (PRC) is responsible for the review of all changes to these procedures and the Plant Superintendent approves all additions and changes prior to implementation. A review of hard copy and micro film files of the Site Emergency Plan and Implementing Procedure records for 1985 confirmed that changes and improvements to the Site Emergency Plan and the Implementing Procedures were reviewed and approved by the PRC and Plant Superintendent as require The licensee has implemented a computerized tracking system to aid in the administration of the Emergency Preparedness Program. This tracking system should help ensure timeliness in completing scheduled changes to the Emergency Preparedness Program and ensure that all changes are reflected in the Site Emergency Plan and Implementing Procedures. The inspector reviewed this tracking system and determined that it should be helpful to the Emergency Preparedness Coordinator in maintaining the Emergency Preparedness Progra /

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Changes to the Site Emergency Plan were submitted to the NRC within the time frames specified in 10 CFR 50.54(q). In addition, a~ spot check of changes to the Implementing Procedures determined that they continued to adequately implement the Site Emergency Plan. The inspector also determined through the review of administrative distribution control forms and logs that changes to the Emergency Plan and Implementing Procedures were distributed to the proper licensee and non-licensee personnel in a timely manne Based on the above findings, this portion of the licensee's program is adequat . Knowledge and Performance of Duties (Training) (82206)

To assess the quality of the training program in the area of emergency preparedness, walkthroughs were conducted with three Shift Supervisors and two Site Emergency Directors to determine their proficiency and knowledge in implementing their assigned emergency response duties. None of the three Shift Supervisors had been interviewed during the last routine emergency preparedness inspection in November 1984, and both the Site Emergency Directors interviewed were alternates to the positio The walkthroughs with the Shift Supervisors included hands on use of the Site Emergency Plan Implementing Procedures to classify an event, make the proper Protective Action Recommendations, make all required notifications, ensure the content of the initial and followup notifications were adequate, and ensure knowledge of additional responsibilities in their role as the interim Site Emergency Director. Walkthroughs with the Site Emergency Directors were similar in nature and content, with additional emphasis on command and control responsibilities, shift augmentation and functions of the Emergency Operations Facilit With one exception, all personnel were knowledgeable and proficient in their assigned responsibilitie The exception was one Shift Supervisor who demonstrated a marginal familiarity with the Implementing Procedure Although this individual was able to properly respond to all questions after a sufficient period of time, delays of this nature due to a lack of familiarity with the procedures could cause detrimental delays during an actual incident. One problem was observed that was common to all three Shift Supervisors. Because the titles on the tabs for the Emergency Preparedness Implementing Procedures did not always correspond to the procedura behind the tab, difficulties and delays were experienced in finding the correct procedures. This may be easily corrected by providing new tabs for the Implementing Procedures. This will be tracked as Open Item No. 155/86002-0 Emergency preparedness training at Big Rock Point is conducted by the Consumers Power Company Midland Training Cente The Training Center sends an instructor to the site one day each month to conduct emergency preparedness training. If additional training such as individual tutoring or makeup tests are necessary, the instructor will stay an additional da All training modules are covered in a three month period, which ensures

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that any new employees can be trained within three months, and allows flexibility in scheduling training around normal work assignments with four opportunities a year to obtain annual trainin After each module has been presented, a ten question test is given with at least seven correct answers necessary to pas The inspectors sat in on a portion of this training during the week of the inspection. The training sessio n n Emergency Action Levels was observed, and a review was made of the tests on the communications module and protective action recommendation module. The training session observed was sufficiently thorough and well conducte The tests were adequate to ensure personnel had a good working knowledge of the areas covere Based on the above findings, this portion of the licensee's program is adequat . Licensee Audits (82210)

The inspector reviewed the May 18-25, 1985 independent review of the Big Rock Point Emergency Preparedness Program to determine that an independent review was conducted in accordance with 10 CFR 50.54(t). This review was conducted by three Emergency Preparedness counterparts from the Detroit Edison Company per a Letter of Agreement signed November 26, 1984, thus ensu ing an independent review. The scope of the Detroit Edison review included the sixteen planning standards of 10 CFR Part 50.47(b),

examination of the Site Emergency Plan and a critique of the 1985 annual exercise. The last independent review was conducted in March, 1984. The timeliness of this review is sufficient to meet the requirement that an annual review be conducted every twelve month The inspector determined the 1985 review was comprehensive, detailed and fulfilled the requirements of 10 CFR 50.54(t).

An audit of the Emergency Plan and Implementing Procedures was conducted December 15, 1985, by Consumers Power Company corporate audit staf Improvement items are presently being reviewed by the Emergency Preparedness staff of the Big Rock Point Plan The independent review (report dated May 18-25, 1985) was sent to Consumers Power Company via cover letter dated July 25, 1985 from Detroit Edison and was reviewed by the inspector. Items for improvement noted in this review were placed on a corporate corrective action system with completion dates of May 198 This report is on file, available for State and Local governments and will be maintained for five years; however, there are no provisions to inform the State or local governments of the completion of the audi Based on the above findings, this portion of the licensee's program is adequate; however, the following item should be considered for improvements:

• The licensee should notify State or local gove nments of the completion of any audit involving interfaces with the .. .

8. Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on January 9, 198 The inspectors summarized the scope and findings of the inspection. The licensee was asked to inform the inspectors if any of the information was considered proprietar The licensee did not indicate that any of the information was proprietar