IR 05000155/1987028

Insp Rept 50-155/87-28 on 871130-1204.No Violations or Deviations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Action on previously- Identified Items,Emergency Plan Activations & LER Review

ML20238C465
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/23/1987
From:	Foster J, Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20238C449	List: IR 05000155/1987028 ML20238C448
References
50-155-87-28, NUDOCS 8712310025
Download: ML20238C465 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-155/87028(DRSS)

Docket No. 50-155 License No. DPR-6 Licensee: Consumers Power Company 212 West Madison Avenue Jackson, MI 49201 Facility Name: Big Rock Point Nuclear Plant Inspection At: Big Rock Point Site, Charlevoix, Michigan Inspection Conducted: November 30 through December 4, 1987 Inspectors: tterson / 7J!ff Date J. Foster '

n/o47 Date W.{Snell, Chief Approved By: _ // b 27/*p Emergency Preparedness Date Section Inspection Summary Inspection on November 30 through December 4,1987 (Report No. 50-155/87028(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the Big Rock Point Power Station's Emergency Preparedness program: action on previously-identified items emergency plan activations; LER review; operational status of the emergency preparedness program; dose assessment; notifications and communications; shift staffing and augmentation; emergency preparedness (training); licensee audits; and maintaining emergency preparedness. The inspection involved two NRC inspector Results: No violations or deviations were identifie DR 871223 ADOCK 05000155

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DETAILS 1. Persons Contacted Consumers Power Company

• T. Elward, Plant Manager

• T. Fisher, Quality Assurance

• A. Katarsky, Emergency Preparedness, General Office

• R. Alexander, Technical Engineer

• J. Beer, Chemistry and Health Physics Superintendent

• Hobe, Emergency Preparedness Coordinator (EPC)

• P. Donnely, Nuclear Assurance Administrator N. Abend, Nuclear Training Clerk

• Denotes those personnel listed above who attended the exit interview on December 4,198 . Licensee Action on Previously-Identified Items (Closed) Open Item No. 155/81017-22: Licensee request for exemption from the habitability requirements for the Technical Support Center (TSC). By letter dated December 30, 1983, the Division of Nuclear Reactor Regulation (NRR) indicated that no major modifications to the Control Room need be done for habitability (the Control Room and TSC are adjacent, and share the same overall shielding and air envelope). The Big Rock Point Safety Evaluation Program (SEP),

published as NUREG-0828 (May 1984) addressed this item in Section No. 5.3.5.2., " Control Room Habitability - NUREG-0737 - SEP Topic VI-8." While the worst-case event of core melt and containment failure would make the primary Control Room essentially uninhabitable, no modifications were found be be cost effectiv The licensee proposed that installing a seal between the service building and control building would be cost effective for some postulated accident scenarios, and this was done. This item is closed, (Closed) Open Item No. 155/86015-01: Matrix 5.06 of Administrative Procedure 1.7, Master Training Plan, was inconsistent in its training modules, as it related to core damage and Dose Assessment training requirements for designated On-Call-Technical Advisors (OTAs), with the areas of responsibility as listed in EPIP 4C and EPIP 5 The SEP matrix, Revision 8, approved November 10, 1987, now lists the training module requirements for OTAs and the On-Call Dose Assessors which, corresponds with the areas of responsibilities as indicated in the respective EPIPs. The revised matrix no longer requires On-Call Dose Assessors to receive Post Accident Sampling System (PASS)

trainin All On-Call Dose Assessors and 0TAs have had required EP training including Core Damage for OTAs (but no Dose Assessment)

Dose Assessors still receive Core Damage training, but not PASS trainin This item is close l i

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. '(Closed) Violation No. 155/86015-02: Failure to make the annual review required by 10 CFR 50.54(t) (offsite interface) to offsite authorities; This years audit (QT-87-6) and a rolated surveillance report (S-QG-87-69) adequately documented the required review and the fact that it was made available to offsite authorities. This item is close . Emergency Plan Activations l A review of licensee and NRC records indicated that two activations of l the licensee's Emergency Plan had taken place since the last inspectio On January 31,1987, at 0440 hours0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> (with the reactor in cold shutdown),

smoke.was reported in the Station Power Room. The plant fire brigade responded to the fire, and an Alert was declared at 0445 hour0.00515 days <br />0.124 hours <br />7.357804e-4 weeks <br />1.693225e-4 months <br /> Within four minutes, the fire brigade indicated that actions taken had terminated the event, and the Senior Reactor Operator terminated the Alert. The decision was made not to activate the emergency response facilities due to the short duration of the event, and this was considered appropriate.

i On June 23, 1987, (with the reactor at 62% power) a fire alarm was received from the area outside of the cable penetration room at 0321

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hours. The plant fire brigade responded to the fire alarm, and an Alert was declared at 0325 hours0.00376 days <br />0.0903 hours <br />5.373677e-4 weeks <br />1.236625e-4 months <br />. The fire brigade found that a cord on a dehumidifier in the cable penetration room was overheated and smoking, and unplugged the cord. Cable trays in the area were inspected to assure they were not also smoking. Personnel accountability began at 0349 hours0.00404 days <br />0.0969 hours <br />5.770503e-4 weeks <br />1.327945e-4 months <br /> and was completed at 0415 hours0.0048 days <br />0.115 hours <br />6.861772e-4 weeks <br />1.579075e-4 months <br />. The On-Call Superintendent arrived at the site and assumed the duties of Site Emergency Director (SED) at 0355 hours0.00411 days <br />0.0986 hours <br />5.869709e-4 weeks <br />1.350775e-4 months <br />. The SED chose not to activate the emergency organization, as the fire was out and further problems were not indicated, and this was considered appropriate. The SED terminated the Alert at 0440 hour0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> Documentation related to each plan activation was reviewed. Event classifications and notifications had been performed promptly and within timeframe goal A file documentation package had been assembled for each event, in general consisting of log forms, Event Notification Worksheets, and written summary mem The event summary memo included an overview of actions taken, timeframes for events, and comments as to problems experience While no specific problems were identified, it is recommended that the licensee determine which documents related to activations should be collected. Activation packages could be expanded to contain documentation related to corrective actions in areas where problems were identifie (

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During the inspection, a review of Licensee Event Reports (LERs) generated during December 1986 through December 1987 was performed to determine if events had been properly classified under the Emergency Preparedness program. The following LERs were reviewed:

LER N Brief Description 87-001 Reactor Trip - Upscale /Downscale 87-002 Relay Drift Causing Undervoltage Trip To Be Inoperable 87-003 Inoperable Primary System Safety Valves87-004 Inoperable Reactor Depressurization Snubbers87-005 Personnel Error - Technical Specification Violation 87-006 Informational-EEQ Cable Documentation Deficiency 87-007 Reactor Trip - Upscale /Downscale 87-008 Non qualified EEQ Splices87-009 Effluent Release Without Radwaste Monitor in Service 87-010 Reactor Trip - Spurious Short Period All LER events were found to be properly classified as not falling under the Emergency Plan event classification scheme (no Emergency Action Level had been met).

No violations of regulatory requirements or deviations from commitments were identifie . Operational Status of the Emergency Preparedness Program (82701) EmergencyPlanandImplemenQngProcedures(Also82204)

The Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) were reviewed. The Big Rock Point Plant Site Emergency Plan (SEP) defines initiating conditions, or plant parameters for each emergency classification, and references Appendix "M" (in Chapters 3, 4, 6, and Appendix P), which provides example initiating conditions for each classificatio EPIP No. 1, " Activation of the Emergency Plan" provides specific events or parameters and event

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classifications to implement the guidance in Appendix "M".

The licensee's emergency classification and action level scheme was generally consistent with the guidance contained in Appendix 1 of NUREG-0654, Revision 1. Some differences were observed, as the Emergency Plan initiating conditions, or Emergency Action Levels (EALs) were initially developed based on a Probabilistic Risk Assessment specific to the Big Rock Point Plan Licensee personnel indicated that both Appendix "M" of the SEP and EPIP No. I were in the process of revision, and approved revisions l

would be submitted to the NRC for approval in the near future. A

) review of the draft revisions indicated that while most errors had been identified and corrected, several errors remained in Appendix "M" (principally in Page 7 of 18) which would require correctio _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ . .-___

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Discussion with licensee personnel indicated that Appendix "M" was not directly utilized by plant operating personnel, and was not included in their training, so the errors had not impacted plant safety. It was recommended that Appendix "M" be totally replaced with the Emergency Action Levels in EPIP No. 1 for consistency and ease of revisio A review of the Emergency Action Levels (EALs) in EPIP No. 1 indicated that there was no EAL for a loss of shutdown coolin Plant personnel stated that the probabilistic risk analysis had not identified loss of shutdown cooling as a likely accident sequence due to the unique system configuration at Big Rock Point. The NRC Integrated Plant Safety Assessment, Systematic Evaluation Program for Big Rock Point (NUREG-0828) had stated (Page D-46) that failure of the shutdown cooling systems could eventually lead to a core melt. Discussions were held with plant personnel on the advisability of adding an EAL for loss of shutdown cooling, and the appropriate emergency classification for such a loss, based on the systems unique configuratio On the basis of the above discussions, licensee personnel stated that the EALs in EPIP No. I would be additionally modified to include an EAL on loss of shutdown cooling (to be an Unusual Event),

and that the EALs in EPIP No. I would replace Appendix "M" of the Site Emergency Plan when reviewed and approved. By telephone call of December 11, 1987, it was verified that these revisions were in proces Three revisions of the SEP had been completed and approved by plant management since the previous inspection. Revision 81 was reviewed in draft form with the only recommended change being to revise the minimum shift augmentation staffing requirements into a tabular format for more efficient revision. This was acceptably done in Revision 82. Revision 83 had two items which the licensee was requested to remove or change before the NRC could approve the revisio Site documents indicated that revisions to the SEP and implementing procedures are properly reviewed and approved. Review and approval forms for the most recent revisions of the SEP contained appropriate signature The system utilized for Emergency Plan revision distribution was reviewed to assure that revisions to the Emergency Plan and Implementing Procedures are provided to the NRC within 30 day Site procedures provide for the essentially simultaneous distribution of revisions to onsite and offsite recipient A i

l computerized tracking system provided the document distribution for each document and tracks the document receipt returns from recipients. Records for distribution of the most recent revision to the Site Emergency Plan, Volume 9, were reviewed and found to be adequat . _ _ - _ _ _ _ _ _ _ _ _ _ _ _

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Plant documentation indicated that State and local county representatives had been presented training on the Big Rock Point Emergency Action Levels and Protective Action Guidelines on October 8, 1987. This training session met the criteria for the annual review of these subjects by State and local agencies, as required by 10 CFR 50, Appendix E, Part IV, Organization and Management Control (Also 82204)

Discussion with cognizant personnel indicated that few changes in assigned personnel had occurred since the last routine inspectio The overall plant organization has not change . Emergency Preparedness Training (Also 82206)

The Site Emergency Plan (SEP) delineates training requirements in Chapter 8, " Maintaining Emergency Preparedness." The details of the training program are located in Plant Administrative Procedure Volume 1, Procedure 1.7, " Master Training Plan," which contains a training matrix (5.06) of requirements for each position in the

Emergency Response Organizatio Training matrix 5.06 had been revised since the last inspection, and now correctly reflects SEP training requirement Relevant records were reviewed and discussions held with cognizant personnel regarding the training program for Emergency Response personne A random sample of training records was selected for review, to determine whether personnel had completed selected training requirements within the last 12 to 15 month Training records were readily availabl It was concluded that all selected individuals had completed the selected training requirements within the last 12 month Local electronic and print media were offered orientation training on March 26, 198 The training included an overview of the licensee's and State's emergency planning efforts, operation of the Joint Public Information Center (JPIC), basic information on radiation, plus a tour of the JPI Drills Medical Drill The annually required medical drill was conducted October 7, 198 Two separate drills were held, one with Charlevoix Area Hospital, and one with Northern Michigan Hospital. Both drills were observed by a representative from the Federal Emergency Management Agency (FEMA). In conjunction with the drills,

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training was held at both hospitals, and local ambulance services were invited to training on October 6, 198 During the Charlevoix drill, a Health Physics Technician neglected to take the ambulance kit with him, and this was identified as a problem are Documentation indicated that the overall drill objectives were me Radiological Monitoring Drill The Radiological Monitoring drill was held on March 17, 198 Several problem areas were identified with offsite monitorin There were several new personnel involved in these drill It is recommended that the experienced Health Physics Technicians who have previously performed successfully in Radiological Monitoring Drills drill with the new personne A series on mini-drills is scheduled for July 22, September 16, and November 10, 198 Semi-Annual Health Physics Drills A Semi-annual health Physics drill was held on December 17 and 19, 1987. A Post Accident Sampling System (PASS) demonstration took place on March 17, as a part of the Health Physics drill, and partially to meet the requirement to do the drill semi-annuall The second Health Physics drill is scheduled to take place before the end of December 198 Fire Drills An unannounced fire drill involving participation with the Charlevoix Fire Department was held on August 12, 1987. The drill was conducted by members of the Fire Protection audit team and reported as Audit QT-87-16. Training sessions took place with offsite fire departments on August 3, 4, 6 and 20, 198 d. Independent Reviews / Audits (Also 82210)

The licensee's Quality Assurance group performs an audit every 12 months which meets the requirements of 10 CFR 50.54(t).

Individuals assigned to perform the audit had no responsibilities for implementing the Emergency Response Program. It was confirmed through record review that the audit had been performed within 12 month period Licensee procedures provide for the conduct, documentation, and corrective action associated with audits. Audit findings are tracked on Action Item Records (AIRS), via a computer tracking system. Proposed corrective actions are evaluated for adequacy, and if determined not to be adequate, the responsible organization is advise __ _ __ -_-__

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i The Emergency Plan audit for 1987 (Audit QT-87-6, " Big Rock Emergency Planning") was performed during June 29 through July 3, 1987. The audit report was comprehensive and professional, involving two auditors and resulting in four observations, of which three were considered Conditions Adverse to Quality. Documentation was available to show that Audit QT-87-6 had been made available to offsite authorities. This audit was considerably more comprehensive and complete than those reviewed in previous inspections, and is the first time that Emergency Preparedness has been audited separately from Health Physics and radioactive material contro Audit QA-87-12, " General Office Emergency Planning" was reviewe This audit was conducted by a three-man team during July 7-10, and encompassed both Big Rock Point and the Palisades plants. The audit resulted in six observations, five of which were considered conditions adverse to qualit Resulting items were tracked on AIRS A-QG-87-69 through A-QG-87-7 The audit adequately covered appropriate item Also reviewed was Surveillance Report S-QG-87-1, which was conducted to review the adequacy of the interface between Consumers Power Company and State and Local governments. This surveillance was conducted April 20-30, 1987, and was complete and comprehensiv CFR E0.54(t) requires that the annual emergency preparedness audit address the adequacy of the interface with offsite authorities, and that the audit be made available to offsite authoritie Letters dated August 19 and 24, 1987, documented the transmittal of this surveillance, fulfilling the requirements to make such an annual review available to State and 'iotal representative The licensee's tracking system was reviewed for items related to the Site Emergency Pla Actior. Item Record (AIR) A-EP-87-01, dated Juna 4, 1987, documented items requiring corrective action identified following review of comments and observations submitted following the annual 1987 exercise (BPREX 87). Items included those identified by plant personnel, NRC observers, and observers provided by agreement with Detroit Edison Company. Items were adequately tracked and action was assigned to individuals as appropriate. Some corrective actions were still in progress, as they involved revision to the training program and retraining of individual As noted above, Detroit Edison provided personnel to observe the annual exercise as a part of the independent review of the functioning of the Site Emergency Plan. Observers utilized a checklist (Procedure No. G0EP-08, Revision 2, Appendix B,

" Independent Review Checklist") to record their observations, and evaluate actions. A portion of each section of this form requested input on recommended. corrective actions, but no recommended corrective actions were note No violations of regulatory requirements or deviations from commitments were identifie ... . . . . - . , . -

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J Protective Action Decisionmaking (82202)

A review of the Emergency Plan and Procedures, demonstrated that the authority and responsibility to make protective action recommendations were clearly delineated. Procedures necessary to assess-and analyze emergency conditions and to make recommendations to protect the public and onsite workers were adequately documente No violations of regulatory requirements or deviations from commitments were identifie . Notifications and Communications (82203)

Selected procedures were reviewe It was determined that the licensee had the capability to notify and communicate among the appropriate licensee personnel, offsite agencies and authorities, and the' general public in the event of a radiological emergenc No violations of regulatory requirements or deviations from commitments were identifie . Shift Staffing and Augmentation (82205)

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Records indicated that a call-in shift augmentation drill was held as a part of the practice exercise held on March 17, 198 An unannounced shift augmentation drill was held on September 10, 1987. The TSC Technical Support Group Engineers were also called, using EPIP GF, Attachment 4. Documentation reviewed indicated that several problems previously experienced in the 1987 emergency exercise had been corrected. The Telephone call-list has been finalize No violations of regulatory requirements or deviations form commitments were identifie . Dose Calculation and Assessment (82207)

The equipment and procedures to be used for dose assessment were reviewe A dose assessment course conducted by the EP Coordinator /EP Training Instructor was observed. Procedure EPIP-5A, " Estimation of Offsite Dose," was demonstrated by lecture and actual problem solving for five of the designated On-Call Dose Assessors. These participants requested a classroom session in lieu of an (optional) independent self stud Each student successfully and independently completed the assigned problems with manual hand calculations. These problems included containment leak rate, meteorological data, and stack release rate determinations. The second part of this training involved hands-on training with an IBM-PC computer. The inspector verified that the results l of dose calculations were being incorporated into protective action decisionmakin _-_

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On September 11, 1987, a meeting was held between licensee representatives and the State of Michigan Department of Public Health Staff to review the current dose assessment models now used at the Palisades and the Big Rock Point plants. Results of the review indicated that, for a ground release, both plants models agreed very well with the State's model. For elevated releases at Big Rock Point, the two models did not agree very wel Differences in model results were identified as being due to plume shine calculations included in the child thyroid dose determinatio Because of memory limitations in the State's calculator, the full set of plume shine and iodine depletion equations used by Big Rock Point's elevated release model are not being utilized by the State. The State is considering removing some unused steps in their model, to free memory spac If this were done, it is believed that the full set of equations could be included in the State's model, which would result in good agreement between the two model A second meeting between the licensee and the State, to verify that the State revisions were made, though tentatively planned, has not been scheduled as of this inspection date. These identified differences between the two dose assessment models for an elevated release should be resolved without further dela .

No violations of regulatory requirements or deviations from comn.itments were identifie . Maintaining Emergency Preparedness Procedure RP-36, " Emergency Equipment and Supplies," listed locations for various categories of emergency equipment and administrative supplies; identified the various types of emergency kits; and specified supervisors responsible for ensuring that periodic inventories were completed. The procedure also included inventory checklists which listed minimum quantities of emergency equipment and supplies maintained at onsite and offsite locations. The procedure required that inventories be conducted at least quarterly, or after emergency supplies usag Completed inventory records for 1987 were reviewed on a selective basis, indicating that required inventories had been completed and adequately documented, including corrective actions taken on identified deficiencies. Reviewed documents included those relative to inventory checks of: first-aid kits, ambulance, and emergency kits (in the TSC, offsite, onsite, hospital).

A review of adequately detailed records indicated that the various types of functional, facility, and integrated drills had taken place on schedul Documents reviewed included those related to the following drills: emergency repair team drill, fire drill with offsite fire department, health physics, radiological monitoring, and augmentation drill i

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Documents indicated that 3,612 copies of the annual public information pamphlet were distributed to households and businesses in the five-mile Emergency Planning Zone (EPZ) during the months of July and August 198 Booklets and placards were distributed in quantity to 73 businesses within the EP No violations of regulatory requirements or deviations from commitments were identifie . Exit Interview (30703)

The inspectors met with the licensee representatives denoted in Paragraph 1 on December 4, 1987. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection repor The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur I

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