IR 05000155/1989020
| ML19354D865 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/10/1990 |
| From: | Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19354D864 | List: |
| References | |
| 50-155-89-20, NUDOCS 9001230040 | |
| Download: ML19354D865 (6) | |
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f U. S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-155/89020(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: December 18-21, 1989 U$dC M
w Inspector:
James P. Patters
'A* />o Date (.A.)@0 b U Approved By: William Snell, Chief th s />o Radiological Controls and Date Emergency Preparedness Section inspection Summary:
Inspection on December 18-21, 1989 (Report No. 50-155/89020(DRSS1)
Areas Ins )ected'.
Routine, announced inspection of the following areas of the Big Rock loint emergency preparedness program; activations of' the emergency plan (IP 92700); emergency plan and implementing procedures; organization and'
management; emeroency facilities and equipment; training; and independent audits (IP82701). Also inspected were licensee actions on previously identifieditems(IP92701). The inspection involved one NRC inspector.
Results: No violations, deficiencies or deviations were identified during this inspection. The EP program continues to be well maintained including training and documentation. Two open items were reviewed however, neither-could be closed at this time (Reference Section 2 of inspection report).
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9001230040 900111 PDR ADOCK 05000155 Q
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1.
Persons Contacted
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i T. Elward, Plant Manager i
R. Abel, Production end Performance Superintendent i
L. Monshor, Quality Assurance Director R. Alexander, Technical Engineer J. Beer, Chemistry / Health Physics Superintendent M. Hobe Emergency Preparedness Coordinator (EPC)
- M. Azure, Shift Supervisor (SS)
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- S. Beachum, On-Call Technical Assistant (OTA)
- R. Fritsch, Nuclear Licensing - Corporate
- Denotes those who did not attend exit interview; all other did attend.
i 2.
Licensee Actions on Previously Identified items (IP 92701)
a.
(0 pen) Open Item No. 50-155/88027-01:
This item was identified.
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as a result of an EAL review in a December 1988 inspection. The recommendation was to reevaluate certain EAls on Pages 9-12, Appendix M of Revision 90 of the Site Emergency Plan (SEP) which i
are designated as " applicable during power operating only." The i
main concern were those EALs classified as Alert or higher, many of which related to natural phenomena and miscellaneous conditions.
J In June of 1989, correspondence relating to these EALs was forwarded to the Corporate Licensing Department in Jackson, Michigan from the plant site.
An official licensing response to Big Rock Point was
sent on December 5, 1989. The Corporate Licensing Department concluded none of the EALs should be changed from the present designation " applicable during power operation."
After discussions between the inspector, the Senior Resident inspector, and the licensee, an informal agreement was made with plant management that a decision will be made in 30-45 days as to which EALs will be changed to eliminate the " application during power operation only." Until this decision from plant management is made this item remains open, b.
(0 pen) Open Item No. 50-155/89010-01:
This item resulted from the
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environmental sampling methods and sampling techniques demonstrated
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by the licensee's environmental sampling team in the May 1989 emergency exercise. To improve on these methods, including steps to eliminate cross-contamination of samples, the EPC has revised the -
existing procedure EPIP-5F, to address NRC's concerns.
Presently
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these procedures are in a draft status awaiting review by the Plant Review Committee. Additionally, changes in training content are being made to better address this sampling of soil, water, and
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vegetation. When these changes in the procedure-and training, along with a satisfactory demonstration of environmental sampling, are completed, this item will be closed.
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3.
Emergency Plan Activations During this inspection period there were two emergency events which were identified by the licensee. One occurred on January 20, 1989, and the other on August 31, 1989. Both events. Notification of Unusual Events (NUEs) involved electrically-related problems which resulted in Limited Condition of Operations (LCOs) which, in each case, resulted in a plant shutdown. The correct EAL was selected for each event.
Notifications for each event were made properly and within the required time frames including notifications to the NRC within one hour after classification.
The licensee's review of the August 31, 1989 NUE concluded that the applicable EAL should have been recognized sooner; which, in turn, would have resulted in the NUE being declared on a more timely basis. The LCO was entered at 1030 with shutdown commencing at 1130, and the NUE declared at 1150, based on the EAL "LCO resulting in a plant shutdown".
The inspector's review concluded that this event was properly identified, classified, and notifications to offsite agencies and the NRC were made within the required timeframes of the classification.
However, this event should have been classified as soon as the shutdown was initiated rather than 20 minutes later. This event did not relate to any previous event which resulted in a violation.
The EP Coordinator had addressed this situation to all Shift Supervisors and other Control Room personnel in subsequent training sessions, so that all will be aware of the importance of recognition of conditions so as not to delay proper use of the EAL tables and resulting classifications.
4.
Operational Status of the Emergency Preparedness (EP) Program (IP 82701)
a.
Emergency Plan and Implementing Procedures All emergency plan revisions made in the last year have been submitted by the licensee to the NRC within 30 days after being issued as required by 10 CFR Part 50.54(q). Changes made in certain EAls, which the licensee included in Revision 90 to the SEP, have been further evaluated following an Open Item initiated in the December 1988 inspection (Report No. 50-155/88027). The conclusions agreed on between t M licensee and the NRC inspectors at the exit interview of this inspection were described previously in Section 2.a of this report.
Based on the above findings, and the agreement to revise certain of the EALs in question (Pages 9-12 of Appendix M. Revision 90 of the SEP), this portion of the licensee's program was acceptable.
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b.
Emergency Response Facilities (ERFs), Equipment and Supplies There have been no functional or structural changes observed in any of the onsite ERFs. The Senior Resident Inspector reviewed all ERFs
in October 1989 including the facilities and response capabilities in the Corporate Office in Jackson, Michigan. He did not observe any items of concern that could effect the licensee's response capabilities. As a followup to an improvement item in the previous inspection, the EPC has affixed temper-indicating seals to all emergency equipment kits.
If a seal is observed as being broken,
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that kit will be subjected to a complete physical inventory of its
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contents, whether this kit is scheduled for inventory at that time
or not.
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Based upon the above findings, this portion of the licensee's program was acceptable, c.
Organization and Panagement Control
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There were no changes in organization or management control that would directly impact on the effectiveness of the EP program, either i
at corporate level or site level of management. One new position identified as an EOF Governmental Liaison was utilized in the I
May 1989 emergency exercise. This position was made effective as of i
February 1, 1988, but had not been activated previously except for a full scale exercise with State and counties participating.
Now this position, which serves as a State and county liaison, is activated for each annual exercise. This position was procedura11 red in J
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Procedure N9 EOF-13, as a General Office EP Procedure.
Based upon the above findings, this portion of the licensee's program was acceptable.
d.
Training Records of all drills required by the SEP were reviewed. Also,
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critique information including areas for improvement were identified. Through a review of related correspondence and training related input, the inspector determined that adequate followup on these items had been accomplished.
These actions were required
according to 10 CFR Part 50, Appendix E. Section !Y F.5.
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following drills were conducted satisfactorily to meet the SEP
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requirements:
Health Physics Drills Shift Augmentation Drills Radiation Monitoring Drill Assembly / Accountability Drill Communication Drills Medical Drill
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Emergency Repair Team Drill In addition, " mini" drills have been conducted with the SSs
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during the last four months of 1989. Scenarios. objectives, and expected actions were addressed by. the EPC in the drills.
Procedures l
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referred to included Emergency Plan Implementing Procedure (EPIP) 1.1 with the EAL tables, EPIP 4A, Duties of the Site Emergency Director
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and EPIP 6F, Emergency Notifications. These mini drills are less structured than other drills, but are informative and useful for those operating staff and supervisory staff who have limited time to t
address EP issues outside the required training.
l Two individuals with emergency response functions, a Shift Supervior (S$) and an On-Call Technical Assistant (OTA), were interviewed on their emergency duties. Both were cognizant of their emergency response functions, utilized the correct EPIPs, and demonstrated where to identify the applicable EAL in EPIP 1.1 that would classify the emergency conditions presented. The annual training, consisting of a review of the EAls with State and county officials, was presented on October 24, 1989. Corporate EP representatives were also present at this training and meeting session; which also included discussion of procedure changes which may be relevant to State and county emergency response plans.
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Based upon the above findings, this portion of the licensee's
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program was acceptable, e.
Independent Review / Audits l
The following documents were reviewed which related to the independent review / audit of the Big Rock Point (BRP) Emergency Preparedness (EP)
Program and the corporate level EP program:
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1.
Quality Assurance (QA) Audit of the BRP-EP Program - conducted
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June 12-14, 1989.
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QA Audit of the General Office EP Program - conducted September 25-29, 1989.
3.
QA Surveillance of the BRP Annual Evaluated Exercise - conducted
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May 23, 1989.
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QA Surveillance of the Adequacy of Interface between BRP and State and local cov between October f ernments for EP related activities - conducted i
November 21, 1989.
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That portion of the annual independent audit that applied to State I
and counties was made available to both entities in a letter dated'
December 5,1989, as required by 10 CFR 50.54(t).
No negative findings or observations were identified as part of the June 12-14,
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1989 audit. Certain meteorological elements of the monitoring system are now included in the General Office EP Procedures as well as in e
the SEP. This subject was a licensee open item from the previous audit.
For the September 25-29, 1989 audit of the General Office
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EP program, four observations were identified.
Two of these four
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observations included a need to review the process for correcting
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weaknesses or deficiencies (licensee tenninology) identified in the j
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annual exercise. The other noteworthy observation was a need to upgrade the evacuation time estimates for both BRP and Palisades.
Information received from the licensee indicated that although evacuation time estimates for both sites will be based on the 1990 U. S. Census, preliminary work related to evacuation routes and topography aspects has been started.
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Based on the above findings, this portion of the licensee's program t
was acceptable.
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5.
Exit Interview (IP 30703)
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The inspector met with the licensee representatives denoted in Section 1
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on December 21, 1989. The scope and preliminary findings were summarized.
No violations were identified.
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An Open item was discussed which concerned the designation of certain
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EALs as " applicable during power operation only" as found in Revision 90,
Appendix M of the SEP.
The inspector, with agreement from the Senior i
Resident inspector (SRI) concluded that some of these EAls should not be
qualified as applicable during power operation only. Licensee management
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agreed that some of these EAls should be reevaluated. An oral commitment
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was made to give a reply to the inspector or the SRI within 30-45 days, i
after which a decision on acceptability would be forthcoming from NRC.
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Overall the EP program at the site continues to be well managed and
the quality of documentation continues to improve.
The addition of
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" mini-drills" to the training program (Reference Section 4.d) has added
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to the readiness capability of key emeroency response personnel. Also, the independent review / audit program has become more definitive and objective in observations and findings as implemented by the Ouality Assuranu Department and the General Office EP group.
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The licensee indicated that none of the. matters discussed during the exit interview were proprietary.
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