IR 05000255/1990034
| ML18057A605 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/27/1990 |
| From: | Dan Barss, Simons H, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18057A601 | List: |
| References | |
| 50-255-90-34, NUDOCS 9012060043 | |
| Download: ML18057A605 (11) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION REGION I I I Report No. 50-255/90034(DRSS)
Docket No. 50-255 Licensee:
Consumers Power Company
. 212 West Michigan Avenue Jackson, MI 49201 Facility Name:
Palisades Nuclear Plant Inspect~on At:. Palisades Site, Covert, Michigan Inspection Conducted:
November 5-9, 1990 Inspectors:
fliVI~~
Approved D. M. Barss
!Ji1~ ~\\-
H. J. Simons
.
~s~
By:
W~iam Snell, Chief Radiological Controls and Emergency Preparedness Section Inspection Summary License No. DPR-20 l1/z..-,/Jo Date Inspection on November 5-9, 1990 (Report Nos. 50-255/90034(DRSS))
- Areas Inspected:
Routine, announced inspection of the Palisades Nuclear Plant including the following areas: follow-up of licensee actions on previously
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identified items (IP 92701); followup on actual emergency plan activations (IP 92700); and operational status of the emergency preparedness program (IP 82701). This inspection involved two inspector Results:
Two violations of NRC requirements concerning the training of emergency response organization personnel were identified as a result of the inspectio Two previous open items were reviewed and further licensee action is ~equired for closur Two open items were identified concerning uncontrolled distribution of forms and untimely updating of lesson plan ;~: g il: ~:: 0 ;~~ g g
~i: ~:~
C!
- DETAILS Persons Contacted K. M. Haas, Radiological Services Manager J. L. Fontaine, Senior Health Physicist N. Brott, Emergency Planning Coordinator W. L. Roberts, CPCo Licensing D. L. Fugere, CPCo Senior Emergency Planner C. Reavy, Senior HP Technician R. Becker, QA Audit Supervisor D. R. Hughes, Director QA - Jackson R. E. McCaleb, Palisades QA Director P. A. Slaughter, Emergency Planner All of the above listed individuals attended the NRC exit interview held on November 9, 199 The inspectors also contacted other licensee personnel during the course of the inspectio.
Licensee Action on Previousl Identified Items (IP 92701)
en 0 en Item No. 255/90011-01:
During the annual exercise the icensee faile to coordinate SC/MSC activities at a supervisor or director level. Also the licensee has no method to uniquely identify and track inplant response team A new status board to track inplant t.eams is being develope The Emergency Planning Coordinator has been observing other utilities OSC's to evaluate possible improvements to the DSC/MS This item remains ope (Open) Open Item No. 255/90011-02:
During the 1990 annual exercise, the licensee failed to activate the EOF in a timely manne The EOF had been set up in advance to accommodate the setup of computer equipment brought from the corporate office, resulting in the li~ensee's failure to demonstrate the ability to activate the facility under normal condition The licensee has purchased new computer hardware for use in the EO This equipment will be maintained and used on a daily basis at the plant site. The licensee has not yet developed plans or procedures for the logistics of relocating this equipment to the EDF upon facility activation. This.item remains ope.
Emergency Plan Activations (IP 92700)
At 2018 hrs on August 4, 1989, the licensee declared an Unusual Event (UE) due to a plant trip per Procedure EI-1, Attachment 1, Miscellaneous Sectio At 0256 hrs on November 21, 1989, the licensee declared an UE per
. Emergency Action Level (EAL) "Primary Coolant System - Temperature or Pressure" when,t~e power operated relief valve (PORV) actuated during a PORV iscilation valve openin Since then, this EAL has been clarified and revised because this is not considered a challenge to the over-pressure protection syste **
At 0829 hrs on June 8, 1990, the licensee declared an UE due to the initiati6ri of plant shutdown due to Technical Specification The licensee's records for each of the above emergency ~lan activations were reviewe For each event an appropriate classification was made and notificatio"ns to State officials and the NRC were accomplished within r-equired time 1 imits..
The licensee conducted an event review for each activation. This review included gatheri~g copies of applicable documents such as Shift Engineer's Logs, Emergency Notific~tion Checklists, Emergency Notification Forms and Licensee Event Reports (LER).
An evaluation was then made to determine if the classification was pertinent, notification timely and
- if the Site Emergency Plan (SEP) and associated procedures were properly implemente No violations or deviations were identified in the review of this program are.
Operational Status of the E~ergency Preparedness Program (IP 82701) Emergency Plan and Implementing Procedures There have been several minor changes to the_licensee's Site Emergency Plan (SEP) since the last routine inspection. Most of these changes were generally of an editorial natur The plan was revised to include fitness for duty requirements, Department of Energy response capabil Hies and recent changes in the command and control responsibilities of the State's emergency operations center.. These changes did not downgrade the effectiveness of pla The licensee has submitted a plan change that reduces the -number of onshift hours for Chemistry Technicians, Mechanical Maintenance personnel, and Electrical Maintenance personnel. The-licensee concluded that this change did not downgrade the effectiveness of the pla A_ review conducted by Regional NRC personnel concluded that this plan change could dtiwngrade the plans effectiveness and that it could conflict with existing NRC guidance. This matter
was referred to NRC/NRR for further revie Subsequent to the inspection, correspondence from NRC/NRR was received by Region III which concluded that this plan change was acceptable. The licensee will be notified under separate correspondence as to the final-decision concerning this matte Interim approval of this change was granted for the Steam Generator Replacement outag Several emergency plan implementing procedures were revised with regards to the implementation of the Emergency Response Data System (EROS).
The licensee has taken steps to ensure that other affected plant procedures were revised concurrently. A minor revision was made to the Emergency Action Levels (EAL) to eliminate the declaration of an Unusual Eevent during testing of power operated relief valves (PORV).
Personnel affected by these changes have generally been informed of the changes as necessar ;:.
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The licensee's records pertaining to the transmittal of procedure revisidns to affected procedure hold~rs were reviewe This review indicated that revisions have been sent as appropriate iricludirig copies to the NRC within 30 days of the change Current copies of the emergency plan and implementing procedures were found-to be maintained and readily available in the emergenty res~onse facilities and the Control Roo No violations or deviations were identified in the review of this program are Emergency Facilities, Equipment, Instrumentation and Supplies An inspection tour was conducted through the Technical Support Center (TSC), Operational Support Center (OSC), Emergency Operations Facility (EOF) and the Control Room (CR).
These facilities were found to be as describe-d in the Emergency Pla With the exception of the CR, the other facilities all serve a double role. They are used on ~ day to day basis for other functions and converted to emergency response centers when neede Each facility was found* to be generally clean, orderly and readily available for conversion to its respective emergency function. It was noted by the inspectors that a vending machine had been installed in the. OSC wh.ich blocked access to, and the view of, *the 110nsite Monitoring" status board. It is recommended that either the vending machine or the status board be relocate Emergency equipment and supplies for each emergency response center was stored in cabinets or lockers in the facility or in an adjacent room. A spot check of inventories was conducted in each facilit Radiological survey meters were found to be calibrated and ready for us~. Several air sampler heads were noted. to have 0-ring seals which have begun to dry and crack. A flashlight was missing from the environmental monitoring van and two flashlights were found to have dead and leaking batteries iri the OS Sample holder planchets were missing froM the EO With the exception of these minor problems emergency equipment and supplies were generally in good order and as described in the pla The licensee continues to make improvements to emergency response facilities. The licensee has voluntarily participated in the implementation of the Emergency Response Data System (EROS).
This improvement provides quick and direct accessibility to selected plant parameters for both the NRC and State officials. Also, additional computer hardware has been obtained for use in the EOF and the TSC computer is being upgrade In the CR, telephones dedicated for emergency use were clearly labeled and positioned to be readily accessible. The NRC emergency notification system (ENS) (red phone) was tested from the CR and found to be in satisfactory working order.* Appropriate procedures
and notification form~ were also found to be readily ac~essible for use in the CR, though the number of -forms kept on hand for use was minimal~
The licensee maintains a supply of uncontrolled copies of forms found in procedures for use in various facil~ties. Several *Of these forms were found to be copies of *out of date revisions. For example:
EI-2.1, Attachment 1, 11 Emergency Notification 11 Revision 13, found in the TSC did not have th~ latest changes implemented with MRN-EI-90-006 and MRN-EI-90-00 EI-3, Attachment 4, 11 Emergency Support Contact List
, Revision 11, found in the TSC did not have the current phone numbers for the Michigan State Police Emergency Operations Center, the Emergency Management Division office, or the doctor identified as providing medical assistanc A form similar in content to EI'."'3, Attachment i, 11Emergency Notification Form 11 was found in the EO This forni had no*
revision number indicated and no identification as to its source.. T.he forms content was slightly different from that found in EI-3, Attachment HP-2.18, Attachment 3, 11 Personnel Contamination Report
, was found in several locations. Revision 5 and 6 of this form were observed while the current revision is 7 in the controlled procedure Through discussion with cognizant licen~ee personnel it was learned that the licensee has no prograrrunatic method in place to ensure that-uncontrolled copies of procedural forms maintained in emergency response facilities are kept current. This is considered Open Item No. 50-255/90034-0.
Emergency communications systems surveillance records for the emergency response facilities were reviewed and found to be complete and thorough. Monthly, quarterly and annual corrmunications tests have been conducted as outlined in established procedure The licensee's inventory records for emergency supplies wer reviewed and found to have been completed as detailed ih appropriate procedures. These inventories included supplies for first aid, environmental sampling, decontamination facilities, TSC, OSC, MSC, EOF, post accident sampling and an ambulance emergency.kit..
_The licensee has been conducting an informal test of the automated call out system hardwar Records were reviewed which indicated this test has been conducted twice a year for the past two year Problems identified through these tests are corrected in a timely manner and repeat testing conducted to verify system operabilit Through discussion with cognizant licensee.personnel it was learned that there was no progranunatic requirement to test the automated call
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out syste Additionally, there a~e no spe~ific acceptance criteria established to determine the systems operability. Personnel response: times and availability are not routinely verifie Though the practice of-testing the automated call out system hardware is commendable, a more meaningful test c.ould be_ accomplished if specific acceptance criteria were established and this test was conducted in a programmatic manne No viola~ions or deviations were identified in the review of this program are One op~n item as discussed above was identified~
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Organization and Management Control It was learned through discussion with cognizant licensee personnel that there have been two changes made in the licensee's organizational structure which affected emergency plannin The corporate position of Direttor of Nuclear Licensing was eliminated and associated responsibil.ities have been reassigned to respective Site Licensing Department With this change in management structure site personnel are now responsible to fill the ERO position of EOF Communicato The licensee was careful during this
- reorganization to ensure emergency response duties were appropriately reassigne The Emergency Plan Coordinator (EPC) has been assigned the added responsibility of coordination of all training within the Radio-logical Services*Department. This increase in responsibility has required the EPC to divide his time between approximately 70% EP and 30% trainin One additional person has been assigned to the EPC's staff to assist with the tasks of coordinating Radiological Services Department training. A second individual continues to function as an EP Technician. All three of these individuals maintain their qualifications current for health_physics duties and support the plant by filling rotational assignment The increase in responsibilities assigned to the EPC has been well
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balanced with additional manpower to ensure that each responsibility is effectively addresse The EP Coordinator reports to a Senior Health Physics who in turn reports to the Radiological Services Manager and finally to the Plant General Manager. This places two levels of management between the EPC and senior plant managemen The EPC also has a secondary reporting chain to the corporate Emergency Planning Administrator
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who reports directly-to the Vice President Nuclear Operation This provides a second option to ensure that emergency planning concerns do reach top manag~ment. Even though the EPC is somewhat removed from direct contac~ with top plant management EP concerns generally received attentio The individuals filling the Radiological Services Manager and the Senior Health Physics positions are both new to these assignment However, both individuals have been long term company employees
and are well acquainted with the emergency plannin~ progra The cbrporate EP staff has been unchanged since the last routine inspectio No v1olations or deviations were identified in the review of this program are Emergency Preparedness Training The current onsite training program was.reviewed with the EP *
Training Instructor and the EP Coordinator, including a review of the training matrix requirements, lesson plans, training records and recent improvements to the progra The review determined that the Emergency Response Organization (ERO) is minimally staffed in some positions, while other positions identified have no one qualified to fill the Numerous personnel exceed the twelve month requali-fication period and the three month grace period, therefore were no longer qualified for their assigned emergency response position The following are examples of the weaknesses in the staffing of th ERO:
During November 1990, there wer~ only four qualified TSC Communications Support Team Member There were another seven
.unqualified communicators (five whose training had expired and two new individuals wh~ had not received trairiing).. The minimum requirement in the Site Emergency Plan (SEP), Figure 5-6 and Emergency Implementation (EI) Procedure 2!2 is thre One of these communicators is also listed as a potential responder for another position. If this individual were needed to fill the other position during an activation, then 100% call out would have to be achieved to fill all the positions with qualified personne Either way, insufficient staff would be available for continuous shift staffing of* all three position *
In October 1990~ none of the four personnel assigned to the position of EDF Reacto~ Engineering Ops Support Team had completed all training necessary to qualify them for the position. This position appears in the EOF organization chart in Procedures EI.2.2, Attachment 3 and EI 4.3, Attachment 4, under Reactor Physics/Accident Assessment.. Therefore, no qualified personnel would be available to fill this position initially or for continuous staffin Palisades Technical Specifications~ Chapter 6.8.1, requires imple-
. mentation of Procedures for Site Emergency Plan implementatio CFR 50.47(b)(15) states that radiolo.gical emerg.ency response training is to be provided to those whb may be called upon to assist in an emergenc In addition, 10 CFR 50.47(b)(l) says that each principal response organization has staff to respond and to augment its initial response on a continuous b~sis.
A~ discussed above, personnel had not received the appropriate annual retraining, therefore were removed from the augmentation list, leaving the ERO unable to either initially staff or continuously staff various positions with qualified personne This is a violation (No. 50-255/90034-02).
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Since April 1988, the Emergency Response Organization (ERO) has maintained only 80 to 93 percent of the available personnel in the ERO trained/qualified at any given tim Personnel are not receiving the appropriate annual retraining, being removed from the augmentation list, and thus leaving the ERO minimally or inadequately ~taffed in various position The following additional examples of ERO staffing weaknesses were noted by the inspector The SEP, Section 7.1.4, "Maintenance Suppor*t Center" (MSC),
specifies that the function of the MSC is to assemble I&C, Electrical, and Mechanical Maintenance personne Th supervisors from each of these groups will then dispatch their personnel as necessar However, in October 1990, and to the date of the inspection (November 9, 1990), the required
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training for all three MSC I&C Supervisors had lapse In October 1990, only 50% of the MSC Directors and Supervisors were qua 1 ifi e In September 1990, only two of four OSC Directors were qualifie On July 31, 1990, only 21 out of 40 HP Techs were qualifie Five of those qualified were listed for another positio The minimum requirement for this position is 14 which, requires a high turn out to ensure adequate initial staff augmentatio In addition, this would leave insufficient staff for shift turnove For a four day period in August 1990, only one of four OSC HP Supervisors was qualified. This position is required to be manned within 60 minutes according to Procedure EI 2.2, Attachment This means no qualified support was available for continuous shift sta.ffi n On at least two occasions top management went well into the three month grace period before obtaining retrainin The inspector also noted a problem in the ERO training matri Due to an administrative error, dose assessment training was inadvertently deleted as a requirement for the HP Support Group Leader position when the training program was updated in January 198 The Health Physics (HP) Supp6rt Group Leader is the person assigned the task of dose assessment in the Site Emergency Plan (SEP), Section 5, Figure 5-6, "Plant Staffing and Augmentation Guidelines" and is the only person required to respond in 30 minutes to perform dose assessment There were three people qualified according to the staff augmentation roster under HP Support Group Leade However, it was determined that only two of these people were trained on dose assessmen One was trained on dose assessment to fulfill a requirement for a different emergency response position. The other person had been previously trained on dose*assessment, but he was in the fifteenth month and his training would lapse in December
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199 This individual had not received or completed the quarterly problem sets that were d1strjbuted to requalify people for the dose
~ssessment positions. The last person had not been trained on dose assessmen Through interviews and walkthroughs with these three personnel, it was concluded that the first two of the three c6uld perform the dose assessmen The last indiv~dual could not perform the dose assessments, thus he was immediately removed from the HP Support Group Leader emergency response position. However, this person had been l.isted as a qualified/trained responder on the augmentation list since February 199 In reviewing the documentation, it was determined that during.
October 1990, there had been only one person who had completed all required training and was therefore qualified for this positio It is reco~nized that the licensee does have additional people trained to perform dose. ~ssessment; however, they were not specified on the 30 minute augmentatiqn list and there was no assurance that a.qualified dose assessor would be called in to meet the 3IT minute commitmen *
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10 CFR 50.54(q) requires a licensee to follow and maintain an emergency plan which meet the standards in.50.47(b} and the requirements in Appendix Section 5 of th~ Site Emergency Plan, Figure 5-6 states that the licensee will have a Senior HP expert respond to an emergency in 30 minutes with the major task of dos~
assessmen.47(~)(15) requires emergency response personnel to be traine As discussed above, the licensee maintained an untrained individual for the HP Support Group.Leader position on the augmentation list from February to November 199 This is a violation (No. 50-255/90034-03)~
The licensee ha~ taken the following corrective actions:
The unqualified personnel under HP Support Group Leader were pulled from the augmentation list~
The training matrix was revised to require the HP Support Group Leader to have dose assessment trainin For augmentation purposes, the HP Support Group Leader and the Technical Support Group positions have been combined under the new name of TSC H~ Dose Assessor to increase the number of personnel available to perform dose assessment withiri 30 minute The lesson plans for some of the EP training classes were reviewed and the scope of the material presented was goo The training class, N00109, 11Emergency Notifications
, was out of date. It did not incorporate procedure changes which had been made due to the implementation of ERO Procedure EI~2.1. including the 11 Emergency Notification Checklist
, Attachment 1 to EI-2.1 was revised to refl~ct the implementation of ERO The class was taught twice since this procedure revision and appropriate changes were not made
to the less6n pla The licensee has methods for trackino procedure changes and incorporating them into trainin* However, the internal tracking form to alert the training instructor to ttie procedure
change was dated August 15, 1990 while the revised procedure was issued a month earlier, July 15, 1990. Other lesson plans were reviewe Some of them were written in 1987 and one lesson plan referenced El-1, Rev 12 while the current revision is 1 The
licensee has two methods for incorporating drill or exercise findings, procedure changes, and other items into training lesson plans.. This can be accomplished through the. generation of an Action Item Record or a Form 31.10. There is no formal programmatic requirement to review EP lesson plans and they are revised on an as needed basis. The EP lesson plans need to be reviewed and
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updated in.a mor.e timely manner (Open Item No. 50-255/90034-04).
The training program continues to improve by us~ng problem sets to requalify people iri their emergency response rcile Problems sets are used for dose assessment, protective action recommendations and are in the final stages of development for emergency action levels. Persons interviewed liked the problem sets and thought they learned a lot from the This is considered an effective way to train people.*
All the training reco~ds were kept in an orderly manne The licensee has an excellent tnicking system for training. The computer flags people who have gone into the three month grace period and are in need of retraining. The computer printout of training records gives a full listing of all the EP courses that were completed and the date when retraining is neede Records of the 1989 emergency preparedness drills were reviewe All 1989 radiological monitoring, medical, radiation safety/chemical dri 11 s and annua 1. exercise requirements were successfully me The 1990 drills have not been completed but they are scheduled appropriat.el Drill records indicated that critiques were conducted and performance evaluated. There were a few minor licensee identified findings associated with the drills *and these problems were corrected in a timely manne Two personnel identified in the licensee's augmentation list as HP Support Group Leaders w~re interviewed~ Both individ~als were well-aware of their emergency response duties and responsibilities..
Du~ing the course of the interview, a dose assessment problem was posed and.each individual successfUlly demonstrated the ability to perform a dose assessment and develop a protective action recommendation in a timely manne The on-shift Shift Supervisor and a Shift Engineer were interviewed and presented with a problem set. Acting asa team, they identified the appropriate EAL and correctly classified the scenarip even They then discussed with the inspectors the notification process and various operational procedures they would have use The Shift Supervisor performed a walk through demonstration of activation of
ERO Both in_dividuals were very knowledgeable of their emergency response dutie _ *
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Two violations and one Open Item were identified in the review of this program area. These violations, in addjtion to the other identified weaknesses int h~ triining program, give the NRG significant concern over the licensee 1s capability to respond-to an accident with trained and qualified personne Independent Reviews/Audits Records of the Quality Assurance {QA) Department audits and surveillances conducted in 1989 and 1990 were reviewe This included a QA audit of the Palisades EP Program and General Office Emergency Planning Program, QA surveillance of the Palisades ann~al e~ercise, and a QA surveillanc~ of the adequacy of interface between Con~umers Pow~r Company and State ~nd local government All records were readily available and complete. These audits fulfilled all the requirements of 10 CFR 50.54(t). Observations identified throu~h these audits and surveillances are appropriately tracked and addresse Results of the audit are reported to top plant and corporate managemen Also the applicable portions of the audit were made available to the State and local government No violations or deviations were identified in the review of this -*
program are.
Other Inspection Observations
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During the course of this inspection, the licensee had scheduled meetings*
with State and county officials to review EALs and discuss program changes implemented over the last yea The inspectors attended the meeting conducted with representatives from Allegan and Berrien Countie The licensee provided a clear explanation of recent program changes including the revision of EAL The addition of EROS ~as also discusse At the conclusion of the meeting~ both counties *representatives expressed appreciation and a strong affirmation of the good working relationship they feel exist with the license.
Exft Interview The inspectors met with licensee reptesentatives denoted in Section 1~
on November 9, 199 The inspectors reviewed the scope and findings of the inspe~tion. The licensee was informed of the concerns which are identified in Section 4.d, as violations. The open items identified in Sections 4.b and 4.d were also discusse The status of previously identified open items were reviewe The licensee indicated that the information discussed was not of a proprietary natur