IR 05000255/1993007
| ML18058B797 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/30/1993 |
| From: | Mccormickbarge NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML18058B798 | List: |
| References | |
| NUDOCS 9305110056 | |
| Download: ML18058B797 (12) | |
Text
APR 3 0 1993 Docket No. 50-255 Consumers Power Company ATTN:
Gerald General Manager
. Palisades ~uclear Generating Plant 27780 Blue Star Memorial Highway Covert,.MI 49043-9530
Dear Mr. Slade:
SUBJECT:
EMERGENCY PREPAREDNESS INSPECTION AT THE PALISADES NUCLEAR PLANT This refers to the routine safety inspection conducted by Mr. T. Ploski and othe~s of this office on Apri~ 12-16, 1993.
The inspection included ~ review of authorized activities at your Palisades facility.
At the conclusion of the inspection, the findings were discussed with those* members of your staff identified in the enclosed report.
.
.
Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of a selective examination of procedures and representative records, interviews, and observation of activities in progress. *
No violations of NRC requirements were identified during the course of this inspect1on.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the encl~sed inspection report will be placed in the NRC Public Document Room.
- We will gladly discuss any questions you have concerning this inspection.
Enclosure:
Inspection Report
No. 50-255/93007(DRSS)
See Attached Distribution
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- Orit,IMI Ii&* by J. W. McCormick-Baraer"
J. W. McCormick-Barger, Chief
Non-Power Reactor Section
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Consumers Power Company
Distribution
REGION II I
Report No. 50-255/93007(DRSS)
Docket No. 50-255
Licensee:
Consumers Power Company
Palisades Nuclear Plant
27780 Blue Star Highway
Covert, MI
49043
Fac;ility Name:
Palisades Nuclear Plant, Unit 1
Inspection At:
Palisade~ site, Co~ert, MI
lnspection Conducted:
April
12~16, 1993
In*spectors:
o~ tJ.r
/~I~-
T. Pl oski
Date
License No. DPR-20
oar
/
Approved By:
Inspection Summary
Inspection on April 12-16. 1993 (Report No. 50-255/93007CDRSS)) _
Areas Inspected:
Routine, announced inspection of the operational status of
the Palisades Nuclear Plant's emergency preparedness (EP) program (IP 82701)
and followup on licensee action on previously identified items (IP 82301 and
IP 82701).
Two NRC inspectors performed the inspection.
Results:
No violations or deviations were identified. The overall status of
the plant's EP program was very* good.
Corrective actions on both concerns
identified,during the 1992 exercise were well underway.
- Four Unusual Events were correctly classified. since mid-February 1992. State,
county, and NRC officials were notified within the regulatory time limits.
One declaration was needlessly delayed by about 15 minutes.
Detailed reviews of selected procedures and related training materials were
conducted to determine their consistency with statements in the emergency plan
.or a letter of agreement.
These reviews were also performed to assess the
adequacy of implementing the procedures, based on their training materials'
9305110060 930430
ADOCK 05000255
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contents.
Two inspection followup items were identified with respect to
inadequate guidance on the following:
relocation of emergency responders to
backup onsite facilities; and preplanning for monitoring and decontaminating
site evacuees at a location in a local community.. The licensee was revising
several* procedures and. lesson plans in order to_provide accurate guidance on
NRC notification requirements and associated comniunications links.
The emergency response facilities were maintained in a good state of
operational readiness. A communications equipment upgrade was completed in
the emergency operations facility.
The emergency response organization was currently trained.
Required drills
were conducted and critiqued.
The 1992 and early 1993 audits and surveillances of the program were thorough.
Auditor followup on identifie~ concerns was good.
DETAILS
1.
Persons Contacted
G. Slade, General Manager
K. Haas, Radiological Services Manager
D. Rogers, Safety and-Licensing Director
R. Rice, Nuclear Performance Assessment Department Director
M. Mennucci, Health Physics Technical Supervisor
S. -Wymer, Emergency Planning Coordinator
-
M. Dawson, Senior Technical Instructor
A. Katarsky, Corporate Emergency Planning Administrator
The above and seven other licensee staff attended the exit ihterview on
April 16, 1993.
The inspectors contacted other licensee personnel
du~ing the inspection. *
-
2.
Licensee Action on Previously Identified Items CIP 82301 and IP 82701)
(Closed) Inspection Followup Item 255/91024-01:
The ~udibility of the
plant's public address (PA) system was inadequate in a portion of the
auxiliary building-, resulting in a concern that personnel could not hear
an emergency announcement following the sounding of the plant's siren.
The audibility of the plant's siren w~s tndependent of the operability
of the plant's PA system.
The audibility of the siren in the auxiliary
building was not a concern.
Instrumentation and controls -staff checked
the audibility of all the PA system's speakers and created a program to
periodically perform such ~hecks: The emergency preparedness (EP)
-coordinator assured that these checks included the PA speakers in the
plant's assembly areas. Repairs were completed as necessary.
The PA
system was expanded to include the training center located in the owner
controlled arei. This item is closed.
(Open) Inspection Followup Item 255/92019-01:
During the 1992 exercise,
-a performance weakness was identified when the shift supervisor _(SS)
failed to dee 1 are an Alert in accordance with the p 1 ant's emergency
action levels (EALs).
The licensee continued the good practice of issuing quarterly problem
sets to persons whose emergency duties included event classification.
The EP instructor indicated an individual must complete at least one
event classification problem set annually to remain qualified.
The
instructor also indicated that the annual training cycle's problem sets
were' expanded in scope to include EALs from all 20 emergency ~ondition
categ~ries listed in the classification procedure. This item will
remain open p~nding de~onstration of a SS's capability to properly
classify an emergency during the 1993 exercise.
-
(Open) Inspection Followup Item 255/92019-02:
During the 1992 exercise,
decisionmakers in the emergency operations facility (EOF) had difficulty
in interpreting procedural guidance regarding the meaning of the words
"consider evacuation if there are no constraints."
The protective action re~ommendation {PAR) flowchart in procedure
EI-6.13 was acceptably revised to include examples of environmental
conditions which tould be constraints to an ~vacuation df persons within
the emergency planning zone {EPZ).
The licensee continued to issue
quarterly problem sets to persons whose emergency duties included PAR
decisionmaking~ although an individual need only complete one problem
set annually. to remain qualified.
The current problem set addressed *
evacuation constraints. Records indicated that personnel were required
to complete a recent PAR problem set, which addressed the evacuation
constraints issue, prior to September 1993.
This item will re~ain open
pending completion of training on the evacuation constraints issue.
3.
Operational_ Status of the Emergency Preparedness Program (IP 82701)
a.
Actual Emergency Plan Activations
Since mid-February 1992, the licensee declared four Unusual Events
in accordance with the plant's EALs.
State, county, and NRC *
officials were initially notified in a timely manner following
each declaration and subsequent event termination.
As noted in the licensee's self-assessment of the Unusual Event
declared on April 1, 1992, the SS did *not declare the Unusual
Event until a root cause assessment was made regarding the reason
for a letdown system isolation to occur, which caused a primary
coolant system relief valve actuation during cold shutdown.
The
perceived need to make this assessment befqre *making an event
classification decision was not in accordance with the relevant
- EAL or NRC guidance.
Consequently, the Unusual Everit declaration
was delayed about 15 minutes. This short delay was an isolated
- instance of an untimely declaration.
No violations or deviations wer~ identified.
b.
Emergency Plan and Implementing Procedures
The licensee continued to revise its emergency plan on a section
by section basis.
NRC approval of the most recent revisions to
sections of the plan was indicated by letter dated February 25,
1993.
Changes to the plant's EALs were subsequently submitted for
NRC review.
Records indicated that revisions to the plan and its
, implementing procedures were sent to the NRC within the required
30 days of their effective dates~
Detailed reviews of several emergency implementing (El) series
procedures were conducted.
Referenced locations, supplies, and EP
training materials were reviewed as necessary.
These reviews were
performed to determine whether statements in the emergency plan or
letters of agreement (LOAs) were consistent with related
-*
implementing procedures, as well as whether the procedures
contained adequate implementation guidance.
Sections 7.1.2 and 7.1.3 of the plan indicated that the feedwater
purity building (FPB} was an alternate location in the event that
the technical support center (TSC} or the operational support
center (OSC} was inhabitable. Procedures EI-4.1, "TSC," and
EI-4.2, "OSC Activaticin," contained good radiological criteria for
considering a relocation of these facilities. While EI-4.2
indicated that the OSC would be relocated to the second floor of
the FPB, EI-4.1. included no reference to the FPB.
Neither
procedure indicated whether response facility evacuees should
bring documents and equipment with them, or whether such items
would be available at their destination.
The inspectors and the.new and former EP coordinators toured the
FPB.
The license~ indicated that the TSC evacuees'* destination
would be the.FPB's control room, while OSC evacuees would
reestablish the OSC at any convenient location o~ the building's
second floor.
The licensee indicated that TSC or OSC evacuees
would be expected to bring needed documents, supplies, ~nd
equipment to the FPB.
The building's control room had several
telephcines and additio~al telephone jacks.
Rele~ant lesson plans only indic~ted that an alternate OSC
location would be the FPB's control room.
These lesson plans did
n6t indicate whether TSC or OSC evacuees should bring needed items
to the FPB, or whether such -items were available in the FPB.
The
need to revise El-4.1 and 4.2, as well as associated lesson plans,
to provid~ adequate guid*nce regarding relocation of TSC or OSC
personnel is an Inspection Followup Item (255/93007-01}.
.
.
.
.
.
.
.
Provisions for the radiological monitoring of site evacuee~ and a
relevant LOA were reviewed.
The current LOA with the Covert Fire
Department indicated that the fire station would ~erve as a
-
decontamination facility for site evacuees and items brought with
them.
Procedures EI-8, "Onsite Radiological Monitoring," and
El-9, "Offsite Radiological Monitoring," indicated that monitoring
and decontamination of site evacuees would be performed by a
combination of onsite and offsiteradiological monitoring teams,
who would perform these functions at one or more specified
locations that did not i~clude the Covert Fire Station.
The
relevant EP lesson plan N00107, "Radiological Mo~itoring and
Rescue," included no reference to the Covert F.ire Station.
The licensee was uncertain whether State or licensee resources
would be utilized for radiological monit6ring and decontaminati-0n
services at this fire *station, if these tasks could not be
performed at predesignated locations closer to the site. The need
to revise relevant procedures and EP training materials to provide
~***
adequate guidance regarding the potential use of the Covert Fire
Station as a monitoring and decontamination facility is an
Inspection Followup Item {255/93007-02).
In response to a similar concern identified during a November 1992
inspection at the Big Rock Point Nuclear Plant {Inspection Report
No. 50-155/92023(0,RSS)), the Palisades Plant's EP coordinator and
instructor were revising procedures EI-2.1, "Emergency.Actions a~d.
Notifications," and El-3, "Communications and Notifications," and
the-assciciated lesson plan N00109, "Emergency Notification", td
a~curately reflect the followup notification requirement in *
10 CFR 50.72{c)(3). The current revisions of these procedures and.
lesson plan incorrectly indicated that the licensee would only
provide followup information to the NRC at 15 minute intervals if
an event *was classified as an Aler.t or a higher emergency cJass.
During tour$ of the TSC and EOF, the insp~ctors noted several
health physics network (HPN) telephones, which NRC requires
licensees to utilize to communicate HP-related information to
remotely located NRC incident responders.
Neither EI-3 nor lesson
plan N00109 addressed the use of the HPN telephones.
The licensee
was advised of NRC's expectations regarding the use of the HPN
telephones and the lack of associate*d guidance in the previously
listed procedures and lesson plan, which were being revised during
the inspection.
No violations or deviations were identified; however, two.
Inspection Followup Items were identified.
c.
Emergency Respon~e Facilities CERFsl, Equipment. and Supplies
The inspectors toured the control room, TSC, OSC, EOF, and the
FPB, which was identified as an alternate location for either the
TSC or the OSC.. The TSC, OSC, and EOF.continued to b~ utilized as
,normal workspace and were capable of being readily converted into
emergency response facilities (ERFs).
The TSC shared the adjacent co~trol room's e~ergen~y ventiiation *
system.
Records indicated that both trains of the system's
particulate and radioiodine filters were inspected and tested
during the Winter of 1992-93. *The licensee conservatively
replaced both trains' charcoal filter beds following successful
"as found" performance testing, since the charcoal was in place
for some years.
The new charcoal beds passed their "as left"
, performance tests.
Records inditated that all procedurally required emergency
equipment inventories and communication*s equipment tests were
performed since the previous inspection.
Based on facility tours *
and review of inventory records and communications equipment
tests, the TSC, OSC, and EOF were determined to be maintained in a
good state of operational readiness. It was noted that the
- operating frequencies of the response facilities' radio
communications equipment were recently changed following instances
of ~ignal interference from an offsite signal source.
Procedure El-8, "Onsite Radiological Monitoring," indicated that
monitoring teams would obtain up to 15 specified items, including
- an "onsite monitoring team deployment package," from an OSC
emergency Ht. During the tour of the OSC, the OSC emergency
"kit" was determined to be a 1 ocker, while the "dep 1 oyment
package" was a folder containing relevant procedu_res.
Upon comparing the kit's contents versus the inventory record, 'the
inspectors determined that several items were not available~ The*
technician responsible for inventoring this kit indicated that
missing items could be found in one of several nearby locations.
While so~eone performing periodic inventories was aware of that
fact, other technicians assigned to onsite monitoring team~ during
an emergency response might not have this knowledge, resulting in
delays in their deployment.
The missing items were returned to
the emergency kit before the exit interview.
The EOF was located at the licensee's conference center in South
Haven, Michigan.
The areas utilized as EOF workspace would be set
up by the center's groundskeeper and his staff, who were on
24-hour call to perform this function.
During the EOF tour, the licensee indicated that the facility had
- a communications equipment upgrade during late 1992.
At that
time, the facility's internal layout was significantly revised.
Although the revised layout was posted in an equipment storage
~area, drawings in procedure EI-4.3, "EOF Activation,"* depicted
only.the former layout.
The groundskeeper and a corporate
emergency planner stated that they_perform~d*a walkthrough of the
revised set up procedure in February 1993;
The planner indicated
that a revised EI~4.3, which had drawings of the revised EOF
1 ayout, would be issued in sever a 1. weeks.
The inspectors.
concluded that good interi~ measures on setting up the EOF
workspace were taken, pending issuance of the revised EI-4.3~
The plume pathway EPZ had 84 sirens. *The licensee's records
indicated that the sirens successfully passed operability tests on
97 percent of the test otcas ions._ The 1 i censee used a mixture of
volunteers and onscene tape records to document the test re~ults.
Records indicated that each siren had a single power supply.
, Several sources provided power to segments of the 84 siren
- network.
For example, one power source was associated with
49 sirens, while another provided power to seven sirens.
No violations or deviations were i~entified.
~*
d.
Organization and Management Control
The EP coordinator remained a full time position within the
Radiological Services Department.
The coordinator reported to the
plant manager through the health physics.supervisor and the
radiological services manager. A new coordinator, who* was
previously a member of the licensee's general office staff,* was
appointed in mid-February 1993.
Based on records review and discussions with cognizant licensee
staff, very good plans were implemented to develop the expertise
of the new coord~nator. These plans included observation of
several other sites' annual exercises, observation of the State's
emergency" operations center during a drill, and attendance at a
national EP seminar.
The coordinator was being qualified as a
member on the onsite review committee, which would facilitate her
involvement in th~ review of proposed changes to the plan and
implementing procedures.
Two technicians continued to serve as part-time assistants to the
EP coordinator. A senior instructor from the Training Department,
possessing excellent Knowledge of the licensee's EP program,
remained assigned as a part-time EP instructor.
The former EP
coordinator remained in the Radiological Services Department and
was another resource for the new coordinator.
The corporate EP.staff continued to consist of an administrator,
an analyst, and a planner.
The emergency response organization's (ERO's) staffing levels
ranged from very good to* excellent for all key and support
positions.. Although the licensee's emergency plan did not include
a commitment to conduct off-hours staff augmentation drills, the
licensee conducted several telephone callout drills during 1992
that successfully ~emonstrated the capability to augment onshift
personnel in a timely manner.
Several refinements were made to
the callout methodology during 1992.
Letters of agreement with offsite support organizations were*
current, with one exception. Auditors recently identified an
outdated mutual aid agreement with several other licensees.
Actions were in progress to update that agreement.
No violations or deviations were identified.
e.
Training
Records indicated that all. required drills had been conducted ~nd
critiqued since the last inspection.
The emergency organization's
roster was updated on a monthly basis. A spot check of several
dozen members' training records indicated that all were currently
trained for their assigned positions.
(
A sample of EP training m~terials were reviewed and were
determined to accurately reflect information in the current
revisions of relevant implementing procedures.
However, as
indicated in Section 3.b of this inspection report, several lesson
plans and the associated El-series procedures contained incomplete
or inaccurate information.
Interviews were conducted with members of the ERO.
A.control roo~
shift supervi~or and a shift engineer were interviewed with
respect to the following aspects of their emergency
responsibilities: emergency classification; notification of NRC,
State, and county officials following event classification;
activation of the ERO; and onsite and offsite protective ~ction*
decisionmaking. Their overall level of knowledge and performance
was good.
Separate inter~ie~s were conducted with two persons who would be
assigned to offsite dose,assessment tasks. Their overall
performances were good with respect to the following tasks:
acquiring current onsite ~nd/or local forecast meteorological
information; performing several offsite dose calculations using a
computerized methodology; and developing offsite protective action
recommendations for their supervisor's consideration, using the
guidance in procedure EI-6.13.
Separate interviews were conducted with two additional persons whb
could be assigned to communicator or communications group leader
positions in the EOF.
Their performances ranged from very good to
adequate with respect to th~ notification requirements invol~ing
NRC,
St~te, and county officials. As noted in Section*3.b of this
inspection report, several procedures and lesson plans contained
incorrect guid~nce about NRC notification *requirements, which
adversely affected some responses.
One individual exhibited
confusion with respect to the NRC's HPN telephone li~e and.its
. purpose versus a similarly named communications link with State
officials.
Records indicated that the required meeting with State and county
officials regarding the plant's EALs and other topics of mutual
interest occurred in 1992, as did the annual offering of EP
program orientation training to local.media representatives.
No violations or deviations were identified.*
f.
Independent Re~iews/Audits
- '
Records of and 1992 and early 1993 audits and surveillances* of the
EP program were reviewed.
The audits were thorough and met the *
requirements of 10 CFR 50.54(t} for 1992. * The requirement to
assess the adequacy of the interfaces with State and local support
organizations was scheduled to be performed later in 1993.
That
assessment would satisfy the regulatory requirements for 1993
independent reviews of the EP program.
Records indicated good
followup by the auditors on previously identified concerns.
The nuclear performance assessment department's (NPAD's) practices
with respect to EP exercise observation were discussed with a lead
auditor. Several NPAD staff typically pe_rformed surveillances of
exercises by observing in selected response facilities.
If either
the licensee's controller/evaluator organization or the NRC
inspection team identified a concern, the NPAD staff would note
this fact; however, the auditors ~ould not issue an audit finding
if they observed the same performance concern, since this was
considered an unneeded duplication.
Instead, NPAD staff would
monitor the progress on corrective actions taken on such ~oncerns.
No violations or deviations were identified.
4.
Exit Interview*
The inspectors held an exit interview on April 16, 1993, with those
licensee representatives identified in Section 1 tn present and discuss
the preliminary inspection findings.
The licensee indicated that none
of the matters discussed were proprietary in nature.
10