IR 05000255/1996011
| ML18065B067 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 11/15/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18065B065 | List: |
| References | |
| 50-255-96-11, NUDOCS 9611220206 | |
| Download: ML18065B067 (14) | |
Text
Docket No:
U.S. NUCLEAR REGULATORY COMMISSION REGION 3 License No:
50-255 DPR-20 Report No:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved by:
9611220206 961115 PDR AOOCK 05000255 G
Consumers Power Company Palisades Nuclear Generating Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530 September 30 - October 4, 1996 James E. Foster, Senior EP Analyst James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety
EXECUTIVE SUMMARY Palisades, Unit 1 NRC Inspection Report No. 50-255/960ll(DRS)
This inspection included a review of the emergency preparedness program, an aspect of Plant Support. This was an announced inspection conducted by a regional Emergency Preparedness Analys Licensee personnel performed very conservatively during an actual activation of the emergency pla (Section Pl.I)
The overall effectiveness of the licensee's emergency preparedness facilities, equipment, training, and organization was goo (Sections P2.l, P3, PS, and P6)
Quality assurance oversight of the EP program was comprehensiv EP staff self-assessments were a worthwhile and effective initiativ (Section P7)
The inspector completed Temporary Instruction 2515/134 "Onshift Dose Assessment" and verified that the licensee's capabilities met requirement (Section P9)
Report Details Pl Conduct of Emergency Preparedness (EPf Activities Pl.l Actual Emergency Plan Activation Inspection Scope (82701)
The inspector reviewed the single emergency plan activation which had occurred since the last routine inspectio Findings and Observations An Unusual Event was 9eclared at 9:02 p.m. on January 16, 1996, when a reactor shutdown was required by Technical Specification (TS) 3.7.2 due to the unavailability of a safeguards electrical bus and plant station power transforme The Unusual Event was terminated at 4:05 p.m. the following day when the plant reached hot shutdow Subsequent discussion with the NRC indicated that the classification was not required under the current Emergency Pla The licensee had modified the Emergency Action Levels (EALs) in accordance with acceptable deviations to the guidance in NUREG-0654, deleting the Unusual Event for a TS related shutdown unless the TS action statements were exceede However, the example initiating condition had not been deleted from the EALs, and the operating shift staff made the conservative decision to classify the event based on meeting the initiating conditio The initiating conditions have subsequently been modified to clarify that a classification is not required for a standard TS shutdown which meets the TS action statement Records reviewed indicated that the classification was very conservative, and notifications had been made properly and in a timely manne A documentation package for the event was adequat A procedure did not exist for the collection of actual event documentation, conduct of event critiques or overall event response evaluatio Discussion indicated that such a procedure would be developed after assessing other licensee's procedures for such review Conclusions The inspector concluded that the licensee had very conservatively implemented the emergency plan in declaring the Unusual Event, and corrected a minor error in the Emergency Action Levels following the even The licensee's review of the event was considered adequat P2 Status of EP Facilities, Equipment, and Resources P2.l Material Condition of EP Facilities Inspection Scope (82701)
The inspector toured the Technical Support Center (TSC}, Operational Support Center (OSC}, and Emergency Operations Facility (EOF) and assessed their material conditio The field team monitoring vans were inspected, as well as field team monitoring kit Findings and Observations Each facility was well maintained and in an excellent operational state of readines Current copies of the Emergency Plan, Emergency Plan Implementing Procedures and appropriate forms were present -in each facility, as require Minor enhancements intended, to improve performance were noted in various facilitie The inspector requested numerous pieces of equipment (survey equipment, computers, vehicle engines) to be operated; no problems were eviden New resource and team tracking boards were present in the OSC and TS Likewise, new priorities and equipment-out-of-service boards were present in the TSC and OS The TSC had a new facility sign-in board providing minimum manning requirement The Sequence of Events status board had been relocated to a more central location in the TS The Plant Process Computer (PPC)
terminal had been relocated to adjacent to the Operations Are Simulator data was available on the PPC terminals in the TSC and EO New telephones *in the TSC were a part of a plant-wide telephone system installed in May, 199 A "performance aid" had been placed in the TSC outlining issues to be discussed during TSC briefings. A new permanent computer for meteorological data was available in the EO Provisions for collocation of members of the NRC Site Team remain to be developed for the TSC and EO This long-standing item involved identifying where NRC Site Team members would physically sit and which telephones would be available for their us Discussion with the licensee confirmed that this issue would be reviewed as a part of the
. upcoming biennial emergency exercis Documents reviewed indicated emergency equipment inventories and maintenance were properly performed, with timely corrective actions taken where deficiencies were identifie Conclusions Overall, emergency response facilities were in excellent material condition with no problems or concerns. identifie Several facility enhancements addressed previous exercise shortcoming P3 EP Procedures and Documentation Inspection Scope (82701)
The inspector reviewed a small selection of licensee emergency procedures and emergency plan implementing procedures (EPIPs). Findings and Observations Responsibility for a number of the EPIPs was transferred as of June 1996 from the emergency planning group to line organizations more directly responsible for the procedure For example, Health Physics was responsible for emergency vehicle and some kit inventorie The Maintenance Department was responsible for OSC kit inventories. This placed responsibility for inventories with the organization which would utilize the inventoried equipment, and distributed the emergency preparedness workloa The current augmentation procedure has all four response teams called out at once, in order to insure that sufficient personnel are availabl Conversely, discussion with licensee staff indicated their concern that, with the new four-team ERO, it was possible that this will cause
facility crowding and possible confusio This was to be evaluated as a part of the upcoming exercis Conclusion No problems were identified with any of the reviewed procedure PS Staff Training and Qualification in EP Inspection Scope (82701)
The inspector reviewed the licensee's EP training progra This included interviews with selected key individuals, review of critiques, and comparing training records against the roster of emergency response organization (ERO) personne A sample of lesson plans was reviewed, including the Emergency Employee Augmentation Listing" and the training
"Requirement Status" printou Findings and Observations Records indicated that drills and exercises were formally critiqued, training had been provided formal critiques, and significant critique items were appropriately selected for corrective actio Printouts from the training tracking systems were compared with the
"Emergency Employee Augmentation Listing," with no problems identifie The training record database of response personnel was reviewed and found to be comprehensiv No Emergency Response Organization (ERO)
personnel reviewed were out of qualificatio *
Records indicated that walkthrough drills were conducted in the TSC and EOF on February 27 and 28, 199 These drills involved hands-on training by "walking through" the activation and tasks of the facilitie Participant feedback (critique sheets) for these drills as an alternate to the traditional classroom training were very positiv Walkthroughs were also conducted in the TSC, OSC and EOF during May 5 and 8, 199 Lesson Plan N00108, "Emergency Dose Assessment," revised May 2, 1996 was reviewe Section 6.10 "Automated Dose Assessment Program," provides guidance on the computerized dose assessment metho A minor error in the training and associated procedure described a computer start-up procedure no longer required. A procedure change was immediately initiated, and a notation made to update the lesson plan in the next revision (see section P9).
Lesson Plan N00336-4, "Orientation to Emergency Preparedness",
addressing Emergency Operations Facility and Federal Response, was reviewe Section 6.6 provides a brief overview of the NRC incident response program with response modes, discussion of site team composition, and assigned response location The Department of Energy's Federal Radiological Monitoring and Assessment Center's rol.e in the overall federal response was also outline The inspector noted that the NRC section was primarily meant for key responders in the TSC and EOF, and was not necessary for all response personne Review indicated that some EP lesson plans have not been revised since 198 Discussion indicated that the lesson plans were being updated as use of the particular module was require Further discussion indicated that the underlying training program was basically unchanged; a training matrix with position-related lesson plans and required drills. The program has allowed challenging of the exam in lieu of attending trainin The walkthroughs conducted this year supplemented the basjc program, were effective and well receive The inspector reviewed the Palisades Exercise (PALEX) 1995 results summary, dated December 22, 199 The summary matched the NRC evaluation teams' findings very well and identified additional item This confirmed the licensee's ability to self-assess their own exercise performanc A "dress rehearsal" for PALEX-96 was conducted on September 24, 199 The licensee's evaluation of overall drill performance was that they had performed well, exceeding their performance expectations for 6 of 24 objectives and failing to meet 2 objective Interviews with two key emergency response personnel indicated the individuals clearly understood their emergency responsibilities and activities.
6 Conclusions The overall EP training was considered adequate, with challenging drills and adequate training sessions. Critique documentation was adequate and problem areas were highlighted for further trainin The training records were complete and interviewed individuals were knowledgeable about their ERO responsibilitie P6 EP Organization and Administration (82701)
The overall organization and management control of the EP function was extensively changed since the last inspectio The Emergency Planning Section Supervisor reported to the Plant Manager through the Training Manage The corporate emergency planning staff, previously responsible for both Big Rock Point and Palisades plants, has been eliminate A new Emergency Response Organization (ERO) was put in place starting July 1, 199 This organization consisted of four complete emergency response teams, and increasing the ERO from approximately 70 people to approximately 350 peopl Designated ERO personnel were issued pagers during their teams designated weeks as lead tea Increasing the size of the ERO should enhance incident response capability; the team concept has worked well at other utilitie P7 Quality Assurance in EP Activities P7.l Audits (82701) Inspection Scope (82701)
The Inspector reviewed Nuclear Performance Assessment Department (NPAD)
Audit PA-96-02, "Emergency Preparedness Audit," dated May 17, 1996, performed during March 18-22, 199 The inspector also reviewed the following surveillances:
Surveillance Report NPAD/P-95-030, "PALEX 95 Practice Drill",
dated 11/10/9 Surveillance Report NPAD/P-95-036, "PALEX 95 graded Exercise",
dated 12/8/95, and associated Field Monitoring Reports P-95-548, 549, 550, 551, 552, 547, and 553, that formed the basis for the conclusions in the surveillanc Surveillance Report NPAD PA-96-17, "Palisades and Big Rock Point Meteorological Monitoring Project Plan," dated 7/22/9 Surveillance Report NPAD/P-95-037,"State and Local Government Emergency Preparedness Interfaces". This surveillance, conducted during December, 1995, covered the offsite interfaces for both Palisades and Big Rock Poin The surveillance noted positive relationships between both plants and offsite authoritie Distribution for the surveillance included offsite authorities as required by 10 CFR 50.54(t).
The inspector reviewed the following Field Monitoring Reports:
FM-P-96-052, Emergency Medical drill FM-P-96-053~ Post Accident Sampling Monitor (PASM) Drill FM-P-96-070, Emergency Drill Training Sessions FM-P-96-076, Technical Support Center Facility Training FM-P-96-077, Operational Support Center Facility Training Findings and Observations The annual EP audit (PA-96-02) covered Palisades Emergency Planning (EP), and was performed by two auditor The audit concluded that the EP program was being effectively implemented by the Training Department, with all requirements being me There were no significant weaknesses identified in the audit; there were four self-identified "potential risks to the program" which had been identified to the auditors by the EP staf The audit team noted strengths in the areas of self-assessment, program performance enhancements, and internal and external communication interfaces. The auditors also noted minor documentatton errors which were not considered as indicating a significant proble The audit was complete and well detaile The 1995 audit of the EP program satisfied the requirements of 10 CFR 50.54(t) with respect to scope~ Records also indicated that the EP staff fulfilled the requirement to make relevant 1995 audit results available to State and county official In addition to the audits, a number of Field Monitoring Reports had been performe These reviews identified several minor items, including needed procedure revisions and procedure dispositio The EP group had performed thirteen self-assessments of various areas during 199 A comprehensive self-evaluation of EP training was completed in February, 199 Other self-assessments focused on ERO membership and Site Emergency Director (SEO) succession, drills, emergency kits, EP roles/responsibilities, TSC layout, OSC layout (possible relocation), Status boards, the second quarter drill, instrument calibration, wa1kthroughs and scenario developmen EP staff self-assessments enabled detailed reviews of program areas by the most cognizant individuals, and were a worthwhile and effective initiativ Conclusion The licensee's 1996 audit of EP activities was effective and satisfied the requirements of 10 CFR 50.54(t). Other oversight activities were comprehensiv EP staff self-assessments were a worthwhile and effective initiativ PS Miscellaneous EP Issues (Open) Exercise Weakness (50-255/95013-0l(DRS)):
During the 1995 Exercise, TSC activation was unsatisfactory; there were insufficient pe.rsonnel in the facility for the assumption of Command and Control, and they had not been briefed on the emergenc This item will remain ope (Open) Inspection Follow-up Item (50-255/95013-02(DRS)):
During the 1995 exercise, the process of briefing TSC team leaders prior to briefing facility personnel extended the briefing process by creating an unnecessary redundanc Facility operations slowed while team leaders attended such briefings. This item will remain ope P9 Temporary Instruction 2515/134 On-shift Dose Assessment Inspection Scope The inspector discussed dose assessment capability and prov1s1ons with licensee personnel, reviewed the Emergency Plan and Emergency Plan Implementing Procedures (EPIPs), and inspected equipment in the Control Roo Training plans and Job Performance Measures for dose assessment were also reviewe Findings and Observations The Emergency Plan contained prov1s1ons for on-shift dose assessment in Sections 3.0 (3.2, table '3.1), 4.0 (4.1, table 4.1), and Section 6.1.l, Control Room Personnel," specifically indicated that the Shift Supervisor was responsible for projection of offsite dose rate Section 6.2,5, Estimation of Offsite Dose", provided for three methods of offsite dose calculation, a computerized straight-line gaussian, a manual backup method, and a computerized segmented plume mode Emergency Plan Implementing Procedures EI-1, EI-2,l, and EI-6.0 provtded guidance as to when and how the dose calculation was to be performe El-6.0, "Offsite Dose Calculation and Recommendations for Protective action, section 6.1, "Quick Method Dose Assessment," provided specific instructions for on-shift use of monitored release (stack or steam dump releases only) and meteorological information to make inputs to a personal computer running the "offsite" dose calculation progra The program had the capability of printing a Michigan notification form if require Discussion with control room personnel and a demonstration of the program indicated that personnel were familiar with the required sources of information, running the program, inputting data and obtaining notification form printout The inspector reviewed procedure EI-6.0 in detail. Section improperly called for reboot of computer, while inspection indicated that the program start is currently initiated by a windows icon in the control room personal compute Licensee personnel immediately
'ii initiated a procedure rev1s1on to correct this ite This item was of very minor significance, as Control Room personnel demonstrated familiarity with the syste Discussion with licensee personnel and a review of training plans, including Job Performance Measures TBAL-JPM-03 and TBAL-JPM-03A,
"Calculate Offsite Dose," and lesson Plan N00150, "Emergency Dose Assessment, Quick," indicated that adequate training was provide Per the EP training matrix, lesson plan N00150 is required annually for Senior Reactor Operators and Shift Technical Assistant The training may be satisfied by self-study after initial lesson completio Conclusio The Emergency Plan and EPIPS contain prov1s1ons for on-shift dose assessmen Needed equipment and personnel training were provide Control Room personnel were knowledgeable of their responsibilities and how to perform dose assessmen All of the acceptance criteria for the'~
TI were met and this TI is close Documentation as to these findings is attached as Attachment PIO Review of UFSAR Commitments Inspection Scope A discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures, and parameters to the. UFSAR description While performing ~he inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to Emergency Preparednes Observations and Findings Chapter 12, "Conduct of Operations," Section 12.5, "Emergency Planning,"
of the UFSAR contains the single statement that the Palisades Plant Site Emergency Plan has been submitted as a separate documen The inspector discussed whether some general overview of the program should be placed in the UFSAR in addition to the brief reference to the Emergency Pla The UFSAR was not meant to contain a full Site Emergency Plan, nor be updated each time an Emergency Plan change was mad Internal NRC guidance was not specific as to the acceptable level of detail for this section of the UFSAR, but many other plants place overview material in this.sectio Conclusion The UFSAR should, at a minimum, contain some general overview information as to the Emergency Preparedness progra Licensee
- personnel advised that this would be considered for the next UFSAR revisio Xl Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on October 4, 199 The licensee acknowledged the findings presente The inspector asked the licensee whether any materials examined during the inspection should be considered proprietar No proprietary information was identified.
PARTIAL LIST OF PERSONS CONTACTED Licensee T. Palmi.sano, Plant Manager M. Mennucci, C&RS Manager Alternate K. Haas, Training Manager R. Vincent, Licensing Supervisor C. Kozvp, Licensing Engineer E. Karpe, Emergency Planning Section Supervisor J. Brunet, Emergency Planning Coordinator N. Brott, EP Planner M. Hobe, EP Planner K. Penrod, EP Planner M. Parker, Senior Resident Inspector, Palisades P. Prescott, Resident Inspector, Palisades
INSPECTION PROCEDURES USED IP 82701 Operational Status of the EP Program TI 2515/134 Temporary Instruction, On-shift Dose Assessment ITEMS DISCUSSED 50-255/95013-01 50-255/95013-02 IFI TSC activation was unsatisfactory IFI TSC briefing process inefficiencies CFR EAL EP ENS EOF EPIP ERO IFI IR NPAD NRC NU REG osc PAL EX PASM PIF SQV TS TSC UFSAR LIST OF ACRONYMS USED Code of Federal Regulations Emergency Action Level Emergency Preparedness Emergency Notification System Emergency Operations Facility Emergency Plan Implementing Procedure Emergency Response Organization Inspection Followup Item
Inspection Report
Nuclear Performance Assessment Department
Nuclear Regulatory Commission
Nuclear Regulatory Commission document
Operational Support Center
Palisades Exercise
Post Accident Sampling Monitor
Problem Identification Form
Site Quality Verification
Technical Specification
Updated Final Safety Analysis Report
- .
ATTACHMENT A FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY
Palisa
lUnit 1 /50-255
SITE/UNIT/DOCKET #s
4.01
DOSE
Acceptance Criteria
(Refer to page 1 of this Appendix for
further detail on the acceptance criteria)
Section 4.01 Item 1
Emergency Plan contains commitment for on-
shift dose assessment capabilit Section 4.02 Item 1
Procedure initiates dose assessment
Section 4.02 Item 2
Indications initiate dose assessment
Section 4.02 Item 3
Procedure for performing dose assessment
availabl Section 4.03 Item 1
Ellen Karpe
Ellen Karpe
Ellen Karpe
Ellen Karpe
Ellen Karpe
Ellen Karpe
On-shift Personnel trained for dose assessment
Norm Brott
2515/134
/'
--
) Jr'
Consumer's Power Company
LICENSEE
Position Title(s)
EP Section
Supervisor
EP Section
Supervisor
Position Title(s)
EP Section
Supervisor
EP Section
Supervisor
EP Section
Supervisor
EP Section
Supervisor
EP Projects
Plan Section
containing
commitment
Section 6, 6. 1. 1 (g)
(6, 8, 9, 10). page 4
of 1 Section 6, 6.2.5,
page 9 of 1 El-2.1, Attachment 1,
item 16, page 1 of El-1, Attachment 1,
"Actions" colum El-6.0, Section 6.1,
Revision N and Date
Rev. 7
11 /20/95
Rev. 7
11 /20/95
Revision N and Date
Rev. 19
08/5/96
Rev. 24
08/29/96
Rev. 7
01/10/96
El-1 Attachment
Meets acceptance
criteria?
Ye Ye Meets acceptance
criteria?
Ye Ye Ye Meets acceptance
criteria?
Ye lnsoector: James E. Foster. Region Ill, DRS. Plant Support Br. 1
A-14
Issue Date:
09/26/96