IR 05000266/1986013

Insp Repts 50-266/86-13 & 50-301/86-12 on 860804-08 & 13.No Violations,Deficiencies or Deviations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Action on Previous Open Items

ML20214L388
Person / Time
Site:	Point Beach
Issue date:	08/26/1986
From:	Foster J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214L382	List: IR 05000266/1986013 ML20214L379
References
50-266-86-13, 50-301-86-12, TAC-62292, TAC-62293, NUDOCS 8609100124
Download: ML20214L388 (12)

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U.S. NUCLEAR REGULATORY COMMISSION i

REGION III

. Reports No. 50-266/86013(DRSS); 50-301/86012(DRSS)

Docket Nos. 50-266; 50-301 Licenses No. OPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Power Plant, Units 3 and 2 Inspection At: Point Beach Site, Two Creeks, WI Inspection Conducted: August 4-8 and 13, 1986 Inspectors: s't Jr/u/3 Team Leader Date M. Smith T. Allen Approved By: I ef 8/2G/8c, Emergency Preparedness Date Section Inspection Summary Inspection on August 4-8 and 13, 1986 (Report No. 50-266/86013(DRSS);

No. 50-301/86012(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of

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the Point Beach Nuclear Power Plant emergency preparedness program: action on previous Open Items; activations of the licensee's emergency plan; emergency detection and classification; dose projection; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); public information; licensee audits; LER review; and, PASS sample. This inspection involved three NRC inspectors, and one consultan Results: No violations, deficiencies or deviations were identifie ,

8609100124 860827 PDR ADOCK 05000266 O PDR

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DETAILS 1. Persons Contacted

• J. Zach, Plant Manager

• R. Bruno, Superintendent Training

• R. Winget, Emergency Planning

• P. Dent, Supervisor, Staff Service

• J. Knorr, Regulatory Engineer D. Stevens, Emergency Preparedness Coordinator E..Ziller, Shift Superintendent I. Bleeker, Shift Superintendent J. Reisenbeucher, Duty and Call Superintendent T. Koehler, Site Manager-(EP)

R. Mitchell, Shift Superintendent C. Gray, Shift Superintendent G. Rau, Duty Technical Advisor G. Sherwood, Duty Technical Advisor T. Staskal, Duty Technical Advisor R. Arnold, Chemistry Supervisor D. Gesh, Chemistry Technician D. Evers, Chemistry Technician P. Lightbody, Radiological Control Operator T. Fredrichs, Chemistry Director R. Neustadter, Chemistry Director T. Branam, Duty Technical Advisor W. Fromm, Duty Technical Advisor W. Hennig, Duty Technical Advisor A. Shedlosky, Shift Superintendent K. Sokol, Shift Superintendent R. Hague, NRC Senior Resident Inspector

• R. Leemon, NRC Resident Inspector

• Denotes those attending exit intervie . Licensee Actions on Previously-Identified Open Items (Closed) Open Item (266/85005-01; 301/85005-01): Evacuation time estimates. EPIP 1.1 as revised, leads individuals through to protective action recommendations which have built-in the evacuation time estimates for varying weather conditions. Evacuation times are found in Appendix "J" of the Emergency Plan if more time is available for formulating protective action recommendations (EPIP 1.1 uses conservative values). This item is close (Closed) Open Item (266/85005-02; 301/85005-02): Inventory lists for emergency kit Inventory lists are kept in offsite (mobile) kits, but not stationary kits or cabinets containing emergency supplie Inventory assurance for stationary kits and cabinets is maintained through quarterly inventory verifications. This item is close _ . _ __ _ _ _-.. . _

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d (Closed)'Open Item (266/85012-01; 50-301/85012-01): Fifteen minute

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notification time requirement for local agencies. By letter dated December 20, 1985, the NRC advised the-licensee that the fifteen

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minute notification time for all emergency classifications was a

. regulation, and could not be expanded. The EPIP relative to notifications has been changed to require a fifteen minute notifica-tion of local authorities for an Unusual Event, and licensee personnel advised that the Emergency, Plan will be revised to reflect the same requirement. This item is closed.

! d .- - (0 pen) Open Item (266/84013-04; 50-301/84011-04): Emergency Action

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Level Review. Licensee personnel indicated that an EAL-task force had been formed to review the EALs, compare them with the guidance

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in NUREG-0654, and consider including reference to fission product -

barrier analysis. In addition, consideration is'being given to

! deleting references to grab or chemistry samples, due to the time required to perform such testing in an accident situation. This item will remain open pending completion of the EAL review and possible revision.

(0 pen) Unresolved Item (266/85005-03; 301/85005-03)

Security EAL The licensee was advised that Security incidents must receive an

emergency classification. As noted in Section 16 of this report, I a meeting was held on August 13, 1986, and it was determined that i a change to the Security Plan, to provide for security event j classification and notification of offsite authorities would be acceptabl This item will remain open pending final review and i acceptance of the revised Security Plan.

1 Activations of the Emergency Plan

! The licensee has had two Emergency Plan activations since the last

, inspection, both Unusual Events (UEs), one on July 25, 1985, and one

on December 31, 1985, and both involving electrical transformer (loss

of offsite power). problems.

i The inspector reviewed documentation related to both events. Both had

properly been classified under,the Emergency Action Levels in EPIP 1.2, Category 8, related to " sustained loss of offsite AC to the Safeguards bus for over fifteen minutes." State and local agencies, and the NRC

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(Duty Officer and Resident Inspector) had been properly notified in each j case.

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It was noted that notifications for State and local agencies had exceeded j thirty minutes. However, site procedures in effect during the events l allowed up to one hour for such notifications. As detailed elsewhere in

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this report, the' implementing procedures have been revised to require a fifteen minute notification of State and local authorities for Unusual t

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During the event on July 25, 1985, the Headquarters Duty Officer had difficulty obtaining information regarding plant status, and called back to the plant several time Due to this problem, the licensee was requested to evaluate the methods used for notification of offsite

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agencies, including the NRC. The licensee provided clarifying information to the extent that they place emphasis on making the initial notification as soon as possible, with the intent that detailed informa-tion will follow in subsequent contacts. Other subsequent changes to reporting procedures, such as an improved report form, have improved emergency information exchange with the NR No violations of regulatory requirements or deviations from commitments were identifie . Emergency Detection and Classification (82201)

The inspector reviewed the Wisconsin Electric Power Company and Wisconsin Michigan Power Company Emergency Plan (EP) and the Point Beach Nuclear Plant Emergency Plan Implementing Procedures (EPIPs). The emergency action levels (EALs) were determined to be consistent with those identified in NUREG-0654 with the exception of Security EAls. Units obtained from instrumentation in the Control Room, used in the EAls, were verified as adequat The notification procedures (EPIPs) include criteria for the initiation of offsite notifications and for development of protective action recommendations. These procedures require that offsite notifications for each of the four categories be completed within fifteen minutes. The EP still states, however, that "For an Unusual Event, notification....must be completed within one hour of the initial classification." (EP Section 7.1). Discussion with licensee personnel indicated that they were aware of the disparity, caused by revision to the EPIPs to provide for fifteen minute notifications at the Unusual Event level, and the EP will be revised in the near futur Licensee documentation showed that the EALs had been discussed with State and local officials in October 1985, and that a meeting to discuss EALs and the Emergency Plan and procedures is scheduled for August 1986.

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Ten members of the emergency plan organization, two Site Managers, four i Shift Superintendents, and four Duty Technical Advisors (the latter two in teams of one of each) were interviewed to establish their knowledge of and ability to implement the EP and EPIPs. All of the individuals were knowledgeable and displayed an ability to implement the procedures in

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relation to accident classification and escalation. notification, and

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protective actions recommendation Knowledge of * arious core damage

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indications and their relationship to the status of the core was demonstrated by reacting to scenarios presented to the Personnel interviewed promptly and properly classified simulated accident conditions presented to them.

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No violations of regulatory requirements or deviations from commitments were identifie . Protective Action Decisionmaking (82202)

The inspector reviewed the EP and EPIPs and determined that the responsi-bility and authority for accident assessment and protective action decisionmaking were clearly delineated. Interviews and walkthroughs with four teams of two duty personnel (Shift Superintendent and Duty Technical Advisor) and discussions with two Site Managers clearly indicated that these responsibilities and authority are understood and could be carried ou Each appeared to be cognizant of appropriate onsite protective measures and aware of the range of protective action recommendations appropriate to the protection of personnel offsite, and the need for timeliness in making initial protective action recommendations to offsite official The relationship between core condition, containment status, and protective action recommendations was demonstrated for the scenario conditions presented for interview purpose The capability of offsite officials to make protective action decisions and to promptly notify the public was discussed with licensee representatives. Procedures are in effect to notify responsible offsite authorities on a 24-hour basis with back up communications availabl No violations of regulatory requirements or deviations from commitments were identifie . Communications (82203)

The notification procedures in the EPIPs are consistent with the emergency classification and Emergency Action Level schemes. Provisions are made for message verification. Adequate procedural means exist for alerting, notifying, and activating emergency response personnel. The EPIPs specify when to notify and activate the TSC, OSC, and EOF. The EP does not require activation of the TSC for an Alert as specified in NUREG-0696, but leaves this to the discretion of plant management. The EP requires the TSC to be activated in thirty minutes, and " Fully Operational" in one hour, and the E0F to be activated in one hour, and staffed by corporate personnel in two hours. Discussion with licensee personnel indicated that they had considerable assurance that these facilities could be staffed and operational in the shorter timeframe. It was not clear that the timeframes for facility operation were consistent with the guidance in NUREG-0696, and it is recommended that this section of the EP be clarifie The initial emergency message form was found to contain the information provided in the guidance in NUREG-0654. This form has been reviewed and approved by State and local government authoritie It was noted that no guidance had been provided in the EPIPs on when update notifications should be provided (generally each hour, on major plant parameter status change, or on change of emergency classification).

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Provisions exist for prompt communication between emergency response organizations and facilities and thd public. These systems are described in the EPIPs. Selective operability checks were conducted satisfactorily, and records indicate the required communications tests are being conducte Based on the above findings, this portion of the licensee's program is adequate, however, the following items should be considered for improvement:

• The EP should be revised and clarified to reflect the criteria in NUREG-0696 that the TSC should be activated at an Aler * Include guidance on when to make update notifications to State, local, and NRC personnel 7. Changes to the Program (82204)

The inspectors reviewed documentation related to changes to the Emergency Plan (EP) with regard to processing, distribution, and implementation, and determined that all changes were appropriately processe The Point Beach Emergency Plan is classified by the licensee as a " major" procedure. " Major" procedures require review by the Manager's Supervisory Staff with approval by the Plant Manager. The EP implementing procedures are classified as " minor" procedures. Changes to these minor procedures now require approval of Emergency Preparedness supervision and the cognizant supervisor prior to implementation. This process assures changes to the EP program are reviewed by the proper level of managemen No violations of regulatory requirements or deviations from commitments were identifie . Shift Staffing and Augmentation (82205)

The inspector reviewed the records of the shift augmentation drills conducted in December, 1985, and July, 1986, reviewed Section 5 of the Emergency Plan, Section 3.3 of the Emergency Plan Maintenance Procedures, and EPIP 1 The minimum shift staff, outlined in Figure 5-1 of the EP, provides for four Auxiliary Operators, one Shift Superintendent, one Operating Supervisor, two Control Operators, one Duty Technical Advisor and one Rad / Chem Technician on shift 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> per wee This shift staff compliment is in accordance with an exemption from shift staffing levels in Table B-1 of NUREG-0654, previously granted by the NR Key emergency response personnel have radio pagers and can be contacted via group pager codes. Shift augmentation is initiated by the Shift Superintendent contacting the Duty and Call Superintendent (DCS) via telephone or pager. The DCS then contacts a second Duty and Call Superintendent and Health Physics Supervisor to discuss manpower need All supervisory personnel contacted by pager or through phone calls from the Duty and Call personnel are then responsible for contacting working level personnel sufficient to respond to the emergency. This system is

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designed to achieve staffing goals such that the TSC can be activated within 30 minutes and the EOF activated within one hour of the decision to augment TSC staff. Records of the 1985 and 1986 drills indicated that sufficient personnel would have responded to the notification to meet the (unmodified) augmentation goals of Table B-1 of NUREG-0654, Revision It is recommended that each drill be documented as successful or unsuccessful and a short critique be included. Call lists of personnel were reviewed quarterly in accordance with the emergency pla The licensee has improved the program by specifying the Supervisor, Staff Services and the EP Coordinator as responsible personnel for quarterly revisions of the telephone number listing, and establishing Procedure to assure that Shift Augmentation Drills will be conducte No violations of regulatory requirements or deviations from commitments were identifie . Knowledge and Performance of Duties (Training) (82206)

The inspector reviewed the licensee's program for training personnel involved in the emergency program, and tracking the completion of training modules to assure individuals assigned emergency responsibili-ties were qualified for their position The inspector reviewed the licensee's emergency preparedness training program, including training course descriptions for various personnel training programs, lesson plans for the training courses, drills, quarterly training audits, and training records of selected key emergency response personnel. The licensee's training program requirements were specified in Emergency Preparedness Maintenance Procedure 3.1. All Point Beach Nuclear Plant (PBNP) employees have been provided basic emergency response training during the General Employee Training Program. All perso'nel not assigned major response duties were to be retrained biannually in the content of the Emergency Plan and the EPIPs. Personnel who are assigned major roles in the emergency response organization receive annual training on substantive changes in the Emergency Plan and EPIPs, in addition to biennial participation in a drill for each position they may be assigne The inspector reviewed the drill scenarios used to train Control Room personnel and verified that they addressed all emergency actions these personnel are assigned, including the responsibility to make a protective action recommendation upon declaration of a General Emergenc A random review of various employee records verified that initial training and retraining were provided at the required frequenc Walkthroughs were conducted with several members of the licensee's Emergency Response Organization. The results of the walkthroughs are documented in Sections 6 and 10 of this repor The licensee had provided annual training for offsite emergency support personnel, media and general public in conjunction with neighboring Kewaunee Emergency Preparedness personnel. A review of training records verified all training of offsite perscnnel was conducted at the required frequenc '

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No violations of regulatory requirements or deviations from commitments were identifie t 10. Dose Calculation and Assessment (82207)

Individual walkthroughs were conducted with five Duty Technical Advisors, '

two Shift Supervisors, and two Chemistry Directors. These positions had emergency response duties for dose calculation and assessment, and for making protective action recommendations. Each person was presented a scenario involving a simulated Loss Of Coolant Accident (LOCA) with released airborne radioactivity and asked to determine offsite dose rates, accumulated doses, and recommended protective action Each person demonstrated the capability to correctly analyze the scenario, calculate .

dose rates and accumulated doses, and to recommend appropriate protective '

actions. The calculations were made using the Dose Projection program resident on the Radiation Monitoring System (RMS) computers in the Control Room and Technical Support Center. The computer program automatically incorporated dose calculations into protective action recommendations which were color coded (e.g., red for evacuate, white for sheltering, and green for no action required) on the display monitor. The interviewees L also demonstrated the capability to perform the calculations and assessments manually using EPIPs 1.1, 1.4, and 1.8. Graphs, overlays, and tables used for the manual determinations were reviewed by the inspector and appeared to be readily available and acceptabl The walkthroughs indicated that responsible personnel can adequately conduct dose calculations and assessments using either the RMS computer or manual methods. A few of the individuals exhibited some uncertainty or slowness in recognizing the meaning of the RMS computer color codes for protective actions. The most common delay regarded determining whether the evacuation area indicated in red included only the distances listed in red or extended on to the first adjacent distance listed in whit The inspector compared the licensee's RMS Dose Projection program with the NRC's Interactive Radiological Dose Assessment dose projection program (IRDAM) by running RMS with the same radiological release and meteorological data used for a recent protective measures training session at Region III. The RMS dose rates, accumulated doses, and protective action recommendations were very consistent with the IRDAM result The inspector also reviewed the licensee's July 1985 report of comparison between the licensee's mainframe computer dose projection program (MAD) i and the State of Wisconsin's, Division of Health and Social Services,

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dose projection models. The evaluation of nine different accident release scenarios concluded that licensee and State programs produced acceptably similar result Based on the above findings, this portion of the licensee's program was adequat However, the following item should be considered for improvement:

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• Training provided to RMS Dose Projection program operators should ensure that operators clearly understand the color-coded protective action recommendation *

1 Public Information Program (82209)

The 1986 edition of the Emergency Information Handbook was in the annual review process and is presently planned for production in September, 198 It will subsequently be be distributed to residents in the ten mile EP The inspector's review of the revised draft handbook indicated that its contents met the guidance of NUREG-0654, Revision 1. The revised wording and format of the brochure appeared to be a significant improvement over the previous brochure. The format and content of the brochure had been coordinated with State and local officials. An annual media briefing, shared with the Kewaunee Nuclear Power Plant, had also been held. The licensee's emergency public information program therefore meets the requirements of 10 CFR 50, Appendix No violations of regulatory requirements or deviations from commitments were identifie . Licensee Audits (82210)

The inspector verified that the licensee had in place provisions for conducting an independent annual audit of the Emergency Progra The inspector reviewed the two 1986 audits performed relative to Emergency Plannin Audit A-P-86-02 reviewed the Emergency Preparedness program itself, and was conducted by corporate personnel during April 9-10, 1986. The audit was adequately comprehensive and detailed, resulting in five findings, three observations, and four comments / recommendations. Findings from the audit were tracked via Audit Finding Reports. A review of the Audit Finding reports indicated that corrective action had been or was in the process of being taken where appropriat A separate section of the Audit dealt with the adequacy of the interface with off-site authorities. Licensee personnel indicated that the audit is provided to offsite authorities when specifically requeste CFR 50.54(t) requires that the portion of the audit dealing with the adequacy of offsite interfaces be made available to offsite authoritie In order for offsite officials to recognize that they can make such a request, they should be advised that the audit report has been generated, and provided with a contact where the request can be mad Audit A-P-86-05 reviewed Emergency Preparedness training, and was conducted by corporate personnel during May 19-20, 1986. This audit resulted in four findings, one of which required no response. The three Audit Finding Reports generated by the audit were reviewed. In each

case, corrective action had been or was in the process of being taken.

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One of three findings indicated that no specialized training had been provided for fifteen of the emergency response organization position As specialized training may not be required for each EP position, a Needs Analysis (No.86-215) and job task analysis was performe Based on the above findings, this portion of the licensee's program is adequate, however, the following item should be considered for improvement:

• Provide a method of advising offsite authorities that the annual audit has been performed and provide a contact so that they may request the portion of the audit dealing with the adequacy of offsite interface if desire . Maintaining Emergency Preparedness (82701)

A review was made of the licensee's letters-of-agreement with offsite groups and agencies. Letters were dated within the two year timeframe requirement, however, the licensee indicated that letters would now all be reviewed as a group with one expiration dat An examination was made of documentation of the following drills, required by the Emergency Plan and Emergency Plan Maintenance Procedure (EPMP) 3.3:

Communications Drills Medical Emergency Drills Radiological Monitoring and Health Physics Drills Chemistry Drills Site Accountability and Evacuation Drills Search and Rescue Drills A check of the dates on which the drills were conducted determined that all were within the frequencies required by the Emergency Plan and procedures. It was noted that drills involving local ambulance personnel participation were to be scheduled every four years (with alternating drills with the Kewaunee plant). The licensee should evaluate this frequency of training to determine if it is adequat EPMP 1.1 and 1.2 specify the scheduling for routine checks, maintenance calibrations, and inventories for health physics emergency plan maintenance. A review of the documentation for routine checks, maintenance, calibrations and inventories conducted since November, 1985, determined that all were conducted within the required timeframe. The records indicated inventory shortages were replenished in a timely manne Discussion with licensee personnel indicated that there is no automated system for reminding personnel that inventory timeframes are expiring, and some inventory dates were near the end of the allowable period. It is recommended that some form of computerized tracking be utilized to assure that inventories do not exceed required timeframe *

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Discussions with licensee personnel and a check of field monitoring kits and TSC cabinets determined that copies of inventory sheets had been placed in kits and cabinets. A random check of the instrumentation contained in the kits and cabinets determined that calibration dates would not expire prior to the next scheduled inventor A review of siren system tests revealed three of six sirens out of service for three months and out of service intermittently for six months before that. Discussions with licensee personnel and a representative from FEMA revealed the implementation of a much larger system by September 13, 198 Once certified by FEMA, the system will be tested monthly with final certification in a yea The system will consist of a total of 26 sirens in Manitowoc and Kewaunee countie Point Beach will be responsible for the purchase, installation and maintenance of 13 of these sirens in Manitowoc County. The Kewaunee Nuclear Plant will purchase, install, and maintain 13 sirens in Kewaunee Count No violations of regulatory requirements or deviations from commitments were identifie . Post Accident Sampling and Analysis Post accident sampling and analysis of potentially high level reactor coolant was satisfactorily demonstrated. The sampling crew, two Chemistry Technicians (cts) and one Radiological Control Operator (RCO),

worked well together and coordinated their efforts to efficiently collect, handle, and analyze the sample (actual reactor coolant). No procedural problems were encountered and the RCO correctly maintained radiological safety controls as appropriate for As Low As Reasonably Achievable (ALARA) and contamination contro The cts demonstrated proper radiological controls to contain or minimize contamination during sample collection and analysis procedures which included withdrawing a sample from the pressurized sample container, depressurization and dilution of the coolant sampl The capability to analyze gaseous and liquid samples was adequately demonstrated by. chemistry laboratory personne No violations of regulatory requirements or deviations from commitments were identifie . Licensee Event Report Review During the inspection, a review of Licensee Event Reports (LERs)

generated during 1986 were reviewed to determine that events had been properly classified under the EP program. The inspector reviewed the following LERs!

85-002-01 (Unit 1)

86-003-00 (Unit 1)

86-003-00 (Unit 2)

86-004-00 (Unit 1)

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j All events were found to be properly classified as not falling under the l

EP program (no Emergency Action Level had been met).

The inspector discussed LER 86-003-00 with licensee and the NRC Resident Inspectors, and reviewed relevant control room instrumentation and equipment specifications, as it initially appeared that the event should have been classified as an Unusual Event. The event, loss of the " white" instrument bus, had resulted in a plant cooldown and subsequent safet injection initiation on low system pressure. The relevant EAL deals with initiation of safety injection and injection (of water) into the rector vessel. Licensee personnel indicated that injection into the vessel had i not occurred, and a review of system pressures and pump head pressure l confirmed their position, therefore, the event was appropriately not classified.

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No violations of regulatory requirements or deviations from commitments were identifie . Management Meetina On August 13, 1986, Mr. W. Fay, Vice President Nuclear Power Department, and others of his staff met with RIII personnel to discuss the implementa -

tion of Security EALs. Licensee personnel discussed their philosophy regarding security events, and their concerns relative to handling security events under the Emergency Plan and procedure Discussion indicated that onsite actions and the extent of communication of security events-l were the focus of their concerns.

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l RIII personnel indicated that State, local, and NRC personnel have a l need for notification of security events, classified as to the level l of severity, using the classification guidance for emergencies presented in NUREG-0654, Revision Licensee personnel inquired as to whether it would be acceptable to include notifications and classifications of security events with the Security Pla RIII personnel indicated that this would be acceptable, and later provided clarification that the notifications would have to include the same agencies and meet the same timeframes as those in the Emergency Plan.

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changes, and amendment of the Security Plan if the changes are acceptable to both Emergency Preparedness and Security personnel, l 1 Exit Interview (30703)

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The inspectors met with the applicant representatives denoted in 1 Paragraph 1 on August 8, 198 The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report. The applicant did not indicate that any of the information disclosed during the inspection could be considered proprietary in nature.

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