IR 05000315/1986040
| ML20214T933 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/28/1986 |
| From: | Foster J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20214T916 | List: |
| References | |
| 50-315-86-40, 50-316-86-40, NUDOCS 8612090062 | |
| Download: ML20214T933 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
I Reports No. 50-315/86040(DRSS);50-316/86040(DRSS)
Docket Nos. 50-315; 50-316 Licenses No. DPR-58; DPR-74
Licensee: American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Facility Name: Donald C. Cook Nuclear Power Plant, Units 1 and 2 Inspection At: Donald C. Cook Site, Bridgeman, Michigan
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Inspection Conducted: November 3-7, 1986
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Inspectors:
mes E. Foster
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eam Leader Date
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Marcia J. Smith H. Peterson
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Approved By: W1 liam Snell, Chief ajdLs/6c Emergency P.'eparedness Date Section
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Inspection Summary
Inspection on November 3-7, 1986 (Reports No. 50-315/86040(DRSS);
50-316/86040(DR55))
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Areas Inspected:
Routine, unannounced inspection of the following areas of l
the Donald C. Cook Nuclear Plant emergency preparedness program:
emergency detection and classification; protective action decisionmaking;' notifications
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and communications; shift staffing and augmentation; changes to the emergency
preparedness program; knowledge and performance of duties (training); public information. program; licensee audits; activations of the licensee's emergency plan; and licensee actions on previously identified emergency preparedness
items. The inspection involved three NRC inspectors and one consultant.
Results: No violations, deficiencies, or deviations were. identified.
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DETAILS 1.
Persons Contacted W. Smith, Jr., Plant Manager
- A. Blind, Assistant Plant Manager
- R. Simms, STA Supervisor
- D. Loope, Emergency Planning Coordinator
- K. Baker, Operations Superintendent
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- L. Matthias, Administration
- J. Rischling, QC/ Administration Compliance Coordinator
- L. Gibson, Managerial
- C. Ross, Computer Science
- T. Kriesel, Tech. Superintendent
- R. Glendenning, Tech. Phys. Sci.
- J. Nadeau, AEPSC Site QA
- J. Dickson, Training N. Wollenslagel, Shift Supervisor J. Cassidy, RP Technician A. Zuber, RP Technician Bronicki, RP Technician s. Limko, RP Technician B. Bala, Murry & Trettle, Forecaster M. Glissman, RP Performance Engineer M. Clark, RP Technician S. Spica, RP Technician S. Kalil, RP Performance Engineer T. Anderson, STA L. Smith, Shift "E" Supervisor B. Zordel, Sr Chem /Radpro Technician D. Petroff, RP Performance Engineer
- Personnel listed above attended the exit meeting on November 7, 1986.
2.
Licensee Actions on Previously-Identified Open Items a.
(Closed) Open Item (50-315/86016-02; 50-316/86016-02):
Inability of the team sent to activate the Post Accident Sample system to energize the system panel without controller intervention (during the June 1986 Exercise).
During this inspection, the inspector observed an actual PASS sample (liquid) being obtained, using the relevant procedure (12THP 6020 PAS.005). The sample was obtained and analyzed within a three hour period.
This item is closed.
b.
(0 pen) Open Item (50-315/M0M-02; 50-316/86002-02):
Lack of the EP program to have three crained individuals designated for each emergency response position.
Licensee personnel advised that a revision to the Emergency Preparedness program (in the review process)
designates a minimum of three individuals for each emergency response position.
The draft organization was reviewed and appeared acceptable.
This item will remain open pending approval and implementation of the revised organization.
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c.
(0 pen) Open Item (50-315/86016-01; 50-316/86016-01):
Completion of assembly / accountability not reported to the Site Emergency Coordinator during the June 1986 Exercise.
This item will remain open pending demonstration during an exercise or drill.
3.
Activations of the Emergency Plan The licensee has had three activations of their Emergency Plan since the last inspection, all Unusual Events (UEs), and all during 1986.
The inspector reviewed documentation related to the events.
Each of the events had been properly been classified under the Emergency Action Levels (EALs).
In addition, State and local agencies, and the NRC (Duty Officer and Resident Inspector) had been properly notified in each case.
a.
Activation on February 1,1986 at 8:11 a.m. (Unit 2) due to a reactor t. rip resulting from a fire in an auxiliary transformer.
The event was declared at 8:15 a.m., and the fire was extinguished at 8:27 a.m.
The event was declared as terminated at 9:03 a.m.
b.
Activation on April 8, 1986 at 8:02 a.m. (Unit 2).
The licensee voluntarily entered into a condition requiring activation of the Emergency Plan. This activation was pre-coordinated with the NRC, State and local representatives on April 4, 1986. With the' reactor core unloaded, the licensee removed the second of two unit diesels from service.
This removed all onsite alternating current capability.
for one unit, requiring an Unusual Event, per the Emergency Plan.
The inspector noted that documentation for initial notifications was present, but no documentation for termination of the event was available.
c.
Activation on July 10, 1986 at 1:22 p.m. (Unit 1).
The unit was determined to be in noncompliance with Technical Specifications related to steam generator high water level trip response time, and the licensee brought the reactor to shutdown. The problem resulting in the unit shutdown had originally been identified in early 1986, was determined reportable on March 26, 1986 (Licensee Event Report No.86-007), without any corrective action required.
This conclusion had later been questioned by the NRC and further review determined
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that testing of the steam generator high water level trip response time was required.
The event was declared and terminated at 1:22 p.m.
No violations of regulatory requirements or deviations from commitments were identified.
4.
Emergency Detection and Classification (82201)
The inspector reviewed the-Emergency Plan (EP) and'the Emergency Plan Implementing Procedures (EPIPs).
The EALs were determined to be consistent with the guidance in NUREG-0654.
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.The notification procedures (in the 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.
One shift of Control Room personnel, all members of the emergency organization, 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 relation to accident classification and escalation, notification, and protective actions recommendations.
Personnel interviewed promptly and properly classified simulated accident conditions presented to them per the wording of their EAL criteria.
However, it was noted that the wording of the EAL on explosions (ECC-4)
caused the Control Room team to conservatively over classify an explosion scenario presented to them.
No violations of regulatory requirements or deviations from commitments were identified.
However, one item should be considered for improvement:
The wording of EAL ECC-4 (explosions) should be reviewed for clarity,
and additional detail added as to the cause of the explosion and number of affected trains of equipment involved in the explosion.
5.
Protective Action Decisionmaking (82202)
The inspector reviewed the EP and EPIPs and determined that the responsibility and authority for accident assessment and protective action decisionmaking were clearly delineated.
Control room personnel interviewed 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 officials.
The relationship between core condition, containment status and protective action recommendations was demonstrated for the scenario conditions presented for interview purposes.
The capability of offsite officials to make protective action decisions and to promptly notify the public was discussed with licensee representatives.
Procedures were in effect to notify responsible offsite authorities on a 24-hour basis with back up communications available.
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No violations of regulatory requirements or deviations from commitments were identified.
6.
Communications (82203)
The inspector reviewed PMP 2080 EPP.012 " Initial Off-Site Notifications" and PMP2081 EPP.020 " Activation and Operation of TSC".
These procedures contained the forms to document initial and followup messages transmitted
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to State and county officials following any emergency declarations.
The State or Michigan form located in PMP 2081 EPP.020 entitled " Nuclear Plant Accident Notification Form" contained the required NVREG-0654, Planning Standard E information.
Notification procedures were consistent with the emergency classification and action level schemes as designated by the Emergency Plan.
Telephone call-back back notification provisions for verification of information were contained in the procedures.
During a walkthrough with Control Room personnel and discussion of notification procedures,-it was noted that the notification form used for the initial contact with the NRC Duty Officer (red phone) lacked much of the information required by the NRC.
The notification form should contain the information in the form attached to Information Notice No. 85-78,
" Event Notification," dated September 23, 1985.
The inspector reviewed PMP 2080 EPP.008 " Notification of Plan Personnel" and determined that emergency response personnel notification procedures were complete and addressed the appropriate personnel for staffing.
The Prompt notification system was in place and maintained.
Procedures required monthly tests activated and monitored by the state authorities with problems reported to the licensee who maintains the system. Test records are maintained by the offsite authorities.
The inspector contacted the FEMA representative and verified the licensee's adequate response to maintenance problems.
The inspector conducted walkthroughs of the E0F, TSC, and OSA and determined that communication equipment and procedures were in place to assure ability to maintain communication within the plant, with off-site support and with State and local agencies as required by 10 CFR 50.47(b)(6).
A random check of commercial and microwave telephones, during the walkthroughs, indicated equipment was operable.
Redundant and diverse systems were available through the emergency electrical supply systems with back up batteries to enable communication operability in the event of power failure.
A review of communication test procedures indicated the communication tests were conducted at greater frequency than required by licensee Procedure No. PMP 2082 EPP.005.
Based on the above findings, this portion of the licensee's program is acceptable.
However, one -item should be considered for improvement:
The notification form used for contact with the NRC Duty Officer
should either duplicate or contain the information provided by the form attached to Information Notice No. 85-78.
7.
Changes to the Emergency Preparedness Program (82204)
The inspectors reviewed documentation related to changas to the Emergency Plan (EP) with regard to processing,. distribution, and implementation.
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The Emergency Planning Coordinator was in the process of an Emergency Plan Program revision.
At the time of the inspection all EPIPs had been revised and were in the plant review process.
A revision to the plan was also accomplished during 1986.
The EP Coordinator was ir. the process of developing an Emergency Plan Administrative Manual which would contain checklists, program maintenance procedures and administrative procedures.
A computerized tracking system had been developed and was ready.for implementation.
A review of past NRC inspection reports indicated that the Program review had been in progress since mid 1985.
Due to the large scope of the program revision, a review of this module was not conducted, other than a brief review of selected revised (draft) procedures.
The changes to the EP program were discussed at the exit interview, during which the licensee committed to complete all EP program revisions 30 days prior to the next annual exercise.
No violations of regulatory requirements or deviations from commitments were identified.
8.
Shift Staffing and Augmentation (82205)
The inspector reviewed the records of a shift augmentation drill conducted on Saturday, February 22, 1986, as a part of an overall drill of the emergency response program.
Records of the drill indicated that sufficient personnel would have responded to the notification to meet the augmentation goals of table No. B-1 of NUREG-0654, Revision 1.
Call-outs started at approximately 0619 hours0.00716 days <br />0.172 hours <br />0.00102 weeks <br />2.355295e-4 months <br />, and finished at approximately 0707 hours0.00818 days <br />0.196 hours <br />0.00117 weeks <br />2.690135e-4 months <br />, with the longest response time being approximately one hour.
No violations of regulatory requirements or deviations from commitments were identified.
9.
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 responsibilities were qualified for their positions.
The inspector reviewed the licensee's emergency preparedness training programs as identified in the following procedures:
PMP 2082 EPP.005, Tests, Drills and Exercises PMP 2082 EPP.006, Emergency Plan Training Procedure No. EPP.005 specifies the fregency, methodology, acceptance criteria, and documentation of communication _ tests and Emergency Plan drills and exercises.
The Emergency Planning Coordinator is responsible i
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for the implementation of this procedure.
It was determined that the licensee's program for conducting emergency preparedness tests, drills, and'
exercises satisfied the requirements of 10 CFR 50.47(b) (14), 10 CFR 50 Section IV, Appendix F, and NUREG-0654, Section N.
Drill and exercise records examined were in_ compliance with the procedure.
Procedure No. EPP.006 specified the criteria for the development, implementation.and maintenance of Emergency Plan training for 1icensee
. personnel. The licensee's Training-Section is responsible for the Emergency Plan Training Program.
The Emergency Planning Coordinator is responsible for:
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Identifying'the training requirements and scope of training modules.
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Notifying the Training Section of individuals recently assigned to
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the emergency response organization.
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The conduct of periodic reviews of the training program.
The Emergency Plan Training Prcgram consisted of nine modules 'as. identified in.the procedure.
The trainieg modules required.for each emergency response organization position had been identified.
It was noted that no formalized training module for dose calculations and assessment had been included in the training program.
The licensee should develop a module for dose calculation and assessment.
This is an Open Item (No. 315/86040-01; 316/86040-01).
The licensee reported that the 1986 requalification program ~was approximately 45% complete'as of the time of the inspection.
It was-expected to be completed within three weeks, with December reserved for training of those who missed module training for some reason. The licensee described how retraining would be conducted when revisions to the Emergency Plan and implementing procedures were issued.
Every emergency organization individual would be advised in writing of the procedural changes affecting their assignment and expected to study these changes.
A series of table-top or mini-drills would be conducted using newly adopted procedures. The licensee reported that the new procedures would be implemented and training completed prior to the annual emergency preparedness exercise now scheduled for February 1987.
It was determined that the licensee's Emergency Plan Training Program satisfied the requirements of 10 CFR 50.47(b)(15), 10 CFR 50, Appendix E, Section IV, Item F, and NUREG-0654, Section 0.
Walkthroughs were conducted with two field monitoring teams.
Each team consisted of four radiation' protection technicians assigned to two vehicles.
One vehicle had primary responsibility for performing radiation surveys. The other vehicle served as a mobile counting-laboratory.
Both four member teams demonstrated their knowledge of, and adherence to approved procedures.
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It was noted that a technician held the survey instrument probe outside the vehicle window during most of the survey time.
Not only did this limit the technicians. operability, it required the vehicle window to be open when in the postulated plume.
The air sampler electrical leads were not long enough to allow the air sampler to be placed on an appropriate vehicle surface (hood or roof). This resulted in a technician having to hold the sampler during the entire sampling period while being exposed to the radioactive cloud.
The anti-contamination (anti-C) gear assigned to the technicians were minimal e.g., only one pair of plastic pull-over shoe, covers per technician, and no plastic bags for disposal of potentially contaminated materials.
The vehicle speed during plume monitoring was often much below the normal speed for the roads.
Neither vehicle carried any appropriate safety and road repair equipment (jumper cables, flares, slow moving vehicle signs, chains, shovel, tool box, etc.).
It was also noted that potassium iodide (KI) tablets were not present in the field monitoring kits, and discussion with the field team indicated that they would have had to return to the plant site to obtain KI if needed.
A drill was conducted by telephone with the licensee's meteorological consulting firm. Walkthroughs were conducted with the Shift Supervisor and staff to determine emergency classification and protective action recommendations as the result of a sudden, high level release of radioactive gas. A walkthrough with the EOF dose assessment staff was also conducted.
Results of the telephone drill and the two walkthroughs are reported in Section 10 of this report.
Based on the above findings, one open item was identified concerning this portion of the licensee's program.
In addition, the following items should be considered for improvement:
Provide a means for positioning the survey probe outside the survey
vehicle.
Provide a sufficient length of electrical lead to allow.the air
sampler to be placed on an appropriate vehicle surface.
Provide additional anti-C equipment for each vehicle.
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Provide each vehicle with safety features to identify it as a slow
moving vehicle.
Provide each vehicle with appropriate road service and minor repair
equipment.
Provide KI tablets in each of the field monitoring team kits.
- No violations of regulatory requirements or deviations from commitments
were identified.
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10.
Dose Calculation and Assessment (82207)
The inspector examined the following procedures:
PMP 2080 EPP.006, Initial Dose Assessments (Gaseous)
PMP 2081 EPP.014, Off-site Dose Assessments Procedure No. EPP.006 provides the Shift Supervisor /0nsite Emergency Coordinator with a method to initially assess potential off-site dose effects of unplanned radioactive gaseous releases.
This procedure is applicable prior to activation of the TSC.
The procedure provides for establishing emergency classification and appropriate protective action recommendations.
Procedure No. EPP.014 provides guidance in accessing computer programs used in estimation of off-site doses to the whole body and thyroid.
General information concerning meteorological and survey data useful in dose assessment is included.
This procedure provides for the use of a meteorological consulting firm in the event the licensee's meteorological system fails.
A drill was conducted by telephone with the licensee's consulting firm that provides back-up meteorological data.
A forecaster was requested to provide:
(1) wind direction, wind speed, stability index, status of precipitation, and (2) a forecast for these parameters for the next six hours.
The requested information was promptly provided and reasonably matched the current meteorological conditions at the plant site.
A walkthrough with the Shift "E" Supervisor, Assistant Shift Supervisor and a STA was conducted to determine the adequacy of training and their ability to determine emergency classification and protective action recommendations.
The scenario was based on a rapid high level release of radioactive gases to the atmosphere.
Proper and timely use of EPP.006 was demonstrated.
The team was able to adequately identify the emergency classification and the appropriate protective action recommendation within fifteen minutes.
The team correctly identified the procedure and method to be used to notify State and local officials and the licensee's emergency organization staff.
A walkthrouph with the E0F dose assessment staff was conducted to demonstrate their ability to correctly perform dose calcul'ations using the Dose Assessment Program (DAP) and to provide recommendations for protective action guides.
Input parameters were provided by the inspector.
These parameters permitted a comparative analysis with similar calculations performed by the inspector using the IRDAM program.
The DAP calculations compared favorably with those calculated using the IRDAM program.
The team was able to quickly perform the dose calculations and to identify the proper protective action recommendation.
The PAR was determined using PMP 2081 EPP.004, Protective Action Guides and Protective Actions.
The inspector noted that the DAP printout contained approximately 80% of the data required for the Nuclear Plant Accident Notification Form, Part II.
This form, developed by the State of Michigan, is required to be updated every fifteen minutes.
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Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement:
Extend the DAP programming to permit the protective action
recommendation to be determined by the computer based on computed doses.
Develop an extension to the DAP computer program that would produce
all, or most of the objective data required by the Michigan Nuclear Accident Notification Form.
11.
Public Information Program (82209)
The FEMA review of the licensee's annual revision of the public information booklet was completed in June of 1986 and changes were then approved by State and county officials.
At the time of this inspection.the revised booklet was in the printing process and the licensee indicated they would be mailed out to residents in the 10 mile EPZ with the monthly billing upon completion of printing.
No violations of regulatory requirements or deviations from commitments were identified.
12.
Licensee Audits (82210)
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The inspector verified that the licensee had in place provisions for conducting an independent annual audit of the Emergency Program.
The inspector reviewed the 1986 audits performed (to date) relative to Emergency Planning.
The inspector reviewed Report No. NSDRC-125 which was the QA report of the licensee's internal audit. The audit was made during the period of February 18-20, 1986.
Since the previous audit was held February 19-22, 1985, the requirement of an audit every twelve months was satisfied.
The 1986 audit did not reveal any areas of noncompliance to the Emergency Plan. There were four recommendations for improvement.
The responsible licensee personnel' reviewed the recommendations and implemented corrective actions where warranted.
The review of the audit determined that the licensee addressed items that had been addressed in previous audits, as well as followed up on the status of NRC emergency preparedness open items, violations and weaknesses.
After completion of the audit, findings were sent to the plant for review and responses.were tracked. Audit records are designated as Lifetime QA Records in accordance with the provisions of AEP Service Corporation General Procedure.
A portion of the audit dealt with the adequacy of the interface with State and local governments.
The inspector verified that the results of the audit of this interface was made available to the State and local-authorities.
The inspector reviewed letters to Lt. James Tyler of the Department of State Police, Pre-Disaster Services Section, and F. L. Jewell, m
Sheriff, Berrien County, which notified them that the results of that
portion of the audit were available to them.
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No procedural problems were encountered and the individual correctly.
i maintained radiological safety controls as appropriate for.ALARA and i
- contamination control.. The assigned individual demonstrated proper-radiological controls to contain or minimize contamination during sample collection and analysis procedures.
-During sample acquisition, it was noted that the.present procedure results in a liquid sample which is pressurized to approximately-15 psi. While this pressure is not considered inordinate, the potential still exists for spilling or squirting:the sample onto the individual assigned to obtain the sample.
Discussion with licensee personnel indicated that relatively minor
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changes to the present. sample procedure would result in a sample which'was pressurized to approximately 5 psi.
Such a pressure would still provide'an
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adequate differential pressure for easy sample collection, and would lessen
the hazard should an accident occur during sample collection.
The capability to analyze the sample was demonstrated by chemistry laboratory personnel.
No violations of regulatory requirements or deviations from commitments were identified. However, the following item should be considered for improvement:
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The Post Accident Sample procedure for collection of liquid samples
(12THP 6020 PAS.005) should be modified so that the pressure of the i
sample is approximately 5 psi immediately prior to collection.
15.
Licensee Event Report Review i
During the inspection, a review of Licensee Event Reports (LERs) generated since the last inspection was performed to determine if events had been properly classified under the EP program.
The inspector reviewed the following LERs:
LERS86-001 through 86-022 for Unit 1 LERS86-001 through 86-028 for Unit 2 Also reviewed were two " hospital-cail-industrial-accident" forms, and
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fifteen "special reports".
All events were found to be properly classified-as events (LERs86-005
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[ Unit 2],86-007 [ Unit 1]) or as not falling under the EP program.
i No violations of regulatory requirements or deviations-from. commitments were identified.
f 16. Open Inspection Items Open inspection items'are matters which have been discussed with the
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licensee, will be reviewed further by the NRC, and which involve some action on the part of the NRC or applicant or both.
An (spen inspection i
item identified during the inspection is discussed in Section 9.
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The inspector consulted with the licensee as to the position titles of the team members performing the licensee audit.
It was determined that all of the members came from the corporate office and did not have any responsibilities in the area of implementing the Emergency Plan.
No violations of regulatory requirements or deviations from commitments were identified.
13.
Maintaining Emergency Preparedness The Emergency Plan Procedures specify periodically required tests, checks, reviews and drills.
The inspector reviewed documentation to verify the following items were implemented as required.
PHP 2080 EPP.008 - Quarterly verification of telephone call lists PMP 2082 EPP.002 - Education information disseminated yearly to the public in the EPZ PMP 2082 EPP.003 - Monthly Communication tests
- Quarterly drills
- Semiannual drills
- Annual drills
- Annual review of EAL's with State and local governmental authorities
- Verify Letters of Agreement
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PMP 2082 EPP.007 - Quarterly inventory of emergency equipment kits The inspectors review of the documentation for the above items indicated that these activities were being implemented as required.
The inspector reviewed the inventory of supplies maintained in the Operations Staging Area and the field monitoring kits.
Procedures governing inventory of emergency supplies were reviewed.
No discrepancies were noted. All inventories appeared to be within the requirements of NUREG-0654, Revision 1,Section II.H.
A review was made of the licensee's letters-of-agreement with offsite groups and agencies.
Letters were dated within the 2 year update requirement.
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.
No violations of regulatory requirements or deviations from commitments were identified.
14.
Post Accident Sampling and Analysis Post accident sampling and analysis of reactor coolant was satisfactorily demonstrated during this inspection.
The individual assigned to collect the sample worked efficiently to collect, handle, and provide the sample (actual reactor coolant) for analysis.
The individual was familiar with the equipment and the relevant procedure.
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Exit Interviews-The inspectors met with the applicant representatives denoted in
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Paragraph 1 on November 7; 1986.
The Team Leader summarized the scope-and.results of.the inspection and discussed the content of the inspection report. During the interview, the Team Leader discussed the pending (major) change to the EP procedures and requested a commitment that the changes be completed by thirty days prior to the scheduled February 1987 emergency exercise.
This commitment was' verified via telephone-subsequent to the~ inspection.
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The applicant did not indicate that any of the'information disclosed during the inspection could be considered proprietary in nature.
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