IR 05000341/1987024

Insp Rept 50-341/87-24 on 870615-18.Major Areas Inspected: Emergency Preparedness Program,Action on Open Items, Activations of Emergency Plan,Emergency Detection & Classification & Dose Assessment

ML20235G687
Person / Time
Site:	Fermi
Issue date:	07/06/1987
From:	Foster J, Peterson M, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235G668	List: IR 05000341/1987024 ML20235G665
References
50-341-87-24, NUDOCS 8707140345
Download: ML20235G687 (13)

Text

- - _ _ _ _ _ _ _ _ - - _ _ _ - _ _ _ _ - - _ _ _ _ _ _ _ - - _ - _ _ _ - _ - - - _ _ - - _ _ _ _ _- -.

+

,

].

U. S. NUCLEAR REGULATORY COMMISSION  !

l <

REGION III

Report No. 50-341/87024(DRSS)

Docket No. 50-341- License No. NPF-33 Licensee: 'The Detroit Edison Company I 6400 North Dixie Highway-  ;

Newport, MI 48166

'

Facility Name: Enrico Fermi Atomic Power Plant, Unit 2 g Inspection At: Fermi 2 site,' Monroe, Michigan Inspection Conducted: June 15-18, 1987 Inspectors: J. Foster Team Lead

,[g Date

/ /

Sini' 7 2f87 p Date Pe #

Date Approved By: ef '7

~'

Emergency Preparedness Section Date Inspection Summary Inspection on June 15-18,1987 (Report No. 50-341/87024(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the Fermi Nuclear Power Plant emergency preparedness program: action on previous Open Items activations of the licensee's emergency plan; amergency d3tection and classification; dose assessment; protective action decisionmaking, notifications and communications; changes to the emergency

preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); licensee audits; maintaining emergency preparedness; and LER review. This inspection involved three NRC inspector Results

No violations, deficiencies, or deviations were identifie ;

kk O g050003e 870707 PDr* j a i L____1_________._._____-___-- _ _ - _ - - - - - - - - - - -

,. .

\

i DETAILS

~ Persons Contacted-Detroit Edison Company

• F. Agosti,'Vice President, Nuclear Operations I

• B. Sylvia, Group Vice President- l T. Randazzo, Director, Regulatory Affairs l

~* J.'Mulvehill', EP Response Planner -

• F. Schwartz, Supervisor, Staff QA <

• L. Bregni, Compliance Engineer, Licensing

• R. McLeod, Asst. Director, Nuclear Training

• M. Hoffman, Emergency Planner

• J. Coffin, Procedure Writer

• E. Madsen, Licensing

• R. Lenart, Plant. Manager

• G. Trahey, Director, NQA

• J. Bobba, General Sup., HP

• G. Overbeck, Director, Operator Training J. Petoskey, Associate Nuclear Training Specialist

.

• M. Cooley, Emergency Response Planner B. Masserant, Senior Records Clerk M. Rumney, Data Entry Operator R. Henson, Shift Supervisor L. DeLucia, Assistant Shift Supervisor C. Byrd, Shift Technical Advisor

• 0enotes those psrsonnel listed above who attended the exit interview on

~

June 18, 198 . Licensee Actions on Previously-Identified Open Items (0 pen) Open' Item 341/85018-03: Correction to the orientation of the meteorological tower measurement booms. The work order to re-orient two of the. met tower booms into the prevailing wind was reissued in October 1986. The package for the work to be performed was sent to Stone and Webster in May 1987. This package.fdentified other work to be accomplished, such as replacement of cracked conduit, and is :

scheduled to be completed and ready for maintenance in October 198 This item remains ope (Closed) Open Item 341/85034-03: Deficiencies in the tracking of training and requalification for the RERP program. This inspection i showed that improvements have been made to the RERP training l tracking system, and the systen is functioning acceptably. This !

item is close ,{

i p (Closed) Open Item 341/86018-04: Annual audit evaluation of offsite interfaces and availability of the audit to offsite authoritie The licensee had made the 1986 audit report available to offsite j

i (

_ _ _ _ _ _ - _ _ _ _. - - _ _ _ _ - _ - _ - _ _ -__-

fi ry

%

1,

, ,

authorities,'and the 1987' audit specifically addressed offsite interfaces. Licensee personnel indicated that the 1987 annual audit and subsequent audits will be made. available= to offsite authorities ,

at the annual EAL review meeting. This item is closed.

' '

~ (0 pen) Open' Item 341/85041-04: Suggested revision of Dose Assessment  ;

computer Code to accommodate ATWS conditions. The licensee presently has the capability to utilize ATWS conditions in dose {

calculations performed on the IBM PC-based ERIS (RADOSE) syste '

Licensee' personnel indicated that this option will be incorporated into the mainframe ERIS code in the future. This item remains ope ' ActivationsoftheLicensee'sEmergencyPM A review of licensee and NRC records indicated that five activations of the licensee's Emergency Plan had taken place since the last routine inspectio On July 15, 1986, the Emergency Core Cooling System (ECCS) activated based on a spurious low reactor level signa Low reactor coolant level signals were received at 2310 hours0.0267 days <br />0.642 hours <br />0.00382 weeks <br />8.78955e-4 months <br /> and the Unusual Event was declared at 2320 hours0.0269 days <br />0.644 hours <br />0.00384 weeks <br />8.8276e-4 months <br />. The event was declared terminated at-2332 hour On. August 6,.1986, at approximately 1717 hours0.0199 days <br />0.477 hours <br />0.00284 weeks <br />6.533185e-4 months <br />, a fire was detected in the DC electrical distribution panel for the High Pressure Core Injection (HPCI) system. An Alert was declared at 1725 hours0.02 days <br />0.479 hours <br />0.00285 weeks <br />6.563625e-4 months <br />. The event was i terminated at 1925 hour0.0223 days <br />0.535 hours <br />0.00318 weeks <br />7.324625e-4 months <br /> On January 7,1987, a chlorine leak was detected in the circulating water pump house. An Unusual Event was declared at 1655 hour0.0192 days <br />0.46 hours <br />0.00274 weeks <br />6.297275e-4 months <br /> On April 10, 1987, due to electrical failures, the HPCI and RCIC systems were declared inoperable. An Unusual Event was declared at approximately 1810 hours0.0209 days <br />0.503 hours <br />0.00299 weeks <br />6.88705e-4 months <br />. The Unusual Event was terminated at approximately 1850 hour0.0214 days <br />0.514 hours <br />0.00306 weeks <br />7.03925e-4 months <br /> On May 20, 1987,- unidentified leakage into the drywell was measured at approximately 2 gallons per minute. Investigation by the licensee indicated the RWCU isolation valve as the likely source of the leak, but this could not be positively confirmed. An Unusual Event was declared at 2310 hours0.0267 days <br />0.642 hours <br />0.00382 weeks <br />8.78955e-4 months <br />, due to the possibility of primary system leakage. The Unusual Event was terminated at 0725 hours0.00839 days <br />0.201 hours <br />0.0012 weeks <br />2.758625e-4 months <br /> on May 21, 198 Documentation related to each RERP activation had been gathered into a file specific.to the activatio Included were notification sheets, deviation reports, shift logs, notes, or other documentation as appropriate. Each activation had been reviewed for correction of problems or improvement of procedures, a nd memos documenting such actions were included in the file. The the licensee review of the documentation for the Alert declared during August 6,1986 had, in particular, resulted in the' identification of a number of prccedural problems. The inspector i i

l

\

b - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

_ _ - . _ _ _ _ _ - _ _ _ - - _ _ _ - _ _ _

.

f determined that activations had, in general, been accomplished per the .

RERP and implementing procedures, and instances where problems existed

'

had been identified and corrective action proposed and/or completed.

No violations or deviations were identified in this are . Emergency Detection and Classification (82201)

The inspector reviewed the RERP and Procedures, and interviewed one shift of Control Room personnel, consisting of one Nuclear Shift Supervisor, one Nuclear Assistant Shift Supervisor, and one Shift Technical Assistan The licensee's emergency classification and action level scheme was consistent with the guidance contained in Appendix 1 of NUREG-0654, Revision 1. The licensee demonstrated the capability to analyze and i assess emergency conditions on a twenty-four hour basis.

The individuals interviewed exhibited good attitudes, both toward their normal duties and to the interview itself. They were uniformly knowledgeable, and enthusiastic. When a team member made an error, the other members were quick to step in and correct; minor weaknesses were pointed out and suggestions made were accepted constructivel The interview showed the interviewed shift personnel to be well-versed in fission product barrier analysi An annual review of the EAL's was held with state and local authorities, as required by 10 CFR Part 50, Appendix E, IV.B. This review was held in the spring of 1987. The next annual review is scheduled to be held on July 15, 198 No violations or deviations were identified in this are . Protective Action Decisionmaking (82202) i A review of the RERP and Implementing Procedures, along with the interviews of shift operating personnel, demonstrated that the authority and responsibility to make protective action recommendations were clearly  :

delineated and understood. Personnel interviewed demonstrated facility and familiarity with their procedures, and made reference to them when appropriat The ability of licensee personnel to assess and analyze emergency conditions and to make recommendations to protect the public and onsite workers was and adequately demonstrate No violations or deviations were identified in this are I 6. Notifications and Communications (82203) l

The inspector reviewed selected. procedures and conducted discussions with personnel who have notifications or communications responsibilitie Interviews with shift operations personnel included questions relevant to

!

-- -_ _ . _ . ._ .__ __ _ _ _ _ _ _ - _ _ _ - - _ - _ - -

..

,

communications and notifications associated with the various emergency cla ssi fications. It was determined that the licensee had the capability:

to notify and communicate among the appropriate licensee personnel, offsite agencies and authorities, and the general public in the event of a radiological emergenc Morthly siren tests had been conducted and documente Siren test results, a recap of problems encountered and actions taken to correct these problems were documented in_the. cover memo for each monthly tesu packet. A review of monthly communication drill packets. indicated tetts .

of the Emergency Notification System (ENS) and Health Physics Network

'

(HPN) were conducted. Action taken to corrcet any deficiency in these systemr, was timely and clearly documente No violations or deviations were identified in this are . Changes to'and Maintaining the Emergency Preparedness Program (82204. 82701)

The Fermi Radiological Emergency Response Plan (RERP) now consists of a number of procedures in the EP-99 series. These individual procedures I l are promulgated, and revised, utilizing the same procedures as the former sections of the RERP as a single procedure. This change has been made to

'

facilitate the update and revision of sections of the. program without the-requirement for a revision to the entire RERP. This will allow more rapid changes to the program and reduce or eliminate the occasional discontinuity between the RERP and the implementing procedures previously caused by the revision process.

'

An administrative oversight (accidental deletion of a portion of the RERP) was discussed, and prompt corrective action was take The inspector reviewed the changes made to the program since the last inspection, and determined that these changes have not affected the licensee's overall state of emergency preparedness. The Vice-President, Nuclear Operations, maintains overall authority and responsibility for the RERP. The RERP Supervisor is directly responsible for the development and updating cf revisions to the RERP and Implementing i Procedures. The RERP Supervisor was assigned to the position of Director, Regulatory Affairs in 1986, and still maintains the J

responsibility of two full time position Three emergency planners are responsible for the coordination ard maintenance of the RERP program and report weekly to the RERP Supervisor / Director, Regulatory Affairs. One emergency planner had been designated as permanent Wo.A Leader with responsibilities for daily management and tracking of assigned work task The inspector reviewed coordination with offsite support agencies and determined the program in place was adequat Letters of Agreement were up to date, offsite support agency training was conducted as recuired, and the licensee remained responsive to offsite agency concern I

_____ ___-__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -

- _ - _ - - _ _ __ ._ - _ _ - _ __ _ _ - - - _ _ _ _ _ _ _ _ - _ _ - _

.

,

Drill records l indicated that required Health Physics, environmental monitoring, medical and assembly / accountability drills were conducted and critiqued as required per NUREG-0654, Revision 1. Problem areas were assigned to thefemergency. planners with completion dates. A review of

'the tracking system: indicated timely followup on all corrective task All changes _to the RERP and procedures are part of the licensee administrative review process. This process requires two. levels of

. review before submittal to the On Site Review Organization (OSR0) for review prior.to Plant Manager approval. Temporary changes are in effect for'two weeks during the review process and are automatically cancelled if final approval by the Plant Manager is not obtained, i The' Nuclear Administration Information System (NAIS) administers distribution of plan and procedure' revisions. The inspector reviewed this system and verified all changes for this year have been distributed according to the requirements of 10 CFR 50, Appendix The, inspectors review of the Emergency Preparedness (EP) program determined that the licensee's EP surveillance program was well maintained and effectiv No violations or deviations were identified in this are . Shift Staffing and Augmentation (82205)

The inspector reviewed minimum shift staffing and capabilities for all shifts and concluded the emergency response organization met the  !

guidelines of Table B-1 of NUREG-0654, Revision 1. -Table B-2 of the i RERP lists the position, alternates, reporting' function, location and responsibilities for each position. An administrative system is in place to assure that off-site emergency response personnel are available as needed to meet the 30 and 60 minute response times. Licensee personnel meet functional requirements for staffing by having assigned emergency tasks related to their normal dutie The call-out list of emergency personnel is updated and distributed weekly, according to Procedure EPA-7. The notification system and call-out procedures to implement shift augmentation are described in Procedures EP-290 and EP-29 The licensee successfully activated the call-out procedure as part of their October 22, 1986, off-hours, unannounced exercise, and again during-a June 10, 1987 drill. The licensee demonstrated their ability to augment their staff according to guidelines of Table B-1 of NUREG-0654, Revision 1, and per Procedure EPA-4, Section 5.2.9 of the licensee's Emergency Plan Administrative procedure No violations or deviations were identified in this are l

. _ _ _ _ - _ _ _ _ _ _ - ~]

,

.

9. Knowledge and Performance of Duties (Training) (82206)

The new revised RERP delineates the RERP training requirements in i Section EPA-99-0 (SR), Revision 0. A training matrix of qualification I requirements for each position in the RERP organization and the details 1 of the qualification program are located in the Emergency Plan Administrative Procedure EPA- l The training documentation for initial and requalification are accomplished by course attendance sheets which contain the participants signature along with the participants examinations. These records, in hardcopy, are kept O r approximately three months, at which time they are microfilmed. The hardcopies are sent to the archives in Toledo, Ohio, and the microfilms are kept at the Fermi Nuclear Operations Center (N0C).

The training matrix and procedures for RERP training Program, EPA-8, was reviewed for context and implementation. The RERP Training Program consists of initial qualification and requalification. The initial qualification implements classroom and instructor presentation, with demonstration and examinations. The requalification utilizes individualized instruction, consisting of individual reading of the course materials, instructor assistance as needed, a video presentation for one training module (No. 4, "RERP - Notification Procedures") and course examination. Course materials for training Units 5, 6, and 15 were reviewed (No. 5, "RERP - Emergency Classification",

File No. 08-32-00-00; No. 6, "RERP - Reentry and Recovery", File No. 08-33-00-00; No.15, "RERP - Emergency Classification and Protective Action Recommendation", File No. 08-44-00-00). The review included lesson guide, lesson objectives, and course examinations. The material was adequately comprehensive and complet The tracking of the individuals qualification /requalification is accomplished through the use of the Personnel Training History System (PTHS) which provides qualification /requalification status for each individual assigned to a position in the emergency organizatio Printouts from the PTHS system are normally made by area assigned (Control Room, TSC, EOF, off-site), and by position assigned in the RERP organization. These printouts also indicate the last requalification date for an individual's assigned training module The PTHS printouts are used as preliminary " ticklers" of upcoming requalification date PTHS printouts are also issued to the administrative section of each department of the Fermi organization, to be used as a guide to indicate who will be requiring requalificatio To assist in this endeavor, the printouts are issued on a monthly basis, and contain a column indicating a 45 day warning of upcoming r9 qualification date To enhance the maintenance of the RERP training, a new system of notifying personnel of qualification and requalification was incorporated in July, 1986. This was in direct response to the continuing problems in RERP training as noted in the two previous NRC inspection reports, and tracked as Open Item 85034-0 _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

'

.

The riew system consists of a letter from the training department to the Vice President, Nuclear Operations, with attached RERP Training Status-

' Reports. One report lists personnel with expired qualifications and

_

another lists personnel whose upcoming requalification is due.in 45 days or less. In addition to .this letter, a mid-month expiration report and memos are used to. direct management attention to attaining requalification by delinquent.or upcoming requalifying personne A review of.41 training records was conducted,'and of these, several were apparently delinquent in their requalification time requirement of 1 12 months, but they were satisfactorily requalified withW the 25%

(3 month) " grace period". The majority were adequately completing their requalificatior, requirement The RERP training organization tracks the 12 month requalification- '

requirement with no added grace period. If an individual becomes delinquent the-PTHS' printouts." expire" in the associated training unit column, and the individuals telephone number is removed from the Emergency Call-in List until requalification is completed satisfactoril In respect to the Control Room personnel, who are in primary positions in the RERP organization, it was found that they had all completed their required training within the time requirement of 12 months plus 25%

(3 months).

Off-site training requirements for personnel of State and local organizations.which support the Detroit Edison Emergency Response Organization are also described in Procedure EPA-8. An associated training matrix is listed in' Enclosure 1 to EPA-8. The training for

-

State and local officials, ambulance, medical, fire department and volunteers are provided.for on an annual basis by a contractor. This training is made available on a flexible schedule, to best accommodate the off-site organization The licensees annual training audit for 1987 (Audit Report A-QS-P/TS-87-05) was conducted prior to the present inspection. The auditors had noted that several of the training records reviewed indicated that RERP training Unit No.17 (drills / exercises) was not completed. It was pointed out to the licensee auditor by an RERP representative that training in Unit No. 17 was not a prerequisite to performing assigned RERP functions (initial qualification).

The requirements for the training and qualification of'RERP personnel are delineated in Procedure EPA-8. It was noted by the licensee auditor and confirmed by the inspector that EPA-8 did not clearly address this ite It was recommended, consistent with the licensees' audit recommendation, that EPA-8 be revised to appropriately address that training Unit No. 17, it is not required as a part of the initial qualification prerequisites I for performing RERP function l

.

The requirements for the maintenance of qualification and requalification j state that personnel requiring Unit No.17 shall satisfactorily l participate in at least one drill or exercise annually. Training records  ;

I l,

- _ _ _ _ _ _ _ _ _ _ - _ _ _ _ -

- _ - _ _ - - _ _ - _ - _ _ _ _ - _ - _ - _ - _ _ _ _ ___

- - _

'

.

for five individuals, two STA's, one NSO (SR0 licensed), and two TSC Engineering staff, were reviewed. It was found that these individuals did not participate in any drill or exercise in 1986. With further investigation, it was determined that the STA's were in the STA eperations training progiam (not actually in an STA position), the NSO was not on shift, but rather was assigned to the Radwaste department for 1986,~ and the two TSC Engineering staff members had been dropped from the RERP organization and were recently reassigned back into the RERP organization. In summary, these indivirtuals were not part of the RERP organization and, therefore, did not require participation in training Unit No. 1 To best accommodate the requirements of drill participation, the Fermi plant had recently incorporated a system to conduct full activation drills quarterly and two drills annually, prior to the evaluated exercis Overall, the RERP training system has shown continued improvement in the maintaining of RERP qualification and in ensuring adequate RERP organizational manning. Further steps are being taken to increase the effectiveness of timely requalification within 12 months without the 25% grace perio The training organization showed great zeal and attentiveness towards maintaining overall RERP training. The enthusiasm and attention given to RERP training is commendable and should be maintaine One shift of Control Room personnel, consisting of the Shift Supervisor, Assistant Shift Supervisor and the Shift Technical Advisor, all members of the RERP organization, were interviewed to establish their knowledge

.of and ability to implement the RERP plan and implementing procedure All of the individuals were adequately knowledgeable and displayed an ability to implement the procedures in relation to accident classification and escalation, notification and protective action recommendation Personnel interviewed exhibited good team work and utilization of each individuals knowledge and experience. Appropriate use and response  !

to classifying simulated accident conditions per the wording of their I EAL criteria was adequately demonstrated. Excellent use of evacuation time estimates as a factor in formulation of a Protective Action i Guideline (PAG) recommendation was also demonstrate All three personnel exhibited adequate knowledge of their associated j RERP positions and duties. However, it was noted that there was some i

'

confusion as to who to notify first, State, 7ocal officials, or the NR Those interviewed statec' they would have to notify the NRC first, but clarified that in actual situation they would, in all respects, use the j notification checklis It was apparent that due to the past history of l

._

Fermi operations, the opert: ors were sensitized to the necessity of notifying the NRC on any significant reportable items. This seemed to have caused confusion on the order of emergency notification i i

!

l

_-_-____-_--______a

_ _ _ _ . _ _

_ _ _ _ _ _ _ _ _ _ _ . . _ - _ _ - _________ __ _ _____ --___- -_

-

y I

i

Training Unit No. 4, "RERP.- Notification Procedures", File No. 08-31-00-00, clearly presents the procedure and sequences of events to follow in completing the off-site n. notifications. It gives the required time limits and specifies what notifications are to be made according to -]

i the notification for '

,

There were no violations or deviations identified in this area.

r .

1 Dose Calculation and Assessment (82207)

'

The inspector reviewed the equipment and procedures to be used for dos assessmen i The primary dose assessment method utilized an Emergency Response I Information System (ERIS) program, RADOSE. The same RADOSE program  !

(presently Version 2.1 dated April 30,1987) is used on the IBM microcomputer as a backup to ERIS. A manual technique contained in Procedure EP-540, " Manual Calculation of Offsite Radiological Dose Rates and. Doses - Airborne Releases", used in conjunction with EP-544,

" Meteorological Data Assessment", and EP-546, " Manual Calculation of Dose Assessment Factor for Lake Breeze Conditions", can be used as a secondary backup, should the mainframe and microcomputer methods be unavailabl The ERIS and IBM methods are proceduralized in EP-542, " Radiological Dose ,

Assessment Calculational Procedure Based on the Use of a Microcomputer, i Airborne Releases." 4 The inspector interviewed a Dose Assessor (whose normal position would  :

be in the TSC), and observec'while he demonstrated the mainframe and i PC based versions of ERIS (RADOSE). He was able to adequately demonstrate

.the use of both the dose assessment programs, input and change data, and select cutput The mainframe ERIS system automatically selects two and eight hour defaults, which can be altered, and recalculates values every ten minute The microcomputer version allows the operator to select a " reactor operating" calculation' mode for an accident where the reactor is no successfully shut down and the fission process continues to add to the fission product inventor Licensee personnel indicated that this option will be included in the mainframe version of ERIS in the futur There were no violations or deviations identified in this are . Licensee Audits (82210)

The licensee's Quality Assurance group performs an audit every twelve months which meets the requirements of 10 CFR 50.54(t).

Individuals assigned to perform the audit had no responsibilities for implementing the Emergency Response Program. The inspector confirmed through record review that the audit has been performed within 12 month period Licensee procedures provide for the conduct, documentation, and corrective action associated with audits. The RERP audit for 1987 (Audit A-QS-P/TS-87-06, " Emergency Planning") was performed during

_____-_____________-_-__-__D

- - _ - _ . _____ ___--- - .

.

February 23, 1987-March 12, 198 The audit report was comprehensive and professional, involving three auditors (192 man-hours total) and contained one Audit Finding Report and sixteen observation Four Audit Finding Reports (AFRs) from the previous report were reviewed in the current audit, to verify the adequacy of corrective action. Also, l four observations (Numbers 1, 3, 5, and 6) from the previous audit were reviewed, and it was determined that action hrJ been taken as recommended on Items 3, 5, and .

,

The previous review of the 1986 audit indicated that an evaluation of interfaces with offsite authorities had been directly addressed within several portions of the audit, but that the audit had not been made available to offsite authoritie CFR 50.54(t) requires that the audit address the adequacy of the interface with offsite authorities, and i that the audit be made available to offsite authoritie Documentation ;

was available to show that the 1986 audit had subsequently been made !

available to offsite authoritie Discussion with licensee personnel indicated that they plan to make the 1987 audit available to offsite authorities at the July 1,1987 annual EAL review meetin The portion of Audit A-QS-P/TS-87-05 " Employee Nuclear Training, i Education and Verification Records Program" related to RERP training was l also reviewed during this inspection. No Audit Finding Reports were associated with emergency response training, but the report did address a concern (Number 6) that the requirements for RERP training Module 17 (drills or exercises) were not clear as written in Procedure EPA- No violations or deviations were observed in this are . Licensee Event Report Review During the inspection, a review of Licensee Event Reports (LERs)

generated during June 1986-June 1987 was performed to determine if events had been properly classified under the EP program. The inspector reviewed the following LERs:

LER N Brief Description 86-015-01 Initiation of Control Center HVAC recirculation mode 86-016-00 Computer data misinterpretation re: pipe stress !

86-017-00 EECW system capacity inadequacy i 86-018-00 ESF actuations due to power loss {

86-019-00 ESF actuation due to unknown cause i 86-020-00 Hydraulic transient during in-service leak test (UE) l 86-021-00 Reactor Water Cleanup system isolations 86-022-00/01/02 Investigation of adequacy of Technical Specifications 86-023-00 ESF actuation of Control Center ventil. & SGTS systems 86-024-00 ESF actuation of Control Center ventilation system 86-025-00/01 Improper design of RCIC isolation valves 86-026-00/01 MCC fire, potential loss of HPCI system (ALERT)

86-027-00 Plant shutdown due to failed containment relief iso. Inadvertent ESF actuation of RCIC isolation valve )

.

86-029-00 HPCI system isolations due to failed flow transmitter 86-030-00 Emergency. diesel generator oil filter checks missed 86'031-00 Actuation of RPS/ reactor trip on high pressure 86-032-00 Fire protection TS Action Statement entry delayed 86-033-00 ESF and RPS system actuations during system calibration 86-034-00/01/02 RWCU temperature switch malfunction during surveillance 86-035-00 Manual reactor trip following gland steam press. re ; 86-036-00/01 ESF actuation due to overloaded modular power unit 86-037-00 RCIC and HPCI system inoperability, TS 3.0.3 not entered 86-038-00/01 ESF actuation caused by blown fuse 86-039-00 Tech. Spec. surveillance requirement not performed 86-040-00/01 Scram due to Reactor Pressure Reg. Transfer feature 86-041-00 Omission in a surveillance procedure, drywell sump 86-042-00/01 Short circuit causes Torus Water MS isolation 86-043-00/01 Surveillance missed on RSCS and RWM during testing

'86-044-00 Potentially degraded torus relief line 86-045-00 Overpressurization & rupture of CST piping 86-046-00/01- Reversed thermocouple leads on RWCU diff. temperature 86-047-00/01 Inoperability of hydrogen recombiners, TS 3.0.3 entered 86-048-00/01 RCIC and HPCI system inoperability, TS 3.0.3 entered 86-049-00 ESF actuation due to RWCU system gasket failure 86-050-00 Manual isolation of RWCU system due to valve failure 87-001-00 Automatic isolation of RWCU system 87.-002-00 Airlock pressure test not performed within required time 87-003-00' Airlock pressure test not performed per test interval 87-004-00 Accidental actuation of ESF ventilation 87-005-00 Gasket. failure results in manual ESF isolation 87-006-00 Lack of lubrication causes HPCI turbine damage 87-007-00 ESF/RPS activation as RHR system fills with coolant i 87-008-00, Reactor rcram on h'gh pressure 87-009-00 Isolation of Residual Heat Removal system 87-010-00 Discrepancies in Reactor Operator Requalif training 87-011-00 Reactor scram during APRM functional testing 87-012-00 Inoperable HPCI and RCIC due to blown fuse (UE)

87-013-00 Failure of terminal box adaptors on RBCU fan motors 87-014-00 Actuation of RPS during pressure test 87-015-00 Sodium pentaborate concentration exceeding TS limits All LER events were found to be properly classified as either an Unusual Event or Alert, or as not falling under the EP program (no emergency Action Level had been met).

It was noted that the latest version of the RERP has a provision for declaration of an Unusual Event when the reactor is required to be shutdown due to the lack of various safety system The Emergency Action  !

Level scheme delineates those safety systems (and relevant Technical Specifications) which require the declaration of an Unusual Event. The inspector discussed this item with licensee personnel, indicating that ,

this was more restrictive than some interpretations of the relevant sections of NUREG-0654 by other licensees, and does not address Technical Specification 3.0.3, which requires i::setor shutdown whenever a Limiting Condition for Operation cannot be met. Licensee emergency preparedness 12 ,

_ .__________ - ________

_

'

.

personnel stated that-they would take this comment under consideration, and compare their EAL scheme (in the area of reactor shutdowns per Technical Specifications) with that of another Michigan plan The licensee had notified NRC Region ~III, on February 27, 1987, that their review of an unclassified event on February 23, 1987 indicated it should have been classified as an Unusual Even The event concerned initiation of a reactor shutdown in compliance with the unit Technical Specifications due to High Pressure Coolant, Injection (HPCI) system unavailabilit The NRC had been notified of the reactor shutdown, but ,

the. event had not been classified as an Unusual Event per the licensee '

Emergency Action Level (EAL) schem The licensee initiated a Deviation Event Report (87-078) to track and document the event, and notified the NRC via letter of May 20, 1987 of

the corrective action taken to correct the identified problems and prevent recurrence. The inspector reviewed relevant documentation and determined that corrective actions were adequat Failure to correctly classify an actual event as an Unusual Event would

-

normally result in the the issuance of a Notice of Violation. .However, the licensee's actions meet the provisions of 10 CFR 2, Appendix C, Section IV.A, which provides criteria for the non-issuance of a Notice of Violation under certain specified conditions. As per these criteria, the-licensee identified the situation, promptly notified the NRC on its discovery, the Violation would have been at Severity Level IV, and the ,

Violation was adequately corrected within a reasonable time. As such, '

the licer,see has met the five criteria, and no Notice of Violation will be issue q

No violations of regulatory requirements or deviations from commitments l were identifie . Exit Interview (30703) l The inspectors met with the applicant representatives denoted in !

Paragraph I on June 18, 1987. 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 consioered proprietary in natur ;

<

I