ML20040G147
| ML20040G147 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/28/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20040G148 | List: |
| References | |
| NUDOCS 8202110335 | |
| Download: ML20040G147 (13) | |
See also: IR 05000155/1981017
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. January 28, 1982
9
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Docket No. 50-155
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Consumers Power Company
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ATTN:
Mr. R. B. DeWitt
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Vice President
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FE8101982*
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Nuclear Operations
c/ sanwasumeranum
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212 West Michigan Avenue
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Jackson, MI 49201
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Gentlemen:
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Subject: EMERGENCY PREPAREDNESS APPRAISAL
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection- and Enforcement is conducting special
appraisals of the emergency preparedness programs at all operating nuclear
power reactors. The objectives of these appraisals are to evaluate the over-
all adequacy and effectiveness of emergency preparedness and to identify
areas of weakness that-need to be strengthened. We will use the findings
from these appraisals as a basis not only for requesting individual licensee
action to correct deficiencies and effect improvements, but also for
effecting improvements in NRC requirements and guidance.
During the period of November 30 - December 10, 1981, the NRC conducted a
special appraisal of the emergency preparedness program at the Big Rock
Point Nuclear Power Plant. This appraisal was performed in lieu of
certain routine inspections normally conducted in the area of emergency
preparedness. Areas examined during this appraisal are described in the
enclosed report (50-155/31-17). Within these areas, the appraisal team
reviewed selected procedures and representative records, inspected emergency
facilities and equipment, observed work practices, and interviewed personnel.
During their review it was noted by the inspectors that significant improve-
ments have been made in the emergency preparedness program at the Big Rock
Point Nuclear Plant. However, deficiencies still exist in this program.
These deficiencies are discussed in Appendix A, "Significant Appraisal
Deficiencies," and in summary include:
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January 28, 1982
a.
Emergency Operating Procedures and Off Normal Procedures do not
contain statements directing Reactor Operators to inform the Shift
Supervisor of a possible emergency condition.
b.
A backup meteorological system must be installed, consisting of wind
direction and speed sensors mounted on the stack.
c.
EPIP-1 does not base its classification on reliable and observable
indicators.
d.
Personnel acting as Site Emergency Directors, Shift Supervisors and
Shift Technical Advisors need training in EPIP-1 with emphasis
placed on classification of accident.
e.
An offsite laboratory facility must be established, according to the
Big Rock Plant Emergency Plan, in Boyne City.
f.
Consolidate those procedures needed to perform onsite/offsite radio-
logical monitoring.
Significant deficiencies for which you have made acceptable commitments to
resolve are discussed in the Confirmation of Action Letter dated December 14,
1981. This letter is enclosed as Appendix A.
The findings of this appraisal
also indicate that there are areas in need of improvement in your emergency
preparedness program. These areas are discussed in Appendix B, " Preparedness
Improvement Items."
In conjunction with the emergency preparedness appraisal, emergency plans for
your facility were reviewed. The results of this review indicate that defi-
ciencies exist in your Emergency Plan. These are discussed in Appendix C,
" Emergency Preparedness Evaluation Report."
Areas in your amergency preparedness program not completed at the time of
this appraisal were not examined. These areas are identified as Open Items
and are listed in Appendix D.
These will be examined by our staff at a
future date.
Please notify our office relevant to your completion schedule
of these items for re-examination by our staff.
The Probabilistic Risk Assessment (PRA) for Big Rock Point dated March 31,
1981, is being reviewed by the Division of Nuclear Reactor Regulation and
a decision as to the acceptance of the PRA will be made by June 1982.
It
is to be understood that the items covered by the PRA arc presently unre-
solved until such time that the items in the PRA are approved.
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Consumers Power Company
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January 28, 1982
We recognize that an explicit regulatory requirement pertaining to each
item identified in Appendices A, B, and C may not currently exist. Not-
withstanding this, you are requested to submit a written statement within
thirty days of the date of this letter, describing your planned actions
for improving each of the items identified in Appendix A and the results
of your consideration of each of the items in Appendix B.
This description
is to include:
(1) steps which have been taken; (2) steps which will be
taken; and (3) a schedule for completion of actions for each item. This
request is made pursuant to Section 50.54 (f) of Part 50, Title 10, Code
of Federal Regulations. With regard to Appendix C, within 90 days of the
date of this letter, you are requested to provide changes to the emergency
plan correcting each deficiency. Copies of these changes are to be submitted
in accordance with the procedures delinested in 10 CFR 50.54(q).
This is to inform yot that should the deficiencies addressed in the
Confirmation of Action Letter of December 14, 1981, not be corrected by the
commitment dates provided, the Commission will determine whether the reactor
shall be shut down until such deficiencies are remedied or whether other
enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, the enclosures, and your response to this letter will be placed
in the NRC's Public Document Room.
If this report contains any information
that you (or your contractors) believe to be exempt from disclosure under
10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by telephone
within ten (10) days from the date of this letter of your intention to file a
request for withholding; and (b) submit within twenty-five (25) days from the
date of this letter a written application to this office to withhold such
info rmation.
If your receipt of this letter has been delayed such that less
than seven (7) days are available for your review, please notify this office
promptly so that a new due date may be established.
Consistent with Section
2.790(b)(1), any such application must be accompanied by an affidavit executed
by the owner of the information wSich identifies the document or part sought
to be withheld, and which contains a full statement of the reasons which are
the bases for the claim that the information should be withheld from public
disclosure. This section further requires the statement to address with
-
specificity the considerations listed in 10 CFR 2.790(b)(4).
The information
sought to be withheld shall be incorporated as far as possible into a separate
part of the affidavit.
If we do not hear from you in this regard within the
specified periods noted above, a copy of this letter, the enclosures, and your
response to this letter will be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are not
subject to the clearance procedures of the Office of Management and Budget
as required by the Paperwork Reduction Act of 1980, PL 96-511.
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Consumers Power Company
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January 28, 1982
Should you have any questions concerning this appraisal, we will be pleased
to discuss them with you.
Should you have any questions, please contact the
Emergency Preparedness Section at (312)932-2535.
Sincerely,
Original signed by
James G. Keppler
James G. Keppler
Regional Administrator
Enclosures:
1.
Appendix A, Confirmation of
Action Letter dtd 12/14/81
2.
Appendix B, Preparedness
Improvement Items
3.
Appendix C, Emergency Plan
Evaluation Report
4.
Appendix D, Open Items
5.
Inspection Report
No. 50-155/81-17
cc w/encls:
D. P. Hoffman, Nuclear
Licensing Administrator
C. J. Hartman, Plant
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
Al Kenneke, OPE
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Regional Director, FEMA Region V
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Appendix A
CONFIRMATION OF ACTION LETTER
Docket No. 50-155
Consumers Power Company
ATTN:
Mr. R. B. DeWitt
Vice President
Nuclear Operations
212 West Michigan Avenue
Jackson, MI 49201
Gentlemen:
This letter is to confirm the agreements reached between Mr. Fred W. Buckman,
Executive Director of Nuclear Operations, and others of your staff, and
Mr. C. Paperiello, Region III, and other members of the Nuclear Regulatory
Commission staff on December 9,1981, during the management exit interview
following the NRC Eracrgency Preparedness Appraisal of Big Rock Point Nuclear
Plant.
Immediate corrective actions are required for the significant Appraisal
findings. The exact nature of the required actions, as well as the agreed
upon dates for such actions, are as follows:
1.
Emergency Implementation Procedures
Emergency Operating Procedures and Off Normal Procedures shall contain
statements directing the Reactor Operator to inform the Shif t Supervisor
of a possible Emergency Plan Condition requiring possible classification
of an event. These statements ch:11 be conspicuous.
(155/81-17-01)
(Section 5.2)
This shall be completed by February 15, 1982.
2.
Meteorology
a.
A backup meteorological system will be installed, consisting of
wind direction and wind speed sensors mounted on the stack at the
level of the isokinetic probe, and read out in the control room.
This will be completed by May 15, 1982, contingent on procurement.
(155/81-17-02) (Section 4.2.1.4)
b.
A description of the above system will be submitted for NRC review
by February 1, 1982.
(155/81-17-03) (Section 4.2.1.4)
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Appendix A
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3.
Emergency Action Levels
EPIP-1 will be reviewed and revised so that accident classifications
are based on reliable and observable indications available to the
control room operator. This will be completed by March 1, 1982.
(155/81-17-04) (Section 3.2.2)
4.
Training
Personnel acting as Site Emergency Directors and Shift Technical
Advisors will be trained in the revised emergency plan implementing
procedures with emphasis on the classification of accidents in
accordance with EPIP-1. This will be completed by May 1, 1982.
(155/81-17-05) (Section 3.2.2)
5.
Backup Analytical Capability
An offsite laboratory facility at the E0F in Boyne City will be
established by May 1, 1982.
(155/81-17-06) (Section 4.1.1.9)
6.
Survey Procedures
<
Those procedures necessary to perform plant environs and offsite radio-
logical monitoring will be consolidated into one procedure for use by
monitoring teams by March 1, 1982.
(155/81-17-07) (Section 5.4.2.1)
If our understanding of the actions as described in this letter are not
correct, you should contact this office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Further, please
provide our office written notification upon completion of your corrective
actions.
Sincerely,
James G. Keppler
Regional Administrator
cc:
D. P. lioffman, Nuclear
Licensing Administrator
C. J. Hartman, Plant
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Ronald Callen, Michigan
.
Public Service Commission
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Appendix B
PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Big Rock Point Nuclear
Plant Emergency Preparedness Program conducted November 30 - December 10,
1981,
the following items should be considered for improvement:
1.
The Emergency Planning Coordinator should attend at least one training
course per year to update his knowledge and expertise.
(Sections 1.0,
1.1,1.2,1.3,1.4)
2.
Establish written action levels for evacuation for all Site Area and
General Emergency conditions as per KUREG-0654.
(Section 5.4.3.2)
3.
Clearly mark and/or identify site evacuation routes, primary and
secondary, inside and ou+. side the facility.
(Section 5.4.3.2)
4.
Prepare a concise oral announcement for evacuation of owner-controlled
area.
(Section 5.4.3.2)
5.
Each emergency kit should contain an inventory list and inspection
documentation.
(Section 4.2.1.1)
6.
Formalize all procedures to include use of privately-owned vehicles and
county vehicles during an emergency.
(Section 4.2.6)
7.
Establish a procedure to control vehicle keys and availability.
(Section 4.2.6)
8.
Provide visible alarms in all high noise areas for emergency evacuation.
(Section 5.4.3.2)
9.
All support agencies that may be requested to provide onsite assistance
should be made aware of how personal dosimeters will be issued.
(Sections 3.1.3.2, 6.0 and 6.1)
10.
The licensee should ensure the compatibility of their equipment with
equipment from all support fire departments.
(Sections 3.1.3.2, 6.0
and 6.1)
11.
The Charlevoix Township Fire Department should be provided with a copy
of the Big Rock Point Emergency Plan, and Big Rock Point should provide
annual site tours for these firefighters.
(Settions 3.1.3.2, 6.0 and 6.1)
12.
Hospital procedures, in support of the Big Rock Point Emergency Plan,
should be specific to each facility.
(Sections 3.1.3.2, 6.0 and 6.1)
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Appendix B
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13.
Big Rock Point should ensure that the U.S. Coast Guard is familiar with
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the Big Rock Point Emergency Plan, the Implementing Procedures and what
actions Big Rock Point expects the U.S. Coast Guard to take.
I
(Sections 3.1.3.2, 6.0 and 6.1,
]
14.
Procedures for prompt sample preparation, packaging, and transport to
)
the Midland and Palisades plants for assaying should be prepared - if
setting up the facility at the EOF is unduly delayed.
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Appendix C
EMERGENCY PREPAREDNESS EVALUATION REPORT
PLAN
COMMENTS
9.7.3
A.I.e
A.
Assignment of Responsibility (Organizational
,
!
Control) Indicate that all communications links
,
are capable of being manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
l
(155/81-17-08)
Appendix A A.3
Letters of Agreement (LOA) (155/81-17-09)
l
The following Letters of Agreement
I
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are missing:
a.
Petoskey Fire Department
b.
Emmet County Emergency Services
c.
State Department of Health
d.
Charlevoix County Road Commission
The following Letters of Agreement need to
.
be updated:
a.
Department of Energy, Chicago
Operations Office
b.
Michigan State Police
c.
Charlevoix Township Fire
Department
In addition, all Letters of Agreement
.
should be revised to provide concepts of
operation, specific support commitments,
and responsibilities for contractors,
private organizations and local service
support groups.
B.
Onsite Emergency Organization (155/81-17-10)
9.5.2.1
B.3
Specify the conditions required for transfer of
Emergency Director responsibilities.
9.5.1
B.5
Specify how minimum shift staffing require-
.
ments of the criteria will be established.
Specifically, indicate how augmentation will
be ensured.
Ii.dicate that unannounced drills,
will be conducted, documenting the response
achieved. These drills should be conducted
during off normal hours.
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Appendix C
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PLAN
COMMENTS
Specify how the following emergency functions
.
will be implemented 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day:
(1)
Inplant sample collection and analysis; (2)
.
inplant monitoring; (3) out-of-plant monitoring;
(4) decontamination; and (5) first aid / rescue.
'
Indicate in the plan that a trained dedicated
.
individual, not the Shift Supervisor, will be
available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day for performing
communication functions.
C.
Emergency Response Support and Resources
(155/81-17-11)
9.5.5
C.1
1.
Specify each federal resource relied upon
and the support required by licensee, State
and local governments.
9.5.3
C.3
2.
Identify support radiological laboratories and
their general capabilities and availabilities.
M-7
Appendix 1
.D.
Emergency Classification System (155/81-17-14)
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1.
Alert
a.
Radiological Effluents
(1) Now states "...if continued over
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." this should be modified
to state 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
Appendix 1
(2) Now states "High radiation levels
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or high airborne contamination...",
should delete word "high."
Appendix 1
b.
NUREG-0654 EAL number 18 addresses
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turbine failure causing penetration.
This EAL should be added.
2.
General Emergency
Appendix 1
a.
Regarding reactor containment should
- 6c
add "...could lead to core degradation
or melt in several hours without con-
tainment boundary."
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Appendix C
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PLAN
COMMENTS
Appendix 1
b.
Should add "Any major internal or
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external events (e.g., fires, earth-
quakes, substantially beyond design
basis) which could cause massive common
change to plant systems resulting in any
of the above".
E.6
E.
Notification Methods and Procedures (155/81-17-15)
Appendix 3
Commit and describe the prompt Alerting and
.
Notification System which meets the design
objectives of NUREG-0654, Appendix 3.
The
plan shall address the administrative and
physical means, and the time required to
promptly notify the public of an emergency.
The plan should commit to the establishment
of such a system and indicate when the system
will be operational.
9 . 8'. 5
G.
Public Education and Information (155/81-17-16)
G. 3.c
Define the methods to be used for rumor control.
.
9.7.1.2
H.1
Emergency Facilities and Equipment (155/81-17-17)
Specify how NUREG-0696 criteria will be met.
This information should include the following:
The types of equipment available in the TSC
.
and E0F, identified in NUREG-0696, including
the types and locations of communications
equipment. This information should be de-
tailed on a scale drawing.
9.7.4.2
I.5 &
I.
Accident Assessment (155/81-17-18)
Appendix 2
Provide a description of the meteorological
.
instrumentation and procedures that meet
the criteria set forth in Appendix 2 of
NUREG-0654 and the provisions to obtain
representative real-time meteorological
information from other sources.
9.6.4.1. B J.10c
J.
Protective Response (155/81-17-12)
Specify how fishermen or other near site beach
.
users will be warned or advised of an emergency
at the site. Clear emergency instructions which
would require them to take protective measures
should be posted on the beach.
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Appendix C
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PLAN
COMMENTS
L.
Medical Support and Public Health (155/81-17-13)
-
19.6.5.2
L.2
'Specify who makes the medical decision-
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0.1
regarding and transporting of the seriously
}
-onsite injured.
9.6.5.4
L.3
Describe the training received by hospital,
4
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0.1.b
emergency squad and ambulance personnel regarding
-
0.4.f
handling of contaminated patients.
Identify who
instructs these individuals and the instructor's
qualifications.
P.
. Responsibility For Planning Effort (155/81-17-19)
P.8
Submit a cross-referenced index to NUREG-0654
.
criteria.
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Appendix D
OPEN ITEMS
,
The following is a list of Open Items identified in the area of emergency
preparedness which will be re-examined by the staff.
I
_1.
A historical record system to demonstrate through unannounced drills,
conducted during off-hours and long holiday weekends, that Table B-1
auguentation can be accomplished in 30 to 60 minutes.
(Section 2.2)
(155/81-17-20)
2.
A decision on the licensee's Probabilistic Risk Assessment (PRA) dated
March 31, 1981, regarding control room habitability by NRR is expected
to be made in June 1982.
(Sections 4.0, 4.1, 4.1.1 and 4.1.1.1)
(155/81-17-21)
3.
A decision on the licensee's PRA dated March 31, 1981, regarding TSC
habitability by NRR is expected to be made in June 1982.
(Section 4.1.1.2) (155/81-17-22)
4.
Installation of the Safety Parameter Display System in the EOF or TSC
has not been accomplished.
(Section 4.1.1.4) (155/81-17-23)
!
5.
A decision on the licensee's PRA dated March 31, 1981, regarding Post-
Accident Containment Air Sampling Capability by NRR is expected to be
made in June 1982.
(Sections 4.1.1.6, 5.4.2.6, 5.4.2.7 and 7.2.6)
(155/81-17-24)
6.
The licensee plans to install stack sampling capability during the
next refueling outage, scheduled for February 1982.
(Sections 4.1.1.7,
5.4.2.8 and 5.4.2.9) (155/81-17-25)
7.
The prompt notification system (alerting system and instructions) for
the 5 mile plume exposure emergency planning zone which must be in-
stalled by February 1, 1982.
(Section 6.2 and 6.2.2) (155/81-17-26)
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