ML20040G149
| ML20040G149 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 01/28/1982 |
| From: | Axelson W, Fairobent J, Grant W, Pagliaro J, Paperiello C, Psomas P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20040G148 | List: |
| References | |
| 50-155-81-17, NUDOCS 8202110338 | |
| Download: ML20040G149 (34) | |
See also: IR 05000155/1981017
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. ~50-155/81-17
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Docket No. 50-155
Licensee: Consumers Power Company
212 West Michigan Avenue
Jackson, MI 49201
Facility Name: Big Rock Point Nuclear Power Plant
Appraisal At: Charlevoix, MI
Appraisal Conducted: November 30 - December 10, 1981
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Inspectors: Paul P. Psomas
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Team Leader
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Approved By:
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Emergenc Preparedness Section
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Emergency reparedness and
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Program Support Branch
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Appraisal Summary
Appraisal on November 30 - December 10, 1981 (Report No. 50-155/81-17)
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Areas Appraised: The appraisal of the state of onsite emergency preparedness
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at the Big Rock Point Nuclear Power Plant involved seven general areas:
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ministration of the Emergency Preparedness Program; Emergency Organization;
Training; Emergency Facilities and Equipment; Procedures which Implement the
Emergency Plan; Coordination With Offsite Agencies; and Exercises and Drills.
The Appraisal involved 473 inspector-hours onsite by four NRC inspectors and
two consultants.
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8202110338 820128
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PDR ADOCK 05000155
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Results: No items of noncompliance or deviations were identified. Significant
deficiencies are identified in the Confirmatory Action Letter dated December 14,
1981, which is attached as Appendix A.
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1.0 ADMINISTRATION OF THE SITE EMERGENCY PLAN
1.1
Responsibility Assigned
1.2 Authority
1.3
Coordination
1.4 Selection and Qualification
The Plant Health Physicist functions as the site Emergency Planning
Coordinator (EPC). The EPC reports directly to the Plant Superintendent.
The counterpart at the corporate level is the Nuclear Emergency Planning
Coordinator. Onsite, the EPC is a parttime assigned position. The Shift
Supervisor, who assumes the role of an interim Emergency Director, has
the authority and responsibility to initiate all emergency actions within
the provisions of this Emergency Plan. The operating shift crew is
responsible for implementing emergency actions according to their speci-
fically assigned response functions in health physics, reactor operation,
radiological laboratory, etc.
These emergency actions are performed in
accordance with implementing procedures of the Emergency Plan.
Coordination
between onsite and offsite emergency planning organizations is the respon-
sibility of the General Office Control Center Director.
During an interview with the Plant Superintendent and other management
personnel the inspectors determined that there was adequate coordination
between the site and corporate organizations as well as between the onsite
organizational groups. The responsibility for this coordination is docu-
inented in administrative records maintained by the Plant Health Physicist.
Technical Specification 6.5.1.6H states that the Plant Review Committee
(PRC) is responsible for review of the plant emergency plan and emergency
plan implementing procedures (EPIP) and shall submit changes to the Safety
and Audit Review Board (SARB) chairman. Plant documentation shows that the
reviews are performed and appropriate changes have been made.
There is good coordination between the Licensee and offsite groups. The
responsibility for coordination has been adequately verified by conversa-
tions with offsite group representatives (Reference Section 6.0).
Selection
criteria have bec.. cotablished for personnel responsible for emergency
planning and are formally documented. The qualifications are specified in
functional areas and job descriptions. Training courses have not been
attended by those responsible for emergency planning. The results of the
review indicated that the administration of the Emergency Plan is adequate,
but the EPC should attend at least one training course per year to update
his knowledge and expertise.
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2.0 . EMERGENCY ORGANIZATION
2.1
Offsite Organization
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A review of the Corporate Administration and Organization was made to
determine that the responsibility, authority and coordination for admin-
istration of the Big Rock Point Emergency Plan had been established. This
review included the following:
a.
A review of Section 9.0 of the Emergency . Plan.
b.
Discussions with the following:
1.
Vice President Nuclear Power
2.
Director Radiation Services
3.
Chief, Corporate Health Physics
4.
Director, Nuclear Licensing
c.
General Office Nuclear Energy Implementation Procedures.
The results of the review indicate that each of the above individuals
could explain the actions they would take in the event of an emergency
at the Big Rock Point Nuclear Power Plant. _Those individuals responsible
for directing the corporate efforts are issued a laminated card listing
those persons to be contacted for each Director's position. There is a
duty EOF Director on a pager system for a 24-hour period. On the reverse
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side of the walletsized laminated card is listed a quick critical path to
begin Emergency Plan (EP) initiating procedures. The Corporate office
has devised a reference document for each corporate emergency team member
containing decision making aids.
Corporate personnel meet regularly with State personnel to ensure that dose
calculation methods, terminology and procedures are compatible.
Therc were no written criteria for personnel qualifications or specific
procedures for each director of the Corporate staff at the time of the
interview.
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Those personnel interviewed at the Corporate office were well versed in their
respective roles.
2.2 Onsite Organization and Shift Augmentation
The inspectors determined that functional areas specified in the Emergency
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Plan and implementing procedures by title and description are consistent
with the actual organization. Designated management structure is provided
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for these and other emergency support functions by organization chart and
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procedural descriptions.
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The Duty and Call Superintendent, as designated by the Plant Superintendent,
is on 24-hour call and would arrive at the plant to relieve the Shift Super-
visor in an emergency situation. The Plant Health Physicist is also on
24-hour call. The Plant Superintendent, as Site Emergency Director, is also
the highest official onsite to serve in an emergency coordinating function.
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Next in the line of succession is the Operations / Maintenance Superintendent.
Selection criteria for personnel assigned to onsite emergency functions are
specified by the Licensee in the Plan or procedures for each job description.
The Licensee has provisions for supplementing the Health Physics staff beyond
24-hours under accident conditions with the addition of contractor radiation
safety technicians. The current shift staffing is as specified in the
October 15,1981, letter, Bordine to Keppler, consisting of:
1 Shift Supervisor (SRO)
2 Control Room Operators
2 Auxiliary Operators
1 Rad / Chem Technician
The Licensee has demonstrated during a drill that minimum staffing require-
ments for emergencies can be met within the 30-60 minutes requirement as
specified in NUREG-0654, Table B-1.
The Plant Superintendent informed
members of the appraisal team that he can assure that this time criterion
will be met.
He does plan to conduct additional unannounced drills to test
the call in response times.
Before the first drill was conducted during the month of October, the Plant
Health Physicist (Emergency Planning Coordinator) surveyed the Big Rock Point
Staff to determine where each individual lived and had that individual
estimate their normal / abnormal driving time to work. Each Big Rock Point
employee's home was then plotted on a map. This map was then used to verify
the estimated travel time for each individual. An unannounced telephone
drill was conducted Navember 19, 1981, and there was an 86.6 percent employee
response.
It was determined that the response to this drill would have met NUREG-0654
Table B-1 criteria.
The results of the review indicated that Section 2.0, Emergency Organization
Program is adequate, however, the licensee has agreed to develop a historical
record system to demonstrate through unannounced drills, conducted during
off-hours and long holiday weekends, that Table B-1 augmentation can be accom-
plished in 30 to 60 minutes.
This is an open item.
3.0 EMERGENCY PLAN TRAINING / RETRAINING
3.1 Program Established
3.1.1
Licensee Personnel
The inspector interviewed Licensee employees and a contractor instructor
concerned with the plant's emergency plan training / retraining. The
Licensee had a well-established program, the scope of which was covered in
the plant's Emergency Procedure 6.I (dated November 23, 1981).
In addition
to its own training resourcec (six fulltime instructors plus designated
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plant personnel), the Licensee uses contractor instructors. The 26 lesson
plans for onsite training conducted by that contractor. were contained in a
manual titled, " Annual Emergency Plan Training for Big Rock Point Plant,"
dated November 1981. Each lesson plan contained its title, objectives,
training aids, and references.
The lesson plans were grouped into seven modules. Persons assigned functions
in the plant's emergency plan were to be trained annually in the modules
specified in Emergency Procedure 6.I, Attachment 1.
This procedure also
provided for further training (by employees or contractors) as appropriate
to an individual's assignment.
Persons with no emergency-duty assignments
must also receive emergency training annually, on the module specified icr
them. The Licensee also offered annual training to offsite groups, such
as fire department, medical support, police, and news media. Additionally,
the Licensee provided training to other offsite local groups; e.g. , for
example, school bus drivers, upon request.
The Licensee keeps a record of emergency training (and other training)
received by each employee, specifying the date, lesson title, and instructor.
Following a contractor-conducted emergency preparedness training session,
each participant is given a written test. For the training to be considered
acceptable, a person must receive a grade of 70% or higher. A person failing
a test would have to repeat the training until a passing grade was received.
Based on the above findings, this portion of the Licensee's program appears
to be acceptable.
3.1.2
Non-licensee Support Personnel
6.0 Coordination with Offsite Groups
6.1 Offsite Agencies
The inspector visited or contacted officials of the following offsite
agencies concerning their roles in the emergency plan and procedures for
Big Rock Point Nuclear Power Plant (BRP):
Charlevoix Fire Department,
Petoskey Fire Department,
Charlevoix Township Fire Department,
Northern Michigan Hospital, Inc.,
Charlevoix Area Hospital U.S Coast Guard Station,
Charlevoix,
Emmet County Sheriff,
Emmet County Emergency Services
All of these agencies acknowledged the existence of Letters of Agreement
between them and the plant.
The three fire departments recognize that the Charlevoix Fire Department is
the primary one in the plant's emergency plan. This department has three
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fulltime firemen, 17 volunteers, two ambulances and is manned 24-hours a day.
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Volunteers are called in by radio from the fire station. The fire department
has participated in joint exercises at the plant at least once a year; the
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last such drill was in May 1981. This group indicated firsthand knowledge
of the compatibility of their equipment, for example, hoses and connections,
with those of the plant. A double female adapter had been obtained to provide
compatibility with the plant's hydrant. The department is self-sufficient in
regard to respiratory protective equipment, recognizing that it uses Scott Air
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Paks while the plant uses Bio Paks. Facilities at Petoskey are used to refill
the department's air cylinders. The department carries 1-1/2 inch foam
equipment and about 60 gallons of foam, used at 100 pounds nozzle pressure.
Their estimated response time is 10 minutes, day or night. They considered
their knowledge of the plant site as adequate. Access of the fire trucks into
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the plant site presents no problem. Access of volunteers reporting directly
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to the plant site is expedited by photo ID's provided to the firemen by the
plant. The department; however, was not cognizant of the plant's current
provisions for the prompt issuing of personal dosimeters to firemen when
responding to a call from the plant. The plant should inform Charlevoix
City Officials and the Charlevoix Fire Department of these provisions.
The department has some civil defense radiation instruments on hand, but
would not use them when responding to a call from the plant. Fire Department
personnel recognized the plant's responsibility for providing full radiation
protection coverage and services while at the plant site, including complete
surveys for contamination and radiation dose rates. The department is pro-
vided with a copy of the BRP Emergency Plan, which is kept current.
When a
fire occurs at BRP, BRP calls the department, even if simply to alert them
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in case of need.
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The situation with the Petoskey Fire Department is very similiar. This
department; however, would generally expect to be called by the Charlevoix
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Fire Department for help, rather than by the plant directly. The department
also has two ambulances. As this department would generally respond as a
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unit (response time of 12-15 minutes, day or night), the firemen were not
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issued individual photo ID's by the plant. The department has knowledge of
the plant site from tours.
Ambulance-service drills with the plant are con-
ducted annually. The firefighting equipment was " standard" and compatible
with that of the Charlevoix Fire Department.
The Petoskey Fire Department;
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however, had not physically checked to assure compatibility of its equipment
with the facilities at the plant.
The Charlevcix Township Fire Department is an all-volunteer unit, (on call
from Sheriff's office via radio beepers) and included no ambulances.
It is
considered a backup unit.
Because of its nearness to the plant, this un -
could have a response time of 5-10 minutes, day or night. The department
has a new fire chief, who has recently signed a new Letter of Agreement with
the plant. The department has not been provided with a copy of the plant's
emergency plan. As with the Petoskey Fire unit, the Township unit had not
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physically checked the plant's facilities to assure compatibility of equip-
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ment. The unit has participated in drills at the plant, the last one being
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in May 1951. This group; however, did not appear to be sufficiently
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acquainted with the plant site. The drills were confined to areas outside
the plant. This matter should be reviewed by the plant, and necessary
improvements affected. The same considerations should be made with the
other two fire departments.
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The Little Traverse Division (Petoskey) of the Northern Michigan Hospitals,
Inc., has facilities for the prompt medical treatment and decontamination
of persons injured at the plant. Hospital personnel, including a Health
Physicist, appeared to be well satisfied with the annual training and drills
conducted and with the equipment provided by BRP. They were cognizant of
the Letter of Agreement with BRP and with their responsibilities. They did
suggest that the plant's cotbined procedure for this activity be prepared as
two separate documents, one for this hospital and the other for the Charlevoix
Area Hospital. This would facilitate inclusion of hospital specific informa-
tion;
e.g.,
for contact personnel and their telephone numbers, in each
procedure. The inspector endorses this recommendation.
The situation at the Charlevoix Area Hospital was found to be similar.
This hospital, being smaller than the one in Petoskey, is designated to
take care of minor cases; the more complex cases are taken to the hospital
at Petoskey.
The inspector contacted the U.S. Coast Guard Station at Charlevoix and
learned that it now has a new Officer-in-Charge. He did not appear suf-
ficiently knowledgeable of the Letter of Agreement with the plant. The
inspector recommends that the plant contact him as soon as possible and
familiarize him with the expected functions to be performed by the U.S.
Coast Guard under the plant's emergency plan.
The officers of the Emmet County Sheriff's Department, Emmet County
Emergency Services, and Charlevoix County Sheriff's Department were
contacted by the inspectors and they acknowledged the Letters of
Agreement with the plant.
Based on the above findings, this portion of the Licensee's program
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appears to be acceptable, however, the following deficiencies should be
corrected:
a.
All support agencies that may be requested to provide onsite assistance
should be made aware of how personal dosimeters will be issued.
b.
The licensee should ensure the compatibility of their equipment with
equipment from all support fire departments.
c.
The Charlevoix Township Fire Department should be provided with a
copy of the BRP Emergency Plan, and BRP should provide a site tour
for these firefighters.
d.
Hospital procedures, in support of the BRP Emergency Plan, should be
specific to each facility.
e.
BRP should ensure that the Coast Guard is familiar with the BRP
emergency plan, procedures and what actions BRP expects the Coast
Guard to take.
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3.1.3
General Public
6.2.1
Information Distribution
A review was made of the methods and implementation of the dissemination
of emergency planning information to the public within the plume exposure
pathway (five mile EPZ) to ensure that they are in accordance with the
appraisal criteria used.
The review included the following:
a.
Discussion with the Big Rock Point Public Affairs Director.
b.
Review of the Nuclear Plant Emergency Public Information Policy
Procedures.
c.
Review of Consumers Power emergency planning information, a phone
book advertisement, and a brochure entitled " Emergency Planning - We
are Prepared," which was distributed to the permanent and transient
adult population in Charlevoix and Emmet Counties in early 1981.
The results of the review indicated that this portion of the Licensee's
program is acceptable.
3.1.4
News Media
6.3 News Media
A review was made of the Licensee's program for familiarizing the news
media with emergency preparedness planning.
The review included a discussion with the Big Rock Point Public Affairs
Director and a review of the records of the emergency planning press con-
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ference on November 9,1981.
Organizations attending the conference
included representatives from the media, Consumers Power, State Police,
and local government officials. The Licensee plans to invite the news
media to similar conferences annually.
Based on the above reviews, this portion of the Licensee's program is
adequate.
3.2 Program Implementation
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3.2.1
Training Performed
The inspector reviewed a sample of the training records maintained by the
plant's training group. The records kept on each individual's training
were very detailed. The licensee audits these records semi-annually to
assure each person has received the required treining. Entries on an
individual's record are made on the basis of written information furnished
by the instructor to the record-clerk of the plant's training group.
These
central records; however, did not include a prepared matrix which indicated,
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for each plant person, the annual emergency lesson modules and emergency
procedures training required by plant Emergency Procedure 6.I, Attachment 1,
and provisions for entering the dates when training on that lesson-module
or procedure was received. The licensee has plans to prepare and use such
a matrix.
On the basis of discussions with local offsite participants (medical support
and fire departments--see Section 6.1), the inspector determined that adequate
training was given to these individuals.
Discussions with plant and contractor training personnel indicated that all
but eleven of the plant's personnel had completed the required training
provided by the plant's contractor. A review of walkthrough demonstrations
to show that licensee personnel understood their emergency plan duties and
procedures as discussed in Items 7.1 and 7.2.
Based on the above findings, this portion of the Licensee's program appears
to be acceptable.
3.2.2
Individuals Understand and Can Perform Duties
5.1
General Format and Content of Emergency Implementing Procedures
7.0 Drills, Exercises and Walkthroughs
7.1
Walkthrough Observations
7.1.1
Emergency Detection Walkthroughs
7.1.2
Emergency Classification Walkthroughs
7.1.3
Emergency Notification Walkthroughs
The inspectors reviewed the Big Rock Point Site Emergency Plan Implementing
Procedures and the General Office Nuclear Emergency Implementing Procedures.
The two sets of procedures used different formats. The " Site" procedure
format contained the following headings:
(1) Purpose; (2) Attachment; (3)
Initial Conditions and/or Requirements; and (4) Procedures. The " General
Office" procedures format was arranged with headings as follows:
(1)
Emergency Position; (2) Responsibilities; and (3) Actions. The General
Office procedure format appeared acceptable for defining the responsibilites
of corporate support personnel.
EALs and Protective Action Guides (PAGs) are given in EPIP 1 and EPIP 4A,
respectively. EALs and PAGs, including emergency and protective actions,
are clearly specified.
Each action, including notifications, are given
under each instruction.
Personnel who would act in an emergency as a Site Emergency Director (SED),
i.e., management personnel and Shift Supervisors and personnel who would
advise the Shift Supervisor (SS),
i.e., Shift Technical Advisors (STAS),
were walked through the procedures for which they would be responsible.
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Walkthroughs were conducted using hypothetical conditions given as accident
scenarios. Scenarios were developed to determine if personnel could detect
and classify accidents and conduct the appropriate notifications.
Most persons acting as SEDs, although they had detected the accident appro-
priately, needed to be prompted to classify the accident appropriately.
Some had problems with finding the appropriate procedure and had difficulty
using the EALs. This indicated they need additional training to become more
familiar with physically handling and finding the appropriate procedures.
A problem with the procedures was identified during the walkthroughs. A
given set of conditions, when identified under the key words " primary coolant
system," " fuel damage" or " reactor containment" yielded different classifi-
cations of the incidents,
i.e., Site Area Emergency and General Emergency.
This is a significant finding and must be corrected.
The notifications of offsite agencies are directed in a stepwise manner by
EPIP 1 and plant personnel recognized their importance. The notification
procedures were used well and current telephone' numbers and names of' personnel
were listed.
STAS who walked through the procedures generally performed well in categorizing
the incident, knowing the actions to be performed, and with prompting could
assess degree of core damage, offsite releases, etc.
However, some were
awkward in handling the procedures,
i.e.,
finding the appropriate procedure
and using it with facility.
This section of the licensee's program is unacceptable and the following
actions must be taken to achieve an acceptable program.
a.
Conduct a training program for personnel acting as Site Emergency
Directors and Shift Technical Advisors to improve their handling and
use of emergency plan implementing procedures.
b.
Review and modify EPIP 1 to remove any ambiguity in classifying
incidents and to assure that given emergency conditions yield the
same emergency classifications under each key word.
4.0 EMERGENCY FACILITIES AND EQUIPMENT
4.1
Emergency Facilities
4.1.1
Assessment Facilities
4.1.1.1
Control Room
A review was made of the Control Room facility to determine compliance with
the requirements of NUREG-0696. The review included discussions with licensee
personnel and observation of the Control Room.
The results of the review
indicated that the Control Room has adequate copies of the Emergency Plan,
Emergency Plan Implementing Procedures and Emergency Operating Procedures,
E0Ps and ONPs.
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Adequate primary and backup emergency communications exist to the Technical
Support Center (TSC), Operational Support Center (OSC), Corporate Office,
and offsite local support agencies. The Control Room operating staff was
familiar with the use of this equipment. However, the Control Room does not
meet the habitability requirements of NUPEG-0737.
The licensee has requested an exemption from this requirement based on a
Probabilistic Risk Assessment (PRA). The PRA is currently under review by
the NRC and a determination is expected to be made in June, 1982. This is
an open item.
4.1.1.2
Technical Support Center (TSC)
A review was made of the Technical Support Center (TSC) to determine its
adequacy in meeting the requirements of NUREG-0696 for emergency facilities
and equipment to support the emergency response. The review included dis-
cussions with the Emergency Planning Coordinator and tours of the TSC. The
review also included Section 9.7.1.2 of the emergency plan and Emergency Plan
Implementing Procedure 3A, Activation of Technical Support Center.
The results of the review indicated that the interim TSC meets the requirements
of NUREG-0578 except for the habitability requirements. This inadequacy of the
TSC is recognized by the Licensee.
The Licensee has addressed this requirement in their PRA, submitted March 31,
1981, and currently under review by the NRC. The Licensee has requested relief
from this requirement. A determination is expected to be made by the NRC in
June 1982. This is an open item.
4.1.1.3
Operations Support Center
A review was made of the Operations Support Center (OSC) to determine if
it was located as specified in the emergency plan and procedures and if
the facilities meet the requirements of NUREG-0696.
The review included discussions with the licensee's Plant Health Physicist,
a review of Emergency Plan Implementing Procedures 4, 5, and 6, and examina-
tion of the Operations Support Center.
The Licensee's Operation's Support Centers are located in the Machine Shop
on the ground floor of the Turbine Building, the hallway outside the Control
Room, and the Service Building Annex outside of the protected area.
The
ventilation is normal building ventilation without filters for airborne
contaminants.
The primary and backup communications consist of plant telephones and
walkie-talkies that must be brought to each OSC. The results of the review
indicated that this portion of the Licensee's program is adequate.
4.1.1.4
Emergency Operations Facility (EOF)
A review was made of the Emergency Operations Facility (EOF) to determine
its acceptability in accordance with NUREG-0696 criteria. This facility
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is located in Boyne City at the Consumers Power Service Center approximately
18 miles from the Big Rock Point Nuclear Power Plant facility. Due to the
distance from the plant, habitability monitoring is not required. This
facility is also used as the reassembly area.
It has sufficient facilities
for decontamination.
The results of the review indicated that the E0F facilities were adequate.
Permanent data display capability (Safety Parameter Display System and other
Regulatory Guide 1.97 parameters) have not been installed. The licensee has
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requested an exemption in the PRA for Big Rock Point. A decision regarding
the PRA is expected in June 1982. This is an open item.
4.1.1.5
Post-Accident Coolant Sampling and Analysis
5.4.2.4
Primary Coolant Sampling Procedures
5.4.2.5
Primary Coolant Analysis Procedures
7.1.5
Post-Accident Coolant Sampling and Analysis Walkthroughs
A review was made of the interim post-accident primary coolant sampling
and analysis program to determine its adequacy in meeting requirements
of NUREG-0737, II.B.3 Post-Accident Sampling (PAS) Capability. The
review included discussions with the Plant Health Physicist, Chemical
and Radiation Protection Supervisors, and Chemical and Radiation Protection
Technicians.
Plant systems that pertained to PAS were inspected. Emergency
Plan Implementing Procedure (EPIP) SE and Radiochemistry Procedures RCP-7.
RCP-9 and RCP-14 were reviewed.
Calibration and training records that
pertained to PAS were also reviewed. Walkthrough reviews of the procedures
were conducted with the Chemical and Radiation Protection Supervisors and
selected Technicians.
The inspection of plant facilities and equipment indicated that adequate
interim PAS facilities and equipment are in place to accomplish this task
for accident sequences resulting in less than 10% core melt.
If core melt
exceeds 10%, these tasks can be accomplished 24-hours (or less) after the
initiating event.
If primary coolant samples cannot be obtained during
this period, the containment radiation monitor can be used to estimate
core damage.
If the sample analysis facilities cannot be used, alternate
equipment is available in the Air Compressor Room and at the EOF, assuming
sample collection and preparation is accomplished at the plant. The review
of EPIP SE and RCP-7, RCP-9 and RCP-14 indicated that adequate procedures
to accomplish PAS are in place. Calibration procedures and records that
pertained to PAS equipment were reviewed and found to be adequate and current.
Training records for EPIP SE were current and complete except for one Chemical
and Radiation Protection Technician who was recently hired and is still
undergoing on-the-job training.
The results of the walkthrough reviews of the PAS procedures indicated that
training had been adequate to ensure that supervisors and technicians on all
shif ts were capable of performing the required tasks.
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The reviews of facilities and equipment, procedures, calibration and
training records and walkthroughs indicate that the Licensee's interim
program for PAS appears to be acceptable.
4.1.1.6
Post-Accident Containment Air Sampling and Analysis
5.4.2.6
Containment Air Sampli<g Procedures
5.4.2.7
Containment Air Analysis Procedures
7.1.6
Containment Air Sampling and Analysis Walkthroughs
In reviewing the interim post-accident sampling program, it was noted that
no facilities, equipment, or procedures exist for containment air sampling
and analysis. The absence of such capabilities has been recognized in a
letter dated May 2, 1980, to David P. Hoffman from Dennis L. Ziemann. An
attachment to this letter acknowledges the deferral of NUREG-0654 and -0737
requirements. NUREG-0654 and -0737 requirements for containment air sampling
and analysis have been addressed in a letter dated March 31, 1981, to
Dennis M. Crutchfield from David P. Hoffman. Attached to this letter was the
Probabilistic Risk Assessment (PRA) for Big Rock Point and the basis for
continued deferral of post-accident sampling capability pending completion of
the NRC review of the PRA. Since che NRC review of the PRA has not been
completed to date, this is an open item.
4.1.1.7
Post-Accident Gas, Particulate, and Radioiodine Effluent Sampling
and Analysis
5.4.2.8
Stack Effluent Sampling Procedures
5.4.2.9
Stack Effluent Analysis Procedures
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In reviewing the interim post-accident sampling program, it was determined
I
that no facilities, equipment, or procedures were in place for stack effluent
sampling and analysis. However, facilities, equipment, and procedures for
online stack monitoring of routine releases and high stack gas releases are
in place and functional. The licensee plans to install stack sampling cap-
ability during the next refueling outage, scheduled for February 1982.
The
planned system will replace the existing system and provide automated sampling
and analysis capabilities for iodine, noble gases, and particulates. The
,
system will monitor normal stack effluents until a high level or a high rate
of change (to be determined) is detected.
It then routes the sampling line
through a gas sampler, through a shielded charcoal filter for iodine, and
through an online NaI detector for noble gas analysis. Another branch of
the line from the gas sampler passes through an automatic filter changer
system. A detector on this system can be operated remotely from the Counting
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Lab to analyze for iodine and particulates. Effluents from the stack sampling
system will be returned to the stack. This is an open item.
A review was made of the existing stack effluent monitoring program to
determine its adequacy in meeting the intent of NUREG-0654. The review
included discussions with the Plant Health Physicist and Chemical and
Radiation Protection Supervisors. Emergency Plan Implementing Procedure
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EPIP 5B was reviewed. The stack effluent monitoring system was inspected,
which includes an isokinetic sampler in the stack, a shielded GM tube that
monitors high stack gas releases with readout in the Air Compressor Room,
and a shielded NaI detector that monitors normal effluents with readouts in
the Control Room for gross gamma and Xe-138. Calibration procedures and
records that pertained to stack effluent monitoring were reviewed. Pertinent
training records were also reviewed. Walkthroughs of the procedures were
conducted with the Chemical and Radiation Protection Supervisors.
The reviews of monitoring equipment, EPIP 5B, calibration and training
records, and walkthroughs indicated that the licensee's interim program
for stack effluent monitoring appears to be acceptable.
4.1.1.8
Post-Accident Liquid Effluent Sampling and Analysis
5.4.2.10
Liquid Effluent Sampling Procedures
5.4.2.11
Liquid Effluent Analysis Procedures
7.1.7
InPlant Sampling and Analysis Walkthroughs
A review was made of the interim post-accident liquid effluent sampling and
analysis program to determine its adequacy in meeting the requirements of
NREG-0737, II.B.3 Post-accident Sampling Capability and NUREG-0654. The
review included discussions with the Plant Health Physicist, Chemical and
Radiation Protection Supervisors, and Chemical and Radiation Protection
Technicians. Plant systems that pertained to liquid effluent sampling and
analysis were inspected. Chemical Analysis Procedure CAP-2 and Radio-
chemistry Procedures RCP-1, RCP-7, RCP-9, RCP-14 and RCP-31 were reviewed.
Calibration procedures and records that pertained to liquid effluent sampling
and analysis were also reviewed.
Walkthrough reviews of the procedures were
conducted with the Chemical and Radiation Protection Supervisors and selected
Technicians.
The inspection of plant facilities and equipment indicated that adequate
interim PAS facilities and equipment are in place to accomplish liquid
effluent sampling and analysis.
If the sample analysis facilities could
not be used, alternate equipment is available in the Air Compressor Room.
4.1.1.9
Offsite Laboratory Facilities
At present, the Licensee does not have local offsite laboratory facilities
for assaying elevated radioactive samples in the event the Plant's laboratory
facilities become unhabitable. The plant, however, intends to establish such
facilities at its EOF, located at Boyne City, which is about 18 miles from the
plant, by July 1, 1982.
The EOF laboratory will have a Nuclear Data 6600 gamma ray spectroscopy
system. This instrument will be used primarily for assaying enviroamental
samples, but will also be used for higher level radioactive samples.
According to the licensee, the offsite laboratory facility will be totally
dedicated to emergency use.
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If the need . arises, the licensee.could use the laboratory facilities of
the Consumers Power Company nuclear power plants at Midland and Palisades,
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which are 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 4-1/2 hours by car, respectively, from the Big Rock
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Point Plant. The licensee has a contract with Eberline for processing
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environmental TLDs.
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-There were.no written emergency procedures for prompt sample preparation,
packaging, and transport. to the Midland and Palisades plants for assaying,
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The licensee indicated that instrumentation at its future offsite laboratory
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facility in the EOF will be maintained,' calibrated, routinely checked and
repaired or' replaced.
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Based.on the'above findings, this portion of the licensee's program is
unacceptable and the following actions must be taken to achieve an
acceptable program:
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' Set up the offsite laboratory facility'at the EOF in Boyne City, as
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planned by the Licensee.
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Prepare interim procedures for prompt. sample preparation, packaging,
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and transport .to the Midland and Palisades plants for assaying--if
setting up the facility at the EOF is unduly delayed.
4.1.2
Protective Facilities
4.1.2.1-
Assembly / Reassembly Areas
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A review was made of the Licensee's emergency assembly / reassembly areas to
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determine if they are located as specified in the Emergency Plan Implementing
Procedures and if their facilities are acceptable under the criteria.of
NUREG-0654. The review included discussions with the Licensee Emergency
Preparedness Staff. A review of the Licensee's procedures for implementing
emergency assembly .of personnel and a tour of those areas was conducted.
f
The_results of the review indicated that all three assembly areas meet
established criteria.
This portion of the Licensee's program is adequate.
!
4.1.2.2
Medical Treatment
A review was made of medical treatment capabilities to determine if they
meet the planning standard criteria of NUREG-0654, Section L.
The review included Emergency Plan Implementing Procedures (EPIP) 6D and
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6E.
Interviews were conducted with the Chemical and Radiat^ ion Protection
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Supervisor and Chemical'and Radiation Protection Technicans.
First' aid supplies, equipment and training were examined. First aid supplies
available at the site for the care of injured personnel are adequate in
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meeting Planning. Standard L of NUREG-0654.
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The first aid station is located at Access Control to the Turbine Building.
Examination of a first aid kit at Access Control indicated it was adequately
supplied.
The. review showed the Licensee's program to be acceptable.
4.1.2.3
Decontamination Facilities
5.4.3.4
Personnel Monitoring and Decontamination Procedures
A review was made of personnel decontamination facilities to determine
their adequacy in meeting the criteria specified in NUREG-0654,.K1 and
K5.
The review included Emergency Plan Implementing Procedures (EPIP) 6B
and 6E and inspection of available decontamination supplies. The review
also included interviews with Chemical and Radiation Protection Supervisors,
the Plant Health Physicist and Chemical and Radiation Protection Technicians.
The results of the review indicate that a sufficient number of decontamination
kits are available at designated areas.
This portion of the Licensee's program is acceptable.
4.1.3
Expanded Support Facilities
A review was made of the Licensee's plans to provide facilities for expanded
personnel support during emergencies.
Discussions with licensee personnel revealed that personnel needed to
augment the plant staff will be housed in trailers brought to the Boyne
City Service Center site. The site has a large open area and also contains
the licensee's EOF.
Communications are available.
Since this is a resort area, there are
sufficient lodging facilities available, if needed, to supplement the
trailers that will be available.
The results of this review indicate that this portion of the Licensee's
program is acceptable.
4.1.4
News Center
A review was made of facilities to be used for disseminating information
to the news media following an emergency to determine its acceptability
under planning standards of NUREG-0654. The review of this area included
the following:
a.
The Nuclear Plant Emergency Public Information Policy and Procedures.
b.
Discussions with Big Rock Point Public Affairs Director.
c.
An examination of the News Center - The Bayview Room, Holiday Inn,
Petoskey, Michigan.
d.
Procedures for establishing the Joint Public Information Center (JPIC)
for Big Rock Point.
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The News Center (JPIC) has provisions or arrangements for service, copying,
public address system, audio visual equipment and security. The center is
large enough to accommodate several hundred members of the media.
This portion of the Licensee's program is acceptable.
4.2 Equipment
4.2.1
Assessment Equipment
4.2.1.1
Kits and Survey Instruments
A review was made of emergency kits and survey instruments to determine
their adequacy in meeting Planning Standards H and I of NUREG-0654. The
review included a discussion with the Chemical and Radiation Protection
Supervisor and inspection of the kits in the Control Room, Technical
Support Center (SS office), Machine Ehop, Service Building Annex,
Charlevoix Cai,nty EOC (2), and the Office Building Lobby (ambulance kit).
Inventory checks were made on all kits. Documentation of inspections /
inventories conducted by Chemical and Radiation Protection Technicians was
reviewed. Kit contents and frequency of inspection were adequate to meet
the criteria of NUREG-0654. The kits in the Charlevoix County EOC, while
found acceptable, had no documentation of inspection and inventory.
The results of the review indicate that this portion of the Licensee's
program is acceptable; however, each emergency kit should contain an
inventory list and inspection documentation.
4.2.1.2
Area and Process Radiation Monitors
A review was made of the area and process radiation monitoring program to
determine its adecuacy in meeting the planning standards of NUREG-0654 for
area and process radiation monitors under accident conditions. The review
included discussions with Shif t Supervisors, the Chemical and Radiation
Protection Supervisor, and tours of the control room and plant area monitor-
ing locations conducted by radiation protection technicians.
Section 9.7.4
of the Site Emergency Plan contains a description of the Radiation Monitoring
Program.
It was noted during the appraisal that a containment high range monitor with
a maximum range of 1.0E+6 R/hr is installed.
The results of the review indicated that adequate methods and calibration
for instrumentation and equipment for assessing and monitoring plant con-
ditions during an emergency are in place and properly maintained.
This portion of the licensee's program appears to be adequate.
4.2.1.3
Non-radiation Process Monitor
A review was made of non-radiation process monitors located in the Control
Room to ensure that they are available in accordance with NUREG-0654, H.5.c.
Observation of the following monitors indicated that each were operable:
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reactor coolant system pressure and temperature, containment pressure and
temperature, liquid levels, flow rates, and status of equipment components.
Discussions with several Shift Supervisors showed they had a clear under-
standing of the use of these monitors for emergency detection, classification
and assessment. Monitor readouts were located in the Control Room. The
monitor alarms are used for initiating operator action to respond to a
spectrum of emergency situations.
The Licensee has provided an acceptable program for describing, locating,
and operating non-radiation process monitors.
This portion of the Licensee's program appears to be adequate.
4.2.1.4
Meteorological Instrumentation
Pursuant to the criteria in Regulatory Guides 1.23 and 1.97 and NUREG's-0654,
-0696, and -0737; the inspector reviewed the current meteorological measure-
ments program. Onsite meteorological instrumentation consists of only a
3-bladed Aerovane mounted a few feet above the turbine building. Because of
the location of the Aerovane within the turbulent wake of airflow over and
around plant structures, the representation of wind speed and direction
measurements from this location is highly suspect. Wind speed and wind
direction measurements are monitored on dials at the back of the main
instrument panel in the Control Room. No onsite indicator of atmospheric
stability is available. Only Emergency Plan Implementing Procedure (EPIP)
4E requires recording of the available onsite meteorological data, and the
information is apparently ignored once it is recorded.
Meteorological information used to estimate plume location and for offsite
dose projections is obtained through a service provided by Weather Service
International (WSI) which allows access to current observations at National
Weather Service stations. Access to WSI is accomplished through use of a
portable computer terminal located in the office of the Shift Supervisor
(currently part of the interim Technical Support Center). Emergency Plan
Implementing Procedure 5A (Offsite Dose Projections) utilizes the latest
hourly observations of wind speed and wind direction from Pellston (or
Traverse City, if Pellston is not available), with atmospheric stability
determined automatically by WSI considering wind speed, cloud cover, and
solar insolation.
If WSI does not provide atmospheric stability, the in-
formation can be determined through use of a flow-chart contained in the
implementing procedure to interpret current surface weather observations
at Pellston. Five phone numbers are available for accessing information
from WSI.
If access to the WSI system cannot be accomplished, backup
information may be accessed directly through a phone call to the National
Weather Service Office in Ann Arbor, to Pellston airport, or to the National
Weather Service Office in Sault Ste. Marie.
The current procedures for obtaining meteorological data for use in emergency
situations at Big Rock Point are not acceptable. Onsite meteorological in-
strumentation does not conform to the guidance in Regulatory Guide 1.23 with
respect to location and sensor specifications. Recording of instantaneous
observations from dials does not conform to the criteria of NUREG-0654.
Because the Big Rock Point Plant is uniquely situated on the shore of Lake
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Michigan, the characterization of atmospheric transport and diffusion con-
ditions in the vicinity of the plant by data from stations 40 to 50 miles
distant is questionable. The National Weather Service-stations at Pellston
and Traverse City are not located with the same oroximity or orientation to
Lake Michigan as the Big Rock Point Plant. ComIarisons of real-time data
between Big Rock Point, Pellston, and Traverse City are not available.
However, comparisons of real-time data between Pellston and Traverse 'ity
have shown substantial differences in meteorological conditions.
In addition
to difficulties characterizing atmospheric. transport and diffusion conditions
in the vicinity of the plant, no equipment is installed to routinely inform
the licensee of severe weather expected at or near the site.
As indicated in the August 12, 1981, letter from H. R. Denton to R. B. DeWitt
of Consumers Power Company, pending completion of the staff review of the
probabilistic risk assessment for the Big Rock Point Plant, the licensee is
required, at this time, to have onsite meteorological instrumentation
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equivalent to a backup system as described in the proposed revision to
To fulfill this requirement, onsite measurements of
wind speed and wind direction and an indicator of atmospheric stability which
are reasonably tapresentative of the site and vicinity are necessary. As
discussed with the licensee, an acceptable backup system would be wind
direction and wind speed sensors mounted on the stack at the level of the
,
isokinetic probe (approximately 120 feet above the ground). The length and
orientation of the boom to mount the sensors should be selected to minimize
interference from the stack and nearby structures for winds blowing onshore.
Guidance on mounting and orientation of the sensors is contained in proposed
Revision 1 to Regulatory Guide 1.23.
Either sigma-theta or the Pasquill-Turner
classification scheme are acceptable indicators of atmospheric stability
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within certain limits for such a backup meteorological measurements system at
the Big Rock Point site. Details of a proposed meteorological measurements
system, including' determination of atmospheric stability, designed to conform
to the requirements indicated above should be provided by the licensee and
reviewed by the staff as soo; as possible.
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This description (provided in the response to the Confirmation of Action
letter to be issued as a result of the appraisal) should include length
and orientation of the mounting boom, sensor types and specifications,
maintenance and calibration procedures, data recording and reduction
procedures, and the location of recorders. Until the evaluation of the
PRA is completed, access to the WSI system should be maintained. Also
discussed with the licensee in combination with the onsite measurements
discussed above was the evacuation of all people on land within two miles
of the plant any time offsite evacuations were recommended.
An acceptable mechanism to provide information about severe weather expected
at or. near the plant site is an arrangement similar to that used by the
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licensee at the Palisades Plant.
If the licensee elects to have similar
services provide, by a contractor for the Big Rock Point Plant, information
concerning the t1 pes of forecasts expected, the severe weather phenomena
covered by the contract, and the timeliness of transmittal of the forecast;
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to Control Room personnel should be provided to t he staff for review.
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This portion of the licensee's program is unacceptable and the following
action must be taken to achieve an acceptable program:
An acceptable backup meteorology system consisting of wind "rectirn
and wind speed sensors mounted on the stack at the level of L '
isokinetic probe.
Sensor types and mounting boom specifications; maintenance, calibration,
data recording and reduction procedures; and recorder locations shall be
submitted for evaluation, in response to the Confirmation of Action Letter.
4.2.2
Protective Equipment
4.2.2.1
Respiratory Protection
A review was made of the availability and quantity of respiratory equipment
that would be used during an emergency.
Onsite supplies of both respirators
and self-contained breathing devices (BIO-PAC 60) are adequate, as well as
the stock of spare oxygen bottles. However, respirators stored in some
emergency kits were not maintained in accordance with ANSI Standard Z88.2;
e.g.,
respirators were not sterilized, dated, and scaled in individual
containers.
Prior to the completion of the emergency preparedness appraisal the above
deficiency was corrected by the Licensee.
Sterilized respirators were placed
in plastic bags. Procedures have been established by the Licensec to maintain
stored emergency respirators in accordance with ANSI Standard Z88.2 requirements.
The Licensee's Respiratory Protection Program was found acceptable according
to the planning criteria of NUREG-0654.
4.2.2.2
Protective Cle.hing
A review was made of the availability of protective clothing onsite that
would be used in an emergency.
The review indicated that there was an ample supply of protective clothing
that would be accessible during emergency conditions. Additional supplies
are available at Corporate Headquarters in Jackson, Michigan and from
Palisades Nuclear Power Plant, Covert, Michigan for sustained recovery
operations. This portion of the Licensee's program appears adequate.
4.2.3
Communication Equipment
6.2 General Public
6.2.2
Information Disseminated
A review was made of the proposed prompt notification system to determine
if it was in compliance with the planning objectives of Appendix 3,
KUREG-0654.
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The review included discussions with Consumers Power Emergency Planning
Personnel. The results of the review indicated that the Licensee will
install a prompt public notification system. This system will consist of
pole-mounted speaker assemblies. These assemblies will be operated in a
warning siren mode or in a public address mode by the County Sheriff. The
licensee also plans to install public warning devices in selected public
areas, e.g. , schools, factories, where noise may prevent occupants from
hearing the sirens. The prompt notification system will provide physical
means for alerting and providing prompt instruction to the public within
the plume exposure pathway EPZ out to five miles.
This site system will apparently meet the planning objectives Appendix 3,
Based on the above review this is considered an open item. Regulatory
action may be taken against the utility if this system is found to be
unacceptable after February 1, 1982.
4.2.4
Damage Control / Corrective Action and Maintenance
A review was made of the facilities and equipment that might be required
for damage control / corrective action following an emergency.
The review of this area included discussions with the Maintenance Engineer.
The results of the review indicated that equipment and supplies required
are on hand. Extra equipment and supplies, if required, can be obtained
from Palisades and Midland.
Post-accident corrective action / damage control
activities would be directed by the Maintenance Director, the Maintenance
Engineer and the Director of I&C, from the TSC.
The results of the review indicated that this portion of the Licensee's
program appears acceptable.
4.2.5
Reserve Emergency Supplies and Equipment
5.5.1
Inventory, Operational Check and Calibration of Emergency Equipment,
Facilities, and Supplies
A review was made of the above subjects to determine their adequacy in
meeting the planning criteria of NUREG-0654.
The review included Site
Emergency Plan Section 9.7.6 and Appendix E.
Also included in the review
were Emergency Plan Implementing Procedure (EPIP) 6D and Radiation Pro-
tection Procedure RP-36.
Discussions were held with the Chemical and
Radiation Protection Supervisor and Chemical and Radiation Protection
Technicians.
The results of the review indicated that operational checks, calibration
of emergency equipment, facilities, and supplies are in place and docu-
mented in accordance with planning criteria of NUREG-0654. This item is
acceptable.
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4.2.6
Transportation
A review was made of the transportation program to determine its adequacy
in meeting the planning criteria of NUREG-0654. The review included dis-
cussions with the Plant Health Physicist and Chemical and Radiation
Protection Technicians.
No vehicles have been identified for emergency use only.
It is understood
that during normal working hours, if an emergency occurs, the onsite vehicle
keys will be controlled by the Shift Supervisor. The keys will be routinely
controlled during backshift hours by the Shift Supervisor. Offduty Chemical
and Radiation Protection Technicians are instructed to use their personal
vehicles for offsite monitoring during an emergency.
If an emergency occurs
during severe weather, such as a snowstorm, there is an informal agreement
with the Charlevoix County Road Commission to supply Big Rock Point with
vehicles to perform offsite monitoring. All informal procedures are being
fo rmalized. There are presently two four-wheel drive vehicles onsite. The
results of the review indicated that the planning criteria of NUREG-0654 have
been met; however, the following items should be considered for improvement:
a.
All procedures including the use of privately-owned and county vehicles
during an emergency should be formalized.
b.
A procedure to control vehicle keys and their availability should be
established.
5.0 PROCEDURES
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures
The licensee has Off Normal Procedures (ONPs) and Emergency Procedures
(EMPs) in Volume 3C, " Operating Procedures." The ONPs deal primarily with
operation of the reactor systems and containment and the EMPs are special
procedures dealing with more serious occurrences. The inspectors reviewed
these procedures and found that most of them do not adequately interface
with the Emergency Plan Implementing Procedures (EPIPs). The ONPs and EMPs
that describe emergency conditions warranting the classification of the
event, do not direct the reactor operator to inform the Shift Supervisor of
a possible Emergency Action Level (EAL). The failure of procedures to
interface adequately with the EPIPs is a significant finding which could
lead to a failure to classify and report an event in a timely manner. The
following ONPs and EMPs, as a minimum, must require that the Shift Supervisor
be notified to classify the event and activate the Site Emergency Plan if
required:
ONP 2.4 - Loss of Containment Integrity
ONP 2.5 - Abnormal Radioactive Releases in Containment
ONP 2.17 - Abnormal Off-Gas or Stack Gas Release
ONP 2.10 - Loss of Feed Water System
ONP 2.33 - Abnormal Release of Radioactive Liquid
ONP 2.36 - Loss of Station Power
EMP 3.1 - Loss of D-C Power
EMP 3.3 - Loss of Reactor Coolant
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EMP 3.4 - Fuel Handling Accidents
EMP 3.7 - Earthquake
EMP 3.8 - Tornado
This section of the licensee's program is unacceptable and the following
action shall be taken to achieve an acceptable program:
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The EMPs and ONPs, as appropriate, shall contain statements
directing the Reactor Operator to inform the Shif t Supervisor of
a possible Site Emergency condition requiring classification.
5.3 Implementing Instructions
A review of the Licensee's implementing instructions was made to determine
their adequacy in assisting individuals in emergency detection, classifi-
cation and assessment.
The review included:
A review of appropriate sections of the Emergency Plan Implementing
a.
Instructions.
b.
Discussions with the personnel who would act as Site Emergency
Directors and Shift Technical Advisors.
The Licensee has written implementing instructions as part of the Emergency
Plan Implementing Procedures. The instructions and emergency action levels
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are written in the NUREG-0654 format using a " key word" (i.e. , Primary
Coolant System or Fuel Damage) method of classifying the event under each
of the four emergency classification categories.
The functional responsibilities are specified in the implementing procedures
for the Site Emergency Director, Shift Supervisor, Shif t Technical Advisor
and others of the staff. The immediate and subsequent actions as well as
the responsibilities of the Site Emergency Director which cannot be delegated
are clearly defined in EPIP 4A.
The findings for this section are presented in sections 7.1.1, 7.1.2 and
7.1.3 of this report.
5.4
Implementing Procedures
5.4.1
Notifications
A review was made of the licensee's procedures for notifications required
during emergencies to determine their adequacy in meeting the planning
standreds of Section E of NUREG-0654.
The review included discussions with the Shift Supervisors, Shift Technical
Advisors and the Plant Health Physicist and a review of EPIP 2 and
Attachments 2-1 and 2A, B, C and D.
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-The results of the review indicate these procedures address all of the
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areas required by~the criteria.
This portion of the Licensee's program is acceptable.
5.4.2
Assessment Actions (Meteorology)
7.1.4
Dose Calculations'Walkthroughs
7.1.9
Protective Actiod Decision Making Walkthroughs
The inspector reviewed the use'of meteorological data in plant emergency
procedures describing radiological assessment actions. The emergency plan
implementing procedures reviewed were individual-implementing procedures
for the Shift Supervisor (4B), Control Room Operator No. 2 (4E), and the
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Plant Health Physicist (4J) and the procedure for estimation of offsite
dose (SA).
Review of EPIP' 4B - The Shift Supervisor is instructed _ to delegate monitoring
of meteorological conditions. The monitoring of meteorological conditions is
apparently assumed by Control Room Operator No. 2 who implements EPIP 4E.
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Review of EPIP 4E - This procedure requires monitoring of instantaneous
readings of wind speed and wind direction from instrumentation located atop
the' turbine building. As discussed in Section 4.2.1.4, the_ location of the
meteorological instrumentation'is unacceptable as is the use of instantaneous
values to represent 15-minute averages. However, the meteorological informa-
tion required by this procedure is apparently not used in any procedures for
estimating plume location or offsite . doses. This procedure should require
the monitoring of 15-minute averages of wind speed, wind direction, and
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atmospheric stability considered representative of conditions at and near
the plant. This procedure should also be consistent with the procedure for
estimating offsite dose.
Review of EPIF 4J - This procedure requires the Plant Health Physicist to
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obtain offsite meteorological data through the weather Service International
System described in Section 4.2.1.4 for use in determining the radiological
impact of the emergency. However, the type of meteorological data to be
used in this procedure is somewhat different than the meteorological data
used in the procedure for estimating offsite doses. The reasons for the
differences are not clear. EPIP 4J should be consistent with EPIP 5A,
although EPIP 4J could include procedures for accessing historical and
forecast meteorological infonnation. EPIP 4J should include direct access
to atmospheric stability information.
b
Review of EPIP SA - Offsite dose projections are made utilizing offsite
meteorological information through the Weather Service International System
described in Section 4.2.1.4.
The-uncertainties associated with the use of
offsite meteorological data may be large, particularly with respect to plume
location. Uncertainties may be largest for estimating plume location and
,
s
offsite doses for releases through the plant stack.
s
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EPIP SA considers that calculated doses may be in a 67-1/2 sector (sector
of the indicated wind direction i one 22-1/2* sector). Because of the
uncertainties in wind direction measurements from offsite stations, the
sector of concern should be expanded from 67-1/2* to 111-1/2* until accept-
able onsite information is available. Because releases through the plant
stack will most probably be injected into the marine layer of air, an
elevated plume moving onshore will encounter a thermally-induced boundary
layer which defines the transition from marine airmass characteristics
(stable) to overland airmass characteristics (turbulent).
At- the point of transition, an elevated plume can be mixed rapidly to the
ground in a fumigation-type situation. EPIP 5A currently assumes that an
elevated plume released into a stable environment will travel 4 to 5 miles
inland before maximum groundlevel concentrations are experienced. However,
because of the aerodynamic roughness of the terrain in the vicinity of the
l
Big Rock Point Plant, maximum groundlevel concentrations from an elevated
I
plume may be experienced much nearer the plant.
Smoke tests performed at
the site in the early 1960's confirm the existence of this type of situation.
EPIP 5A should be revised to include calculation of maximum groundlevel con-
centrations for an elevated plume which fumigates to the surface within
several miles of the plant, because of the boundary layer between marine and
land air masses. Also, for the situations where an elevated plume remains
aloft, maximum dose rates may result from shine enroute, and not from
inhalation at the point of maximum groundlevel concentration.
Walk through reviews of dose calculations were conducted with selected Shift
Technical Advisors, Shift Supervisors, and Chemical and Radiation Protection
Supervisors. Demonstrations included activation of the Silent 700 computer
terminal, receipt of weather data f rom WSI, manipulation of the terminal, and
calculation of correct dose rates. The walk through reviews indicated that the
licensee's program for dose calculations and protective action decision making
appears to be acceptable.
5.5.2.1
Offsite Radiological Surveys
5.4.2.2
Onsite (out-of plant) Radiological Surveys
The Licensee's current set of emergency procedures do not include consolidated
f
procedut-s entitled "Offsite Radiological Surveys" or "Onsite (out-of plant)
)
Radiological Surveys."
The Licensee has agreed to prepare a consolidated set of procedures using
appropriate clernents of existing plant procedures.
Interviews with licensee staff members concerned with these surveys gave rise
l
to some observations. There is a need to provide adequate respiratory protec-
l
tion equipment for onsite survey team members.
Since high dose rates may be
I
encountere.1, the onsite survey procedures should include appropriate precau-
tions. The equipment kits for these surveys (currently stored in the Service
Building Annex) did not include radios. Radios should be required equipment
and frequent communication with the TSC should be specified in the procedure.
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These sections of the Licensee's program are unacceptable and the following
actions must be taken to achieve an acceptable program.
Prepare a procedure for "Offsite Radiological Surveys" and a procedure
.
for "Onsite (out-of plant) radiological surveys" for emergency conditions
.'
which include, as a minimum.
a
Common to both areas:
(1)
"How-to" steps for the persons performing the surveys,
including precautions to take, how to test the performance
of instrumentation, dose rate measurements, air sampling,
field assays, computations, communications with TSC, data
recording, routes to take, coordination with other survey
teams, how to report data to the TSC, where to store or
deliver airborne radioactivity samples for assaying, where
to return and remain on standby, etc.
(2) The desirability of including an inventory list of all items
needed, including good, legible maps appropriate for each team
involved, and forms for ready entry of data by the surveyors.
(3) Emphasis should be placed on having as much as possible in
readiness, rather than relying on "ad hoc" instructions and
provisions.
(4) Consideration should be given to providing full face
respirators with charcoal filters to team surveyors.
Reliance on KI tablets to provide adequate protection
from internal exposure should be discouraged.
b
For Onsite (out-of plant) Radiological Surveys:
(1) Provisions for adequate respiratory protection.
(2) Precautions for coping with high dose rates.
(3) A description of the importance and relationship of offsite
measurements to dose assessment and subsequent decision making.
(4) The desirability of having offsite survey teams composed of
two persons, rather than one.
5.4.2.3
Inplant Radiological Surveys
A review was made of the inplant radiological survey program to determine
its adequacy in meeting requirements of NUREG-0654. The review included
discussions with the Plant Health Physicist, Chemical and Radiation Pro-
tection Supervisors, and Chemical and Radiation Protection Technicians.
Emergency Plan Implementing Procedure EPIP 5C and Radiation Protection
Procedure RP 29 were reviewed. Calibration procedures and records of
inplant radiological surveys were also reviewed.
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The above reviews indicated that the licensee's program for inplant radio-
logical surveys appears to be acceptable.
5.4.2.12
Radiological and Environmental Monitoring Program
7.2.8
Offsite Environmental Sampling and Analysis Walkthroughs
A review was made of the program for radiological and environmental monitoring
to determine its adequacy in meeting requi.:ements of NUREG-0737. The review
included discussions with the Plant Health Physicist, Chemical and Radiation
Protection Supervisors, and the Environmental Sampling Contractor. Emergency
Plan Implementing Procedure EPIP 5F and Radiation Protection Procedure RP 32
were reviewed.
Pertinent training records were also reviewed.
The reviews of procedures and records indicate that the licensee's procedures
for radiological and environmental monitoring are acceptable.
A walkthrough review of environmental monitoring procedures was conducted
with the Environmental Sampling Contractor. The Contractor demonstrated a
thorough knowledge of applicable procedures.
Sampling and monitoring
equipment, supplies, procedures and data forms were readily available.
In
short, the Contractor demonstrated a very good state of preparedness and this
section of the licensee's program is acceptable.
5.4.3
Protective Action
5.4.3.1
Radiation Protection During Emergencies
l
A review was made of the program for radiation protection during emergencies
'
to determine its adequacy in meeting the planning criteria of NUREG-0654.
Emergency Plan Implementing Procedures EPIP 4J, 4M, 4AA, SC, 5F, 6G and 6H,
I
Radiation Protection Procedure RP 29, and Calibration Procedures and records
l
were reviewed.
The review included discussions with the Plant Health Physicist and the
!
Chemical and Radiation Protection Supervisors.
The results of the above review and discussions indicated that the
Licensee's program for radiation protection during emergencies is
acceptable.
5.4.3.2
Evacuation of Owner-controlled Areas
A review was made of Emergency Plan Implementing Procedures EPIP 6A and 6B
for evacuating owner-controlled areas to determine their completeness and
effectiveness, discussions with Security Personnel and other plant personnel
and walkthroughs of plant personnel regarding their response to an evacuation
announcement.
The reviews indicated that personnel know the primary and secondary evacuation
s
'
routes.
However, evacuaton routes in the plant are not " clearly marked with
0
conspicuously posted arrows, signs, floor markings or other readily visible
means."
There are no copies of pre-established, " concise oral announcements"
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as specified in the audit criteria. Further, Implementing Procedures do not
establish action levels for site evacuation. The public address system inside
containment cannot be clearly understood at all times. Visible alarms were
not present in each high level noise area.
The results of this review indicated that the planning criteria of
KUREG-0654 have been met; however, the following items should be considered
for improvement:
Provide visible alarms in all high noise areas.
.
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Establish written action levels (Site Area or General Emergency) for
.
evacuation as per NUREG-0654.
Clearly mark and/or identify evacuation routes, primary and secondary,
'
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inside and outside of the facility.
Prepare concise oral announcements for evacuation of the protected area.
.
5.4.3.3
Personnel Accountability
>
A review was made of the plans for personnel accountability to determine if
the procedures:
a.
provided for identifying missing individuals within 30 minutes,
b.
specified the individual or position to whom reports of accountability
are made,
c.
had a means to find missing individuals, and
d.
had provisions for continuous accountability.
The review included Emergency Plan Implementing Procedures 4R and 6A and
discussions with the Property Protection Supervisor, the Burns Security
Lieutenant and Burns Security officers. The Lieutenant and officers were
presented with three scenarios and asked to describe their actions for each.
The results of the review indicated that each individual was aware of what
actions should be taken.
Personnel accountability is performed primarily by visual contact.
If
individual (s) are discovered missing, the Site Emergency Director or his
designee shall direct the property Protection Supervisor to contact the
.'
individual's supervisor to determine the individual (s) last known location.
If unknown, they contact the assembly area leaders to attempt to determine
the last known location. Security, then, immediately starts checking card
reader print-outs in the Central Alarm System (CAS) or the Secondary Alarm
System (SAS). The following items were corrected by the licensee during the
appraisal:
Written procedures for the actions that should be taken by the
.
individual at each guard post during an emergency were provided.
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The officers were familiarized of the time constraints for account-
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ability of personnel.
The results of the review indicate that this portion of the licensee's
program appears acceptable.
5.4.3.5
Onsite First Aid / Rescue
A review was made of onsite first aid / rescue procedures to ensure that they
meet the requirements of 10 CFR Part 50 Appendix E and the criteria specified
in NUREG-0654, K.1, L.1 and L.2.
The review included discussions with the
Plant Health rhysicist and a review of Emergency Plan Implementing Procedure 6E.
The procedure states that lifesaving first aid should be administered prior to
attempts at decontamination.
It also describes the methods of transporting
and handling injured persons who may be contaminated and the criteria for using
the offsite medical facility. A Chemical and Radiation Protection Technician
would accompany the victim to the hospital. This Technician would assist in
radiological monitoring and contamination control in the ambulance and/or
company vehicle used for transportation and during medical treatment of the
victim in the hospital. Plant personnel are required to assist the ambulance
and hospital in decontaminating their areas and equipment and disposing of
waste after treatment is completed.
The Licensee provides training in American Red Cross Multimedia First Aid so
that at least one person having this training is onsite at all times. The
training program for first aid appears to be adequate.
Results of this review indicate that this portion of the Licensee's program
is acceptable.
5.4.4
Security During Emergencies
The inspectors interviewed the Property Protection Supervisor who stated that
during an emergency the Big Rock Point Security Plans are activated. These
security plans and the Big Rock Point Site Emergency Plan have been written
to complement each other. Both plans are formally reviewed once a year for
updating, correcting and ensuring proper interfaces.
In addition, the Property
Protection Supervisor and the Plant Health Physicist / Emergency Planning
Coordinator are in daily contact to ensure a proper interface.
The results of the review indicate that the Licensee's program appears to
be acceptable.
5.4.5
Repair / Corrective Actions
Repair and corrective actions are not specifically addressed in the
Emergency Plan Implementing Procedures. Repair and corrective actions
will be directed by the Maintenance Superintendent.
There is no specific
procedure in the EPIP which addresses safety considerations for repair or
corrective action teams. The proceduras followed are their normal operating
procedures for repair and maintenance.
These teams would normally be accom-
panied by a Chemical and Radiation Protection Technician, who is under the
direction of the Plant Health Physicist. The Plant Health Physicist is
ultimately responsible for radiation protection of each task.
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This portion of the Licensee's program appears to be acceptable.
5.4.6
Recovery
A review was made of the Licensee's recovery procedures and EPIP 6C to
determine their adequacy in meeting the planning standards of NUREG-0654.
The results of the review indicated that the organizational authority for
declaring the recovery phase is identified, evaluations of plant operating
conditions and inplant and out-of plant radiological conditions are provided
for, and key positions in the recovery organization are identified. This
portion of the Licensee's program is adequate.
'
5.4.7
Public Information
A review was made of the procedures to be used in dissemination of information
to the public in the event of an emergency to determine their acceptability
under the planning standards of NUREG-0654.
The review of this area included discussion with the Public Affairs Director
and a review of the Nuclear Plant Emergency Public Information Policy and
Procedures.
The results of the review indicate the above procedures meet all of the
required criteria and that a public information program for the adult
permanent and transient population has been established within the five
mile EPZ.
This portion of the Licensee's program is adequate.
5.5 Supplementary Procedures
5.5.2
Drills and Exercises
The inspectors reviewed this segment of the Emergency Plan Section 9.8.1.2
and related Implementing Procedures, Sections 5.4 and 5.7.
Drills and
exercises are scheduled and planned by the corporate level Emergency Planning
Coordinator in cooperation and coordination with plant management. At the
plant level, the Emergency Planning Coordinator (Plant Health Physicist) is
responsible for ensuring that training for emergency preparedness, including
emergency drills and exercises is carried out.
Development of scenarios
prior to conducting drills and exercises, is the responsibility of the
Corporate Emergency Planning Coordinator. Documentation and evaluation of
both observer's and participant's comments are included as part of these
drills and exercises. Recommendations for improvement of the Plan and
Implementing Procedures are forwarded to the Site Emergency Planning
Coordinator for review and follow-up action.
Implementation Procedure 6.I Section 5.4.3 specifies that communications
drills to test the capability to warn the public are conducted annually
with State and local EOCs within the ingestion pathway. This section
states that communications are tested monthly with State and local govern-
ments within the EPZ. Emergency medical drills (relating to first aid and
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decontamination) and radiological monitoring drills are conducted annually
which test the integrated capability and major portions of the basic
elements within the plan and of the emergency organization.
Offsite agencies and groups having Letters of Agreement with the Big Rock
Point Plant are invited to participate in both drills and exercises. Pro-
visions under Section 9.8.1.2 of the Site Emergency Plan provide for these
to be done within a five-year period to test completely the plans and the
emergency preparedness organizations.
The results of the review indicated that procedures for Drills and Exercises
are adequate.
5.5.3
Review, Revision, and Distribution
Proposals for significant changes to the Site Emergency Plan or Implementing
procedures are required, by Section 9.8.3.1 of the Site Emergency Plan, to be
reviewed by the Plant Review Committee. The changes are then implemented by
submitting them to the Plant Superintendent. Proposals for significant
changes may result from:
deficiencies detected as a result of drills, changes
in key personnel, changes in the plant's organizational structure, changes in
the functions of supporting agencies, changes in Federal or State Regulations,
plant modifications, recommendations received from other organizations, changes
in construction or operating status, or changes in emergency assignments
affecting offsite support agencies.
Telephone list modifications are considered minor changes and, as indicated
in Section 9.8.3.3 of the Site Emergency Plan, are verified and updated as
required on a quarterly basis.
The Emergency Planning Coordinator is responsible for initiating the complete
annual independent review of the Site Emergency Plan and Implementing Procedures.
i
The results of the review determined that this part of the licensee's program
is adequate.
5.5.4
Audit
A review was made of the requirements for conducting reviews and audits of
emergency planning activities in accordance with Technical Specification
(T.S.) 6.5.2.9d and 10 CFR 50.54(t). The Quality Assurance (QA) Department
conducts audits of the Facility Emergency Plan and Implementing Procedures
at least once per two years pursuant to T.S. 6.5.2.9d.
The audit report
,
and results of actions to correct deficiencies are reviewed by the licensee's
Safety and Audit Review Board. Section 9.8.3.4A of the Emergency Plan states
that an independent review of the Preparedness Program will be conducted
annually by a competent organization, either internal or external to CPCo.,
which is not immediately responsible for the program. Discussions with the
Emergency Plan Coordinator indicate that the Quality Assurance Department
has been selected as the independent organization to conduct the annual
review and audit. Significant findings are:
(1) The Technical Specifi-
cations 6.5.2.9 requires a 24-month frequency for audit while the plan,
Section 9.8.3.4A, requires a 12-month frequency.
(2) There is no EPIP
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for audit of the emergency plan in Volume 9A. The licensee's QA Department
conducted an audit of emergency planning, environmental monitoring, and
radiological material control programs on August 17-21, 1981, as described
in Audit Report No. A-QT-81-8, dated October 15, 1981. Most of Emergency
Preparedness audit observations have been corrected.
The audit of emergency planning involved assessment of the implementation
of the Emergency Plan, observation of activities and review of records.
This item of the Licensee's emergency preparedness program is acceptable;
however, the following recommendations were made.
Change Technical Specification 6.5.2.9d to require a 12-month audit
.
frequency to coincide with the Emergency Plan Section 9.8.3.4A.
Implement the Emergency Preparedness audit program described in the
.
Emergency Plan by developing an implementing procedure or refer to
the QA program procedure.
.
l
The licensee, during the course of this appraisal, corrected these problems;
therefore, this item is acceptable.
8.0 Persons Contacted
Big Rock Point /Consumera Power Company Employees
Abel, C. R. - Big Rock Point, Operations and Maintenance Superintendent
- Alexander, R. J. - Big Rock Point, Shift Technical Advisor
- Axtell, C. E. - Big Rock Point, Plant Health Physicist
Bichel, R. - Big Rock Point, Shift Technical Advisor
Bielinski, M. J. - Big Rock Point, Shif t Technical Advisor
- Blanchard, D. P. - Big Rock Point, Probabilistic Risk Assessment
- Buckman, Fred - Consumers Power Company, General Office
Burdette, R. - Big Rock Point, Health Physicist Supervisor
Dafoe, Glen - Big Rock Point, Property Protection Supervisor
DeMitchell, E. R. - Consumers Power Company, General Office, Training
Records Clerk
- DeMoor, Don E. - Big Rock Point, Technical Engineer
- Dickson, Mike - Big Rock Point, General Health Physicist
- Donnelly, P. M. - Big Rock Point, Activities Operations Superintendent
Fox, Gill - Big Rock Point, Chemistry and Radiation Protection Supervisor
Fugere, Dave - Consumers Power Company, General Office
Garrett, Bob - Big Rock Point, Health Physicist Technician
- Hartman, C. J. - Big Rock Point, Plant Superintendent
Hoaglund, Bill - Big Rock Point, Radiation Chemistry Technician
- Hoffman, David - Consumers Power Company, Licensing
- Jury, Milton J. - Consumers Power Company, Emergency Planner
- Krchmar, R. L. - Consumers Power Company, General Office, Quality Assurance
Analyst
- Loomis, P. B. - Big Rock Point, Public Affairs Director
McNamara, Ed - Consumers Power Company, General Office, Training Supervisor
- Miller, William W. - Consumers Power Company, General Office, Emergency Planning
Pence, T. K. - Big Rock Point, Shift Supervisor
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- Popa, John - Big Rock Point, Maintenance Supervisor
- Raciborski, E. W. - Consumers Power Company, General Office, Quality Assurance
Superintendent
- Schrader, R. E. - Big Rock Point, Technical Superintendent
Sevener, A. C. - Big Rock Point, Operations Superintendent
- Sinderman, Roger - Consumers Power Company, General Office, Health Physicist
Swem, D. L. - Big Rock Point, General Engineer
Trubilowicz, W. - Big Rock Point, Shift Supervisor
Warner, J. J. - Big Rock Point, Property Protection Operations Supervisor
In addition to the above employees, several Burns Security Officers were
interviewed regarding their tasks in an emergency.
- Denotes those present at exit interview.
Non- Big Rock Point and Consumers Powers Company Employees
Bosa; Kathryn - Charlevoix Area Hospital, Patient Services Manager
- Coffey, Rebecca B. - Cleveland Electric Illuminating Company
Curtis, John - Charlevoix City Fire Department, Chief
Foster, John G. - U.S. Coast Guard Station, Charlevoix Officer-in-Charge
Crant, William B. - Nuclear Regulatory Commission, Region III
- Hulbert, Dan D. - Cleveland Electric Illuminating Company
Jackson, Jan - General Physics Corporation, Contractor
Kosnik, Dr. T. - Northern Michigan Hospital, Petoskey Medical Physicist
Krueger, R. L. - Charlevoix Area Hospital, Administrator
- Lovell, J. R. - Midland Power Plant, Health Physicist
- Paperiello, C. J. - Nuclear Regulatory Commission, Region III
Paul, Jerry - Charlevoix Township Fire Department, Chief
Pennell, C. - Petoskey Fire Department, Chief
Smith, Carole - Northern Michigan Hospital, Petoskey Emergency Room Supervisor
- Denotes those present at exit interview.
9.0 Previous Inspection Finding
a.
(Closed) 80-07-01:
Emergency equipment kits should contain additional
equipment. During the Emergency Preparedness Inplementation Appraisal
(155/81-17) the emergency equipment kits were examined and found ac-
ceptable.
b.
(Closed) 81-09-02: Licensee should check equipment in emergency kits
with list of equipment in Emergency Plan.
Appraisal (155/81-17) found kits to be acceptable.
10.0 Exit Interview
The inspectors and NRC Region III management met with licensee representatives
(denoted in Paragraph 8) at the conclusion of the appraisal on December 9, 1981.
The scope of the appraisal and appraisal findings were summarized at the meeting.
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