ML20054D063
| ML20054D063 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/02/1982 |
| From: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Dewitt R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| Shared Package | |
| ML20054D064 | List: |
| References | |
| NUDOCS 8204220296 | |
| Download: ML20054D063 (6) | |
See also: IR 05000255/1982003
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April 2, 1982
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Docket No. 50-255(DEPOS)
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Consumers Power Company
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ATIN:
Mr. R. B. DeWitt
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Vice President
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Nuclear Operations
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212 West Michigan Avenue
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Jackson, MI 49201
Gentlemen:
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This refers to the routine safety inspection conducted by Messrs. W. L. Axelson,
S. Rozak, M. Schumacher and Ms. N. Nicholson of this office on February 22-23,
and March 5, 1982, of activities at Palisades Nuclear Power Plant authorized
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by NRC Operating License No. DPR-20 and to the discussion of our findings with
Mr. R. Montross, M. Jury and others of your staff at the conclusion of the
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inspection.
The enclosed copy of our inspection report identifies areas examined during
the inspection. Within these areas, the inspection consisted of a selective
examination of procedures and representative records, observations, and
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interviews with personnel.
No items of noncompliance with NRC requirements were identified during the
course of this inspection.
We are concerned with the method of scenario development and of exercise
guidance currently used by your staff.
Several problems encountered during
this exercise were directly rela..ed to scenairo deficiencies, inadequate
management provided to your controllers, inadequate management of the
Operations Support Center, and inadequate activation of the Emergency
Operation Facilities. These deficiencies are listed in the enclosed
Appendix A.
You are requested to submit a written statement within
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thirty days of the date of this letter describing your planned actions for
improving each of the items identified in Appendix A.
This description is
to include:
(1) steps which have been taken; (2) steps t hsch will be taken;
and (3) a schedule for completion of actions for each item.
In the future, we expect your staff to follow the provisions of FEMA
Guidance Memorandum No. 17, Joint Exercise Procedure, which provides for
scenario development and approved by NRC and FEMA.
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We highly recommend that your staff conduct several practice inhouse
excercises prior to your next annual exercise with NRC and FEMA observers.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of
this letter, the enclosures, and your respons.s to this letter will be placed
in the NRC's Public Document Room.
If this veport 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 (.1) actify this office by tele-
phone 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 information.
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 estab-
lished. Consistent with Section 2.790(b)(1), any such application must
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be accompanied by an affidavit executed by the owner of the information
which 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 infdrmation 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.
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Consumers Power Company
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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.
We will gladly discuss any questions you have concerning this inspection.
Sincerely,
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. Hin , Director
1e Division of Emergency Preparedness
and Operational Support
Enclosures:
1.
Appendix, Exercise
Deficiencies
2.
Inspection Report No.
50-255/82-03
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D, J. VandeWalle, Nuclear
Licensing Administrator
R. W. Montross, Manager
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Ronald Callen, Michigan
Public Service Commission
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Appendix'A
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Exercise Deficiencies
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1.
Scenario Development and Approval (50-255/82-03-01)
a.
The scenario for the Palisades exercise was non-mechanistic and
provided no challenge to the operations, maintenance or technical
staff. Very little technical data other than some radiological
data was provided to the emergency organization. The TSC staff,
particularly the plant operations assessment and plant system
engineering, repair and corrective actions groups, were not
exercised.
b.
Scenario development and approval process did not follow FEMA
Memorandum Guidance No. 17.
c.
Exercise controllers were not provided proper instructions and
guidance relevant to their roles during an exercise.
2.
Emergency Facilities, Equipment and Supplies (50-255/82-03-02)
a.
The Technical Support Center was overcrowded and is inadequate
to support and manage an emergency organization over an extended
period of time.
Insufficient space for status boards or data
acquisition was provided.
If this had been a real emergency,
the emergency organization would have relocated to the Control
Room to manage the emergency.
-b.
The Operations Support Center was poorly managed primarily due
to inadequate facilities and equipment. .The general noise level
interferred with the OSC coordinator's ability to communicate.
No status board was available for the OSC. The PA system was
barely audibic in the OSC.
Equipment controls for radios and
radiation monitoring did not exist. Contaminated instruments
were brought into the OSC lunchroom,
c.
High range effluent monitor readouts located in the TSC were
inadequately labeled. Each monitor was marked with an A or B
causing confusion regarding which detector was for the stack
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and which for the steam dump monitor.
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d.
High range pocket dosimeters and potassium iodide were not issued
or their need considered for OSC personnel.
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Remote handling tools were not used for post-accident sample
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dilution of the primary coolant sample.
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Appendix
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f.
The interim EOF in Jackson, Michigan, does not have an organiza-
tion chart and sign-in chart, which is highly visible to all
participants to ensure timely activation of the EOF.
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g.
Offsite survey teams were provided with inadequate survey maps
which were too small and lacked sufficient details
i.e.,
side
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roads, landmarks, etc.
h.
Communications capability with the site environs teams does not
exist in the interim EOF in Jackson, Michigan.
3.
Training of the Site and Corporate Emergency Organization (50-255/82-
03-03)
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a.
EOF staff personnel did not appear to be fully aware of their
roles, tasks, and location in the EOF.
Periodic updates were
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not given to the staff from the EOF Director. The interim EOF
was not activated in a timely manner.
b.
Self Contained Breathing Apparatus were not always used for
inplant post-accident sampling.
Some participants used full
face respirators. The maximum respiratory protective factor
should be utilized until extensive inplant survey results are
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conducted and analyzed.
c.
Inexperienced and untrained health physics technicians were dis-
patched to high radiation areas to perform critical tasks.
d.
The EOF Director initially went to the site TSC.
He never
established full licensee command and control authority at the
South Haven EOF.
c.
The Site Emergency Director was not involved in the decision
to allow emergancy worker exposure limits to 25 rems.
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4.
Emergency Plan Implementing Procedures (50-255/82-03-04)
a.
Protective measures procedures do not provide for full radial
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cvacuation or sheltering as a minimum for the first two miles
around the facility.
Instead, only three sector evacuation was
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recommended. This is inconsistent with the State of Michigan,
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Appendix
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b.
Public address announcements relevant to critical changes in the
emergency status were not made in a timely manner and as a result
of that-OSC personnel were not kept' informed relevant to changing
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conditions in the emergency.
In general, the OSC coordinator
procedure does not provide sufficient information in order for
him to manage the OSC (i.e., personnel exposure control, status
updates, equipment controls, habitability monitoring, and per-
sonnel inventory for dispatching for emergency tasks.)
c.
Trending of critical parameters was not conducted in the TSC.
However, the scenario did not provide sufficient data to be
trended. Nevertheless, even the data provided was not trended.
d.
Interim EOF procedures have not been submitted to NRC in accord-
ance with Appendix E to 10 CFR 50.
e.
Primary coolant sample dilution was not conducted in the chemistry
hood.
f.
No checks were periodically made of personel dosimeters for
people in the TSC/ control room area.
g.
Obtaining forecasting information regarding meteorological
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changes was not implemented oy the EOF staff.
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