IR 05000155/1997003

Insp Rept 50-155/97-03 on 970331-0404.No Violations Noted. Major Areas Inspected:Emergency Preparedness Program

ML20141D611
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	05/13/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141D593	List: IR 05000155/1997003 ML20141D589
References
50-155-97-03, 50-155-97-3, NUDOCS 9705200154
Download: ML20141D611 (13)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lli

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Docket No: 50-155 License No: DPR 6 l

Report No: 50-155/97003(DRS)

l Licensee: Consumers Energy l

Facility: Big Rock Point Location: 10269 U.S. 31 North Charlevoix, MI 49720 Dates: March 31 - April 4,1997 Inspectors: Robert D. Jickling, Emergency Preparedness Analyst James E. Foster, Sr. Emergency Preparedness Analyst Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety l

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9705200154 970513 5 PDR ADOCK 0500

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EXECUTIVE SUMMARY l Big Rock Point NRC Inspection Report 50-155/97003 ,

This inspection included a review of the Emergency Preparedness (EP) program, an aspect of Plant Support. This was an announced inspection conducted by two regional emergency preparedness analyst The emergency preparedness program was effective in maintaining the operational readir.ess of your emergency response facilities, equipment, and personnel. Emergency response facilities, equipment, and supplies were in a very good state of operational readiness. Interviews with emergency response personnel demonstrated very good knowledge of emergency implementing procedures and responsibilities. Management i support had been strong and no unfavorable changes were identified.

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• The overall effectiveness of the licensee's emergency preparedness facilities, equipment, training, and organization was very good. (Sections P2.1, P3, PS, and P6)

• Licensee personnel performed conservatively during actual activations of the Emergency Plan and provided timely notifications to offsite agencies. (Section P1.1)

• The emergency response facilities were well maintained and in very good material condition. (Section P2.1)

Interviews with key emergency response organization personnel demonstrated very good knowledge of the emergency implementing procedures and their responsibilities. (Section P5)

• Quality assurance oversight of the EP program was good and included a low threshold for identifying issues. (Section P7)

• The inspectors completed Temporary instruction 2515/134 "Onshift Dose Assessment Capabilities" and verified that the licensee's capabilities met requirements. (Section P9)

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Report Details l

E IV. Plant Suncort P1 Conduct of Emergency Preparedness (EP) Activities P1.1 Actual Emeroency Plan Activations

i Insoection Scone (8270U -

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The inspectors reviewed records and documentation packages regarding plant l response for three actual emergency events which occurred Ating 1996.

. Q)servations and Findinas

An Unusual Event was declared at 8

25 p.m. on February 29,1996, due to a small

! fire on the turbine deck. The fire (possibly due to an oil soaked rag falling on a

piece of insulation) occurred in a narrow gap several feet below the front end

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turbine stand. The fire was identified at '7:45 p.m., extinguished at approximately i

7:55 p.m., and the Shift Supervisor was advised the fire was extinguished at 8:05 p.m. Due to the fire lasting approximately ten minutes, an Unusual Event was

.i declared per emergency implementing procedure EPIP-1, " Activation of the Emergency Plan." The event was terminated at 10:36 p.m.

} The licensee's review of the event identified that the sequence of emergency-I notifications made to offsite agencies was ir correct. After the State of Michigan was called, notifications were made to the NRC instead of the county. Although notifications were conducted out of sequence, the offsite agencies were notified within the required time An Unusual Event was declared at 11:00 a.m. on May 3,1996, due to a partial loss of commercial and dedicated communications lines. At approximately 8:15 a.m., control room personnel identified failures of the telephones and declared the telephone systems inoperable at 8:30 a.m. Non-emergency notifications were made to the NRC at 9:00 a.m. and the State of Michigan at 10:15 a.m. At 10:51 a.m., the site was informed by Ameritech that a fiber optics cable had been severe At the time of this event, the Big Rock Point Emergency Plan and Emergency Plan Implementing Procedures (EPIPs) did not include an Emergency Action Level (EAL)

for loss of communications capability. Discussions with personnel at the Palisades plant indicated that Palisades and other facilities had EALs for loss of communications. Concerns were identified regarding the inability to notify local agencies for emergency conditions and the inability to callout emergency response organization (ERO) personnel to augment shift staffing during an emergency. The decision was made by management to classify the event as an Unusual Event and notify accordingly, in response to this incident, two cellular telephones were used from the Shift Supervisor's office and additional cellular phones were delivered to the site. Plant

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personnel were also sent to the Emergency Operations Facility (EOF) to establish communications links with offsite agencies. The event was terminated at 1:42 l p.m. when service was restored. Additional actions taken included revision of EPIP-1, " Activation of Emergency Plan," dated November 19,1996, to include a loss of offsite communicdons EAL.-

An Unusual Event was declared at 11:00 p.m. on October 27,1996, due to a

threatening telephone call. - Three consecutive telephone calls were made to the j control room with the last call containing a vague threat. The Unusual Event was i terminated at 1

05 a.m. on October 28,1996, when no further calls were receive The thres events had been reviewed and detailed packages were compiled by the  !

} Emergency Preparedness (EP) Supervisor to docums:nt the reviews. The review

packages contained descriptions of the events, ar,sessments of the adequacy of the

, response, observations, and recommendations. ,ilthough the licenes did not have l a procedure for assessing and documenting resocnse to actual emergency plan i l activations, the event review packages were detailed, comprehensive, and i appropriately distributed to licensee managemen Conclusions i

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The inspectors concluoed that the licensee had conservatively implemented the emergency plan in declaring three Unusual Events. The EP Supervisor's reviews of i the events were detailed, comprehensive, and well doc. mnted.

i P2 Status of EP Facilities, Equipment, and Resources I

i j P Material Condition of Emeroency Resoonse Facilities insoection Scone (82701)

The inspectors evaluated the material condition of the Control Room, Technical

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Support Center (TSC), Operations Support Center (OSC), and EOF. The offsite

! - team kits were also inspected. The licensee demonstrated the operability of

numerous pieces of equipment, including survey equipment, communications

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/ Observations and Findinas

Current copies of the EPIPS were available in the Control Room and Shift Supervisor's office. The TSC and associated kits were in excellent material condition. Status boards and equipment were in a state of readiness. The OSC I was in good material condition and status boards were readily located under the stairs. The specific location for storage of OSC status boards had been incorporated into the EPIPs and reenforced during training drills to correct an issue identified during the 1996 EP exercise. The EOF was in very good material condition. The dose assessment computers and printers were verified operable and communications systems were functional. Offsite team kit instruments and equipment were calibrated, functional, and in very good order. Several minor

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procedural inconsistencies identified by the inspectors were immediately corrected by the EP Superviso l Records for the early warning sirens for 1996 were reviewed by the inspector Reported annual operability for 1996 was 99.3 percent, with 92 percent for the lowest month's average. Siren operability exceeded the acceptability limit of greater than or equal to 90 percen c. Conclusic it l Overall, the emergency response facilities were in very good material condition.

l Several minor procedural inconsistencies were immediately corrected by the EP l supervisor. Numerous instruments and equipment were demonstrated and found to i be functional. The emergency warning sirens had been appropriately maintaine . P3 EP Procedures and Documentation l

i a. Inspection Scone (82701)

The inspectors reviewed a selection of licensee emcrgency procedures and EPIPs.

i Condition Reports (CRs) assigned to the EP Supervisor were also reviewed. EPIPs and emergency plan sections reviewed including Emergency Plan Chapter 8,

! Revision 123, " Maintaining Emergency Preparedness," EPIP-61, Revision 163,

" Training and Drills," EPIP EOF-7, Revision 9, " Health Physics," EPIP-3C, Revision 163, " Activation of the EOF," EPIP-38, Revision 175, " Activation of the OSC," and EPIP-4A, Revision 167, " Site Emergency Director."

b. Observations and Findinas EPIP-3B had been revised to include the s't: race locctinr fer OSC status boards, and designate an alternate location (access control) for the OSC if the primary OSC (machine shop) and secondary location (compressor room) were unusable. The procedure appropriately included arrangement diagrams for the various facilities when utilized as an OS Discussion with the EP Supervisor indicated that the State of Michigan was working with the nuclear power plants in the state to develop and implement a new Protective Action Recommendations format. The new format woulel utilize I

subareas rather than affected sectors and would facilitate local govsrnment determination of areas to be evacuated or sheltered, using geopolitical boundarie l The inspectors reviewed several EP related CRs in various stages of completio l Two of the CRs reviewed included inspection followup items from the 1996 EP )

exercise and differences between Palisades and Big Rock Point's EALs to determine i any changes that were necessary. The tracking system effectively identified l responsible individuals, due dates, and current status.

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l Conclusions

The EPIPs were clear and easy to use. The CR system was effective fc assigning

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responsibility, tracking, and closing EP related issues. No problems were identified in the procedures or documents reviewe '

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Pfi Staff Trainlag and Qualification in EP l Insnection Scone (82701)

The inspectors reviewed the licensee's EP training program. This included ,

intervi6ws with selected key individuals, training attendance records, and the  !

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" Telephone List For TSC/OSC/ EOF Activatica For March 1997." Additionally, selected training instructor's guides were reviewed, including N00108, Revision 5,

" Emergency Dose Assessment."

! Observations md Findinas

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j interviews with key emergency response organization personnel indicated very good  ;

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knowledge of emergency procedures and responsibilities. Good knowledge related '

to the NRC's and Department of Energy's incident response was demonstrated by

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i the Site Emergency Director (SED). Federal incident response information had been

incorporated into the licensee's Emergency Plan, training lesson plans, and a i memorandum that issued to the EOF directors, and SEDs at the sit '

l Training records compared to the activation telephone list indicated all ERO

. personnel reviewed were currently qualifie Discussion with the EP Supervisor indicated that new quarterly drills and tabletop

training had been conducted. Additionally, the SEDs had participated in licensed

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operator requalification simulator training. Operations personnel provided positive feedback to the EP Supervisor on this trainh Conclusions I Overall, EP training was considered very good. Critique documentation was available and critique forms were adequately detailed. Training records were complete and interviewed individuals were knowledgeable about their ERO responsibilitie P6 EP Organization and Administration (82701) Insoection Scone (82701)

The inspectors and EP staff discussed the current station organization and reviewed then current organizational char . - . --

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rha Emergency Preparedness Supervisor now reported to the Plant Manager, who reported to the General Manager, who reported to the Senior Vice President of d

Generations. Discussion with the EP Supervisor indicated that management support I for the EP program was excellent under the past and current plant organizat'.o l

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Due to recent organizational changes, Site Emergency Plan (SEP), Chapter 5, 1

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Revision 126, Figure 1, " Big Rock Point Plant Organization," was no longer curren i The inspectors discussed the figure with EP personnel and determined that a

revision was in proces

Support for some aspects of the Big Rock Point Emergency Preparedness program )

was supplied by EP personnel from the Palisades plant. A Big Rock Point / Palisades EP Support Agreement Specification provided details of which aspects of the

program will be performed by Palisades personnel. One example of provided

support was that annual reviews of the Site Emergency Plan were assigned to Palisades personnel.

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. Management support to the EP program continued to be strong. A significant support agreement had been finalized with Palisades plant EP personnel which-

provided needed assistance for specific EP responsibilities.

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P7 Quality Assurance in EP Activities

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i P Audits (82701)

Insoection Scone (82701)

The inspectors reviewed Quality Assurance Department Audits which have been performed since the last routine inspectio Observations and Findinas 3-The inspectors reviewed Nuclear Performance Assessment Department (NPAD)

g report PA-96-04, Big Rock Point Emergency Preparedness Audit, dated May 10, i j 1996. This audit was conducted by two auditors during March 25-29,199 i l Also reviewed was NPAD report NPAD/P-96-018, State and Local Government

Emergency Preparedness Interfaces," issued January 13,1997. This audit was 1

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performed during December 16-20,1996. The audit concluded that the emergency preparedness program was effectively implemented.

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J The inspectors also reviewed NPAD Field Monitoring Report FM-B-96-164,  !

I documenting evaluation of the Big Rock Point 1996 exercise controller's briefin !

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At the time of this inspection, the 1997 BRP Emergency Planning Audit had been completed, but the report had not been finalized. An audit debriefing had been held

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o j on March 21,1997. A summary of the audit debriefing meeting indicated that the

assessment was that the program continued to be effecuvely implemented.

Interfaces with offsite authorities were good. Two open items were opened -

regarding a procedure update and emergency kit inventory deficiencies, and one

, cono'+ ion report was open regarding corrective actions on medical drill deficiencies.

Conclusions

! The licensee's 1996 audits of EP sctivities were effective and satisfied the requirements of 10 CFR 50.54(t).

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P8 Miscellaneous EP issues

! ) (Closedl Insoection Follow-un item 50-155/95008-04: Federal incident response ,

l information needed in training. This item is close '

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(Closed) Insoection Follow-un item 50-155/96007-03: Unable to locate OSC status l boards. All OSC boards were relocated to the stairs in the ma2ine sho Discussion indicated that this location was reviewed with exercise participants during a February 18,1997 OSC drill. OSC status boards were readily located

under the stairs as indicated in the OSC procedure. Thia item is closed i

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j (Closed) Insoection Followun item 50-155/95008-05: Resolution of Meteorological i

tower inaccuracies. Condition Report C-BRP-95-309 was written to track identified

meteorological tower inaccuracies (plant stack effects). It was determined that the

! current meteorological instrumentation, in conjunction with weather information I

! from Pollston, MI, provided the most accurate meteorological information for the j site. As the wind direction could be inaccurate from certain directions, additional

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sectors were to be added if the wind was from the West, North Northwest, or %

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A meeting was conducted with personnel from the State of Michigan. It was

agreed that implementation of the proposed protective action recommendations was appropriate and would not cause undue problems in a real event.

Attachment 1 to EPIP-58, " Protective Action Recommendations for Offsite i Populations," Revision 167, dated July 19,1995 had been appropriately modified.

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Documentation reviewed indicated that reading packages containing the procedure

revisions had been provided to response personnel on July 17,1995. This item is i i close l i

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(Onen) Insoection Followuo item 50-155/96007-01: Slow TSC initial notification to

offsite. Condition Report C-BRP-97-825 identified turnover from the simulated

control room. A comprehensive assessment of communications issues was in

progress with several recommendations for 1,mprovement under review. This item j will remain ope !

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(Onen) Insoection Followuo item 50-155/96007-02: Delayed dispatch of OSC teams. Discussion indicated that this was covered in the February 18,1997 OSC i

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. i drill and was scheduled to be reviewed in subsequent drills. This item will remain l ope '

P9 Temporary Instruction 2515/134 Onshift Dose Assessment l Insoection Scone ,

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The inspectors discussed onshift dose assessment capability and provisions with licensee personnel, reviewed the Emergency Plan and Emergency Plan implementing Procedures (EPIPs), and inspected the equipment utilized for dose assessmen l l

b. Observations and Findinas

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The Big Rock Point Site Emergency Plan, Section 1.0, " Organizational Control of !

Emergencies,' Section 1.1.2.a, "On-shift Organization," indicated that the Shift

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Supervisor was capable of performing dose assessmen .

EPIP-4A, " Site Emergency Director " indicated that the Shift Supervisor would become the Site Emergency Director (SED) until relieved of SED responsibilities by

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the Plant Manager. Attachment 4A-1, " Mandatory Actions by Emergency ,

Classification," listed performing dose assessment for actual or potential  :

radiological releases as a mandatory action for the Alert classification level or .l highe EPIP 4F, " Health Physics Group Leader," provided for the Health Physics Group Leader to proceed to the TSC and assure calculations estimating offsite dose are '

performed every fifteen minutes until the EOF HP Support Team is activated to assume this responsibilit j

EPIP 4G, "On-Call Dose Assessor," provided guidence in developing an assessment of offsite dose and directing the offsite radiological monitoring team. The on-call dose assessor, if on shift, was to report to the TSC; if on-call, come to the plant and report to the TSC. The on-shift Dose Assessor's primary duties included performing dose calculations using EPIP 5A, request and provide direction for the off-site radiological monitoring team EPIP 5A, " Estimation of Offsite Dose," Revision 98, provided guidance on performing calculations of offsite dose. The procedure provided for two methods of estimating offsite dose, an IBM PC automated dose assessment program ,"Offsite",

and a manual calculation backup metho Comprehensive manuals for the "Offsite" dose assessment system and segmented gaussian plume model (utilized at the EOF) were available. The Offsite dose model was Version 4.2, dated March 21,199 l i

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The Emergency Plan and EPIPS contained provision = for enshift dose assessmen Needed equipment and personnel training were provided. Personnel were j knowledgeable of their res,T sibilities and how to perform dose assessment. The

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acceptance criteria for the Tl were met and this Tl is closed. Documentation as to

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these findings is attached as Attachment P10' Review of UFSAR Commitments Inspection Scope A discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for

a special focused review that compares plant practices, procedures, and parameters to the UFSAR descriptions. While performing the inspections discussed in this report, the inspectors reviewed the applicable portions of the Big Rock Point Updated Final Hazards Summary Report (UFHSR) that related to Emergency

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Preparednes Observations and Findir.as UFHSR Chapter 13, " Conduct of Operations," Revision 6, Section 13.3, pertained to Emergency Planning. Section 13.3.1, " Site Emergency Plan," incorporated the Site Emergency Plan by reference. UFHSR Section 13.3.2 pertained to the Site Emergency Plan implementing Procedures, noting that they had been developed and l implemented, but were not considered a part of the UFHS Conclusions Overall maintenance of the Emergency Preparedness sections of the UFHSR was good. Licensee actions were consistent with UFHSR commitments.

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X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on April 4,1997. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Addy, Plant Manager

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J. Boss, Operations Manager l

M. Bourassa, Acting Licensing Manager E. Karpe, Emergency Preparedness Section Supervisor K. Pallagi, Chemistry / Health Physics Manager K. Penrod, Emergency Preparedness K. Powers, General Manager K. Wooster, Senior Nuclear Emergency Planner INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program Tl 2515/134 Temporary Instruction, Onshift Dose Assessment ITEMS OPENED, CLOSED, AND DISCUSSED CLOSED 50-155/95008-04 IFl Federalincident response information needed in trainin /96007-03 IFl Unable to locate OSC status board /95008-05 IFl Resolution of Meteorological tower inaccuracie l DISCUSSED 50-155/96007-01 IFl Slow TSC initial notification to offsit /96007-02 IFl Delayed dispatch of OSC team i

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LIST OF ACRONYMS USED BRP Big Rock Point CFR Code of Federal Regulations EAL Emergency Action Level EP Emergency Preparedness ENS Emergency Notification System EOF Emergency Operations Facility EPIP Emergency Plan implementing Procedure ERO Emergency Response Organization IR inspection Report IFl Inspection Followup item NPAD Nuclear Performance Assessment Department NRC Nuclear Regulatory Commission NUREG Nuclear Regulatory Commission document OSC Operational Support Center SED Site Emergency Director TS Technical Specification TSC Technical Support Center UFHSR Final Hazards Summary Report

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FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABOUTY . - .

Bia Rock Point / Unit 1/ 50-155 Consumers Power Comoany 10/11196 S!TE/ UNIT / DOCKET #s UCENSEE DATE

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1 DOSE ASSESSMENT COMMITMENT IN EMERGENCY PLAN .

Acceptance Criteria Person (s) Contacted Position Title (s) Plan Section Revision N Meets acceptance (Refer to page 1 of this Appendix for containing and Dato criterlo?

further detail on the acceptance criteria) commitment .

Karen Wooster EP Coordinator Chap 6. Subsectens Rev.124 of Not yet Sgrtion 4.01 Item 1 2.2; 2.3; 2.4 - Plan Chapters 5 ,

Emergency Plan contains commitment for on- revision inineted to and 6; 7/96 shift dose assessment capabelit specife onshift person Karen Wooster EP Coordinator Chapter 6, Subsection Rev.124 of Yes Fection 4.01 Item 2 Chapter 6; Emergency Plan contains commitment for 7/96

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backup dose assessrnent capability.

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Person (s) contacted Position Title (s) ProcedureAndscation Revision N Meets acceptance i

and Dato criteria?

Karen Wooster EP Coordinator EPIP-4A; EPlP-4G Rev.167, Yes Section 4.02 Item 1 7/95; Re *

Procedure initiates dose assessment 155, 7/95

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Karen Wooster EP Coordinator EPIP-SA, Attachments vanous rev Yes Section 4.02 Item 2 SA-1 through SA-9 numbers &

Indications initiate dose assessment dates

. Karen Wooster EP Coordinator EPIP-5A, Attachments various rev Yes

Section 4.02 Item 3 5A-1 through 5A-9 numbers &

Procedure for performing dose assessment dates availabl ~ P -

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04.03 ? ON-SHIFT DOSE' ASSESSMENT; TRAINING ' W ~~ ,

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Person (s) contacted Position Title (s) Personnel Trained Meets acceptance (Title /#1 cnteria?

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Karen Wooster EP Coordinator Shift Supervisors; 10 n/a Yes Section 4.03 Item 1 On-shift Personnel trained for dose assessment inspector: Thomas Ploskt Reason llL DRS. Plant Suncort B ,

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