ML20154E058
| ML20154E058 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 09/30/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20154E014 | List: |
| References | |
| NUDOCS 9810080028 | |
| Download: ML20154E058 (7) | |
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e Oro a & UNITED STATES 3
2 j NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20eWM001
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION ON THE APPROVAL OF THE DEFUELED EMERGENCY PLAN CONSUMERS ENE'4GY COMPANY BIG ROCK PQLfiT. NUCLEAR PLANT l
DOCKET NO. 50-155 l
1.0 INTRODUCTION
By letter dated September 19,1997, as supplenaented by letters dated October 29,1997, and March 2, July 30, August 28,1998, Consumers Energi/ Company (the licensee) I submitted a defueled emergency plan (DEP) to replace its current site emergency plan for the Big Rock Point (BRP) Nuclear Plant. BRP was permanently shutdown on August 30, 1997, and the fuel was permanently removed from the reactor vessel on September 20, 1997. The licensee revised its emergency plan in order to reflect the radiological risks associated with a permanently shut down and defueled plant undergoing decommissioning. l In addition, in its letters listed above, the licensee submitted a request for exemption from certain emergency preparedness requirements it believed were not appropriate for tne BRP plant in its permanently shutdown and defueled condition. The staff's review of the 1 licensee's DEP took into consideration the current shutdown and defueled status of the l plant and the licensee's exemption request.
2.0 REGULATORY REQUIREMENTS AND REVIEW CRITERIA The proposed DEP was reviewed against the applicable requirements in 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50. Criteria for meeting these requirements are contained in NUREG-0654/ FEMA-REP-1, "Critsria for the Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants,"
Revision 1, dated November 1980. .
3.0 EVALUATION The manner in which the DEP meets the applicable review criteria in NUREG-0654 is described below. This review concerned the adequacy of the plan to protect licensee personnel and the public in case of a radiological emergency at BRP.
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3.1 Assianment of Resoonsibility - 10 CFR 50.47(b)(1)
The DEP describes the onshift and augmented organizations that are intended to be part of the overall response organization in the event of an emergency at BRP. The DEP specifies its concept of operations and illustrates this in a block diagram. The individualin charge of the event is identified by title (Site Emergency Director). The functions and responsibilities for major elements and key individuals are specified as follows:
Maior Elements Kev Individuals Command and Control Site Emergency Director Alert and Notification Site Emergency Director Communications Site Emergency Director Accident Assessment Site Emergency Director /Techr.ical Coordinator Fire and Rescue Security /Onsite Fire Brigade Radiological Exposure Control Individual Qualified in Radiological Protection / Radiological Assessor j
The licensee and supporting offsite agencies provide for 24-hour per day emergency response. The licensee's organization has sufficient personnel to ensure 24-hour coverage during a radiological emergency.
The DEP identifies the following State, local, and private sector organizations that are part ,
of the overall response organization: 1 State of Michigan )
Charlevoix Township Fire Department Northern Michigan Hospital, Incorporated Charlevoix Area Hospital I Charlevoix Township Board Boyne City Teledyne Isotopes Midwest Laboratory Life and L;.)k, incorporated NUREG-0654 specifies that written agreements between the supporting organizations and the licensee that refer to the support to be provided in an emergency are to be included in an appendix to the emergency plan. The DEP does not include these written agreements; 1
' 7 wever, these supporting organizations are listed. Prior to plan implementation, the DEP needs to be revised by Consumers to include the written agreements.
1 3.2 Onsite Emeraency Oraanization - 10 CFR 50.47(b)(2) l The DEP describes the normal plant organization, the onshift emergency response organization, and the augmented emergency response organization. Minimum backshift coverage will consist of one Shift Supervisor, one individual qualified in radiological ,
protection, and one member of the plant security force. An onsite fire brigade will be l maintained in accordance with the BRP fire protection plan. In the event of an emergency,
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the Shift Supervisor is designated as the Site Emergency Director. The augmented emergency response organization will be activated at an Alert declaration with a goal of reporting to the site within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaration of the Alert. The augmented response organization consists of the following additional positions:
Radiological Assessor: Responsible for radiation protection, chemistry, and dose assessment activities.
Technical Coordinator: Responsible for accident assessment and repair of plant equipment and systems.
In addition, public information personnel will be notified when an emergency is declared and will respond as needed. Public information personnel will be resoonsible for ensuring prompt and accurate dissemination of information about the emergency event to the news media and public.
3.3 Emeroencv Resoonse Sucoort and Resources T h( DEP identifies the services to be provided by local agencies, such as ambulance nee, medical service, and fire fighting support. The DEP includes provisions for contacting the Palisades nuclear plant, if needed, for additional emergency support. The BRP DEP identifies radiological laboratories that can be used in an emergency.
3,4 Emeraencv Classification Svstem Table 5.1 of the DEP contains an emergency classification and emergency action level (EAL) scheme for classifying events at the Unusual Event and Alert classification levels.
Specific process parameters and plant conditions are included in the EALs for classifying events. The staff has reviewed the EALs and determined that they are acceptable when ,
compared to the applicable standards considering the permanently shutdown and defueled i condition of the facility.
3.5 Notification Methods and Procedures l I
The DEP states that several systems are available to alert or activate emergency response personnel. A plant paging system is located throughout the plant and is utilized as a paging and intercom system. Furthermore, site sirens will be activated to notify personnel. During off-hours, personnel will be notified by pagers and/or telephone as necessary.
Upon declaration of cn Unusual Event or Alert, the Site Emergency Director will notify the State of Michigan and county personnel within 30 minutes and the NRC as soon as possible thereafter, but within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of classifying the emergency.
Section IV.D.1 of Appendix E to 10 CFR Part 50 specifies that " Administrative and physical means for notifying local, State, and Federal officials...shall be described. This description shall include identification of the appropriate officials, by title and agency, of the State and
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4 local government agencies...." The BRP DEP does not include identification of the appropriate officials, by title and agency, of the State and local government agencies. Prior to plan implementation, the DEP needs to be revised by Consumers to meet this requirement.
3.6 Emeraencv Communications A plant paging system is located throughout the plant and is utilized as a paging and interconi system. In addition the plant two-way radio system is available for communication among support teams. A plant- based station allows radio communication beyond the range of the hand-held radios.
The DEP states that an auto-dial telephone is present in the Emergency Support Center for notifications to the Michigan State Police, county personnel, or to contact emergency agencies. In the event of a telephone outage, a base radio is aveilable to contact the Michigan State Police.
Section IV.C of Appendix E to 10 CFR Part 50 specifies that the " existence, but not the details, of a message authentication scheme shall be noted...[for notification of offsitel l agencies." The DEP did not specify that a message authentication scheme would be used. !
Prior to plan implementation, the DEP needs to be revised by Consumers to include the I message authentication scheme. l l
Section IV.E.9 of Appendix E to 10 CFR Part 50 specifies that adequate provisions be made l for at "least one onsite and one offsite commur;ications system; each system shall have a l backup power cource. All communication plans shall have arrangements for emergencies, l i ,;luding titles and alternates for those in charge at both ends of the communication links !
I nd the primary and backup means of communi:ation." The BRP does not specify the I titles and alternates for those in charge at both ends of the communication links. Prior to plan implementation, tite DEP needs to be revised by Consumers to include the titles and alternates for those in chwge at both ends of tte communication links.
3.7 Public Education and Information Public information personnel will be responsible for ensuring prompt ani 2ccurate dissemination of information about the emergency event to the news inedia ano public.
3.8 Emeraency Facilities and Eauioment The DEP identifies the Emergency Support Center K.SC) as the location from which emergencies will be managed. The ESC is located adjacent to the Control Room / Monitoring Station. The ESC has contro! i to maintair' habitability. Emergency equipment includes respiratory devices, anti-contamination garments, and radiation monitoring arsd sampling equiproant.
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3.9 Accident Assessment The DEP states that area radiation monitors are installed throughout the plant and may be supplemented with or replaced by portable units, as required, during the conduct of various decommissioning activities. The effluent process monitoring system provides indication of radioactivity levels of all airborne and liquid effluents released from the ple-t via the liquid and gaseous radwaste systems and the plant ventilation systems. The DEP also states that spent fuel pool (SFP) water level indication is provided and that a containment building radiation monitor near the SFP will monitor radiation level changes in the event of a loss of water level in the fuel pool or damage to fuel.
In Section 10.2, " Assessment Methods," of the DEP the licensee states:
Radiological release assessments are performed using measured radiological and meteorological data. Dose assessment graphs are initially used by the Site Emergency Director or other trained emergency response personnel to determine the industrial area dose rate.
Additional assessments of potential radiation dose to plant personnel from direct radiation or potential exposure from various other sources will be performed as appropriate.
The licensee states that it plans to use National Weather Service (NWS) data available through the automated computer system, which is accessed by telephone or data transfer vis the computer in the ESC, rather than measured data from its on-site meteorological measurement system. The staff has accepted the use of NWS data as a backup source of meteorological data for emergency purposes. Until such time as the licensee evaluates die :
representativeness of and the relationship between data collected from the on-site meteorological system and the proposed alternative primary data source, the on-site meteorological system will continue to be maintained for accident assessment purposes.
When the evaluation is completed, it should be submitted to the Commission for review ano approval under the provisions of 10 CFR 50.54(q).
In addition, the licensee has committed to reviso Section 10.2 of the DEP to specify that it will have the capability to determine the potentialimpact of a raciological emergency on l ue general public. This information would be used to determine whether offsite measures for the general public would be appropriate.
3.10 Protective Actions i
The DEP has provisions for performing accountability of allindustrial area personnel at the '
Alert classification and for providing search and rescue efforts of any unaccounted for personnel. In addition the DEP contains provisions for evacuation of personnelif this action is needed. The DEP also specifies that accountability for industrial area personnel will be accomplished within 60 minutes.
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3.11 Radioloaical Exoosure Control The DEP states that the Radiciogical Assessor is responsible for in-plant radiological protection activities for plant staff and support personnel during an emergency. The DEP states that the plant maintains personnel showers for decontamir tion and survey instruments for personnel frisking. The plan provides dose limit for :ndividuals performing emergency functions which are equivalent to the limits recommenoed in the U.S.
Environmental Protection Agency's guidance for emergency workers (EPA 400-R-92-001).
3.12 Medical Suoco.n The DEP states that first aid kits, stretchers, and fire blankets are available for treating injured personnel. Agreements are in place with local hospitals to provide offsite emergency medical treatment. Ambulance services have been arranged.
3.13 Recoverv and Reentrv Plannina The DEP contains provisions for terminating an event once conditions have been restored to a safe condition. The Site Emergency Director is responsible for terminating the event and providing notification to appropriate offsite authorities.
3.14 Exercises and Dri!!s Communication drills with the NRC, Michigan State Police, county personnel, and offsite support agencies will be performed quarterly. A medical emergency drillinvolving a simulated contaminated individual will be conducted annually. Radiological monitoring drills will be conducted annually. A radiological emergency preparedness exercise will be conducted biennially. Performance will be evaluated and critiqued by the licensee in order to judge the effectiveness of emerg'ncy planning elements.
3.15 Training All plant personnel assigned emergency responsibilities will receive annual training. Offsite support personnel (medical and fire fighting) will be invited to participate in annual training.
Local law enforcement personne! wil! be invited to participate in annual review sessions on plant status.
3.16 Resoonsibility for the Plannina Eff 0.Et The DEP identifies the BRP Site General Manager as responsible for the defueled emergency plan. The DEP will be reviewed every 2 years. An audit of the DEP will be conducted at least once per 12 months.
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3.17 Summarv of Outstandina Issues On September 9,1998, the staff informed the licensee that the DEP as provided in the August 28,1998, submittal provided insufficient detail as to the implementation of the emergency planning requirements in the areas lisied below.
e The DEP does not include written agreements between the supporting offsite organizations and the licensee that refer to the support to be provided in an emergency (Safety Evaluation Section 3.1).
e The DEP does not identify, by title and agency, the appropriate offsite officials to be notified and .does not identify the existence of a message authentication scheme for the notification of offsite officials (Safety Evaluation Sections 3.5 and 3.6).
The DEP does not specify that it will have the capability to determine the potential impact of a radiological emergency to the general public (Safety Evaluation Section 3.9).
The licensee acknowledged this and stated that it will correct these deficiencies in the DEP prior to implementation of the plan. The licensee also stated in a letter dated September 11,1998, that Consumers will inform the staff in writing confirming completion of this action. In addition, the on-site meteorological measurement system will continue to be relied upon as a meteorological data source for accident assessment purposes. In a discussion with the licensee on September 29,1998, the licensee committed to maintain the meteorological measurement system until such time as the licensee receives Commission approval for the use of an alternative data source.
4.0 CONCLUSION
The licensee's proposed DEP has been reviewed by the staff against the planning standards in 10 CFR 50.47(b), the requirements of Appendix E to 10 CFR Part 50, and the acceotanca criteria in NUREG-0654/ FEMA-REP-1, Revision 1. The staff review took into consideration the permanently shutdown and defueled status of tb ? plant, the storage configuration of the spent fuel, and the length of time since the final reactor shutdown conducted on August 30,1997.
The staff concludes that the DEP, upon adequate completion of the issues summarized in Section 3.17 of this safety evaluation, provides for an acceptable level of emergency preparedness at BRP in its permanently shutdown and defueled condition. Further, the DEP provides reasonable assurance that adequate protective measures can and will be taken in l the event of a radiological emergency at BRP.
Principal contributors: Jim O'Brien Paul Harris Date: September 30, 1998 l l
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