IR 05000255/2006007

IR 05000255-06-007; Nuclear Mangagement Company LLC; 09/18/2006 - 09/22/2006; Palisades Nuclear Plant; Emergency Preparedness Specialist Report

ML062790374
Person / Time
Site:	Palisades
Issue date:	10/03/2006
From:	Riemer K R Plant Support Branch II
To:	Harden P A Nuclear Management Co
References
IR-06-007
Download: ML062790374 (12)

Text

October 3, 2006

Mr. Paul A. HardenSite Vice President Nuclear Management Company, LLC Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043-9530

SUBJECT: PALISADES NUCLEAR PLANTNRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000255/2006007(DRS)

Dear Mr. Harden:

On September 22, 2006, the NRC completed an inspection at your Palisades Nuclear Plant. The enclosed report documents the inspection findings, which were discussed on September 22, 2006, with you and members of your staff.The inspection examined activities conducted under your license, as they relate to safety, andcompliance with the Commission's rules and regulations, and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. Specifically, this inspection focused on emergency preparedness, including your staff's determinations of performance indicators for the Emergency Preparedness Cornerstone.On the basis of the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR Part 2.390 of the NRC's "Rules of Practice," a copy of this letterand its enclosure will be available electronically for public inspection in the NRC Public P. Harden-2-Document Room, or from the Publicly Available Records (PARS) component of NRC'sdocument system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/Kenneth Riemer, ChiefPlant Support Branch Division of Reactor SafetyDocket No. 50-255License No. DPR-20

Enclosure:

Inspection Report 05000255/2006007(DRS)

w/Attachment:

Supplemental Informationcc w/encl:J. Cowan, Executive Vice President and Chief Nuclear Officer R. Fenech, Senior Vice President, Nuclear Fossil and Hydro Operations D. Cooper, Senior Vice President - Group Operations L. Lahti, Manager, Regulatory Affairs J. Rogoff, Vice President, Counsel and Secretary A. Udrys, Esquire, Consumers Energy Company S. Wawro, Director of Nuclear Assets, Consumers Energy Company Supervisor, Covert Township Office of the Governor State Liaison Office, State of Michigan L. Brandon, Michigan Department of Environmental Quality -

Waste and Hazardous Materials Division W. King, DHS, Region V

SUMMARY OF FINDINGS

IR 05000255/2006007(DRS); 09/18/2006 - 09/22/2006; Palisades Nuclear Plant; EmergencyPreparedness Specialist Report.The report covers a 1 week baseline inspection by two regional emergency preparednessinspectors, a senior resident inspector, a licensed operator examiner, and a radiation protection inspector. The inspection focused on the Emergency Preparedness cornerstone in the Reactor Safety strategic performance area during the biennial emergency preparedness exercise. This inspection also included a review of records related to the three emergency preparedness performance indicators for the period April 1, 2005, through June 30, 2006.The NRC's program for overseeing the safe operation of commercial nuclear power reactors isdescribed in NUREG-1649, "Reactor Oversight Process," Revision 3, dated July 2000. A.Inspector-Identified and Self-Revealed FindingsNone.

B.Licensee-Identified Violations

None.

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REPORT DETAILS

1.REACTOR SAFETYCornerstone: Emergency Preparedness1EP1Exercise Evaluation (71114.01)

a. Inspection Scope

The inspectors reviewed the September 19, 2006, biennial emergency preparednessexercise's objectives and scenario to ensure that the exercise would acceptably test major elements of the licensee's emergency plan, and to verify that the exercise's simulated problems provided an acceptable framework to support demonstration of the licensee's capability to implement its plan. The inspectorsalso reviewed records of a sample of emergency preparedness drills, which wereconducted between August 2004 and August 2006, to verify that those dr ills'scenarios were sufficiently different from the scenario used in the September 2006 exercise.The inspectors evaluated the licensee's exercise performance, focusing on therisk-significant activities of emergency classification, notification, and protective action decision making, as well as implementation of accident mitigation strategies in the following emergency response facilities:*Control Room Simulator (CRS);*Technical Support Center (TSC);

• Operations Support Center (OSC); and

• Emergency Operations Facility (EOF).The inspectors also assessed the licensee's recognition of abnormal plant conditions,transfer of responsibilities between facilities, internal communications, interfaces withoffsite officials, readiness of emergency facilities and related equipment, and overallimplementation of the licensee's emergency plan.The inspectors attended post-exercise critiques in the CRS, TSC, OSC, and EOFto evaluate the licensee's initial self-assessment of its exercise performance. The inspectors later met with the licensee's lead exercise evaluators to obtain the licensee's refined assessments of its exercise participants' performances. These self-assessments were then compared with the inspectors' independent observations and assessments to assess the licensee's ability to adequately critique its exerciseperformance.These activities completed one inspection sample.

b. Findings

No findings of significance were identified.

4OA1 Performance Indicator (PI) Verification

Cornerstone: Emergency Preparedness.1Reactor Safety Strategic Area

a. Inspection Scope

The inspectors reviewed the licensee's records associated with each of the threeemergency preparedness PIs to verify that the licensee's program was implemented consistent with the industry guidelines in Nuclear Energy Institute Publication No. 99-02, "Regulatory Assessment Performance Indicator Guideline," and related licensee procedures. Specifically, licensee records related to the performance of the Alert and Notification System (ANS), key Emergency Response Organization (ERO) members' drill participation, and Dr ill and Exercise Performance (DEP) were reviewed to verifythe accuracy and completeness of the PI data submitted to NRC for the period fromApril 1, 2005, through June 30, 2006. The following three PIs were reviewed:*ANS;*ERO Drill Participation; and

• DEP.These activities completed three PI samples.

b. Findings

No findings of significance were identified.4OA2Identification and Resolution of ProblemsThe following performance concern, which could have adversely impacted responseactivities had exercise events been real, was independently identified by the inspectors and the licensee during the September 2006 exercise and was added to the licensee's corrective action program:*Degraded plant conditions associated with the third and fourth emergencydeclarations were not adequately provided in the associated press releases, while the initial emergency declaration was not mentioned in any press release. 4OA6Meetings.1Exit MeetingAn exit meeting was conducted for:

• Emergency Preparedness with Mr. P. Harden and other members of licenseemanagement and staff at the conclusion of the inspection on September 22, 42006. The licensee acknowledged the information presented. No proprietaryinformation was identified..2Public and Media Briefing*On September 22, 2006, an inspector summarized NRC's preliminary exerciseinspection conclusions at a public and media briefing hosted by Department of Homeland Security Region V Field Office staff in Paw Paw, Michigan.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

P. Harden, Site Vice President

D. Mims, Site Director

G. Hettel, Plant General Manager

J. Broschak, Engineering Director

L. Blocker, Operations Manager

G. Higgs, Maintenance Manager

T. Blake, Nuclear Safety Assessment Manager

J. Ford, Emergency Preparedness Manager

B. Patrick, Chemistry and Radiation Protection Manager

G. Baustian, Training Manager

D. Rogers, Fleet Optimization Manager

S. Wawro, Consumers Energy/Asset Manager

M. Vonk, Corporate Senior Emergency Preparedness Specialist

C. Morgan, Corporate Emergency Preparedness Specialist

B. Dotson, Regulatory Compliance Specialist

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed, and

Discussed

None.

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LIST OF DOCUMENTS REVIEWED

The following is a list of documents reviewed during the inspection.

Inclusion on this list doesnot imply that the NRC inspectors reviewed the documents in their entirety but rather that selected sections of portions of the documents were evaluated as part of the overall inspection effort.

Inclusion of a document on this list does not imply NRC acceptance of the document orany part of it, unless this is stated in the body of the inspection report.

1EP1Exercise EvaluationPalisades Plant September 2006 Exercise Scenario Manual Palisades Plant August 2006 Integrated Dr ill Report; undatedPalisades Plant September 2005 Final Dr ill Report; undatedEmergency Action Level Technical Bases Document; Revision 0

Slide Presentation; September 2006 Palisades Exercise Critique Conclusions; datedSeptember 21, 2006Draft Report; September 2006 Palisades Exercise Critique Report; undated

EI-1; Emergency Classification and Actions; Revision 47

EI-2.1; Site Emergency Director; Revision 26

EI-3; Communications and Notifications; Revision 24

EI-4.1; TSC Activation; Revision 18

EI-4.2; OSC Activation; Revision 18

EI-4.3; EOF Activation; Revision 17

EI-5.0; Re-Entry; Revision 5

EI 5.1; Recovery; Revision 3

EI-6.0; Offsite Dose Calculation and Recommendations for Protective Actions;Revision 9EI-6.1; Release Rate Determination from Stack Gas Monitors; Revision 7

EI-6.7; Plant Site Meteorological System; Revision 6

EI-6.8; Backup and Supplemental Meteorology; Revision 6

EI-6.13; Protective Action Recommendations for Offsite Population; Revision 14

3EI-11; Determination of Extent of Core Damage; Revision 6EI-12.1; Personnel Accountability and Assembly; Revision 12EI-13; Evacuation/Re-Assembly; Revision 10

4OA1 Performance Indicator VerificationSample of Palisades Plant

ERO Participation PI Records from April 2005 throughJune 2006Sample of Palisades Plant DEP Performance Indicator Data from April 2005 throughJune 2006Sample of Palisades Plant Emergency Planning Zone Sirens' Test Reports andAssociated Records from April 2005 through June 2006

LIST OF ACRONYMS

USEDADAMSAgencywide Documents Access and Management SystemANSAlert and Notification System

CFRCode of Federal Regulations

CRSControl Room Simulator

DEPDrill and Exercise PerformanceEIEmergency Implementing (procedure)

EOFEmergency Operations Facility

EROEmergency Response Organization

IRInspection Report

NRCUnited States Nuclear Regulatory Commission

NUREGNuclear Regulatory GuideOSCOperations Support Center

PARSPublicly Available Records

PIPerformance Indicator

TSCT echnical Support Center