IR 05000331/1987003

Insp Rept 50-331/87-03 on 870105-09.No Violation or Deviation Noted.Major Areas Inspected:Changes to Emergency Preparedness Program,Emergency Facilities & Equipment, Organization & Mgt Control & Training

ML20210A701
Person / Time
Site:	Duane Arnold
Issue date:	02/02/1987
From:	Patterson J, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210A654	List: IR 05000331/1987003 ML20210A649
References
50-331-87-03, 50-331-87-3, NUDOCS 8702060520
Download: ML20210A701 (9)

Text

_ - _ _ _ _

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-331/87003(DRSS)

Docket No. 50-331 License No. DPR-49 Licensee: Iowa Electric Light and Power Company IE Towers P.O. Box 351 Cedar Rapids, IA 52406 Facility Name: Duane Arnold Energy Center Inspection At: Palo, Iowa Inspection Conducted: January 5-9, 1987

1. a k V Wu? !

Inspectors: J. P tterson, /

Team Leader Date M. Smith

, k f. Williamsen

'~

2 <2 a Date Approved By: e ef .A,&

Emergency Preparedness Section ham!

Inspection Summary Inspection on January 5-9, 1987 (Report No. 50-331/87003(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program: changes to the emergency preparedness organization and management program; emergency facilities and equipment;ts;fied items control; training; independent licensee audi plan, and licensee actions on previously identi activations of the emergency

. The inspection involved observations onsite by three NRC inspector Results: No violations or deviations were identified as a result of this inspectio E)702060520 870203 PDR ADOCK 05000331 o PDR

. _ _ . ______ _ _ _ _ _ _ _ _ - - _ - _ _ _ _ _ - - _ _

_ _ _ _ _ _ _ _ _ _

.

DETAILS 1. Persons Contacted D. Mineck, Plant Superintendent

• R. Hannen, Assistant Plant Superintendent, Operations

• K. Young, Assistant Plant Superintendent, Radiation Protection and Security C. Mick, Operations Supervisor

• W. Rothert, Manager, Nuclear Projects, Corporate

• D. Wilson, Manager, Nuclear Licensing and Emergency Planning, Corporate l

• D. Hingtgen, Emergency Planning Coordinator, Corporate l R. Lessly, Manager, Nuclear Division, Corporate

• G. Harper, Emergency Planner

• S. Marshall, Emergency Planner

• Grim, Site Licensing Engineer

• Van Middlesworth, Training Superintendent, Training Department

'

R. Tucker, Staff Instruction Technologist, Training Department

• B. Klotz, Quality Assurance Engineer P. Serra, Health Physics Supervisor C. Armstrong, ALARA Coordinator i P. Schmelzer, Health Physicist M. Craver, Emergency Preparedness Instructor, Training Department D. Johnson, Operations Shift Supervisor (OSS)

J. Edom, OSS J. Thorsteinson, OSS G. Thullen, OSS H. Giorgio, Radiation Protection Supervisor j K. Howard, Plant Performance Supervisor i J. Leohrlein, Supervising Engineer

• Denotes those attending the exit intervie . Licensee Actions on Previously Identified Items Related To Emergency l Preparedness l (Closed) Open Item No. 331/84-05-02: All six Symptomatic Emergency Operating Procedures (E0Ps) have been revised to include a statement that the OSSs are to classify the emergency and to reference the Emergency Plan Implementing Procedure (EPIP) 1.1. Training on these six Symptomatic E0Ps, revised as indicated, has been completed in calendar year 1986. This item is close (Closed) Open Item No. 331/84-10-01: The plant EPIPs and the Corporate EPIPs have both been revised to be consistent with each other. Now all three implementing procedures, EPIP 1.1 and CPIP and 5.1 clearly state who will have the authority and responsibility to immediately and unilaterally initiate emergency actions, including upgrading and downgrading of emergency event classifications. This item is close _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

'

. (Closed) Open Item No. 331/86003-01: Attachment 1, page 5, of EPIP 1.1 has been revised to improve and clarify the guidance for a General Emergency. Also under the categorical description for C-5, " Degraded core with possible loss of coolable geometry,"

indicators have been added to include instrumentation to detect inadequate cooling, coolant activity and/or containment radioactivity levels for the Site Area Emergency. This is close (Closed) Open Item No. 331/86003-02: Attachment 1 of EPIP 3.3,

" Dose Assessment and Protective Action Recommendations" (PARS),

was revised to include more realistic values on the PAR flow chart for projected doses at the Site Boundary and at two miles. Also references to Ci/cc were changed to uCi/cc in EPIP 3.3 for the Dose Projection Worksheet for stack release concentration This item is close (Closed) Open Item No. 331/86003-03: All outdated emergency telephone lists have been removed from CPIP 1.2. Attachment 2 of EPIP 1.2 and Attachment 6 of CPIP 1.2 have been revised to reflect the current 10 CFR 50.72 notification requirements. This item is close . Actuation of the DAEC Emergency Plan (Closed) Open Item No. 331/860xx-03: A Notice of Unusual Event (NUE)

was declared based on taking the "B Emergency Service Water Pump" out l of service for maintenance. Notifications were made in a timely manner I to the State of Iowa, Linn County, Benton County and the NRC. This item is closed.

Two other activations (March 15, 1986 and October 15,1986) were made resulting in NUEs. The March 15 incident was correctly classified as an A-10/A-11 EAL category due to Low Pressure Coolant Injection (LPCI)

l System being inoperable. The October 15 incident, also correctly I

classified as an NUE based on an A-11 EAL category, resulted from both Standby Filter Units (SFUs) being inoperable. These two events resulted in timely notifications to State, Counties, and the NR . Operational Status of the Emergency Preparedness Program (82701) Emergency Plan and Implementiv.g Procedures With one exception there were no major changes made to the program which would affect the overall status of emergency preparednes That exception was the omission of the EAL tables in the current DAEC Emergency Plan, Revision 6, Section D, Emergency Classification System. These EALs were included as Table D-2 in the previous issue of the DAEC Emergency Plan. This item was addressed separately in a review of the licensee's entire Emergency Plan which was

_ _ _ - _ __ - _____- _______________-__________ ______

.

submitted to the licensee by letter on November 25, 1986. The licensee has agreed to include this EAL table in an amended revision to the present Plan. This item will be tracked as Open Item No. 50-331/87003-0 All changes to the emergency plan and to the EPIPs were submitted within the required 30 days after being issued by the license Also these changes went through the review committee and had proper management approval. A separate company, TELECONNECT, was engaged to assist in the notification process for shift augmentation personnel. A Letter of Agreement with TELECONNECT has been finalized and inserted in the Emergency Plan. In conjunction with this, notification procedures and telephone check lists have been revised to address this company's responsibilities in shift augmentation notifications. Procedures and relevant check lists are presently in the review process to address the recent activation of the commercial HPN telephones in the TSC and the E0 The inspector's review of the EALs in the EPIPs determined that EPIP 1.1, Revision 7, page 23, should be revised to indicate that a General Emergency should be declared when there is a loss of two of three fission product barriers plus a potential loss of the third barrier. Currently EPIP 1.1, page 23, in that section that leads to a General Emergency, Category D5 does not include the qualifying phrase, "with a potential loss of the third fission product barrier."

The recommended change should be made to conform with NUREG-0654, Revision 1 guidance. This item will be tracked as Open Item No. 50-331/87003-0 Also in EPIP 1.1, Attachment 2, EAL tables, walkthroughs indicated that there were some conflicting statements when referring to " loss of offsite power" and " total loss of all AC power," respectively, on pages 7 and page 3 Page 7 provides the general guidelines and indicators for the emergency condition. More specific information on page 32, following the " plant conditions" heading, lists a series of " ands" and " ors" that led one OSS to conclude that a Site Area Emergency was warranted. Another OSS in the walkthrough classified the event as an Alert. An NUE or Alert would have been the appropriate emergency classifications for the scenario. This particular EAL which relates to loss of power should be reviewed and revised to clarify instrumentation guidance and emergency classification. This item will be tracked as Open Item No. 50-331/87003-0 Section 2.1.1.2 of the Emergency Plan made no distinction as to which OSS, "A" or "B", could be the acting Emergency Coordinator at the initiation of an emergency. In practice, the "A" 0SS, the senior individual, would probably be the one to assume the Emergency Coordinator role until relieved. However, the Emergency Planning Coordinator stated that the intent was that either OSS could fill the positio EPIP 3.3 Revision 2, " Dose Assessment and Protective

-

.

t Action Recommendations," stated that the Emergency Coordinator is defined as "The 'A' Operations Shift Supervisor (OSS) until relieved."

Also in EPIP 3.3, Section 3.1.1(b) a second interim Emergency Coordinator is defined as being the " Control Room Coordinator after turnover from the OSS and until relieved by the assigned Emergency Coordinator." This responsibility of the Control Room Coordinator is contrary to the Emergency Plan and contrary to the licensee's intent. These inconsistencies should be clarified to be consistent in both the Emergency Plan and the EPIPs. The correction of these items will be tracked as Open Item No. 331/87003-0 Based upon the above findings, four open items were identifie b. Emergency Facilities, Equipment, Instrumentation and Supplies The licensee made five major changes related to key facilities or emergency equipment since the 1986 inspection, as follows:

(1) Thirteen additional sirens were added to their prompt notification system to meet FEMA's siren system review which is scheduled for April 1987. Twenty-eight more sirens to be installed in the first quarter of 198 After installations are completed, the system will contain a total of 68 sirens, which should provide 100% coverage for all areas within the 10 mile EPZ, according to the license (2) To improve the notification capabilities for shift augmentation drills, the licensee contracted a local communications firm to perform notification calls. Using revised procedures adapted to this firm's methods, two successful tests of the procedures and ecuipment successfully demonstrated the capability of this outsice firm to make the notifications within the 30 and 60 minute guideline (3) Addition of a dedicated radio frequency for use by the Radiological Monitoring Team (RMTs) was successfully demonstrated in the November 1986 annual emergency exercis (4) Commercial HPN telephones were activated in December 1986 for NRC use at the site and E0 (5) The microwave telephone system was enlarged to provide an additional means of communicating with the two County E0C's, the Iowa Office of Disaster Services and TELECONNEC Members of the Safety Committee were conducting an assessment of decontamination facilities at their primary support hospital, to determine whether any change or expansion is necessary to assure the hospital's capability to treat contaminated personnel under emergency condition .

.

,

An emergency kit in the Control Room was inventoried by the inspector. All required equipment and emergency supplies were present, as verified by the inspector using the enclosed inventory list as part of EPIP 6.1. A complete set of EPIPs was also included in the kit. The kit included four copies of an area map, but the maps did not include degrees, areas or EPZ sector divisions. The road designations on the map were difficult to read and the map did not have a title block or date. These maps were similar to those in Attachment 3 of EPIP Based on the above findings, this portion of the licensee's program was acceptable; however the following item should be considered for improvemen * The licensee should re evaluate the quality of the area maps placed in the emergency kits to make them more readable and include EPZ sector letters and/or number designations as well as degree sectors, correlating letter designations with the maps in EPIP c. Organization and Management Control A new Emergency Planner has been hired, beginning employment at the licensee's site #n late December 1986. His assignments and responsibilities will include spending three days a week at the DAEC site in emergency preparedness work and interacting with the operations group and radiological monitoring group and others which have key emergency response functions. The remainder of the week he will work with the corporate portion of the EP group and investigate special projects, such as the new pager system; assisting Linn County in revising their emergency plan; and other eniergency preparedness duties. There are now three professional level emergency preparedness specialists in the EP group including the Emergency Planning Coordinator (EPC). The EPC reports to the Manager, Nuclear Licensing and Emergency Plannin A review of the organizational structure of corporate and plant staff indicated no changes that would result in a downgrade of plant ability to protect the health and safety of the public. Members of the Emergency Planning staff made presentations at seminars which were given by the Office cf Disaster Services (0DS) of the State of Iowa for state wide, regional emergency directors. One licensee Emergency Planner gave a presentation in Waterloo, Iowa to the Iowa Chapter of the American Red Cross, to clarify the role of the nuclear aower industry in emergency planning. These examples indicated t1at the licensee has expanded its emergency planning policies to include offsite agencies beyond those within the ten mile EP Based on the above findings, this portion of the licensee's program is adequate.

!

_

~

. Training Walkthroughs and interviews were conducted with three Operations Shift Supervisors (OSSs), two Site Radiation Protection Coordinators and two Technical and Engineering Supervisors. The three OSS demonstrated adequate familiarity with their Integrated Plant

,0perating Instructions (IP0I) and EPIP 1.1 which includes the EALs. However, as identified in Section 4.a of this report, there was disagreement on the final classification of an event resulting from the extended scenario conditions as provided by the inspecto Initial scenario conditions related to total loss of offsite power were properly identified by all OSS's as a Notification of Unusual Event. This aspect is further described in Section 4.a of this repor All three OSS's appeared to be fully aware of their emergency responsibilities, except that they were not clear about which three main areas of their authority could not be delegated to a subordinate or anyone else. These areas were: classification of the emergency; initiation of protective action recommendations (PARS); and authority to authorize increased radiation exposure above 10 CFR Part 20 limits for life saving or other emergency conditions. Evacuation time estimates and weather effects were also included in the walkthrough. Two of the three could not readily express how they would utilize this information, especially as related to offsite agencies. One of these two did not understand the relationship or importance between evacuation time estimates and the emergency. The inspectors recommended a re-emphasis on this aspect, since it is part of EPIP 3.3, Attachment 1, Table 3 and Attachment 8, Evacuation Time Estimates. The licensee should consider expanding the Protective Action Decisionmaking Chart to two

) ages and moving the evacuation guidance footnotes from the fold-up

)ottom of the page to a more prominent )osition on the chart where it would be more easily observable by tie Emergency Coordinato The Site Radiation Coordinators and Technical and Engineering

[ Supervisors all demonstrated very good knowledge of their emergency response functions. All but one had either participated in practice i drills or the annual exercise within the last year, f Training records of emergency response personnel were reviewed, and it was determined the required that all had received EP training)withintraining, time. Post-AccidentSamplingSystem(PASS

,

including drawing an actual reactor coolant sample, had been

'

performed bimonthly on an unannounced basis to the technicians with that responsibility. All recuired communication tests, annual

,

radiological monitoring drill, anc semiannual Health Physics drills l have also been performed and documented satisfactorily as determined l by the inspectors.

l

l _ _ __ _ . _ _ _ _ _ _ . _ _ ,__ , _ _ _ _ . _ _ . . _ _ _ _ _ _

"

.

.

'

Plant-specific training for offsite support agencies was conducted on October 29, 1986. The annual review of the EALs with State and local governmental agencies was conducted on December 12, 1986 by a member of the licensee's corporate emergency planning group. The meeting format and the attendance lists for both the plant specific training and the EAL review were examined by the inspector and found

, to be satisfactory. A complete revision of the EP lesson plans to make them site specific was made in 1986 by the licensee training staff. Currently EP training is conducted based on these lesson plan revisions. Reviews and critiques of drills and other training sessions were held, and actions were taken to include these findings in future drills and training sessions, as applicabl Based on the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvemen * More emphasis should be placed in training on the value of evacuation time studies for the OSS as initial Emergency Coordinator. Also the OSS's should be cognizant of the non-delegable responsibilities which they alone have the authority to act upo '

e. Independent Reviews / Audits An annual independent review of the emergency preparedness program was conducted as required during February 3-7, 1986. This included an evaluation of the adequacy of the interfaces with State and local governments. The entire review was made available to the State of i Iowa and Linn and Benton Counties as verified by the inspecto This annual review contained one finding and 11 observations. By licensee definition the finding is of greater importance and requires a written response and correction if one is warranted; while the observations did not required a written response. The findings and the 11 observations were primarily administrative and minor procedure change Communication tests of the HPN telephones were also observed by the audit team. The NRC Team Leader, however, emphasized at the Exit Meeting that he would like to have included as part of the annual review, surveillance tests, observations of practice drills, criticues and even a monitoring of some EP training sessions. This would adc more depth and meaningfulness to the EP review. Licensee management i

indicated that they would consider some of these approaches for future audits / review As listed in Section 4.d the inspectors concluded that a program for follow-up on drill findings and exercise critiques was being conducted and included as part of an internal tracking system.

,

The Manager, Nuclear Licensing and Emergency Planning, is part of

'

the review committee to decide on the priority level for corrective actions on the areas listed abov Based on the above findings, this portion of the licensee's program

'

is adequat . . - -. __- .-__

- . _ . - _ _ _ - - -

. ..

5. Exit Meeting The inspectors met with licensee representatives (denoted in Section 1)

at the conclusion of the inspection on January 9, 1987. The team leader summarized the scope and findings of the inspector. The content of the report was discussed with the licensee to determine whether the licensee was aware of any information that might be considered proprietary. The licensee responded that none of the information should be considered proprietary.

l f

I

1 l 9 i

L