IR 05000331/1997003

Emergency Preparedness Insp Rept 50-331/97-03 on 970203-07. No Violations Noted.Major Areas Inspected:Review of Emergency Preparedness Program

ML20136E064
Person / Time
Site:	Duane Arnold
Issue date:	03/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136E034	List: IR 05000331/1997003 ML20136E029
References
50-331-97-03, 50-331-97-3, NUDOCS 9703130102
Download: ML20136E064 (14)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil

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Docket No: 50-331 i

License No: DPR-49

Report No: 50 331/97003(DRS)

Licensee: lowa Electric Company Facility: Duane Arnold Energy Center

. Location: RR#1

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Palo. Iowa Dates: February 3-7, 1997 Inspectors: James E. Foster, Sr. Emergency Preparedness Analyst Robert D. Jickling, Emergency Preparedness Analyst Approved by: James R. Creed, Chief, Plant Support Branch 1

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Division of Reactor Safety

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l 9703130102 970305 PDR ADOCK 05000331

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EXECUTIVE SUMMARY Duane Arnold, Unit 1 NRC Inspection Report 50 331/97003(DRS)

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 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 an actual activation of the Emergency Plan. (Section P1.1)

Each emergency response facility was well maintained and in an excellent operational state of readiness. (Section P2.1)

Quality assurance oversight of the EP program was very good. (Section P7)

The inspector completed Temporary instruction 2515/134 "Onshift Dose Assessment" and verified that the licensee's capabilities met requirement (Section P9)

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Renort Details I P1 Conduct of Emergency Preparedness (EP) Activities P Actual Emeroency Plan Activation

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' Inspection Scone (82701)

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The inspectors reviewed emergency plan activations which had occurred since the last routine inspectio Findinas and Obsgrvations I

An Unusual Event was declared at 12:49 p.m. on Octob6 28,1996, when a j

potentially contaminated, injured individual was transported to a local hospital. The l individual had received a piece of metalin his eye while working in the drywell, and it could not be determined whether the piece of metal was contaminated, although contamination monitors and area scans did not detect any contamination. A health physics technician was dispatched to accompany the injured individual and deal with any contamination. The health physics technician reported back that the piece of metalin the individual's eye was not contaminated, and the Unusual Event was exited at 1:58 p.m. The Unusual Event was retracted at 4:15 p.m. the same dat ' Local and NRC notifications were made well within the required timeframes of 15 minutes and one hour, respectivel Discussion with the EP staff indicated that the Emergency Plan and implementing procedures did not provide for the " retraction" of an event. Additional discussion l

was held on the positive and negative aspects of " retracting" an emergency I classification rather than " cancelling" the event, as provided by the Emergency Plan j and implementing procedures. Action Request 970386 was generated to document I the need for procedural guidance relative to event cancelling / terminating and evaluate the option of retracting a declared even Records reviewed indicated that the classification was conservative, and '

notifications had been made properly and in a timely manner. The documentation package for the event was adequate. A procedure did not exist for the collection of actual event documentation, conduct of event critiques, or overall event response evaluatio Conclusions The inspector concluded that the licensee had conservatively implemented the emergency plan in declaring the Unusual Event. The licensee's review of the event was considered adequate, although a procedure did not exist for the collection of actual event documentation, conduct of event critiques, or overall event response evaluatio _ . , - --

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l l P2 Status of EP Facilities; Equipment, and Resources P Material Condition of Emernancy Reanonne Facilities Insnaction Scone (82701)

The inspectors toured the Technical Support Center (TSC), Operational Support l Center (OSC), Offsite Radiological and Analytical Laboratory /Offsite l Decontamination Facility (ORAL /ODEF), and Emergency Operations Facility (EOF)

and assessed their material condition. The field team monitoring kits were also

inspected. The inspectors requested numerous pieces of equipment (survey l equipment, computers) to be operate Findinas and Observations Each facility was well mainteir, d and in an excellent operational state of readines ' Current copies of the Emergency Plan, Emergency Plan Implementing Procedures (EPIPs), and appropriate forms were present in each facility, as required. Major changes to fac!!: ties, such as provisions for NRC site team seating, had been completed prior to the April g,1996 emergency exercise. Minor enhancements intended to improve performance were noted in various facilities. A wall with two cardkey locked doorways had been erected in the EOF, and minor revisions to J

status boards were noted. No problems were identifie Two air portable samplers were found configured so that the air exhausted from the unit was directed toward the area being sampled, effectively recirculating some of the filtered air. These air samplers were found in the onsite emergency equipment lockers and in the ORAL. The identified configuration could affect the representativeness of the air sample. The issue was discussed with health physics

personnel and resulted in the two air samplers being taken out of service until

' further information could be obtained. The licensea initiated an Action Request to document this issue. Radiation Protection personnel indicated that other similar air samplers would be checked to determine if this configuration was presen Documents reviewed indicated emergency equipment inventories and maintenance were properly performed, with timely corrective actions such as replacement of expended stock where deficiencies were identifie Conclusions i

Overall, emergency response facilities were in excellent material condition. Two air samplers were found configured with the air exhausted from the unit directed toward the area being sampled, possibly affecting the representativeness of the air sample. Several minor facility enhancements were noted in each facilit l

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. P3 EP Procedures and Documentation

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a .' Insoection Scone (82701)

The inspector reviewed a selection of licensee emergency procedures and EPIP Action Requests assigned to the Emergency Planning Group were also reviewe V Findinas and observations

Discussion with licensee personnel indicated that the Corporate Plan was being !

eliminated and Corporate Plan implementing Procedures (CPIPs) were being

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converted to EPIPs as appropriate, and the entire CPIP series canceled in the near future. Licensee staff indicated they would also be implementing the Emergency i

Action Level system developed by the Nuclear Management and Resources Council !

(NUMARC) in the near futur I

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Emergency Planning Department Procedure 1008.4 covered maintenance of

emergency response facilities and emergency equipment. This procedure provided for quarterly and post use inventories of emergency supplies in the Control Room,

Technical Support Centeri Operational Support Center, offsite Relocation and .

j Accountability Area, and Offsite Radiological and Analytical Laboratory (ORAL).

Inventory forms for each facility were provided. Also included in this procedure

were inventory forms pertaining to the Joint Public Information Center, EOF, Mercy Medical Center, University of Iowa, and various equipment kit The inspector reviewed the procedure for sampling snow as a part of the field monitoring team environmental sampling process. The procedure, Environmental Sampling Procedure ESP 4.1.1.12, " Snow Sampling", Revision 2, called for gathering the equivalent of one gallon of water after the snow melts. It was not clear to the inspector how the results of the sample could be related to the area where the sample was obtained. The purpose of the procedure, depth of sample taken, units for the area sampled, and how sample results could be converted into a

contamination level per area, was discussed with the Chemistry Supervisor. Action i Request 970463 was written to document the need to clarify the procedure, Conclusion Inventories indicated that supplies were appropriately inventoried and squipment problems identified and corrected appropriately. Minor problems were identified in the snow sampling procedur P5 Staff Training and Qualification in EP Insoection Scoos (82701)

The inspector reviewed the licensee's EP training program. This included interviews with selected key individuals, and review of course critique forms, attendance records, and the Emergency Plan Telephone Book for emergency response

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organization (ERO) personnel. Additionally, selected training instructor's guides

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were reviewed, including the Emergency Federal Response and facility walkthrough guides for the TSC, OSC, and the EOF.

. Findinas and Observations

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Records indicated that drills and exercises were formally critiqued. Training had i

' beenl provided which outlined formal critiques, and selected critique items were documented for corrective action. The primary means for annual requalification i

- training had been changed to drill and exercise participation instead of classroom

' attendance. If participation in a drill or exercise did not occur, a facility tabletop session or one on-one instruction would be acceptable for annual requalification.

initial EP training had been streamlined into a facility specific, modular forma Instead of approximately 192 Instructor's Guides for each specific ERO position and for requalification treining, there were ten Instructor Guides; one for each facility, one for initial indoctrination training, and one for Emergency Federal Response.

) Records from the training records tracking program were compared with the i

Emergency Telephone Book (issued quarterly) to verify ERO personnel listed in the book were qualified. Ten ERO personnel reviewed had not received annual requalification training and were listed in the current Emergency Telephone Book, Notification and Call List section dated January 6,1997.

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The DAEC Emergency Plan, Revision 18, Section 2.5.1, indicated that " Annual l'

d requalification training shall be conducted to maintain proficiency " Of these ten ERO persons with expired qualifications listed in the Emergency Telephone Book,

one person was on sick leave (out of the state), three were to be deleted from the

' emergency organization and not available to respond to an emergency call, and five were waiting to participate in the next dril Also, an Action Report had been initiated during the 1996 EP Program audit to address the out of-qualification personnel listed in the Emergency Telephone Boo The licensee's review and actions regarding out of-qualification ERO personnel'

identified in the Notification and Call List sections of the Emergency Telephone Book will be tracked as an inspection Followup item (50-331/97003-01(DRS)).

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Interviews were conducted with the two key ERO persons. The individuals interviewed demonstrated excellent knowledge of their emergency responsibilities and procedure The Instructor's Guide for Emergency Federal Response was a four hour presentation for selected key ERO personnel. The guide was extremely detailed and delineated the Department of Emergency's Federal Radiological and Assessment Center response, numerous other Federal agencies' responses, and the NRC's emergency response responsibilities and organizatio I l

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During the fourth quarter 1996 Assessment, it was identified that the changes to the EP training program lacked assurance that Updated Final Safety Analysis Report !

(UFSAR) commitments would be met to have trairdng address procedure changes and industry events. This was tracked via Action Request 9616732, which'was

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olosed based on revising the UFSAR to correctly reflect training and delineating the process for accomplishing future ERO continuing training. Emergency Planning Department Manual 1000 had been revised to add a comprehensive attachment for EP requalification training to ensure changes to the emergency plan and procedures, facilities and equipment, ERO organization, lessons learned from exercises and

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drills, and pertinent industry events were included during the drills and exercises, I tabletop sessions, and one-on-one trainin Records indicated that drills and exercises were formally critiqued, training had been provided formal critiques, and significant critique items were appropriately selected for corrective actio c. Conclusiorja Overall, EP training was considered very good, with six drills per year which provided performance based requalification training for the ERO personnel. Critique documentation was available and critique forms were adequately detailed. Training records were complete and interviewed individuals were knowledgeable about their ERO responsibilities. NRC and Department of Energy incident response information provided to key ERO personnel was extremely detailed and comprehensive. An Inspection Followup Item was identified for listing out of qualification and unavailable personnelin the notification and calllist section of the Emergency Telephone Boo P6 EP Organization and Administration (82701)

The overall organization and management control of the EP function was extensively changed since the last inspection in addition, the Emergency Planning staff had moved from the Corporate Office to the Duane Arnold site. The positions of Manager, Emergency Planning and Supervisor, Emergency Planning, have been combined. The Emergency Planning Supervisor now reports directly to the Manager, Regulatory Performarce, who reports to the Vice President. The Emergency Planning Staff has lost approximately three positions since the last routine inspection. Position and group tasks had been reapportioned, and the decrease in staff did not appear to decrease their effectivenes P7 Quality Assurance in EP Activities P Audits (82701)

a. Insoection Scone (82701)

The inspector reviewed Quality Assurance Department Audits which have been performed since the last routine inspectio >

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, Findinas and Observations e

i The inspector reviewed Audit Report I-95-10, " Emergency Plan and implementing Procedures Audit," dated August 9,1995. The audit was conducted by three individuals between June 26 - July 21,1995, and resulted in two findings (relative

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to document control and qualification tracking) and one recommendation regarding

training on use of the NRC notification form. The audit was highly detailed and

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comprehensive, with tables depicting items reviewed. Records and procedures

' were reviewed, and drill performance was observed and evaluated during the audi Minor procedure enhancement comments were provided to the EP staff as an attachment to the audit report. A standardized questionnaire was utilized for interviews with offsite authorities in assessing the adequacy of offsite interface.

i The overall audit was outstandin !

) Discussion with licensee personnel disclosed that a major revision had subsequently

been made to the audit program. Instead of a single document, assessments of the i

Emergency Program were spread over the year, and reported in a section of the Quality Assurance Quarterly Assessment report. For calendar year 1996, I assessments in the Emergency Planning area were documented in first, second, and fourth quarter Quarterly Assessment Reports 0-04/l-96-01, -02, and -04. The three reports were highly detailed, and, taken as a whole, very comprehensive.

Procedure, and plan reviews, drill observation, and an assessment of offsite

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interface were included in the course of the year. The auditors had also reviewed

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applicable portions of the UFSAR The fourth quarter report contained a comprehensive 1996 overview of Emergency Planning Assessments. The overall EP audit effort was outstanding.

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The 1995 and 1996 audits of the EP program satisfied the requirements of 10 CFR

! 50.54(t) with respect to scope. Records also indicated that the EP staff fulfilled the

requirement to make relevant audit results available to State and county official .etters to State and County officials provided their input to the offsite interface evaluation and advised that the entire report would be made available upon request.

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The licensee's 1995 and 1996 audits of EP activities were very effective and

, satisfied the requirements of 10 CFR 50.54(t).

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(Closed) Inspection Follow-up item (50 331/96003-04(DRS)): During the 1996

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exercise, considerable discussion centered around the protective action

! recommendation (PAR) flowchart included as Attachment 1 in Emergency Plan Implementation Procedure 3.3, " Dose Assessment and Protective Action." The licensee agreed to review of the PAR flowchart for possible revision. The licensee has revised the PAR flowchart to be consistent with the guidance in NUREG-0654, Revision 3. Discussion indicated that the revised PAR flowchart had been discussed with State officials. This item'is close .- . .-- - . . --- - . - - . , . .

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P9 Temporary Instruction 2515/134 Onshift Dose Assessment J

Insoection Scone

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' The inspector 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 assessment.

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y Findinus and Oh==rvations '

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The Emergency Plan contained provisions for on-shift dose assessment in Section '

6, " Emergency Measures." Section 6.1, " Shift Supervisor / Control Room

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Operators," Item 6.1.1.b.2, provided for the Shift Supervisor (initial Emergency

! Director) to implement the applicable Emergency Plan Procedure.

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The primary dose assessment method was via the Meteorological Information and

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Dose Assessment System (MIDAS) dose assessment program via inputs from plant monitors and meteorological data from the plant towe Dose assessment was covered in the Emergency Plan Section 2.2.6, which

' described how information was provided through the Kaman effluent monitoring system to the MIDAS program running on the plant process computer. If the MIDAS dose projection program was unavailable, Section 2.4.2 provided for running a PC-based program on laptop computers available in the TSC and EO The Duane Amold Emergency Plan, Section 2.3, " Exposure Control," Paragraph 2.3.1,~" Exposure Monitoring," indicated, in part, that the on-shift chemist had been assigned to run the MIDAS Dose Projection Syste .

' Emergency Plan implementing Procedure (EPIP) 2.5, " Control Room Emergency Response Operations," Revision 11, Section 4.2.2, provided "At initial Emergency Classification, the on-shift Chemist will report to the TSC to run MIDAS."

" Projected doses shall be communicated to th6 Control Room until the TSC is activated."

EPIP 3.3, Dose Assessment and Protective Action, Revision 12,in a note to Section 3.2.5, also provides for initial dose assessment by the on-shift chemist. Section 4.5, " Dose Projection Activities," Paragraphs 4.5.1-4.5.3 described the use of MIDAS in the TSC, with backup provided by the MIDAS laptop personal compute ~

Until the TSC is activated, it is the responsibility of the Operations Shift Supervisor, as the Emergency Coordinator, to assure the performance of dose projections by the on-duty shift chemis /

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Equipment in the TSC and EOF for support of MIDAS was inspected, and the program run. User aids were available at both units to clarify the initial sign-on procedure. Discussion with licensee personnel indicated that adequate training was provide .1 - - - ~ '

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f Adequate information, training, and procedures were in pisce and in use. This Tl is closed, documentation of the Tlis attached as Attachment A.

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The Emergency Plan and EPIPS contained provisions for onshift dose assessmen Needed equipment and personnel training were provided. Personnel were knowledgeable of their responsibilities and how to perform dose assessment. The 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 insoection Scone

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A discovery of a licensee operating their facility in a manner contrary to the

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Updated Final Safety Analysis Report (UFSAR) description highlighted the need for '

" a special focused review that compares plant practices, procedures, and parameters i

to the UFSAR descriptions. While performing the inspections discussed in this j

report, the inspector reviewed the applicable portions of the UFSAR that related to Emergency Preparednes !

, Observations and Findinas UFSAR Section 13.1.1.2.2.1 "Duane Arnold Energy Center," and Figure 13.1-1 I identified the positions of key personnel in the Emergency Flanning organizatio Section 13.2.7, " Emergency Preparedness Training," describes the training provided to individus!s assigned positions in the Emergency Response Organization. UFSAR change 96102 provided improved wording for this section, while not changing previous commitment UFSAR Section 13.3 pertains to Emergency Planning. It notes that a separate Emergency Plan was submitted, dated August 1981. Also referenced was the l

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Corporate Emergency Response Plan (to be deleted). The location of the Supervisory portion of the OSC has also changed location. UFSAR change 97-026 provided for appropriate changes or updates to this section. An overview of EP l would enhance this section of the UFSAR. The UFSAR was not meant to contain a full site Emergency Plan, nor be updated each time an Emergency Plan change was made. Internal NRC guidance was not specific as to the acceptable level of detail for this section of the UFSAR, but general practice has been to place an overview of the Emergency Plan in this sectio Section 13.5.2.2.2, " Emergency Planning Procedures," pertained to the Corporate and site EPIP _ _ . - __ -

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Section 17.2.18.22, " internal Organizations," provided requirements for the Emergency Plan and implementing procedures to be audited at least once per 12 3 month Conclusions Overall maintenance of the Emergency Preparedness sections of the UFSAR was

excellent. Licensee actions were consistent with UFSAR commitments. As noted in Section P7.1.b, the UFSAR sections have been reviewed during audit activitie The UFSAR should contain some general overview information as to the Emergency Preparedness program. Licensee personnel indicated this would be considered for the next UFSAR revision.

I X1 Exit Meeting Summery

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' The inspector presented the inspection results to members of licensee management at the

' conclusion of the inspection on February 7,1997. The licensee acknowledged the findinos presented.

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The inspector asked the licensee whether any materials examined during the inspection

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should be considered proprietary. No proprietary information was identifie _ _- _ _ . _ _ _ _ _ _ _ . .- __ _ _ . . _ _ _ _ _ _ . _ _ _ . _ _ . . _ ._ . __

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k 4 PARTIAL LIST OF PERSONS CONTACTED Licensee

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K. Putnam, Licensing Supervisor

' C. Vogeler, Emergency Planning R. Hite, Radiation Protection Manager

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L. Heckert, Manager, Emergency Planning  !

K. Peveler, Manager, Regulatory Performance R. Anderson, Manager, Outage & Support  !

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G. Van Middlesworth, Plant Manager D. Johnson, Emergency Planning )

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K. Williams, Emergency Planning i

K. Morgan, Quality Assurance

P. Sullivan, Emergency Planning f P. Tillman, Emergency Planning ,

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i C. Hilzendager, Emergency Planning L. Gibney, Emergency Planning

, K. Dunlap, Emergency Planning ,

C. Titella, Emergency Planning I K. Young, Manager, Training NBC.

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K. Riemer, Senior Resident inspector, Duane Arnold i C. Lipa, Resident inspector, Duane Arnold

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INSPECTION PROCEDURES USED

IP 82701 Operational Status of the Emergency Preparedness Program

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Tl 2515/134 Temporary Instruction, Onshift Dose Assessment

ITEMS OPENED AND CLOSED

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i 50-331/97003-01 IFl Unavailable and out of qualification ERO personnelin Notification and Call List

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Closed 50-331/96003-04 IFl Review of Protective Action Flowchart i

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LIST OF ACRONYMS USED

CFR Code of Federal Regulations

DAEC Duane Arnold Energy Center

EAL Emergency Action Level i EP Emergency Preparedness )

ENS Emergency Notification System EOF Emergency Operations Facility

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EPIP Emergency Plan implementing Procedure ERO Emergency Response Organization l

) IFl inspection Followup Item i IR Inspection Report NRC Nuclear Regulatory Commission NUREG Nuclear Regulatory Commission document

, ORAL Offsite Radiological Analysis Laboratory

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ODEF Offeite Decontamination Facility OSC Operational Support Center TS Technical Specification TSC Technical Support Center UFSAR Updated Final Safety Analysis Report l

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ATTACHMENT A FORfA FOR DOCUMENTATION OF ONSHIFT DOSE ASSESSMENT CAPABILITY ,

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Duane Amold Eneroy Center / Unit 1/ 50-331 IES Utilities. In /04/96 i SITE / UNIT / DOCKET #s LICENSEE DATE t

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' 4.011 ,i DOSE ASSESSMENT COMMITMENT IN EMERGENCE PLAN .4 -

Acceptance Criterie Person (s) Contacted Peeltson Title (s) Plan Section Revisen N Meets acceptance !

(Refer to page 1 of this Appendix for containing and Dato critorie?

further detail on the acceptance criteria) commitment

Larry Heckert EP Supervisor Section K, paragraph Rev.18, Yes  !

Section 4.01 Item Charles TireHa Emergency Planner 2.3. /95 i

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Emergency Plan contains commitment for on-shift dose assessment capabilit Larry Heckert EP Supervisor Section I, paragraphs Rev.18, Yes Section 4.01 item 2 Charles Tireus Emergency Planner 2.4.1 and 2. /95 Emergency Plan contains commitment for

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backup dose assessment capability.

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YO4.02'ONSHIFT DOSE ASSESSMENT EMERGENCY PLAN WlEPLEMENTWIG PROCEDURE Person (s) contacted Position Title (s) Procedurellndication Revision N Meets acceptance and Date criteria?

Larry Heckert EP Supervisor EPIP-2.5, paragraph Rev.11, Yes Section 4.02 Item 1 Charles Tirella Emergency Planner 4. /94 Procedure initiates dose assessment Larry Heckert EP Supervisor EPIP-3.3, paragraphs Rev.13, Yes Section 4.02 Item 2 Charles Tirella Emergency Planner 3.2.5; 4.5.1; 4.5.2; 4/94 Indications initiate dose assessment 4. Larry Heckert EP Supervisor EPIP- Rev.13, Yes Section 4.02 item 3 Charles Tirena Emergency Planner 4/94 '

Procedure for performing dose assessment availab '

~ 04.03SON ISHIFT DOSE ASSESSMENT TRAINWIGL

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

Larry Heckert EP Supervisor Chemistry n/a Yes l Section 4.03 Item 1 Charles Tirella Emergency Planner Technicians; 10 Onshift Personnel trained for dose assessment

, Insoector Thomas P%@i R=<=1 IIL DRS. Plant haa~t Br.1

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2515/134 A-14 issue Date: G.~/26/96 I

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