IR 05000341/1999004

Insp Rept 50-341/99-04 on 990503-07.No Violations Noted. Major Areas Inspected:Radiological Emergency Response Preparedness Program,Aspect of Plant Support

ML20207D340
Person / Time
Site:	Fermi
Issue date:	05/26/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207D334	List: IR 05000341/1999004 ML20207D331
References
50-341-99-04, 50-341-99-4, NUDOCS 9906030313
Download: ML20207D340 (12)

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U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No: 50-341 l

. License No: NPF-43 {

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Report No: 50-341/99004(DRS)

Licensee: De'roit Edison Company i

i Facility: Enrico Fermi, Unit 2

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Location: 6400 N. Dixie Hw Newport,MI 48166 Dates: May 3 - 7,1999 Inspectors: R. Jickling, Emergency Preparedness Analyst D. Funk, Emergency Preparedness Analyst Approved by: Gary L. Shear, Chief, Plant Support Branch l Division of Reactor Safety

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EXECUTIVE SUMMARY Enrico Fermi, Unit 2 NRC Inspection Report 50-341/99004(DRS) 4 This inspection reviewed the Radiological Emergency Response Preparedness (RERP)

program, an aspect of Plant Support. The inspectors selectively evaluated the quality of the RERP program, related audits and reviews, reviewed the effectiveness of management controls, verified the adequacy of emergency response facilities and equipment, reviewed a number of RERP training and qualification activities, and followed up on previous inspection findings. This ;

. was an announced inspection conducted by two regional inspector ;

Plant Suooort j e Licensee personnel performed proper classifications and timely notifications during two j actual activations of the emergency plan. (Section P1)

• ' Emergency response facilities, equipment, and supplies were well-maintained and in an adequate state of operational readiness. Demonstration of selected emergency response equipment verified that the equipment was operable and ready for us (Section P2)

e The Condition Assessment Resolution Document system was an effective method to track and close RERP issues. Procedures were clear and easy to use. (Section P3)

e The RERP training program appeared effective. All personnel reviewed were qualifed l for their emergency response positions. Interviewed emergency response organization personnel successfully demonstrated good knowledge of their emergency roles and procedures. (Section PS) ,

e Continued strong management support for the RERP program was indicated during discussions with site and RERP staff. The program showed evidence of improving trends. (Section P6)

• The licensee's 1997 and 1998 Nuclear Quality Assurance audits of the RERP program >

were adequate and satisfed the requirements of 10 Code of Federal Regulations l 50.54(t). The 1998 evaluation of adequacy of interface with State and local govemments lacked supportive documentation. (Section P7)

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Reoort Details IV. Plant Supp_qd -

P1 Conduct of Emergency Preparedness Activities P1.1 Actual Emeroency Plan Activations Insoection Scope (82701)

The inspectors reviewed records and documentation packages regarding plant response for emergency plan activations that occurred since the last routine emergency preparedness program inspection. Also, the inspectors reviewed the procedure for the Radiological Emergency Response Preparedness (RERP) staff's assessment of plant response for actual emergency plan activation Observations and Findinos An Alert was declared at 2:30 a.m. on October 8,1998, based on an operator report of smoke within the Emergency Diesel Generator (EDG) #12 control panel located at the Residual Heat Removal (RHR) Complex. The Emergency Director appropriately declared the Alert using emergency action level (EAL) HA2, " Fire or Explosion Affecting the Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown,"in accordance with EP-101, Classification of Emergencies. The classification was timely and correct. Offsite notifications were made to both Wayne and Monroe Counties, and the State of Michigan, at 2:37 a.m. using Michigan Notification Form 1, which met the 15 minute requirement. The Emergency Notification System (ENS) call to the NRC was completed at 3:19 a.m. and within the one hour requiremen The Alert was terminated at 3:50 a.m. based on stable plant conditions when a visual inspection in the RHR Complex revealed smoke but no flames from the EDG. All notifications for termination of the Alert were completed at 4:05 At 1:18 p.m. on October 10,1998, an electrical fire was confirmed in the Radwaste Building Mezzanine Electrical Motor Control Center. An Unusual Event (UE) was declared at 1:27 p.m. when the Emergency Director correctly classified and declared the UE using EAL HU2," Fire Within Protected Area Boundary Not Extinguished Within ,

15 Minutes of Detection, initial notifications to offsite authorities were completed at 1:30 p.m. The fire brigade leader reported that the fire was extinguished at 1:30 and the UE was terminated at 1:51 p.m. with the plant shutdown and in a safe and stable condition. The NRC was notified via ENS of both the declaration and termination of the UE at 2:24 In accordance with RERP Work Instruction, Revision 1, " Actual Event Package l Preparation," the licensee's EP staff conducted an assessment of plant personnel's emergency response. Documents and records related to the event had been organized into a complete and detailed package. Documents reviewed indicated that the event classification and related notifications of offsite authorities and the NRC were made properly and in a timely manne ] Conclu's ions The inspectors concluded that the licensee appropriately implemented the emergency plan. The emergency classifications were made correctly and offsite notifications were '

timely. The evaluation packages were detailed and provided good assessments of plant l

personnel response to the actual events.

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j P2 Status of EP Facilities, Equipment, and Resources P Material Condition of Emeroency Response Facilities j

, Inspection Scope (82701)

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The inspectors evaluated the material condition of the control room, Technical Support !

Center (TSC), Operational Support Center (OSC), Altemate OSC, Emergency Operations Facility (EOF) and the offsite radiological emergency team (RET) vehicle Emergency plan sampling kits were also inspected. The licensee demonstrated the ,

operability of numerous pieces of emergency response equipment, including radiological survey instruments, dose assessment and plant data computer terminals, and l communications equipment. Records of periodic inventories and equipment tests were also reviewed.

I Observations and Findinos i

! Each facility was well maintained and in an adequate state of operational readiness. No l concems were identifieki during the inspections of emergency supplies, procedures, l forms, and equipment in these facilities. Dose assessment programs, Emergency j l Response Information System (ERIS) and Auto Dose, were demonstrated by the 1 l licensee, and verified operable in the control room, TSC and EOF. The offsite RET '

l vehicles and emergency supplies were in a good state of readiness. A quick connect j l plug was added to the vehicles to operate the portable air samplers. The plug enhanced i personal safety in that direct, manual hookup to the vehicle battery would not be j require New ten mile emergency planning zone (EPZ) maps in the EOF used color coded area !

overlays to designate the States' protective actions ordered for the public. The ten mile !

i EPZ, which had previously utilized subareas based upon compass sectors and distances i to the plant, had been revised to utilize five subareas based on geopolitical boundarie This should clarify the communications for Protective Action Recommendations to the

! State and protective actions taken by the public.

l Inventory records of emergency equipment and supplies for calendar year 1998 through the first quarter of 1999 were reviewed by the inspectors. Onsite and offsite emergency

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kit maintenance responsibility had been changed from the Radiation Protection group to ,

the RERP group, which allowed RERP to better control the kits. Plant Technical Procedure 67.000.405, Revision 12, * Maintenance and Inventory of Radiation Protection Emergency Kits," stated that these inventories should be conducted quarterly and following each use. Also reviewed were monthly communication tests and semiannual

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l Hulth Physics drills. The inspectors' reviews determined that the records and drills had been completed as required and within the appropriate time frame The inspectors also reviewed the May 1997 to March 1999 records, for testing of the emergency call out system. RERP Work Instruction, Revisica 7, " Emergency Call Out .

System Maintenance," stated that emergency call out system " activation ... is performed every two months." All tests were completed as required. For each case when staffing times were not met, comments on the work instruction attachment provided information regarding the identified discrepancies, whether the positions were not filled within the prescribed time frame, whether the position was a required minimum staffing position, and corrective actions, when appropriate. RERP Plan Implementing Procedure, EP-292, i Revision 22, * Emergency Call Out - Backup Method," was also reviewed and determined to be acceptabl Records for the prompt alert and notification sirens for 1997 and 1998 were reviewed by the inspectors. Annual operability for 1997 was 99.59 percent with 97.48 percent for the lowest month's average. The 1998 annual operability average was 99.09 percent with 96.50 percent for the lowest month's average. Siren operability exceeded the annual acceptability limit of greater than or equal to 90 percen c. Conclusions Emergency response facilities, equipment and supplies were well maintained and in an adequate state of operational readiness. Demonstration of selected emergency equipment verified that the equipment was operable. The new geopolitical areas used by the licensee to communicate PARS to the State should prove to be an effective enhancement. Siren operability records indicated the prompt alert and notification sirens had been well maintaine P3 EP Procedures and Documentation a. Inspection Scooe (82701)

The inspectors reviewed a sample of Radiological Emergency Response Preparedness Plan implementing Procedures (EPs) and emergency plan sections, including those related to the December 15,1998 emergency plan revision. Also, the Condition Assessment Resolution Document (CARD) system reports related to the RERP program were also examine ;

b. Observations and Findinas The inspectors reviewed changes to the RERP Plan, Revision 22, dated December 15, 1998. The changes for this revision focused on updating the Nuclear Genersting Organization positions assigned to the Emergency Response Organization (ERO),

adding the Severe Accident Management (SAM) program description, and adding the SAM responsibilities to the TSC positions. Also, telecommunications providers were update .

RERP Plin implementing Procedures, EP-545," Protective Action Recommendations,"

- Revision 13, dated August 20,1998 and EP-110, " Organization and Responsibilities,"

Revision 10, dated December 22,1998, were reviewed by the inspectors. Revision 13 of EP-454 included a conversion table to take the affected sectors and convert them to areas to be protected. Also, maps of the new five EPZ geopolitical areas were adde Revision 10 of EP-110 added SAM program responsibilities to TSC personnel. This provided that the Emergency Director would provide oversight of Severe Accident Guidelines (SAG) implementation, and the Technical Engineer would perform SAG decision makin The inspectors reviewed the CARD system, and associated procedure MQA11, i " Condition Assessment Resolution Document," Revision 1, dated June 3,1998, to j determine the range of issues identified and the effectiveness of identified issue tracking j and disposition. Approximately 32 CARDS related to the RERP program were generated l since the program switched to the plant-wide issue tracking program in 1997. Of the l total 32 CARDS,22 had been closed.

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persons identified, due dates and item status listed. These report printouts were used to document and track the progress of corrective actions related to a spectrum of items

! identified by RERP staff, Nuclear Quality Assurance (NQA), and other plant personnel.

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An improvement item List was used in concert with the CARD system, to capture issues identified during critiques of exercises, drills, and classroom training. From January 1997 through April 1999, a total of 98 improvement items had been identified, tracked,

! with 88 of the items closed.

l The Fermi Public Information Emergency Preparedness Booklet, distributed to the public l during the month of December 1998, was reviewed by the inspectors. This document

included information on how individuals can be prepared for an emergency, emergency sirens, evacuation, maps, and basic information about radiation. The information was clearly presented and appeared to be appropriat Conclusions

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The CARDS and the improvement item List were effective methods to track and close RERP issues, and had been appropriately used by the RERP staff. RERP Plan Implementing Procedures were clear and easy to use. The Fermi Public Information Emergency Preparedness Booklet was easy to read and appeared to be appropriat P5 Staff Training and Qualification in EP

Insoection Scope (82701)

The inspectors reviewed various aspects of the RERP training program. The review ,

l included interviews with selected key emergency response organization personnel (an l EOF Emergency Officer, a control room communicator, a control room Emergency j

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Director, and a TSC Emergency Director), review of drill and related critique records, attendance records, and the call out list of ERO personnel. Records from the training

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tracking progr:m were compared with the call out list to determine whether listed personnel were qualified. Respirator and Self Contained Breathing Apparatus (SCBA)

qualifications of plant personnel were also reviewe Observations and Findinos Interviews with four key emergency response personnel indicated a good knowledge of procedures and emergency responsibilities. The EOF Emergency Officer and the TSC Emergency Director displayed appropriate knowledge of the NRC's incident response program and the Federal Radiological Monitoring and Assessment Center. During the interviews, personnel uniformly commented that the RERP staff was professional, responsive, and proactiv Discussions and records reviewed indicated that quarterly, or as needed, revisions to the ERO call out list were issued, as appropriate, since the last inspection. Review of the call out list indicated that the numbers of personnel assigned to specific positions in the ERO were acceptabl The training records tracking program printout was compared with the ERO call out list to verify personnel on the call out list were qualified. All ERO personnel reviewed were currently qualified for their emergency response positions. Training files contained appropriate documentation, including tests and attendance forms. Formal feedback forms were available, which provided an open forum for comments related to RERP training and indicated effective training was being conducte Review of respirator and SCBA qualification documentation provided the following information:

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Resperator/ SCBA7Qh~all5MRicissWg%yN(a M* ' *. ;

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DEPARTMENT NUMBER oF TRAINING / MEDICAL RESPIRATOR sCBA QUALIFIED INDivlDuALs QUALIFIED oVAUFIED Radiation Protection 34 34/30 30 29 l Operations 109 109/98 98 97 Instrument Maintenance 36 36/27 27 26 Electrical Maintenance 26 26/19 19 18 Mochanical Maintenance 39 39/34 34 33 Chemistry 26 26/23 23 22

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Welders 6 6/6 6 6 i

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NRC Information Notice 98-20, * Problems with Emergency Preparedness Respiratory Protection Programs," was issued June 3,1998. This information notice alerted licensees to multiple generic weaknesses in respiratory protection programs supporting emergency preparedness. Respiratory protection qualifications included three parts; respiratory training, medical testing, and a mask fit. The numbers above represented the

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current respirctory qualifications by department. The results of this review indicated that I

there appeared to be sufficient respirator and SCBA qualified personnel to respond in the event of an emergency. Discussion indicated that licensee personnel were aware of the information notice, and had evaluated its informatio . c. ' Conclusions The_ overall effectiveness of the RERP training program was good. Training, drills, and -

l exercises were properly critiqued. Interviewed ERO personnel demonstrated very good

- knowledge of their emergency roles. Personnellisted on the ERO call out list were

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~ currently qualified for their emergency position P6 EP Organization and Administration Insoection Scoos (82701)

The inspectors conducted discussions with the RERP staff regarding the current organization and any change Observations and Findinas No significant changes had been made to the EP organization since the last routine inspection in May 1997. ' The RERP Supervisor reported to the Director, Nuclear Licensing who reported to the Assistant Vice President, Nuclear Assessment. Four Emergency Response Specialists and an Office Specialist reported to the RERP Supervisor. All of the specialists and the supervisor had responsibility for administration of the ERO training program. Scheduling, implementation, development, and maintenance of the RERP training program had been provided by the RERP group for-the last year and a hal Discussions with the RERP staff identified a number of enhancements to the program had been completed. In addition to assuming responsibility for the onsite and offsite emergency kits from the radiation protection group, the FERP staff implemented the Severe Accident Management program in December 1998. The telephone system used in the emergency response facilities was upgraded with new digital equipment during the third quarter of 199 , Conclusions Discussions with the RERP staff and site personnel indicated appropriate management support to the program. Upgrades and enhancements, plus the RERP staffs responsive approach have continued improving trends in both the program and trainin p i#

l P7 Quality Assurance in EP Activities L

P Audits t Insoection Scoos (82701)

The inspectors reviewed Nuclear Quality Assurance (NOA) audit reports for 1997 and

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1998. The ' aview also included an interview with the Supervisor of Audits. No RERP program self assessments had been conducted since April 2 and 14,199 Observations and Findinos The inspectors revl'ewed NQA Audit 97-0116," Emergency Preparedness Program,"

conducted by seven individuals during April 28 through May 9,1997. The audit reviewed past reports, emergency procedures, letters of agreement, training, response to

. emergencies and past NQA findings. The audit concluded that the " Radiological Emergency Preparedness Program is assessed as effective in implementing the requirements of the RERP Plan." The audit team identified one Deficiency Event Report (DER) regarding the failure to distribute a revised procedure and one observation. Six previous NQA audit 96-0116 DERs were reviewed and closed. The audit also contained i

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an evaluation, in Enclosure 1 to the audit report, of the adequacy of interfaces with State and local govemments, which is required by 10 Code of Federal Regulations (CFR)

50.54(t). The evaluation of adequacy of interface had been accomplished by a documentation review and telephone interviews.

l NQA Audit 98-0108 was conducted by four individuals during April 20 through May 8, l 1998. The audit reviewed emergency procedures, letters of agreement, training, drills

and exercises and past NQA findings. The audit concluded that the " Emergency ,

Response Preparedness Program is assessed as effective in assuring that Fermi is '

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ready to properly respond to emergencies to protect the health and safety of the public

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and plant personnel." The audit team issued five CARDS: two level 3 CARDS that do not l represent deficiencies in the RERP program and three level 4 CARDS for recommended i improvement opportunities. Two previous findings and observations were reviewed and closed, j

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l The inspectors also reviewed the 1998 audit report to ascertain if the evaluation for )

l adequacy of interface with State and local govemments required by 10 CFR 50.54(t) j was conducted. The audit report, under the heading " Interfacing with outside agencies",

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contained the statement "The actions taken to maintain communications with outside agencies is a strength." By this statement, it was not clear to the inspectors that the j communications with outside agencies included the State of Michigan and local !

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govemments (Monroe and Wayne Counties).

o Discussion with the Supervisor of Audits determined that the evaluation of adequacy was {

not clearly supported by documentation in the audit report and background informatio l A review of the audit plan revealed that the methods of verification from the 1997 to the !

1998 audit had changed. While the 1997 audit plan method of verification was very

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prescriptive in its instruction of how to conduct the evaluation of adequacy, the 1998 l audit plan did not include any instructions. The licensee initiated CARD No. 99-12453 to address the inspectors' concerns related to this activit During the exit meeting and in a phone call with NRC management and the Assistant Vice President, Nuclear Assessment, on May 13,1999, it was confirmed that the evaluation for adequacy of interfaces with the State of Michigan and local governments had been accomplished. The licensee agreed with the inspectors' assessment that their evaluation of adequacy could have been better documented in the 1998 program audi Conclusions i

The licensee's 1997 and 1998 RERP program audits satisfied the requirements of 10 CFR 50.54(t). Corrective actions resulting from the audits were properly tracked and l completed within reasonable times. Evaluation of adequacy of interfaces with State and local govemments for the 1998 audit lacked supporting documentatio X1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the l conclusion of the inspection on May 7,1999. The licensee acknowledged the findings

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presented. The licensee did not identify any items discussed as proprietar l

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l PARTIAL LIST OF PERSONS CONTACTED '

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Licensee ~

J. Baum, Specialist, Radiological Emergency Response Preparedness S. Booker, Superintendent, Work Control l J. Bragg, Supervisor, Nuclear Quality Assurance J. Davis, Director, Nuclear Training J. Davis, Superintendent, Outage Management P. Fessler, Assistant Vice-President, Nuclear Operations G. Garber, Specialist, Radiological Emergency Response Preparedness R. Gaston, Compliance Supervisor, Nuclear Licensing K. Hlavaty, Superintendent, Nuclear Operations K. Howard, Engineering Director, Plant Support J. Kauffman, Specialist, Radiological Emergency Response Preparedness J E. Kokosky, Manager, Radiation Protection

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K. Morris, Supervisor, Radiological Emergency Response Preparedness J. Moyers, Director, Nuclear Quality Assurance W. O'Connor, Assistant Vice President, Nuclear Assessment M. Offerle, General Supervisor, Radwaste J. Pendergast, Principle Engineer, Compliance S. Peterman, Engineer, Operations N. Peterson, Director, Nuclear Licensing J. Plona, Technical Manager S. Stasek, Supervisor ISEG NRC S. Campbell, Senior Resident inspector J. Larizza, Resident inspector l

INSPECTION PROCEDURES USED iP 82701 Operational Status Of The Emergency Preparedness Program

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- LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened None

Closed None j Discussed None

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LIST OF ACRONYMS USED CARD Condition Assessment Resolution Document CFR Code of Federal Regulations DER Deficiency Event Report DRS Division of Reactor Safety l EAL Emergency Action Level i EDG Emergency Diesel Generators i ENS Emergency Notification System EOF Emergency Operations Facility EP Radiological Emergency Response Preparedness Implementing Procedure ,

EPZ Emergency Planning Zone  ;

ERIS Emergency Response Information System ERO Emergency Response Organization NQA Nuclear Quality Assurance OSC Operational Support Center PAR Protective Action Recommendation RERP Radiological Emergency Response Preparedness '

RET- Radiological Emergency Team RHR Residual Heat Removal SAG Severe Accident Guidelines SAM Severe Accident Management SCBA Self Contained Breathing Apparatus TSC Technical Support Center UE Unusual Event l

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