IR 05000346/1985019
| ML20136H363 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 08/06/1985 |
| From: | Patterson J, Phillips M, Ploski T, Matthew Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20136H338 | List: |
| References | |
| 50-346-85-19, TAC-59702, NUDOCS 8508200279 | |
| Download: ML20136H363 (21) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-346/85019(DRSS)
Docket No. 50-346 License No. NPF-3 Licensee: Toledo Edison Company Edison Plaza '
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300 Madison Avenun Toledo, OH 43652
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Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Davis-Besse Site, Oak Harbor, OH Inspection C ted: 11 15-18, 1985 Inspectors: . Plo ki p Team Leader Date V
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Date Approved By: lef [/[
Emergency Preparedness Section Date -
Inspection Summary Inspection on July 15-18, 1985 (Report No. 50-346/85019(DRSS)) l Areas Inspected: Routine, announced inspection of the Davis-Besse Nuclear Power Station emergency preparedness exercise, involving observations by nine NRC representatives of key functions and locations during the exercise. The inspection involved 195 inspector-hours onsite by four NRC inspectors and five consultant '
Results: No violations, deficiencies, or deviations were identifie *
However, exercise weaknesses were identified as summarized in the Appendi _
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DETAILS Persons Contacted NRC Observers and Areas Observed T. Ploski, Control Room, Technical Support Center (TSC), Emergency Control Center (ECC)
C. Paperiello, ECC W. Hansen, Control Room J. Martin, Operational Support Center (OSC) and Inplant Teams R. Traub, OSC and Inplant Teams M. Good, TSC T. Essig, ECC J. Patterson, Radiological Testing Laboratory (RTL) and Offsite Radiological Monitoring Teams M. Smith, Joint Public Information Center (JPIC)
Toledo Edison Personnel J. Williams, Senior Vice President, Nuclear Operations R. Crouse, Senior Vice President, Operations L. Shaffer, Assistant to the Chairman T. Murray, Assistant Vice President, Nuclear Operations L. Storz, Plant Manager S. Queenoz, Group Director of Engineering S. Danielson, Lead Exercise Controller T. Kevern, Lead Onsite Controller W. O'Connor, Controller L. Stalter, Controller J. Scott-Wastik, Controller R. Brown, Cuntroller G. Reed, Controller J. Syrowski, Controller S. Goldman, Controller J. Lingenfelter, Controller J. Marley, Controller '
A. Lee, Controller All the above licensee personnel attended the July 17, 1985 exit interview. That meeting was also attended by a number of exercise participants, whose presence and participation in the meetinD were considered appropriate by the inspector . Licensee Action on Previously-Idontified items (0 pen) Open item No. 340/82001-10: The station's seismic monitoring capability must be upgraded; related procedures written; 1nd required training provided. As indicated in Inspection Report 50-540/85011(DRSS),
three related procedures have been written; however, one was still undergoing internal review. Training on the three procedures for all l
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licensed operators was expected to be completed 3009.31by June had not 198 yet received the inspector determined that procedure AP Consequently, licensed final approval of the Station Review Boar operator training on AP 3009.31, AD 1827.07, and SP 1105.17 had been This item delayed, pending final approval of the AP-series procedur remains open pending approval of all three procedures and completion of related trainin (Closed) Open Item No. 346/84002-02: Revise Section 6.5.1 of the Emergency Plan to specify who, by title, has the authority to authorize emergency worker radiation exposures in excess of regulatory limit The inspector reviewed Revision 8 to the Plan, dated March 1985, and determined that those persons given such authority had been specified by position title. Revision 7 to procedure This EI 1300.00 was consistent item is considered close with this aspect of the Emergency Pla (Closed) Open Item No. 346/85002-04: The licensee must revise the wording of Section 8.3 of the Emergency Plan to conformThe withinspector the regulatory requirements as stated in 10 CFR 50.54(t). This reviewed Section determined that the required word change had been incorporate item is considered close Revise the wording of Section 8.1.2, (Closed) Open Item No. 346/85002-05:
paragraph e.2 of the Emergency Plan to clearly indicate The frequency inspector of drills I involving the use of the post-accident sampling syste reviewed Revision 8 of the Plan, dated March 1985, and determined that itis This item clearly stated that such drills would be conducted annuall considered close Open Items No. 346/85001-01 through -03: The licensee must (0 pen)
re-evaluate all EAL conditions for applicability during any mode of plant operation and ensure that adequate procedural guidance is given to ensure that an emergency is properly classified and declared whenever
. (0 pen Item appropriate EAL indicators have been satisfied.The licensee must have consisten (50-346/85011-01));
footnotes preceding the EALs listed in the Emergency Plan and in procedure El 1300.01. (0 pen item (346/85011-02)); and, the licensee must re evaluate the need for requiring two of four Indicators to be satisfied for the Alert EAL for the " Leak Rate Greater than 50 gpm, but within liigh (0 pen item (346/85011-03)).
Pressure injection System Capacity" Conditio Based on discussions with the licensee's Emergency Planning staff, the inspector determined that the staff had set an internal goal of completing an in-depth EAL review, and that EAL revisions would be incorporated in the revision to the Lmergency Plan scheduled to be issued in the first half of 1986, theso items remain ope (0 pen) Open item No. 346/85011-04: Reviso item 4.a.o. of Attachment 2 to El 1300.04 and 1300.05 to provido adequate guidance that affccted offsito areas will be described to offsite authorities in terms of subarcas, and that Suharea Number 1, which is at least a two milo radius from the station, will alwayn he included when off5lte protective actions
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are recommende The inspector reviewed the current (eighth) revisions of both procedures, dated May 198 Item 4.a.e. in both procedures'
checklists had been reworded to indicate that offsite areas would be described in terms of subareas, rather than in terms of radial distances from the station or 22 degree sector However, as indicated in Paragraph 5d of this report, the licensee was again in the process of revising subarea boundaries. This effort was being done in cooperation with the appropriate State and County agencies, as well as the United States Coast Guar Based on exercise observations and subsequent discussions with the licensee, the inspector understood that the revised Subarea 1 would include all land areas within about a two mile radius of the station, while revised Subarea 8 would encompass all portions of Lake Erie within the plume exposure pathway Emergency Planning Zone (EPZ).
Also, for practical considerations, any implemented offsite protective action recommendations would automatically include the evacuation of all portions of Lake Erie in this EPZ, beginning with the area closest to the station and proceeding outwards to the EPZ border. However, Attachment 2 to EI 1300.04 and 1300.05 has not yet been revised to clearly indicate that the revised Subareas 1 and 8 would be included in any offsite recommendation. This item remains open pending such a revision to Attachment 2 of EI 1300.04 and 1300.0 (0 pen) Open Item No. 345/85011-05: The licensee must develop and implement a system to ensure timely action to correct deficiencies in emergency supplies identified during periodic inventories. The inspector determined that the Emergency Planning and the Chemistry and Health Physics staffs were in the process of transferring certain inventory responsibilities from the latter to the former work group. This transfer of inventory responsibilities would impact the corrective action needed to resolve this Open Item, which will remain (per pending development and implementation of an adequate emergency supplies replenishment syste (Closed) Open Item No. 346/84014-01: The exercise scenario submitted to the NRC was incomplete, and the scenario used for the exercise contained several major technical errors. The 1985 exercise scenario was submitted in accordance with the schedule outline in correspondence dated December 14, 1984, from NRC Region !!! to the licensee. With several very minor exceptions, the scenario package was complete. The number and
' nature of technical errors or apparent inconsistencies contained in the package were typical of those contained in scenario packages submitted by other Ilconsees. The licensee was receptive to the staff's technical review comments and appropriately revised scenario information prior to the exercise. This item is considered close (Closed) Open Item No. 346/84014-02: Activation of the Technical Support Center Radiation Testing Laboratory, Emergency Control Center, and RadiatIonMonitoringTeamswasdisorganizedtothepointwheresome individuals were attempting to implement conflicting assignments made to 1 them by more than one emergency response manager. Even after the in facilitieswereofficiallyactivatedpersonnelwerenotfunctioninb; their assigned positions. As indicated in Paragraphs $c, 5d, and eof this Inspection Report, activation of those cargency response facilities
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was orderly and timely. Persons were aware of their assigned roles for this emergency response and were functional in their assigned roles prior to any of these facilities being declared fully operational by the facility manager This item is considered close (Closed) Open Item No. 346/84014-03: Technical Support Center (TSC)
communications with the Control Room were not sufficiently coordinated to ensure that each group was fully aware of plant status until the differences in data became so disparate that the TSC was told to stop participating. As indicated in Paragraphs 5a and Sc of this Inspection Report, no serious communications problems were noted between the Control Room and the TSC. Personnel in both locations were adequately aware of changes in critical plant parameters. This item is considered close (Closed) Open Item No. 346/84014-04: Neither the TSC nor the Emergency Control Center (ECC) trended critical plant data which would impact on offsite releases, such as the primary to secondary leak rate and radionuclide composition of the release. Neither facility maintained a record involving the total material released. As indicated in Paragraphs Sc and 5d of this report, trending of critical plant data was primarily performed in the TSC. Adequate records of the changing release rate were maintained so that the total quantity or radioactive material released could have been summed. This item is considered close (Closed) Open Item No. 346/84014-05: No inplant radiation monitoring data was supplied to the Operational Support Center (OSC). Some teams left the OSC without an accompanying Chemistry and Radiation Tester to monitor doses, without a prescribed dose allowable to complete the assignment, and without a briefing of routes to follow and other actions to minimize team dose. As indicated in Paragraph Sb of this report, inplant radiation data was made available from the Control Room to the OSC. Inplant teams were composed of Chemistry and Radiation Testers. These personnel were, in general, adequately briefed on assigned tasks, including dose limits and appropriate routes to be take Those teams observed demonstrated good ALARA practice This item is considered close (Closed) Open Item No. 346/84014-06: The Emergency Duty Officer (E00) at the ECC failed to determine if any nonessential personnel were at the plant; and, therefore, a decision to evacuate them was never considere As indicated in Paragraph 5d of this report, the simulated evacuation of nonessential onsite personnel was ordered by the EDO promptly after the completion of assembly / accountability activities. This item is considered close . General An exercise of the licensco's Davis-Besse Nuclear Power Station (DBNPS)
Emergency Plan was conducted at the DONPS on July 16, 1985, testing the integrated response of Ilcensee, State, and local organizations to a hypotheticalaccidentscenarioresultinginamajorreleaseof radioactive materia The normal hours exercise was integrated with a
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test of the Ohio State and Ottawa County emergency plans. This was a full participation exercise for the State of Ohio. Attachment I describes the licensee's scope and objectives for this exercis Attachment 2 describes the scenari . General Obserervations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the DBNPS Emergency Plan and associated procedure Coordination The licensee's response was generally coordinated, orderly, and timely. If these events had been real, actions taken by the licensee would have been sufficient to permit State and local authorities to take appropriate actions to protect public health and safet Observers Licensee observers observed and critiqued this exercise along with nine NRC observers and a number of Federal Emergency Management Agency (FEMA) observers. FEMA observations on the responses of the
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State and local governments will be provided in a separate repor Critiques The licensee held critiques following the exercise on July 16 and 17, 198 The NRC critique was held on July 17, 198 In addition, a public critique was held on July 18, 1985, to present both the onsite and offsite preliminary findings of the NRC and FEMA representatives, respectivel . Specific Observations Control Room Control Room personnel followed those emergency operating procedures and emergency plan implementing procedures that were applicable to this exercise scenari The station's Technical Specifications were reviewed as neede The Plant Manager, acting Operations Engineer Operations Supervisor, and Shif t Technical Advisor (STA) were all In the Control Room shortly after the Shift Supervisor (SS) received a weather warning for tornado activity in the local area. An emergency diesel generator was started as a precautionary measure, and onsite personnel were instructed via the station's public address system to seek shelter. However, Control Room personnel should have made greater efforts to determine that all onsite personnel had, in fact, heard and were following the "take shelter" instructio .
i The SS, who functioned as interim Emergency Duty Officer (ED0),
declared both the Unusual Event and the Alert in a correct and timely manner after becoming aware of conditions that warranted these declarations. He helped compose and reviewed the completed initial notification message subsequently transmitted by the onshift Administrative Assistant. The initial notifications to the Ottawa County Sheriff's Office, Ohio Disaster Services Agency, and the NRC Operations Center were completed in a timely manner. The licensee's key emergency response personnel were told of both declarations following notifications of these offsite organization Initial offsite notifications were adequately documented. The Administrative Assistant maintained a well-detailed record of Control Room activities
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and decisions during the exercise.
l The interim EDO and Plant Manager correctly agreed not to terminate
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the Unusual Event before receiving confirmation that all severe weather had passed through the local area. Management personnel in the Control Room repeatedly challenged a controller who was serving as the load dispatcher and who was blocking their decisions to reduce reactor power even after a small loss of reactor coolant accident (LOCA) condition had become evident. The interim E00 requested guidance from the Plant Manager, prior to the latter's leaving the Control Room for the Technical Support Center (TSC),
regarding at what point he must disregard the load dispatcher's demand to stay at power despite the LOCA. He was told to reduce power if the LOCA exceeded the coolant makeup capacity available via charging pumps. Following reactor shutdown, Control Room personnel made adequate efforts to identify the location of the LOCA inside the containment buildin Prior to activation of onsite emergency response facilities, the Plant Manger contacted the Vice President for Nuclear Operations on several occasions to keep him advised of scenario events. Following the arrival of the on-call E00 in the Emergency Control Center (ECC),
the interim EDO provided him with a thorough briefing of events before transferring E00 responsibilities to that individua The SS informed Control Room personnel when EDO responsibilities had been transferred to the on-call E00, j b. Operational Support Center and Inplant Teams The Operational Support Center (OSC), which was comprised of several inplant areas, was fully operational within about 20 minutes after the Alert declaration. The OSC Manager established and maintained effective control over OSC activities. He provided adequately detailed, periodic briefings to personnel in the Office Building segment of the OSC. He adequately performed his duties associated with the assembly / accountability of station personnel. He selected an acceptable alternate OSC location in the event that the primary OSC became uninhabitabl An initial habitability survey of all portions of the OSC was completed shortly after the OSC became ;
operational. The next habitability survey was not conducted until
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about 90 minutes after the release began; however, OSC personnel monitored nearby area radiation monitors and also obtained associated data available from Control Room readouts. No significant communi-cations problems were observed between the segments of the OSC or between the OSC and the Control Room and TSC. A log of OSC activities was kep A status board was also available in the Office Building portion of the OSC; however, it was not effectively utilized to post plant status information or to record the activities of inplant teams for most of the exercis The Health Physics Monitoring Room (HPMR) portion of the OSC was the location where inplant radiation survey reports were first receive The HPMR Coordinator requested Reactor Coolant System (RCS) panel lineup for a sample in anticipation of such a request from the Control Room or TS He also briefed personnel reporting to his location on current plant status information. A status board was available in the HPMR, but was not effectively utilized as a briefing aid for arriving personne Inplant team activities were limited to radiation survey and post accident sampling tasks. All inplant maintenance teams were simulated, which was not apparant to the inspectors during the earlier scenario review process. Search and rescue teams were also simulated. In general, inplant teams checked their survey equipment for proper operation and current calibration prior to leaving the OS Proper survey techniques and ALARA concern were demonstrate However, several problems were noted regarding one inplant radiation survey team. The technician was only equipped with a micro-R survey meter, although he would likely encounter radiation fields significantly greater than the instrument's measurement range. Enroute survey results provided by an accompanying controller were unrealisticaly low, especially in the vicinity of a rear door to the Control Roo Radiation levels were supposedly several hundred thousand millirem on one side of the door, but only a fraction of a millirem on the other side of the door where the technician was located. Another survey team encountered a security guard who did have an exercise participant armband. The guard was encountered in a simulated high radiation are After several minutes, it was determined that the guard was not to be involved in the exercise. Exercise participants should have assumed that the guard was a participant and taken appropriate measures, rather than being more concerned regarding the guard's status as a player or non participan The post accident sampling team succeeded in collecting a liquid sample from the Number 1 decay heat loop. Use of self-contained breathing apparatus (SCBAs), anti-contamnation clothing, and emergency communications equipment appropriate for use when wearing SCBAs were all simulated. The team checked their survey instrumentation before departing the OSC and demonstrated proper concern for ALARA during their mission. The sample was transported to the Hot Lab where its analysis was simulated. Although the team recognized the need to save the sample, it was not adequately labeled for future identificatio _ _ _ _ , . -
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The exercise included a demonstration and a discussion of decontam-ination techniques to be utilized in the event that an uninjured laboratory technician had spilled a radioactive liquid sample on his skin and clothing. Personal survey techniques were demonstrated, while decontamination steps were described. The initial survey of the technician was too slow, consuming about 45 minutes, considering the facts that the contaminated person was conscious, uninjured, and able to provide the surveying technician with preliminary survey information. The initial survey should have been completed sooner, with the more meticulous surveys being limited to those performed after each decontamination attemp Bases on the above findings, the following items should also be considered for improvement:
Precautionary surveys of OSC areas should be performed to supplement conclusions on OSC habitability based only on available area radiation monitor informatio Status boards should be better used in both portions of the OSC to augment verbal briefings given to transient emergency worker The capabilities of both inplant Health Physics teams and inplant emergency repair teams should be demonstrated in the 1986 exercis Inplant radiation survey teams should be equipped with survey instruments having appropriate instrument ranges for the radiation levels that the teams could encounte Demonstration of post accident sampling capabilities should also include the wearing of appropriate respiratory protection, the use of associated communications equipment, and anti-contamination clothing to enhance the realism of the post-accident sampling activitie Post accident samples should be adequately labeled for future identification.
' Technical Support Center The TSC was activated promptly after the Alert declaration and was
. fully operational approximately 45 minutes after that declaratio Activation of the facility was orderly, with little confusion exhibited by the participants regarding what were their assigned positions in the TSC organization. The facility was declared fully operational only after TSC personnel were ready to perform their dutie TSC staff did a good job in monitoring those plant parameters which were critical in this scenario, by utilizing computerized displays
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augmented by plotting and trending critical parameters on a status board readily visible to all TSC personnel. The validity of data points, occasionally questioned by various personnel, were inves-tigated and resolved in a timely manner. Communications were adequate between the TSC and the Control Roo TSC staff were kept adequately aware of scenario events, major decisions, arid each other's progress on assigned tasks through periodic briefing: that usually were led by the TSC Manager, who was the facility's permanent manager. Key staff were typically asked to speak on their own group's activities during such briefing At times, however, briefings were initiated by either the Station Operations Manager (SOM) (Plant Manager in normal operations) or Operations Director (OD) (Assistant Vice-President for Nuclear Operations). The former was usually in i.he TSC, while the latter divided his time between the TSC, Emergency Control Center (ECC)
and the Emergency Director's (ED's) workspace near the Joint Public Information Center (JPIC). In this licensee's emergency organization, both the SOM and OD oversee activities in the TSC and/or ECC. Persons assigned to the SOM and OD positions have, however, senior positions in the licensee's normal organization compared to those of persons who may function as the full-time TSC Manager. The inspectors also noted that, at times, the SOM or OD engaged in information gathering conversations with one or more key TSC staff, during which the TSC Manager was not always involved. The net result of the emergency organization's structure and conduct of the SOM and OD was that there was occasional, brief confusion exhibited by various TSC staff members regarding who was really in charge of the facility and making final decisions on task prioritization issues or decisions to begin or terminate work on a task, once the SOM and/or OD were present and vocal in the TSC in addition to the TSC Manager. The inspectors did not conclude, however, that the perceived changes regarding who was the senior decisionmaker in the TSC resulted in any cases of gross confusion or poor decisionmaking in this particular emergency scenari The Radcon Operations Manager remained adequately aware of relevant inplant radiation levels which were posted in his work area, and the activities of onsite radiation survey teams that were under his direction. Engineering staff, with some assistance from corporate staff, developed an estimate of when the containment building's pressure would equalize with ambient pressure. They also computed a reasonable initial estimate of the extent of core damage based on post accident sample analysis result Good use was made of a prominently located Problem Analysis status board. In contrast, the Sequence of Events status board was poorly used as a means of displaying significant scenario events and decisions for subsequent reference by TSC staff or later arrivals. Examples of significant items which were never plotted on the status board included the following: loss of the Bayshore Generating Station to the grid; activation times for the TSC and ECC; the reactor trip; the fact that
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six control rods had not fully inserted; and that a contaminated worker had been identified onsite. The TSC Manager too often had to prompt a plotter on what information should be added to the Sequence of Events status boar Logkeeping by individual key TSC personnel varied from adequate to inadequate regarding completeness, especially the times that decisions were made, or when actions were taken or complete Based on the above findings, the following items should be considered for improvement:
. It should be obvious at all times to all TSC personnel who is in charge of activities and decisionmaking taking place in that j facilit . The TSC Manager should be adequately aware of matters discussed by members of his staff and the relatively transient SOM or O . The Sequence.of Events status board should depict all significant scenario events and decisions in order to better serve as a permanent briefing tool for TSC personnel and later arrival . Logkeeping by key individuals should be adequately detailed so that their actions and decisions can be reconstructed at a later dat Emergency Control Center The ECC was fully operational within 45 minutes of the Alert declaration. The Emergency Duty Officer (ED0) declared the facility operational only after he had been adequately briefed by the interim ED0 and had assured himself that ECC staff were ready to perform their duties. Little confusion was exhibited by ECC Staff regarding their assignments during the ECC activation proces The EDO properly classified the Site Area and General Emergencies following brief and appropriate discussions with the Control Room and the TSC Manager. Some confusion was briefly exhibited, however, regarding the interpretation of an indicator in the applicable Emergency Action Level (EAL) for the Site Area Emergency. The indicator was " Safety Features Actuation System (SFAS) functions have activated." The point of confusion was whether the condition should be interpreted as some functions had activated or had all functions activated. The correct decision was made to declare the Site Area Emergency once it was confirmed that some SFAS functions had activate Just after the Site Area Emergency declaration, the EDO correctly sought and received concurrence from the Control Room and TSC that plant conditions could best be categorized as deteriorating. In accordance with procedures, the ED0 then formulated an offsite pro-tective action recommendation, which was to be applicable for all
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land and water areas within about a two mile radius of the statio However, in his hasty translation of a radial distance into one or more predetermined geographic subareas that are utilized by this licensee and the State and County Disaster Services Agencies, the ED0 neglected to include any portion of Lake Erie in his initial recommendation to offsite authorities. The inspector also noted that the boundaries of the irregularly shaped subareas depicted on large scale maps in the ECC and other emergency response facilities did not all match those found in the current, fifteenth revision of Procedure AD 1827.12. Furthermore, the inspectors never observed decisionmakers in the ECC to be consulting the subarea map found in the procedure. Based on discussions with the licensee during and after the exit meeting, the inspectors finally learned that proposed subarea boundary revisions were being tested during this exercise, per prior agreement with State and local official Exercise participants had been instructed sometime before the exercise to utilize the proposed subareas depicted on the large scale maps in their decisionmaking rather than the subareas depicted in the procedur Differences between offsite geographic subareas depicted on large scale EPZ maps and those depicted in Procedure AD 1827.12 contributed to the failure to include all areas within about a two mile radius of the station in the initial offsite protective action recommendatio This is an Exercise Weakness (346/85019-01).
Following the Site Area Emergency declaration, the ED0 became aware of some disagreement between State and County officials regarding what recommended actions should be implemented. Neither the State nor the County was in complete agreement with the licensee's recommendation. Although the EDO remained well aware of what recommendations were initially and subsequently implemented by offsite authorities, he essentially limited his role to that of making recommendations rather than becoming more actively involved in explaining the rationale behind his recommendations to offsite authorities or assisting them in resolving any differences of opinion, on an as needed basi The E00 made the appropriate offsite protective action recommendation for the General Emergency declaration. The recommendation was later revised from sheltering in appropriated offsite areas to evacuation. Estimated release duration was a factor in this decision-making. However, ECC dose assessment staff did not effectively coordinate with TSC staff to incorporate the latter's current best estimate of release duration in their projections. Instead, a two hour default release duration was assumed by the dose assessment staf Evacuation time estimates were not overtly considered in the decision to change the recommendation from shelter to evacuat .
Analogous to what was observed in the TSC regarding the TSC Manager, 00, and SOM, the inspectors noted that the EDO was not always included in ongoing discussions between the CD and the Emergency Operations Manager (E0M), both of whom were responsible for overseeing the activities of the ED0 and his ECC staf However, the temporary presence or absence of the OD and/or E0M from the ECC did not result in confusion of the ECC regarding who was really in charge of the facility in this 1 articular emergency scenari It should also be noted that the E)0 and E0M for this exercise were both division directors in the normal plant organization, whereas others currently functioning as ED0s hold relatively less senior positions in the normal organization, and nevertheless, have the undelegatable responsibility for issuing offsite protective action recommendation Initial offsite notifications to the NRC and State and County authorities were promptly completed following declaration of the Site Area and General Emergencies and issuance of the associated protective action recommendations. Communications between the licensee and Ohio DSA representative in the ECC were adequate regarding the locations of both organizations' field monitoring teams and their survey result Assembly / accountability of all onsite personnel was initiated promptly after the Site Area Emergency declaration and was completed within the thirty minute time goal. Simulated evacuation of nonessential personnel was ordered after completion of accountability. Following a discussion between the OD and EDO, the correct decision was made to have evacuees report to an offsite reassembly area rather than releasing them to proceed to their homes. The simulated evacuation was begun well before the radioactive release bega The decisions to downgrade from a General Emergency to an Alert, and later from an Alert to no emergency classification were poorly thought out, with no attentTon having been paid to reviewing EALs before making these decisions. The reclassification to an Alert was essentially only a title change, as no change to offsite protective actions was recommended and no change in the licensee's emergency organization activities was deemed appropriate. The inspectors concluded that the licensee simply downgraded to an Alert because the Ohio DSA representative in the ECC indicated his willing-ness to recommend that his agency reduce its level of activation to that associated with an Alert. When the emergency was later downgraded from an Alert to no emergency classification, the licensee did not challenge, as did a County official, an offsite agency represent-ative's decision that citizens could be allowed to return to evacuated offsite areas. Licensee staff also decided that the ECC could shortly be deactivated, although the E00 would remain and function from the TS Inadequate concern was paid to the need to complete additional offsite surveys, ensure that the plant would remain in cold shutdown, or even to ascertain the OSC's continued staffing need !
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At least two factors contributed to this poor demonstration of transition to the Recovery phase of the emergency respons Revision 5 to Recovery Procedure EI 1300.11 stated that the emergency classification must be less than an Unusual Event before the procedure could be implemented, if the emergency had once been classified as at least an Alert. The second factor was the realization by some participants that some demonstration of recovery activities had to be performed before exercise terminatio The failure to consult the station's EALs for applicability prior to downgrading from a General Emergency and later from an Alert, plus the incorrect procedural guidance that emergencies classified as at least an Alert must somehow be downgraded below the Unusual Event before commencing Recovery activities, together constitute an Exercise Weakness (346/85019-02).
In addition to the exercise weaknesses, the following items should be considered for improvement:
The wording of the SFAS indicator in the Site Areas Emergency EAL for the "High Containment Radiation, Pressure, and Temperature" condition should be clarified to indicate whether all or some functions have to activate to satisfy this indicato Testing of revised procedures should be confined to drills and practice exercises. However, should the licensee decide to test such revisions during an exercise, all exercise evaluators should be advised beforehan * Licensee personnel involved in protective action decisionmaking should make themselves readily available to offsite authorities to explain their rationale and help resolve disagreements, so that the protection of public health and safety can better be ensure * Dose assessment and engineering staffs should interface so that best estimates of release duration can be factored into offsite dose projection Evacuation time estimates should be factored into shelter versus evacuation recommendation decisionmakin The licensee should reevaluate the desirability of having relatively less senior personnel in the normal organization charged with the undelegatable responsibility, in the emergency organization, for making offsite protective action recommendation e. Radiological Testing Laboratory and Offsite Radiologica Monitoring Teams
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The Radiological Testing Laboratory (RTL) was fully operational well within an hour of the Alert declaration. The, facility was
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effectively managed by the RTL Coordinator, who remained in contact with the TSC, ECC, and OS Adequate records of offsite team activities, survey results, and scenario events were maintained in the RTL. Status boards were effectively utilized and kept reasonably current. Samples brought to the facility were analyzed in a timely manne Two offsite monitoring teams were activated and deployed prior to the radioactive release. The teams inventoried their field kits and checked their equipment for operability prior to leaving the RTL. Vehicle radios were also checked prior to the teams leaving the building's parking lot. The teams demonstrated proper tech-niques when collecting air samples and subsequently handling air sampler filter cartridge Samples were adequately labeled for later identificatio After their departure from the RTL, teams were under the direction of the Radiological Monitoring Team (RMT)
Coordinator and his staff in the ECC. No significant communications equipment problems were noted between the teams and the EC However, the teams were not kept adequately informed on changes to plant status and emergency classification and the status of implemented offsite protective actions. The teams and their controllers in the ECC demonstrated proper concern for minimizing
- the teams' radiation exposures and monitoring accumulated dose The teams did a good job in identifying the approximate boundaries and centerline of the plume as it moved southwesterly through the EP However, for most of the exercise the simulated wind direction was fairly constant and the wind speeds remained low, making the plume tracking problem less difficult than would be the case undar more variable wind condition Collection of soil, vegetation, and water samples was not demonstrated during the exercise despite the presence of radioiodines in the release. When a controller was asked by an inspector why such samples were not being taken, the controller said that such sampling would likely be done during the Recovery phase. However, such sampling was l not observed during the relatively brief Recovery phase demonstrated l in this exercise.
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! Based on the above findings, the following items should be considered r for improvement:
l l The' collection and handling of additional types of samples should be demonstrated in the 1986 exercis Offsite monitoring teams should be kept aware of significant changes in emergency classifications and plant status, as well as the status of protective actions being implemented offsit f. Joint Public Information Center The Joint Public Information Center (JPIC) was activated in a timely
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i (ED), who approved all press releases and also functioned as the licensee's technical spokesperson. The ED did a good job in responding to media questions during the five press briefings, and remained well aware of changing scenario events and major decisions that took place in-between his presentations. Media assistants were available to respond to media needs. The licensee's ability to successfully conduct rumor control activities was repeatedly demonstrate Press briefings and press releases were adequately coordinated with those of governmental agencies. A sufficient number of licensee press releases were issued during the exercise. The contents of the releases were accurate without being too technical in natur Definitions of emergency classifications were incorporated in the press release . Exit Interview The inspectors held an exit interview on July 17, 1985 with those individuals identified in Paragraph 1 as well as many others who participated in the exercise. The inspectors discussed the scope and preliminary findings of the inspection. The licensee agreed to consider the items discussed. The inspectors determined from the licensee that none of the information discussed was proprietary in natur Attachments:
1. Exercise Scope and Objectives 2. Scenario Narrative Summary I
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i Narrative Synopsis The initial conditions simulated at the beginning of131 theactivity exercise( include the following significant items: Dose equivalent I pCi/ gram) and unidentified RCS leakage (0.8 gpm) are just below Tec Spec limits (1 pei/ gram and 1.0 gpm, respectively), and containment (ctmt.) coolinF capacity has been significantly reduced by taking one ctat. spray pump, and two etmt. air coolers out of servic Approximately 15 minutes into the scenario (00/15 or 8:45 a.m.) the Control Room will eceive notification that a tornado has touched down Per EI 1300.01, the Shif t Supervisor will declare an Unusual
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onsit Event due to this sighting, implement the DBNPS Emergency Plan, make the requisite internal and external notifications, and assume the responsi-bilities as Interim Emergency Duty Officer (EDO), until relieved by the on-call EDO. The funnel cloud will continue its path, and will have no impact on Station operations, other than the fact that the Control Room will start the only operable Emergency Diesel Generator (#2) per AD' 1827.0 It will not be carrying any electrical loa At 00/30, the Control Room will receive notification from the Load Dis-patcher that the Bay Shore Station has been forced off the line, and that the power margin on the grid is extremely small. Davis-Besse must renain at as high a power level as possible until the grid can be stabilized, approximately two to three hour Between 00/45 and 01/00, the RCS leak rate ramps up, and steadies out at approximately 60 gp By 00/55, the operators will have indications that the leak rate has exceeded 50 gpm (Make-up tank level decreasing at
~ 2"/ min. , RCS inventory balance and verified by increasing ctmt suurp the EDO should declare an ALERT, based on levels). Per EI 1300.01, This declaratico activates the TSC, ECC, and OS > 50 gpm RCS leakag DBNPS Tech Spec 3.4.6.2 directs that RCS leakage in excess of T.S. limits be reduced within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, or the plant must be in hot standby within the Since the leak cannot be isolated / reduced, the operators l next six hour will begin a controlled shutdown, but the rate of shutdown will be severe y limited by the need to supply power to the gri Shortly after 02/10, the Control Room will receive a high vibration alarm on RCP 1- Once this vibration has been verified, they areImmediately directed by the procedure to reduce power to < 72% and trip the pum af ter the vibration alarm, the reactor will trip, and there will be indications of debris Six control in the reactor rods fail to core insert(Vibration and cannotand Loose Parts be manually Monitor Ala rm) .
inserte The incomplete reactor trip, combined with the debris impinging on the fuel cladding, results in increasing damage to the cladding, and release of some of the gap activity, which is reflected by the cta radiation monitors. By 02/25, those monitors (RE 4597/98) will indicate 3,000 R/HR, equivalent to a release of 50% of the fuel gap activity, The and, cause for declaration of a Site Area Emergenc per EI 1300.01, radiation levels in the containment will continue to increase, as addi-tional reactor coolant leaks into the containmen _ _ _ _ _ _ _ _
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One of the technicians assisting with the RCS chemistry sample will spill reactor coolant and become contaminated at approximately 02/45. Notifica-tions are made to DBNPS C&HP Supervision and onsite decontamination procedures will be initiated. The technician will be successfully decon-taminated onsite, and no offsite assistance will be require At 03/30, a large break Loss of Coolant Accident (LOCA) occurs (double-ended rupture at the discharge of RCP 1-1). Ctmt pressure and temperature increase and will peak at - 52.7 psia /38 psig. The ctmt. design pressure is 36 psig, and when the peak pressure occurs, a small break in ctmt will occur, as indicated by a minor increase on the station vent radiation monito During the blowdown following the rupture the reactor core was partially uncovered before being re-flooded by the Core Flood Tanks and Low Pressure Injection. This results in additional cladding and fuel damage, indicated by increasing ctat. radiation levels. When the Ctmt. radiation levels reach 60,000 R/HR (indicated on RE 4597/98) a General Emergency should be declare *
At 04/00, the station vent will indicate a significant increase in the release rat (Due to continued exposur,e to a high temperature / pressure environment, the break in containment is getting bigger and the release rate peaks at 04/00. A major radioactive release to the environment is in progress, via the following flow path: RCS + CLmt. + Ctmt, annulus +
Penetration Room + Emergency Ventilation System * Station Vent + Atmos-pher The release of radioactivity will continue for approximately two hours, decreasing at a rate roughly parallel to the rate at which the ctat. is depressurize By 06/00, the ctat. will be at atmospheric pressure. With the RCS in cold shutdown, the motive force for the release has been removed, and the release is terminate Meteorological conditions change to contribute to more rapid dissipation of the plume, and by 06/30, all radiation levels within the ten-mile EPZ are at background. The emergency should be downgraded and reentry and recovery discussions should be initiate (Reentry and recovery efforts will be limited to " table-top" discussions of the scope of effort necessary to restore the plant to pre-accident conditions.)
The exercise will be terminated at - 07/3 *
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DAVIS-BESSE NUCLEAR POWER STATION 1985 EVALUATED EXERCISE SCOPE The 1985 Davis-Besse Emergency Preparedness Exercise will test and provide the opportunity to evaluate the Toledo Edison Company, State of Ohio, and Ottawa County emergency plans and procedures. It will also test major portions of each emergency response organization's ability to ascess and respond to emergency conditions, and coor-dinate efforts with other agencies for the protection of the health and safety of the public. Whenever practical, the exercise will incorporate provisions for " free play" on the part of the partici-pant The scenario will depict a simulated sequence of events, culminating in a radiological release of sufficient magnitude to warrant response by State and local agencie B. TOLEDO EDISON OBJECTIVES This section delineates the specific objectives to be demonstrated by the Toledo Edison Company during the exercis . Demonstrate the adequacy of the Davis-Besse Emergency Plan, Emergency Plan Implementing Procedures Emergency Plan Station Supporting Procedures, as well as Toledo Edison Corporate Plan and Procedures, in compliance with 10 CFR 50.47 and NUREG 0654, Demonstrate timely, coordinated activation and staffing of emer-gency response facilities, and effective operation of these facilitics, in support of the emergency respons . Demonstrate proficiency in the recognition and classification of emergency condition . Demonstrate the adequacy of communications equipment and pro-cedures in making requisite emergency notifications, and for informing emergency response personnel of changing condition . Demonstrate the transfer of emergency authorities and responsi-bilities between facilities, as a result of an escalatin8 emer-gency classificatio . Demonstrate coordination of emergency response activities with the State of Ohio and Ottawa Count *
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. Demont trate the ability to plot and trend appropriate opera-tional and radiological data to aid in accident assessment and subsequent reconstruction of the inciden . Demonstrate the capability to determine radioactive release terms and to perform offsite dose projection . Demonstrate a familiarity with Protective Action cuides (PAG's),
formulation of protective action recommendations, and dissem-ination of these recommendations to offsite authoritie . Demonstrate the capability to obtain and simulate the analysis of reactor coolant samples utilizing the post-accident sampling syste . Demonstrate the mobilization of onsite and offsite radiological monitoring team . Demonstrate appropriate equipment, procedures, and communication for onsite radiological monitorin . Demonstrate the capability for offsite radiological monitoring, to include collection and analysis of sample media (e.g. air, water, soil, and/or vegetation, as appropriate), and provision for communications and recordkeeping associated with survey and monitoring activitie . Demonstrate the ability to perform site assembly, accountability, j and evacuatio '
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15. Demonstrate the ability to monitor and control emergency worker exposure within the plan . Demonstrate the ability to continuously staff all emergency response facilities in the event of a long term (i.e. longer than one shift) emergenc . Demonstrate the ability to evaluate the need for administration of thyroid prophylaxis (i.e. KI) to emergency workers, and, if appropriate, simulate distribution of K . Demonstrate adequate equipment and procedures for personnel decontaminatio . Demonstrate the capability to develop news release . Demonstrate the capability to brief the news media in a clear, accurate, and timely canne F'
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s 21. Demonstrate the capability of coordinating media information with the County and State at a combined media briefin . Demonstrate the capability to respond to public inquiries and rumor contro . Demonstrate the ability to initiate recovery operation . Demonstrate the ability to establish and maintain appropriate access control / security measures at all Toledo Edison emergency response facilitie . Demonstrate coordination with other state agencies within the ingestion pathway (i.e. Michigan).
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