IR 05000346/1985038

Special Insp Rept 50-346/85-38 on 851202-06 & Meeting on 851210.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions on Previously Identified Items & Performance of Corporate Emergency Organization Drill

ML20138R354
Person / Time
Site:	Davis Besse
Issue date:	12/26/1985
From:	Phillips M, Ploski T, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20138R352	List: IR 05000346/1985038 ML20138R351
References
50-346-85-38, NUDOCS 8512310213
Download: ML20138R354 (12)

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. U.' S*. NUCLEAR REGULATORY COMISSION

REGION III

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Report No. 50-346/85038(DRSS) 3 6-Docket No. 50-346 / License No. NPF-3-Licensee: Toledo Edison Company

~ Edison Plaza 300 Madison Avenue Toledo, OH' 43652

. Facility Name: Davis-Besse Nuclear Power Station, Unit 1 Inspection At: Edison Plaza, Toledo, Ohio and Davis-Besse Site, Oak Harbor, OH Inspection Conducted: December 2-6 and 10, 1985

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Inspectors: T. Ploski Date

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Dat6 Approved By

[Y M. Phillips, Chief * /I

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' Emergency Preparedness Section .,

Date Inspection Summary Inspection on December 2-6 and 10, 1985 (Report No. 50-346/85038(DRSS)

Areas Inspected: .Special, announced inspection of the following aspects of the emergency preparedness program: licensee' actions on previously identified items; performance of the corporate emergency organization drill; licensee actions on SALP commitments; emergency preparedness training; independent audits of the emergency preparedness program; and status of the TSC relocation study. The December 10,.1985 meeting addressed the. inclusion of the City of Port Clinton in the plume exposure. pathway. Emergency Planning Zone (EPZ). The~

inspection involved 70 inspector-hours onsite and at Edison Plaza by three NRC inspector Results: No. violations of NRC requirements or deviations from committ. ants

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were identifie #

8512310213 851227'

PDR ADOCK 05000346 G PDRf

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DETAILS

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1. Persons Contacted

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3 Toledo Edison Personnel

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+J. Williams, Jr. , Vice President, Nuclear Operations

• S. Smith, Assistant Plant Manager, Maintenance

• L. Ramsett, Quality Assurance Director

1. R. Klein, Nuclear Services Director

• N. Molter, Administrative Coordinator i' #J. Scott-Wasilk, Environmental and Emergency o"

Preparedness Manager i

1. R. Varley, Emergency Planning Supervisor

• R. Simpkins, Operations Training Manager

• B. Geddes, Quality Assurance Engineer

• J. Lietzow, Nuclear Licensing Specialist F. Swanger, Supervisor, Shift Technical Advisers C. Lietzow, Drill Controller, Planning Center R. Markovich, Drill Controller, Engineering Support Center B. Busse, Drill Controller, Financial Group P. Carr, Drill Controller, Legal Group L. Cech, Drill Controller, Procurement Group A. Gephart, Drill Controller, Transportation Group M. Teal, Drill Controller, Personnel Processing Group K. Farr, Drill Controller, Public Relations M. Findley, Drill Controller, Security M. Beier, Drill Controller, Office Services T. Kevern, Drill Controller, Emergency Control Center (ECC)

R. Palazzo, Drill Controller, ECC Dose Assessment

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. L. Klett, Drill Controller, ECC Communications 3 D. Gordon, Drill Controller, Control Room, i J. Kirkpatrick, Emergency Planning Staff a, W. Begin, Emergency Planning Staff C. Dupuy, Emergency Planning Staff

• Denotes personnel who attended only the December 6, 1985 exit intervie I + Denotes personnel who attended only the December 10, 1985 meeting.

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1. Denotes personnel who attended both the December 6 and 10, 1985 meeting Non-Licensee Personnel Attending the December 10, 1985 Meeting J. Fritz, Mayor, City of Port Clinton ij M. McLaury, Port Clinton Safety Director J. Greer, Director, Ottawa County Disaster Services Agency

.- - K. Cole, Nuclear Operations Of fice, Ohio Disaster Services Agency W. Weaver, FEMA, Region V (by conference call)

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.. Licensee Actions on Previously-Identified Items (Closed) Open Item No. 346/85006-01: Unresolved Item regarding the independence of Quality Assurance (QA) Department personnel involved in the audits of the emergency preparedness program. This item was created due to the fact that two QA personnel who were involved in auditing the program also were among those assigned as Emergency Duty Officers.(ED0s)

in the onsite emergency organization. The concern was their independence if they would audit EDO-related or other aspects of the emergency preparedness program, per the requirements of 10 CFR 50.54(t). By memorandum dated November 11, 1985, both QA Department personnel who had

'been assigned EDO responsibilities were relieved of this additional duty and now have no position in the onsite emergency organization. This item is considered close (0 pen) Open Items No. 346/85001-01 through -03: The licensee must 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 appropriate EAL indicators have been satisfied (0 pen Item 50-346/85011-01); the licensee must have consistent wording in the footnotes preceding the EALs listed in the Emergency Plan and in procedure EI 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 High Pressure Injection System Capacity" condition (0 pen Item 346/85011-03).

The licensee was in the process of conducting an in-depth re-evaluation of .the Station's EALs to address the aforementioned NRC concerns plus comments received from internal sources,- including the new Plant Manager and the Shift Technical Advisors (STAS). The licensee planned to issue the revised EALs as part of Revision 10 to the Emergency. Plan, which was scheduled to be issued in March 1986. These items remain ope (Closed) Open Item No. 346/85011-04:

Revise Item 4.a.e. of Attachment 2 to EI 1300.04 and 1300.05 to provide adequate guidance that affected

.offsite areas will be described to offsite authorities in terms of subareas, and that Subarea Number 1, which is about a two mile radius from the station actions are recom, mended.will always be included whenever-offsite protective

.In mid-October 1985, the licensee revised both procedures and the. subarea boundaries of Subarea 1 and those portions of Lake. Erie within the 10 mile Emergency Planning Zone (EPZ). Subarea 1 was redefined as those land areas generally-within about two miles of the Station, while Subarea 8 was redefined.to encompass all portions'of Lake Erie within the EPI. Both procedure revisions clearly indicated that Suba*eas 1 and 8 would be included in any offsite protective action recommendation. This-item is considered close o 1

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(Closed) Open Item 346/85011-05: 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 staff, the Chemistry and Health Physics staff, and the Station's Safety Coordinator have agreed to and have implemented a revised method of accomplishing periodic inventories of various types

, of emergency supplies. Periodic inventory requirements were contained in revised procedure PT-5199.14 and new procedure PT-5199.2 Both procedures addressed the need for timely replacement of depleted or out-

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of-date supplies. This item is considered close (0 pen) Open Item No. 346/85019-01: Differences between offsite geographic

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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 recommendation. The inspectors determined that the licensee was still in the process of eliminating differences between the subarea boundaries

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depicted on large scale EPZ maps, found onsite and at the Corporate Planning Center, and the maps found in procedures EI 1300.04, EI 1300.05, and AD 1827.12. This item remains ope (0 pen) Open Item No. 346/85019-02: 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 be downgraded below the

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Unusual Event class before commencing recovery activities, together resulted in inappropriate emergency declassification. The licensee indicated that revised guidance for downgrading an emergency classification and for declaring a Recovery mode of operation would be contained in Revision 10 to the Emergency Plan and in revisions to the relevant implementing procedures. The Plan revision is expected to be issued in

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March 1986. This item remains ope (0 pen) Open Item No. 346/85034-01: The licensee must revise procedure AD 1839.00 to provide additional guidance regarding the information needs of the NRC Duty Officer. Training on the revised procedure, for all licensed personnel and the STAS, must be completed before restart. The inspectors determined that the STA Supervisor had completed the draft procedure ahead of schedule and that it was being submitted to the Station Review Board (SRB). The draft contained a slightly modified version'of the Duty Officer's checklist so that the licensee's caller could better anticipate the NRC's information need Pending approval by the SRB, the licensee tentatively planned to conduct the required training in January 1986. This item remains ope . Corporate Emergency Preparedness Drill One of the licensee's 1985 emergency preparedness goals was to complete initial training of the corporate emergency organization and to conduct a drill of this organization. Training of-approximately 150 persons having positions in the corporate emergency organization took place during the second quarter of 1985. Due to the impact of the June 9th event on

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I the corporate staff and some changes to its normal organization, the

!~ initial drill was delayed-from late September to December 3, 1985. In addition to various work areas at Edison Plaza, the licensee activated the i Station's Emergency Control Center (ECC) for this drill. Involvement of

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the Control Room and Technical Support Center (TSC) was simulated through the use of controllers. The drill scenario was a modified version of i' that utilized in the 1985 practice exercis Scenario modifications ,

i- mainly involved the inclusion of a variety of messages from the Station i _or non-Toledo Edison sources to various staff at Edison Plaza, which were i all intended to test the capabilities of the various corporate organization  ;

groups. The NRC was provided with copies of the scenario approximately

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_ one week before the drill, which was. sufficient time to review the i submittal and provide comments to the licensee.

i The following corporate groups were activated for this drill: Executive Management; Engineering Support; Legal Services; Finance; Personnel j . Processing; Procurement; Transportation Support; Support Services; Office

! Services; Human Resources; Edison Operators; Security; and Public j -_ Relations (Director only). Two NRC inspectors. observed.the drill at the

Edison Plaza. 'A number of licensee personnel served as controllers for

.; the various groups. The inspectors attended two of the player critiques that immediately followed the drill'and the all-controller critique session that occurred the next morning. The inspectors made the following

conclusions regarding the-corporate drill

• The scenario provided a good challenge to the corporate organization.

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• With very few exceptions, exercise participants demonstrated good understanding of their emergency response functions.

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• The drill provided useful experience for the various groups in

! interfacing with each other or with the Station when dealing with j a variety of problems.

G i * Communications between the Planning Center, Engineering Support j- Center (ESC), and the Station's emergency response centers should i' be promptly established once staffing of the corporate facilities

is well underway.

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k * In general, the Planning Center staff was kept well informed of

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scenario events at the Station and at Edison Plaza.

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! -* The Planning Center staff.did a good job in monitoring offsite l protective action recommendations; however, more concern could have

!  : been exhibited toward ~ monitoring the implementation status of these

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• Planning Center staff should remain aware of current and' forecast ~

meteorological conditions and their impacts on onsite and offsite 1 protective action recommendations formulated at the Station.

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• Information on the current emergency' classification and onsite and offsite protective actions should be posted in the ESC.

I * Plume exposure pathway Emergency Planning Zone (EPZ) maps at Edison Plaza should include numerical and/or alphabetic wind direction i references. The maps should be identical to those used onsit ,

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3 * The simulated arrival and briefing of a congressman and his staff was

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well handled by participants and controllers.

i o * .Although not addressed in this scenario, the corporate organization i should remain aware of all NRC activities in response to an emergency I at the Statio i

• Planning Center staff demonstrated proper concern for the wellbeing i 'of Station personne ;

!- * The various groups adequately developed plans for long-term activation.

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!' * The legal staff did a good job ~ in responding to a number of problem Staff actions.were decisive. Documentation of activities was adequate and was' forwarded to the Planning Center.

. * Communications within the ESC'were somewhat inhibited, as a speaker telephone line was often kept open with the Station.

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• The reactor parameter status board was kept sufficiently current in J the ESC.

* The procurement staff was aggressive in responding to equipment l' needs brought to its attention; however, on one occasion there was j unnecessary confusion about the quantity. and delivery location of nitrogen gas needed at the Station.

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* The Personnel Processing Center was operated smoothly and efficiently.

! Processing activities were well done, even while.the center was 1 still being~ set up.

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! * Recordkeeping should be improved in the ES ,

L The NRC staff will monitor the licensee's actions in response to the i improvements suggested by the participants, drill controllers, and NRC observers.

I j . Performance on SALP IV Initiatives

.The following paragraphs summarize the progress made by the licensee during 1985 on the various initiatives undertaken as a result of the

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SALP IV evaluation of the emergency preparedness' program. Additional

details on-the' licensee's~ actions are contained in one or more of the

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following Inspection Reports:: 50-346/85002(DRSS); 50-346/85006(DRSS);

j 50-346/85011(DRSS); 50-346/85019(DRSS); and 50-346/85034(DRSS).

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Exercise-Related Initiatives'

A successful exercise of the Station's emergency plan was conducted on schedule in July 1985. The sufficiently challenging scenario was ,

, developed by a committee comprised of licensee and consultant '

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personnel. The licensee component of the committee was made up of persons drawn from various divisions. Their efforts toward preparing

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!. a complete, technically accurate scenario on schedule.were gives appropriate senior management support. The licensee had indicated

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that a scenario development. committee would be formed annually, but

, that its membership may vary. In order to improve the overall

, capabilities of the onsite emergency organization and to better prepare for the 1985 exercise, the licensee conducted a number of i

drill within the various emergency response facilities in addition

, to classroom training sessions. All sessions were critiqued and i resulting comments were evaluated for possible action. The increased <

! emphasis on conducting drills within the emergency response facilities

also afforded controllers with additional opportunities to refine their skills. In contrast to the some exercise observations, the 4 1985 NRC exercise inspection team did not identify any significant examples of improper or inept controller actions.

J Tracking of Improvement Items By the Licensee In November 1985 the licensee fully implemented the computerized Emergency Planning Activity Scheduling System (EPASS), which is designed to track corrective actions being taken by the Emergency

! Planning staff with or without the assistance of;other groups. Over 1 five hundred action items have been added to the EPASS, including j' items which originated from NRC Inspection Reports,-internal audits,

. training session critiques, drill critiques, and other source l Responsible personnel and due dates have been identified for each

item on the EPAS Provisions exist for periodically informing

senior management of any overdue item Regional staff has been

, satisfied with the licensee's progress on developing and implementing

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! Establishment of a Lead / Alternate EDO System

, In November 1985 the new Emergency Planning Supervisor completed all 4 ED0 training requirements. In view of his past involvement with the i Station's emergency preparedness program, the new supervisor already j

. had an in-depth knowledge of-the overall program. By internal ' memorandum dated November 11, 1985, all persons who had been rotating

! the EDO duty; on a weekly basis were officially notified that the

! practice was discontinued effective on that date. By memo dated

} November 25, 1985, four persons from the former pool of about twelve

ED0s were designated as Alternate ED0s, with the understanding that

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the individual who is also a member _of the Emergency Planning staff L . would be the first choice to assume the Lead EDO position in the i absence of the Emergency Planning Supervisor. Regional staff is

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satisfied that the transition from a group-of persons.who rotated EDO duties on a weekly basis to a Lead / Alternate EDO concept has been  :

completed in an appropriate manner.

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.- Clarification of the Roles of the Shift Supervisors (SSs) and Shift Technical Advisors (STAS) on EDO Responsibilities Both the SSs and STAS had completed interim EDO training during the first quarter of 1985; however, the STAS had subsequently requested additional ~ interim-EDO training before they were willing to accept the possibility that.the SS could transfer all interim-ED0 responsi-bilities to the on-duty STA following an emergency declaratio This and other factors led to further internal-discussions regarding the desirability of having an STA function as an interim-EDO in lieu of the SS, as had been described in Revision 9 to the Emergency Plan and relevant implementing procedures. By letter dated September 30, 1985,-the licensee formally revised the intended use of STAS as

. interim-ED0s from that concept described in Revision 9 to the Emergency Plan. Although STAS will be trained as interim-ED0s, they would not function as such unless both the SS and Assistant SS were not in the Control Room or were both physically incapable of functioning as interim-ED During October 1985_the licensee revised those implementing procedures which addressed the roles of the SS and STA on performing interim-ED0 responsibilities to conform to the description found in the September 30th letter. All STAS received supplemental training on interim-EDO responsibilities on November 4-6, 1985, to satisfy a commitment in the licensee's Course of Action submittal to the NR The training was conducted by members of the Emergency Planning staff, one of whom had been an instructor in the Station's Training Departmen The inspector reviewed the attendance sheets and final lesson plan for this training effort, and determined that all STAS had been given the training. The lesson plan indicated that the course was adequate in scope and depth, addressed relevan implementing procedures, and was up-to-date, especially regarding the finalized roles of the SSs and STAS on performing interim-EDO dutie The inspectors determined, however, that.there was:some delay in ensuring that all licensed personnel would be formally informed of the final decision regarding the STAS' role in the performance of interim-EDO tasks. Licensed personnel would have until late December 1985 to complete the required reading file containing many recent procedure revisions, including those which clarified the-roles of the_SSs and STAS on interim-EDO duties. Consequently, the licensee committed to issue an internal memorandum to all licensed personnel to inform them of the intended SS/STA relationship on interim-EDO responsibilities in a more timely manner than available through the required reading file. This memo _was issued on December 10, 198 Improvements to the Emergency Planning Staff In early 1985 this staff had decreased to three full-time-licensee personnel, including administrative support, plus a number of consultants. Specialized emergency preparedness training was mainly being done by consultants. A March reorganization resulted in an

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Acting Manager of Environmental and Emergency Preparedness gradually assuming from the re-assigned Emergency Planning Supervisor all responsibilities for the emergency preparedness program, including improving the size and technical expertise of the staf By October 1985, final selection of the Manager and Supervisor had been completed, and both persons were functioning in their position The supervisor's staff had expanded to thirteen identified positions,

divided into the following areas of primary responsibility: onsite emergency planning; offsite emergency planning; corporate emergency planning; computer support; general support; and clerical suppor Recruitment was completed by November and all staff were onboard by December 9th. The staff included persons having health physics, nuclear plant operations and training, environmental, and emergency planning backgrounds. During the staffing process much reliance was appropriately placed on consultants for conducting specialized emergency preparedness training. However, the licensee's staff has

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become increasingly involved in the losson plan preparation and instruction processes, the most recent example being the staff's lead role in preparing and conducting the supplemental training for STAS on interim-ED0 responsibilities. In summary, Regional staff has been satisfied in the growth of the Emergency Planning staff during 1985.

f. Roles of Quality Assurance and Emergency Planning Staffs in Audits

, of the Program During 1985 the licensee provided adequate clarification regarding

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the preparation and review of checklists used by Quality Assurance (QA) Department staff when auditing the emergency preparedness progra Although it was appropriate for QA and Emergency Planning staffs to discuss the checklist at the audit's entrance meeting, it was clarified that the audited staff was prohibited from requesting deletions from the checklist before or. after the audit, and could only suggest that the checklist be enlarged to better ensure that the requirements of 10 CFR 50.54(t) would be satisfied by the audit. Furthermore, any suggested additions to the checklists would

be generally worded by topic area rather than being specific audit questions. The auditors would, therefore, be free to formulate specific questions on any new areas suggested during the audit entrance meetin A separate concern regarding the independence of auditors, who also held positions in the onsite emergency organization, has been resolved by the implementation of the Lead / Alternate ED0 concept in early November 1985. Several persons in the QA Department who were also on the roster of E00s were not selected as alternates to the Lead EDO, who was the new Emergency Planning Superviso . -, . __- . - _ _ -

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. Recent Emergency Preparedness Training Activities' -

The inspectors determined that the new Vice President, Nuclear, the new Plant Manager, and Emergency Planning Supervisor have completed all training requirements for their emergency organization position As indicated in Paragraph.4, all STAS completed supplemental training on interim-EDO responsibilities in early November 1985. Due to a

. reorganization in the Maintenance Department, several persons were added to the roster of Operational Support' Center-(OSC) Managers. The

. inspectors verified that these individuals had successfully completed required training for this position on October 10-11, 1985. The Linspectors also reviewed'the associated lesson plan and concluded that it' adequately addressed relevant procedures; however, the following are

. suggested improvements to the OSC Manager Lesson Plan:

• Greater emphasis should be placed on the habitability criteria for relocating the OS * The lesson plan should also indicate that emergency repair teams must be called-out for any OSC activation, as indicated in the implementing procedur * The lesson plan should clearly indicate who was responsible to call out personnel to form search and-rescue, emergency repair, and re-entry team . Licensee Audits The inspectors reviewed th'e records of several audits of the emergency ,

i preparedness program which had already been completed during 1985. All i recora: of these audits were complete and readily available. Audit-

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No. 1396 addressed the implementation of various EI - and AD - series procedures and the' annual medical. drill. The QA staff was adequately monitoring the Emergency Planning staff's progress 'on corrective L actions for the audit findings. Some extensions on compleLing currective actions had been granted, due,to these actions being associated with the revision to the Emergency Plan scheduled for March 1986. QA staff was also adequately tracking corrective actions on three findings resulting from Surveillance No. 1473, which was performed ~during the annual exercise. The auditor tasked with observing the corporate drill also

' stated that a QA surveillance report would be generated for that event and that QA staff would more frequently audit the various emergency preparedness drills. The principal annual audit of the program was conducted during the period October 28 through Rovember- 15, 1985. The audit was performed by certified auditors.from the SAIC company, with the assistance of one of the Station's QA staff. 'Only~a draft audit checklist was available for review,'as the audit report was still in preparation by SAIC. It was evident, however, that the checklist had '

l largely been based on'the criteria of NUREG 0654, Revision <

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7. Completion Status of the Technical Support Center (TSC)

As indicated in Inspection Report No. 50-346/85034(DRSS), the licensee was conducting a feasibility study to determine whether some TSC staff could be relocated from the current TSC within the Davis-Besse Administration Building (DBAB) to a TSC to be reconfigured from available workspace within the protected area. If the creation of a TSC within the protected area was feasible, any remnants of the TSC organization and equipment remaining at the DBAB would likely be merged with personnel and equipment in the building's Emergency Control Center (ECC) to form, in essence, a single Emergency Operations Facility (EOF) at the DBAB. Based on discussions with the licensee, the inspectors determined that the licensee's initial plan to convert several work areas within the Control Room's emergency ventilation system envelope into a TSC was probably not feasible. In early December, the licensee was determining whether work space in the vicinity of the Radiation Access Control Area (RACA) or on the turbine deck could be converted into a suitable TSC. The licensee indicated that its feasibility study would be completed at the end of January 198 The inspectors requested that the licensee keep Region III Emergency Preparedness staff informed of the progress on the TSC relocation feasibility stud . Emergency Planning Zone (EPZ) Meeting - December 10, 1985 The meeting was held at the Davis-Besse site with those representatives denoted in Section 1 to discuss the December 9, 1985 letters from the Federal Emergency Management Agency (FEMA) to the State of Ohio, especially as they related to the inclusion of the City of Port Clinton in the EPZ. A brief description of the events that had occurred prior to the issuance of the letters was provided. The City of Port Clinton representatives stated that they did not feel any major obstacle would exist, provided that the entire city was included in the EPZ and that the extra provisions provided to Ottawa County were also provided to the City. Licensee representatives agreed with the city's position, and another meeting between the licensee and city representatives was scheduled to work out the details. Both the NRC and FEMA representatives described their respective regulations regarding this issu . Meetings December 6, 1985 Exit Interview The inspectors discussed their preliminary findings with those licensee representatives denoted in Paragraph 1. The licensee agreed to consider the items discussed. The Operations Training Manager committed to issue a memo within one week to all licensed personnel regarding the finalized relationship between the Shift Supervisors and Shift Technical Advisors regarding performance of interim-EDO responsibilities. The licensee indicated that none of the matters discussed were prorietary in natur .

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b. December 10, 1985 Meeting

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The inspector participated in a meeting on FEMA's response to the

!- proposed revision to the plume exposure pathway EPZ borders, j especially as it related to the inclusion of the City of Port i

Clinton, with those governmental and licensee representatives denoted in Paragraph ;

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