ML20044E156
| ML20044E156 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/29/1993 |
| From: | CENTERIOR ENERGY |
| To: | Chilk S NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR12339, RULE-PRM-50-58 2141, 58FR12339-00016, 58FR12339-16, NUDOCS 9305240020 | |
| Download: ML20044E156 (5) | |
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DOCKET NUMBER F3Tm0N RULE PRM 50-SP
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CENTERf0R GWFI2 IMM) i trine ENERGY umc soma $sm Aans Donald C. Shelton 93 Wu -3 P3 :53 Vee Presdent-Nuclear Toledo, OH 435520301 Dus-Besse (419)249-2333 i
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l Docket Number 50-346 l
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License Number NPF-3 Serial Number 2141 l
April 29, 1993 l
Mr. Samuel J. Chilk Secretary of the Commission l
United States Nuclear Regulatory Commission Vashington, D. C.
20555 Attention:
Docketing and Service Branch
Subject:
Comments on Virginia Electric and Power Company's Petition for Rulemaking to Change the Frequency of Emergency Planning Exercises Gentlemen:
Toledo Edison, a subsidiary of Centerior Energy, is partial owner of and is responsible for operation of the Davis-Besse Nuclear Power Station. Toledo Edison has been authorized for power operation of the Davis-Besse Nuclear Pover Station since April 1977. As a 10 CFR Part 50 licensee, Toledo Edison has a vested interest in any policies the NRC may adopt which can affeet the management and operation of a commercial nuclear power plant.
Toledo Edison has reviewed the proposed rule on the Virginia Electric and Pover Company's Petition for Rulemaking to change the frequency of Emergency Planning Exercises issued for comment by 58 Federal Register 12339 dated March 4, 1993. Toledo Edison supports this proposed amendment of 10 CFR Part 50, Appendix E, Section IV, F.2 and is providing the comments contained in the attachment to this letter.
9305240020 930429 PDR PRM 50-58 PDR
!Q S1 Operating Companies:
CleMond Electre tituminating Toleco Edson
Docket Number 50-346 License Number NPP-3 Serial Number 2141 Page 2 Should you have any questions or require additional information, please contact Mr. Robert V. Schrouder, Manager - Nuclear Licensing, at
'419) 249-2366.
Very ly yours, M /,
KAS/dle Attachment cc:
A. B. Davis, Regional Administrator, NRC Region III J. B. Hopkins, NRC Senior Project Manager S. Stasek, DB-1 !EC Senior Resident Inspector j
J. R. Villiams, Chief of Staff, Ohio Emergency Management Agency, State of Ohio (NRC Liaison)
Utility Radiological Safety Board i
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i Docket Numbar 50-346 License Numbar NPF-3 Serial Number 2141 l
Attachment Page 1 Comments on Virginia Electric and Power Company's Petition for Rulemaking to Change the Frequency of Emergency Planning Exercises l
(58 Federal Register 12339 - March 4, 1993)
I General Comments Toledo Edison has reviewed the Virginia Electric and Power Company's Petition for Rulemaking to change the frequency of emergency planning exercises to biennial instead of annual (58 Federal Register 12339 -
l March 4, 1993). Toledo Edison supports this proposed amendment of 10 CFR 50, Appendix E, Section IV, F.2.
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Specific Comments j
1.
Evaluated Emergency Exercises provide only a small part of the means for providing training for the Davis-Besse Nuclear Power j
Station (DBNPS) Emergency Preparedness program. Annually the DBNPS i
conducts a minimum of three training drills, in addition to a preparatory drill to the Emergency Exercise and the Exercise-
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i itself. These three drills involve realistic scenarios where the emphasis is on creative problem solving and successful corrective
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actions. Drills are critiqued by evaluators. If the Exercise frequency requirement was changed from annual to biennial, these three training drills vould-still continue. It is Toledo Edison's I
viewpoint that the most beneficial Emergency Preparedness training l'
is derived from these training drills, whereas the Exercise validates the level of the Emergency Response Organization (ERO) l proficiency.
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2.
Offsite emergency response agencies are routinely invited by Toledo j
Edison to participate in the drills conducted at the DBNPS, to whatever extent they desire. These agencies have participated at some level in most drills. Their participation has' involved i
communications and often dose assessment activities. Key decision makers have also been often involved. Offsite firefighting, l
Emergency Medical Services, and local lav enforcement have also participated in drills.
l 3.
The NRC resident inspectors are generally included in the DBNPS's drills. They have participated as players, or observed and evaluated as they so chose. Toledo Edison anticipates no objection to expanded NRC coverage of a drill if it is understood this is i
primarily a self-critiqued training evolution, and not a test.
4.
Exercise scenarios require the demonstration of numerous objectives which severely limit their flexibility. The need to provide significant and, in many cases, non-credible releases of radioactive material results in negative training. To produce these radioactive releases multiple failures are required, and the ERO's efforts to mitigate them must be thwarted. This results'in i
considerable frustration for the entire ERO, particularly those associated with operations and repair activities. The effort spent on engineering and procuring reliable equipment is negated by
Docket Nuzber 50-346 License Number-NPF-3 Serial Number 2141 Attachment Page 2 the need to accomplish certain objectives driven by radioactive releases scenarios. Changing exercise requirements from annual to biennial vould significantly reduce this negative training.
5.
Exercise costs to Toledo Edison are similar to those experienced by j
the petitioner:
NRC Inspection costs for 1992 vere approximately $20,000, not counting the two resident inspectors who also participated as evaluators.
1 200 persons participated as either players or controllers for the entire 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of the exercise, and another 300 workers I
evacuated their work area as part of the scenario. This totals j
a loss of 1900 manhours, with an equal amount of productivity
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lost in the preparatory drill. Therefore, in 1992 a o
conservative estimate of lost productivity during the performance of the Exercise and its preparatory drill is 3800 manhours.
Direct expenses for office supplies, duplicating, word processing, and meals added another $10,000 to the cost.
i Scenario development for the Exercise and the preparatory drill i
consumed an additional 800 manhours from various plant i
departments, and required 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of simulator time. At least half of these resources vould have been available to be applied to maintaining the actual effectiveness of the ERO had it not I
been for the Exercise.
Local offsite agencies that elect to participate may also be compensated for their time and expenses.
6.
In addition to the drills, the following methods are used to measure and maintain the DBNPS's Emergency Preparedness Program:
l An annual NRC inspection is performed in addition to the
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Exercise inspection. (The NRC staff could schedule this inspection to include a drill.)
An annual Toledo Edison Quality Assurance Department audit is performed.
The Toledo Edison Quality Assurance Department typically has conducted annually a surveillance on at least one drill.
The Emergency Response Facilities and equipment receives veekly valk-downs to verify readiness, and quarterly inventories are performed of all materials. Inventories are also conducted after use.
Daily offsite communication checks are performed, and all j
communication equipment is tested monthly: telephones,-radios, and fax machines.
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Docket Number 50-346 License Number NPF-3 i
Serial Number 2141
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Attachment i
Page 3 l
I Toledo Edison's plant-vide self assessment program called l
"Windovs" covers seven areas of the Emergency Preparedness program.
A preventive maintenance program is in place which maintains the f
Emergency Response Facilities' mechanical and electrical I
systems: heating, ventilating and air conditioning, vater i
supply, electrical distribution, uninterrupted power supply, and l
7.
A comprehensive Emergency Preparedness training program is in place with various training requirements commensurate with the ERO position. Annual requalification and refresher training sessions j
are held with all ERO members. Lessons-learned from drills and industry sources are presented along with program enhancements.
l Self-critiquing of the training program is an ongoing feature, l
ensuring program effectiveness.
Summary Reducing the frequency of Emergency Exercises from annual to biennial vould not have a negative impact on the effectiveness of Emergency l
Preparedness at Davis-Besse Nuclear Power Station. Exercises are only one of many means currently in use to determine and maintain the l
effectiveness of the Emergency Preparedness program. Reducing the frequency of the Exercises vould make available more resources to be l
applied to actual Emergency Preparedness. Toledo Edison supports the Virginia Electric and Power Company's petition to reduce the frequency of Emergency Exercises to biennial from annual.
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