ML20050C686
| ML20050C686 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/23/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Crouse R TOLEDO EDISON CO. |
| Shared Package | |
| ML20050C687 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-654, RTR-NUREG-737 NUDOCS 8204090254 | |
| Download: ML20050C686 (12) | |
See also: IR 05000346/1982001
Text
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IMAR 2 3 682
Docket No. 50-346(DEPOS)
Toledo Edison Company
ArrN:
Mr. Richard P. Crouse
Vice President
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Nuclear
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Edison Plaza
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Gentlemen:
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Subject: Emergency Preparedness Appraisal
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To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals of the emergency preparedness programs at all operating nuclear
power reactors. The objectives of these appraisals are to evaluate the over-
all adequacy and effectiveness of emergency preparedness and to identify
areas of weakness that need to be strengthened. We will use the findings
from these appraisals as a basis not only for requesting individual licensee
action to correct deficiencies and effect improvements, but also for effecting
improvements in NRC requirements and guidance.
During the period of February 8-19, 1982, the NRC conducted a special
appraisal of the emergency preparedness program at the Davis-Besse Nuclear
Power Station. This appraisal was performed in lieu of certain routine in-
spections normally conducted in the area of emergency preparedness. Areas
examinod during this ap.oraisal are discussed in the enclosed 50-346/82-01
report. Within these areas, the appraisal team reviewed selected procedures
and representative records, inspected emergency facilities and equipment,
observed work practices, and interviewed personnel.
Significant deficiencies for which you have made acceptable commitments to
resolve are discussed in the Confirmation of Action Letter dated February 23,
1982, enclosed as Appendix A.
The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program. These are discussed in
Appendix B " Preparedness Improvement Items."
0204090254 820323
PDR ADOCK 05000346
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Toledo Edison Company
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In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed. The results of this review indicate that certain
deficiencies exist in your Emergency Plan. These are discussed in Appendix C,
" Emergency Preparedness Evaluation Report."
Several areas in your emergency preparedness program were not complete at the
time of this appraisal and therefore were not examined. These items are
identified as Open Items and are listed in the enclosed Appendix D.
These will
be examined by our staff upon complete implementation of the area involved.
Please notify our office relevant to your completion schedule for these items
for re-examination by our staff.
We recognize that an explicit regulatory requirement pertaining to each item
,
identified in Appendices A, B, and C may not currently exist. Notwithstanding
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this, you are requested to submit a written statement within thirty days of
the date of this letter describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration
of each of the items in Appendix B.
This description is to include:
(1)
steps which have been taken; (2) steps which will be taken; and (3) a schedule
for completion of actions for each item.
This request is made pursuant to
Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations. With
regard to Appendix C, within 90 days of the date of this letter, you are
requested to provide changes to the emergency plan correcting each deficiency.
Copies of these changes are to be submitted in accordance with the procedures
delineated in 10 CFR 50.54(q).
This is to inform you that should the deficiencies addressed in the
Confirmation of Action Letter of February 23, 1982, not be corrected by the
commitment dates provided, the Commission will determine whether the reactor
shall be shut down until such deficiencies are remedied or whether other
enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulatior.s, a copy of
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this letter, the enclosures, and your response to this letter will be placed
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in the NRC's Public Document Room.
If this report contains any information
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that you (or your contractors) believe to be exempt from disclosure under
!
10 CFR 9.5(a)(4), it is necessary that you (a) notify this office by tele-
phone within ten (10) days from the date of this letter of your intention
to file a request for withholding; and (b) submit within twenty-five (25)
days from the date of this letter a written application to this office to
withhold such information.
If your receipt of this letter has been delayed
such that less than seven (7) days are available for your review,.please
notify this office promptly so that a new due date may be established.
Con-
sistent with Section 2.790(b)(1), any such application must be accompanied
by an affidavit executed by the owner of the information which identifies
the document or part sought to be withheld, and which contains a full state-
ment of the reasons which are the bases for the claim that the information
should be withheld from public disclosure. This section further requires
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Toledo Edison Company
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the statement to address with specificity the considerations listed in
10 CFR 2.790(b)(4). The information sought to be withheld shall be incor-
porated as far as possible into a separate part of the affidavit.
If we do
not hear from you in this regard within the specified periods noted above, a
copy of this letter, the enclosures, and your response to this letter will
be placed in the Public Document Room.
The responses directed by this letter (and the accompanying Notice) are
not subject to the clearance procedures of the Office of Management and
Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you.
Should you have any questions concerning the items
of Appendix C, please contact Mr. W. B. Grant, Emergency Preparedness Section,
at (312)932-2536.
Sincerely,
Original
!gned by
MO R G. Keppler
James G. Keppler
Regional Administrator
Enclosures:
1.
Appendix A, Confirmation of
Action Letter dtd 2/23/82
2.
Appendix B, Preparedness
Improvement Items
3.
Appendix C, Emergency
Preparedness Evaluation
Report
4.
Appendix D, Open Items
5.
Inspection Report
No. 50-346/82-01(DEPOS)
cc w/encls:
T. D. Murray, Station
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
Harold W. Kohn, Power Siting
Commission
Helen W. Evans, State of Ohio
Robert M. Quillin, Ohio
Department of Health
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Appendix A
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CONFIRMATION OF ACTION LETTER
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Docket No. 50-346
Toledo Edison Company
ATTN:
Mr. Richard P. Crouse
Vice President
Nuclear
Edison Plaza
300 Madison Avenue
Toledo, OH 43652
Gentlemen:
This letter is to confirm agreements reached between you and others of your
staff, and Mr. W. Axelson and other members of the NRC staff on February 19,
1982, during the management exit interview following the NRC Emergency
4
Preparedness Appraisal.
1
Immediate corrective actions are required for significant Appraisal Findings.
The exact nature of the required actions, as well as the agreed upon dates
for such actions, are as follows:
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1.
Procedure for Implementation of Emergency Plan
Required Actions
a.
The licensee shall provide a schedule for installation and cali-
bration of a upgraded seismic monitoring system which will be
capable of determining earthquakes greater than OBE levels (Alert
Emergency) and SSE levels (Site Area Emergency). EALs shall be
calculated for OBE and SSE levels and incorporated into the
Emergency Plan and its procedures.
(Sections 4.1.13 and 5.2)
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(346/82-01-02)
This shall be completed by March 22.
b.
All operations crew personnel (licensed operators) shall be
retrained relevant to implementation of Special Procedure 1105.17,
Seismic Monitoring System Procedure.
(Section 5.2) (346/82-01-03)
This shall be completed before startup following the forthcoming
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refueling outage.
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Appendix A
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c.
Documented guidance and training shall be provided for the operat-
ing crew (licensed operators) to cope with a loss of vital DC power.
This shall include provisions to ensure that the Shift Supervisor
will classify such an event in accordance with the Emergency Plan.
(Section 5.2) (346/82-01-04)
,
This shall be completed before startup following the forthcoming
refueling outage.
d.
EALs shall be developed for the main steam line radiation monitors
(N-16) for those events listed in Table 4-1 of the Emergency Plan.
In addition, training shall be provided to appropriate radiation
assessment personnel relevant to the use of the EALs.
(346/82-01-05)
This shall be completed before startup following the forthcoming
refueling outage.
If our understanding of your planned actions described above is not in ac-
cordance with the actual plans and action being implemented, please contact
this office by telephone and in writing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Further, please
inform this office, in writing, upon completion of all the above action items.
Sincerely,
James G. Keppler
Regional Administrator
cc:
T. D. Murray, Station
Superintendent
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
liarold W. Kohn, Power Siting
Commission
llelen W. Evans, State of Ohio
Robert M. Quillin, Ohio
Department of Ilealth
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Appendix B
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PREPAREDNESS IMPROVEMENTS ITEMS
Based on the results of the NRC's appraisal of the Davis-Besse Nuclear
Power Station Emergency Preparedness Program conducted February 8-19, 1982,
the foll ving items should be considered for improvement:
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1.
The individual who is specifically in charge of emergency operations
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when the Operations Director is unavailable should be identified.
(Section 1.2)
2.
The personnel call out list should be prioritized to assure that the
expertise required in Table B-1 of NUREG-0654 can be f.dentified.
,
(Section 2.2.2)
3.
Of f hours shift augmentation drills should be conducted to evaluate
whether the call out system can meet the goals of Table B-1 of
NUREG-0654, Revision 1.
These drills should be conducted quarterly,
documented, and used to identify and correct deficiencies in the call
out procedure.
(Section 2.2.21
4.
The Operations Support Center should be equipped with fixed emergency
lighting.
(Section 4.1.1.3)
5.
All primary coolant sample lines at the rear of the emergency sample
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module should be provided with shielding.
(Section 4.1.1.5)
6.
Table 3 of the Emergency Plan Administrative Procedures Section
Administrative Directive (AD) 1827.10 should be revised to include
Xu/Q values for the G stability class when the new Class A model
meteorology system is adopted.
(Section 4.2.1.4)
a
7.
An HPN telephone should be installed in the Technical Support Center.
(Section 4.2.3)
8.
Procedure AB 1203.06, Inadequate Core Cooling Guidelines, should be
revised to insure that the Shift Supervisors and reactor operators do
not omit the need for implementing Emergency Instructions (EIs) in
accord with the reference provided in Emergency Procedure (EP) 1202.06.
(Section 5.2)
9.
Existing procedures should indicate where post accident samples are to
be stored and disposed of after analysis.
(Sections 5.4.2.4 and
5.4.2.6)
10.
Access and egress routes based on projected radiation levels in cor-
ridors and hallways should be provided for the sample team obtaining the
post accident samples to insure ALARA is adhered to.
(Sections 5.4.2.4
and 5.4.2.6)
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Appendix B
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11.
Procedure AD 1850.04 should be upgraded to provide for the transportation
and relocation of the multichannel analyzer and GeLi crystal.
(Section 5.4.2.4)
12.
The Industrial Security Plan Procedure AD 1808.00 should be revised to
include specific steps involved in personnel accountability, how this
accountability is maintained throughout the emergency and how missing
personnel are identified. A cross reference with Supporting Procedure,
Search and Rescue, AD 1827.16 should be included.
(Section 5.4.3.3)
13.
The licensee should procedurally specify how the corporate response
organization will be mobilized. Sufficient personnel are availabic to
accomplish this, but no detail presently exists in the notification
procedures.
(Section 2.2.1)
14.
A formal training program for the corporate emergency response
organization should be established.
(Section 3.2)
15.
Formal generic training, as well as specific training, should be
conducted for offsite agencies in the Emergency Plan and Procedures.
(Section 3.2)
16.
The training records should be improved to assure that complete,
up-to-date, and timely information is available on the emergency
preparedness training program.
(Section 3.2)
17.
The use of the classroom style training session should be continued in
addition to any prerecorded audio-visual program that is established to
ensure program accuracy, allow for a more in-depth specialized curriculum,
and encourage student / instructor interaction.
(Section 3.2)
18.
A method to test the students understanding of emergency training course
material should be provided.
(Section 3.2)
19.
A system to promptly train emergency personnel when significant changes
occur in policy, plans, or procedures should be provided.
(Section 3.2)
20.
IIP 1602.01 (External Personnel Monitorings) should be replaced by
emergency personnel monitoring procedures which describe the personnel
monitoring function during emergencies, including provision for TSC, ECC,
and OSC personnel.
(Section 5.4.3.4)
21.
Those Emergency implementing Procedures (Els) containing directions to
contact the Station Superintendent should specifically allow the Shift
Supervisor to exercise judgment.
(Section 5.1)
22.
A comprehensive review should be made of the red-blue color coding /
annunciution portion of the newly installed fire protection system by
the licensee's technical / management staff
(Section 5.4.8)
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Appendix C
EMERGENCY PREPAREDNESS EVALUATION REPORT
The following is a list of deficiencies identified in the Davis-Besse Nuclear
Power Station Emergency Plan (September 1, 1981, Revision 3).
These defi-
ciencies are categorized as per the planning standards of 10 CFR 50.47(b).
These deficiencies as well as those listed in Appendix A must be corrected
in accordance with the provisions of 10 CFR 50.54(s)(2):
PLANNING STANDARD 50.47(b)(2) (ONSITE EMERGENCY ORGANIZATION)
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(346/82-01-06)
The Plan does not specify how minimum shift staffing requirements as
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per Table B-1 of NUREG-0654 will be established.
The Plan does not specify how shift augmentation will be ensured.
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Specifically the Plan does not describe the administrat:fe means (e.g.,
studies and/or drills) inplemented to ensure that the design goals of
shift augmentation are met as described in Criterion II B.S. of
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NUREG-0654, Revision 1.
In Figure 5-3 of the plan, (Onsite Emergency Organization), change the
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location indicated for the Operations Director from Edison Plaza to
Emergency Control Center.
In Section 5.2.2.1 of the Emergency Plan, revise the description of
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responsibilities for the Plant Operations Manager and the Operations
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Engineer to reflect a concept of supporting and advising the Shift
Supervisor so that no confusion exists regarding who is in charge of
control room activities.
PLANNING STANDARD 50.47(b)(3) (EMERGENCY RESPONSE SUPPORT AND RESOURCES)
(346/82-01-07)
The plan does not specify how long it will take for Federal resources
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(DOE) to arrive at the nuclear facility if requested, and specify the
availability of resources needed to support the Federal response, such
as air ficids, command posts, and communications capability.
The plan does not specify who is likely to be sent by corporate man-
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agement to the local Emergency Operating Center (EOC) and indicate who
has the responsibility for assuring the person is dispatched to the EOC.
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Appendix C
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PLANNING STANDARD 50.47(b)(4) (EMERGENCY CLASSIFICATION SYSTEM)
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(346/82-01-08)
The Plan does not adequately provide Emergency Action Levels (EALs)
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as per Appendix 1 of NUREG-0654, Revision 1, in the following areas:
UNUSUAL EVENT
Initiating Condition 7 (loss of power). The licensee used the term
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" sustained loss of offsite power." The word sustained should be
removed as it is misleading.
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ALERT
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Initiating Condition 2 (gross failure of one steam generator tube with
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loss of offsite power). The licensee interpreted this initiating
condition to mean leak rates of over 400 gpm wherens the intent of
NUREG-0654 included smaller leak rates (i.e., 100-200 GPM). The
licensee's EALs are acceptable for leak rates over 400 gpm but should
be modified to include lower leak rates.
Initiating Condition 8 (loss of DC power). The word " sustained" should
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be removed from the licensee's EAL.
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SITE EMERGENCY
Initiating Condition 3 (rapid failure of steam generator tubes-several
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hundred gpm Icakage) with loss of offsite power. The EAL set is based
upon a leak rate in excess of 1000 gpm.
The EAL set should be modified
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so that it applies to any leak in excess of several hundred gpm (i.e.,
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400-700 GPM).
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Initiating Condition 13 (dose rates at site boundary). The EAL's
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should be revised to express radiation in terms of dose rate rather
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than dose.
GENERAL EMERGENCY
EALs have not been calculated for those PWR sequences which could Icad
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to a core melt and likely failure of containment.
(See pages 1-18 of
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Appendix 1 in NUREG-0654 Revision 1).
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Appendix C
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When the new Kamen High Range Station Vent System is installed, EALs
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need to be calculated for those dose rates as per Appenoix 1 of
NUREG-0654. EALs need to be calculated for those dose rates
applicable for a Site Emergency also, after installation of the
Kamen system.
PLANNING STANDARD 50.47(b)(5) (NOTIFICATION METHODS AND PROCEDURESJ
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(346/82-01-09)
The Plan does not provide the content for wri+ ten messages intended
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for the public to assure consistency with the licensee's classification
scheme. A discussion of the format of the messages to the public giving
instructions regarding specific protective actions to be taken by
occupants of affected areas should be included in the plan. A statement
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defining who will issue the messages, licensee or local authorities should
also be added.
PLANNING STANDARD 50.47(b)(8) (EMERGENCY FACILITIES AND EQUIPMENT
1348/82-01-10)
The Plan does not specify how NUREG-0696 criteria will be met.
This
information should include:
The types of equipment available in the TSC and EOF identified in
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NUREG-0696, including types and locations of communications equipment.
When commitments are fully implemented as stated in the Plan, then
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the Plan must be revised to reflect these changes;
i.e.,
installation
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of post-accident monitoring and sampling systems, process monitors,
,
)
The Plan contains no provisions for acquisition of data on hydrological
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and seismic parameters form offsite sources.
PLANNING STANDARD 50.47(b)(10) (PROTECTIVE RESPONSE)
(346/82-01-11),
The Plan does not specify capabilities to decontaminate evacuated
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personnel at the offsite assembly point.
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Appendix C
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The time required to warn or advise onsite personnel is not stated in
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the plan. The means used to warn or advise contractor / construction
personnel and individuals who may be in the owner controlled area but
outside the protected area is not addressed.
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The means for transporting evacuated onsite personnnel is not addressed.
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The plan fails to state if personnel can be accounted for within 30
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minutes of the declaration of an emergency or if continuous account-
ability can be maintained after the intital effort.
The plan fails to indicate if protective actions will be in accordance
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with recommendations in EPA-520/1-75-001, " Manual of Protective Action
Guides and Protective Actions for Nuclear Incidents."
PLANNING STANDARD 50.47(b)(11) (RADIOLOGICAL EXPOSURE CONTROL)
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(346/82-01-12)
The Plan does not define action levels for determining the need for
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decontamination of personnel nor that the licensee has the capability
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to remove radioiodine contamination from the skin.
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PLANNING STANDARD 50.47(b)(14) (EXERCISES AND DRILLS)
(346/82-01-13)
The Plan does not address the requirement to test communications with
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NRC Headquarters and Region III Operation Center from the TSC, EOF
and Control Room on a monthly basis. This is required by 10 CFR 50, Appendix E,Section IV E.9.d.
PLANNING STANDARD 50.47(b)(16) (RESPONSIBILITY FOR THE PLANNING EFFORT
(346/82-01-14)
The Plan does not specify training for individuals responsible for
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emergency planning effort, such as the Emergency Planning and
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Preparedness Supervisor.
There is no provision for an independent review of the emergency
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preparedness program every 12 months as per 10 CFR 50.54(t).
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Appendix D
PREPAEEDNESS OPEN ITEMS
The following is a list of Open Items identified in the area of Emergency
Preparedness which must be re-examined and completed in accordance with
schedules set forth in NUREG-0696 or NUREG-0737:
1.
The permanent Technical Support Center is an open item pending approval
by the NRC Division of Emergency Preparedness.
(Section 4.1.1.2)
(346/82 91-15).
2.
The permanent Emergency Control Center is an open item pending approval
by the NRC Division of Emergency Preparedness.
(Section 4.1.1.4)
(346/82-01-16).
3.
High range 10' rad /hr containment dome monitors shall be installed in
accordance with NUREG-0737.
(Section 4.2.1.2) (346/82-01-17).
4.
Seismic monitoring capability shall be upgraded, procedures written,
and training provided in accordance with SP 1105.17.
(Section 4.2.1.3)
(346/82-01-18).
5.
Training shall be provided to Auxiliary and Equipment Operators in
Health Physics (HP) methods and procedures to ensure they can perform
in plant HP surveys during an emergency.
(Section 2.2.2) (346/82-01-19).
6.
The permanant Containment Air Monitoring System shall be installed in
accordance with NUREG-0737.
Procedures for the use of the system and
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training in the equipment and the procedure shall be provided.
(Sections 4.1.1.6, 5.4.2.6, and 5.4.2.7.)
(346/82-01-20).
7.
Installation, testing and development of procedures covering sampling
and analysis using the Kamen Primary Coolant High Range Sampling System
must be completed (Sections 4.1.1.5, 4.1.1.8, 5.4.2.4, and 5.4.2.5).
(346/82-01-21).
8.
Installation, testing and development of procedures covering sampling
and analysis using the Kamen Station Vent System must be completed,
(Sections 4.1.1.7, 5.4.2.8, 5.4.2.9) (346/82-01-22).