ML20084K169
| ML20084K169 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/18/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20084K166 | List: |
| References | |
| 1-423, NUDOCS 8405110130 | |
| Download: ML20084K169 (8) | |
Text
l OfMS*
/
Docket No. 50-346 rotsoo License No. NPF-3 Serial No. 1-423 I,Y
"'* " 22' April 18, 1984 Mr. James G. Keppler, Regional Administrator United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Toledo Edison acknowledges receipt of your March 23, 1984 inspection report (Log No. 1-936) for the February safety inspection on Emergency Preparedness conducted at the Davis-Besse Nuclear Power Station, Unit 1.
In your inspection report cover letter, you recommend inclusion of the Emergency Planning Program into the Regulatory Improvement Program (Per-formance Enhancement Program) (PEP) being implemented for other areas of the Company.
This program began on March 6, 1984, and Phase 1 of the PEP Program, involving situation appraisal and problem analysis has been completed.
Establishment of an Action Planning Team for Emergency Preparedness issues would put this team significantly behind the activities of the other teams, and delay the overall program completion, due to the need for coordination of the next phase.
However, Toledo Edison is addressing, in other Action Planning Teams, the major concerns identified in your inspection report, specifically, the improved adherence to commitment dates to the Commission and coordination with operating groups within Toledo Edison.
Following an examination of the items of concern in Appendix A (apparent non-compliances). Toledo Edison herein offers information regarding these items:
1.
Violation:
10 CFR 50.54(t) states in part, "the licensee shall provide for a review of its emergency preparedness program at least every 12 months by persons who have no direct responsibility for implementation of the emergency preparedness program. The review shall include an evaluation for adequacy of interfaces with State and local governments and of licensee drills, exercises, capabilities and procedures.
The results of the review, along with recommenda-THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO. OH10 43652 g 23 8 8405110130 840508 PDR ADOCK 05000346 G
D:ck;t N2. 50-346 License No. NPF-3 Serial No. 1-423 April 18, 1984 Page 2 tions for improvements, shall be documented, re-ported to the licensee's corporate and plant manage-ment and retained for a period of five years. The part of the review involving the evaluation for adequacy of interface with State and local govern-ments shall be available to the appropriate State and local governments."
Contrary to the above, the licensee did not include in its annual review in 1983 an evaluation for ade-quacy of interfaces with State and local governments and of licensee emergency preparedness capebilities and procedures. The TED Quality Assurance (QA)
Division performed a partial review, documented as j
Report Number 1028. Neither this 1083 review nor the Review and Assistance visit from the Institute for Nuclear Pow;r Operations (INPO) conducted during 1983 included the entire scope and content of the Emergency Planning Program review and defined in 10 CFR 50.54(t).
This is a Severity Level IV violation (Supplement I).
Response: (1) Corrective action taken and results achieved.
1 The Toledo Edison Company Quality Assurance Department has previously performed an annual audit of the Davis-Besse Nuclear Power Station Emergency Plan. However, to meet the j
requirements of 10 CFR 50.54 (t), they will increase their scope to include a complete annual review of the Emergency Preparedness Program. The findings from this review and all future reviews will be reported to Toledo Edison Company Senior Management and State and local officials for those sections of the review that are appropriate.
(2) Corrective action taken to avoid further non-compliance.
The Davis-Besse Nuclear Power Station Emergency Plan will be revised to incorporate the specific requirement of the annual independent review to be conducted under the purview of the Quality Assurance Department.
(3) Date when full compliance will be achieved.
j A complete review of the Emergency Preparedness Program and changes to the Emergency Plan indicated above will be incorporated by December 31, 1984.
Dock t No. 50-346 License No. NPF-3 Serial No.1-423 April 18, 1984 Page 3 2.
Violation:
10 CFR 50.54(q) states in part, "A licensee shall follow and maintain in effect emergency plans which meet the standards in 50.47(b) of this part and the requirements in Appendix E to this part."
The Davis-Besse Nuclear Power Station (DBNPS) Emergency Plan, Section 8.1.2, states in part, "licalth Physics drills shall be conducted semi-annually which involve re-sponse to, and analysis of simulated airborne samples and direct radiation measurements in the environment by Radiation Monitoring Team members."
Contrary to the above, the licensee did not conduct semi-annuti llcalth Physics drills in 1983 as required by the DBNPS Emergency Plan.
This is a Severity Level V Violation (Supplement I).
Response
(1) Corrective action taken and results achieved.
Radiation Monitoring Team (RMT) training has been conducted semi-annually, however, it was not being performed in a drill-type format. The Emergency Planning Group will conduct the initial training drill to complete the first portion of the 1984 training. The second drill required for 1984 will be documented during the Annual Emergency Exercise.
(2) Corrective action taken to avoid further non-compliance.
Semi-annual health physics drills for Radiation Monitoring Team members has been added to the annual training schedule issued by the Nuclear Training Department.
(3) The date when full compliance will be achieved.
The Emergency Planning Group will conduct the first drill prior to July 1, 1984.
Following an examination of the items of concern in Appendix B (program weaknesses) Toledo Edison herein offers information regarding these items 1.
Weakness: Administrative Procedure AD 1827.12 should be revised to clearly require that all protective action recommendations for distances within at least 2 miles of the plant include all areau within a 360* radius.
i Dock 3t No. 50-346 l
License No. NPF-3 Serial No. 1-423 April 18, 1984 Page 4 Also Procedure AD 1827.12 (or other appropriate procedures) should be revised to clearly require that immediately upon l
declaration of any General Emergency, an automatic recom-mendation to shelter within a 2-mile radius and 2 to 5 miles in af fected downwind sectors shall be made to state and local officials in the event that an equivalent recom-mendation had not already been made (346/84-02-03)/(Para-graph 4).
Response Administrative Procedure AD 1827.12 Protective Action Guidelines, has been revised and was approved on April 11, 1984, by the Station Review Board, to provide a clear requirement that all protective action recommendations for a distance out to two piles of the plant include all areas within a 360' radius.( Also, AD 1827.12 has been revised to clearly require that immediately upon declaration of any General Emergency, an automatic recommendation to shelter within a two mile radius and to five miles in affected downwind sectors shall be made to State and local officials in the event that,an equivalent recommendation had not already been made) All other procedures reference AD 1827.12 for providing recommendations to State and local authorities and, therefore, will not have to be revised.
2.
Weakness: Initial messages contained in the notification checklists of El 1300.03 and EI 1300.04 should be revised to address all items in Planning Standard E, Criterion 3 of NUREG-0654 Revision 1.
(Paragraph 5) (346/84-02-04).
Responset The initial messages section of the following Emergency Plan Implementing Procedures, EI 1300.02, Unusual Event, El 1300.03, Alert. EI 1300.04 Site Area Emergency, and El 1300.05, General Emergency, will be revised to address all items in Planning Standard E. Criterion 3 of NUREG-0654, Revision 1.
These revisions will be incorporated into the above listed procedures by July 1, 1984.
3.
Weakness: A supply of copies of the current revisions to the ED0/
Shif t Supervisor checklists f or each emergency class, which include the initial message format, and the associ-ated Periodic l*pdate Record form should be maintained in the Control Room and/or Shift Supervisor's office.
(Paragraph 5) (346/84-02-06)
Response The Control Room is now on the distribution list and has received additional copies of Emergency Plan Implementing Procedure checklists and notification forms. The Control Room has also received additional copies of the necessary
G D;ckst N3. 50-346 License No. NPF-3 Serial No. 1-423 April 18, 1984 Page 5 data sheets from AD 1827.10, Emergency Offsite Dose Esti-mates, and AD 1827.12, Protective Action Guidelines.
4.
Weakness: The outdated Administrative Memorandum No. 37, ECS Pager and Telephone Numbers, should be updated and reissued as soon as possible.
(Paragraph 5)
(346/84-02-07)
Response: Revision 32 to Administrative Memorandum No. 37 ECS pager and Telephone Numbers, was updated and approved on March 1, 1984, and formally distributed on March 5, 1984.
5.
Weakness: Procedure AD 1827.10, should be revised to include a more realistic noble gas dose calculation methodology.
Specifically, the procedure presently containg,a dose factor of 3.3 x 10' mrem /hr per uCi/cc for Xe'".
Other noble gases in the source term are not addressed.
The procedure should contain a factor which is more representative of a tresh noble gas mixture (approximately 3 x 10' mrem /hr per uCi/cc)
(Paragraph 10) (364/84-02-08).
Response: Administrative Procedure AD 1827.10, Emergency Offsite Dose Estimates, was revised and approved by the Station Review Board on March 21, 1984. This revision incorporated the criteria of NUREG/CR-3011. " Dose Projection Considera-tions for Emergency Conditions at Nuclear Power Plants",
which provides offsite dose projections based on a total noble gas mixture associated with a PWR accident scenario.
6.
Weakness: Section 6.5.1 of the EP and stctements in related imple-menting procedures must be revised to specify by title which senior TED management individual has the authority to authorize radiation exposure above 10 CFR Part 20 limits for emergency workers to carry our lifesaving or other emergency activities as sticulated in Planning Standard K.2 of NUREG-0654 and in 10 CFR Part 50.47(b)
(11).
(Paragraph 3)
(346/84-02-02).
Response: This item will be addressed in the, Davis-Besse Nuc1 car Power Station Emergency Plan during the next scheduled revision, due the fourth quarter of 1984.
The revision will identify the Shift Supervisor as initi-ally having the authority to permit radiation exposure above the 10 CFR Part 20 limits up to 100 rem whole body exposure to carry out lifesaving actions. Once the Tech-nical Support Center (TSC) is activated, this responsi-bility is then shifted to the Radeon Operations Manger.
Dockat N2. 50-346 License No. NPF-3 Serial No. 1-423 April 18, 1984 Page 6 In a non-lifesaving, but needed corrective action type emergency, the Station Operations Manager will have the authority to authorize an individual to exceed the pre-scribed limit of 10 CFR Part 20 up to a maximum of 25 rem whole body exposure. During the recovery phase of an emergency, this authority will then shif t to the Recovery Manager.
Following an examination of the items of concern in Appendix C (considered commitment deviations), Toledo Edison herein offers information regarding these items:
1.
Deviation:
Item 4 of Appendix B to Emergency Preparedness Appraisal Report of March 23, 1982 recommended as an improvement item that the Operations Support Center (OSC) should be equipped with fixed emer-gency lighting. The inspection of March 15-18, 1983 concluded that although a Facility Change Request was initiated, installation of lighting by the licensee did not meet the committed date of January 1, 1983. This was the initial devia-tion to the commitment.
As a result of this inspection, although the OSC has been moved from the turbine deck lunchroom to a conference room in the Service Building, the in-spectors determined that neither fixed or portable battery pack emergency lighting has been installed in the OSC.
This a repeat of the initial deviation.
(Paragraph 2)
(346/83-03-09)
Response: (1) Corrective action taken (or planned) and the results achieved.
Facility Change Request (FCR)82-055 has received budget approval and conceptual design work is in progress. This FCR will install fixed emergency lighting in the Operations Support Center (OSC).
Prior to completion of the FCR package, temporary OSC emergency lighting has been installed in the form of marked emergency flashlights in controlled storage.
(2) Date when corrective action will be complete.
FCR 82-055 for Operations Support Center (OSC) emer-gency lighting will be completed prior to December 31, 1984.
m 1
.Dockst No. 50-346
~ *H License No. NPF-3 Serial No.- 1-423
~ April 18, 1984 Page 7
.2.
Deviation:
A weakness from the April 13-14, 1983 Emergency Exercise,. Item 8, stated that " Procedure AD 1827.10 must be revised to incorporate the keyhole approach for identifying affected offsite regions for General Emergency classifications, and must adequately ad-dress both the evacuation-and sheltering options."
The licensee's response in a letter of June 21, 1983 from Mr. R. P. Crouse of TED to Mr. J. G. Keppler of Region III stated that "the keyhole approach, al-though not included in a formal procedure, is con-sidered by personnel responsible for offsite recom-mendations. These concepts will be incorporated into a procedure in conjunction with the completion of a previous commitment to develop a flow chart for immediate offsite recommendations. This item will be complete by January 1, 1984."
This inspection determined that Administrative Pro-cedure AD 1827.10, with which the licensee intended to meet this commitment, was still in draft form.
The changes made were judged unsatisfactory in meeting the ccamitment by the inspection team. The procedure was also not completely revised and imple-mented by the commitment date of January 1, 1984.
(346/84-02-10)
(Paragraph 2).
Response: (1) Corrective action taken (or planned) and the results achieved..
The keyhole approach for identifying affected offsite regions is applicable to AD 1827.12, not AD 1827.10.
Procedure AD 1827.12, Protective Action Guidelines, has been revised and approved by the Station Review Board on April 11, 1984. This revision fully incor-porated the keyhole approach and adequately addresses the options for both evacuation and sheltering. A revised flow chart requiring immediate offsite recom-mendations has also been incorporated into AD 1827.12 during this revision.
(2) Date when corrective action will be complete.
These revisions of AD 1827.12, along with changes noted in Item Number 1. Appendix B, are anticipated to be formally distributed by May 15, 1984.
d
W.
e Dock:t No. 50-346 License No. NPF-3 Serial No. 1-423 April 18, 1984 Page 8 Following an examination of the recommendation items in the inspection Sununary, Toledo Edison has incorporated several of these items into the Davis-Besse Nuclear Power Station Emergency Preparedness Program. Further review of all the recommendations is anticipated with additional changes to the program as deemed appropriate.
Very truly yours,
'R.?. L d
RPC:GJR:EAH:SGW:nif cc: DB-1 NRC Resident Inspector
- -