ML20100A914
| ML20100A914 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/28/1985 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1-501, NUDOCS 8503260313 | |
| Download: ML20100A914 (5) | |
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Docket No. 50-346 rotsoo
-License No. NPF-3 Serial No. 1-501
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February 28.-1985 Mr. James G. Keppler, Regional Administrator United States Nuclear Regulatory Commission Regica.III
-799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
Toledo Edison acknowledges receipt of your Inspection Report 50-346/85-02, dated January 30, 1985 (Log 1-1109), for the Davis-Besse Nuclear Power Station, Unit No. 1. to this letter provides our comments on the recommendations included in the Appendix to your inspection report.
In some cases, our responses to your recommendations will duplicate those submitted in our response to the Systematic Assessment of Licensee Performance (SALP)
(Serial 1-497, February 4, 1985).
It will be noted when this is the case.
Should you have any questions concerning our comments, please contact Terry D. Murray, Assistant Vice President, Nuclear Operations.
Very truly yours, RPC:JH:nif encl.
cc: DB-1 NRC Resident Inspector hDb DR 1eac I i i
THE TOLEDO EOISON COMPANY EDISON PLAZA 300 MAOISON AVENUE TOLEDO, OHIO 43652
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DockGt No. 50-346 License No. NPF-3 Serial No. 1-501 February 28, 1985 i
J Page 1 l
ATTACHMENT 1 1.
Recommendation:
Establish a schedule for selecting and training a Lead Emergency Duty Officer (EDO).
Response
As identified in our SALP response (Serial 1-497 dated February 4, 1985), by March 15, 1985, a per-sonnel requisition for a new Emergency Planning Supervisor /EDO will be approved. Shortly thereafter, the position will be posted internally and any quali-fled candidates interviewed. By April 15, 1985, Toledo Edison will have determined whether the new Emergency Planning Supervisor will be a current employee of the Company. A training schedule will be eatablished within four weeks of the individual's assumption of the position.
However, in the event no qualified candidate is available in-house, Toledo Edison would need to hire from outside the current organization.
In this case, recruiting and personnel availability would dictate the schedule. However, within four weeks of assuming the position of Emergency Planning Supervisor, e training schedule would be provided.
2.
Recommendation:
Include in the 1985 cmergency preparedness exercise oojective, a demonstration of both a Shift Suporvisor and a Shift Technical Advisor (STA) functioning as interim EDO.
Response
The objectives for the 1985 annual emergency prepared-ness exercise will reflect the use of both the Shif t Supervisor and the SIA as an interim EDO, if this pro-gram is to be implemented before the July, 1985 exer-cise. If the program implementation is delayed, then it will not be used during the exercise and no such objective will appear in the 75-day submittal, due *o the Nuclear Regulatory Conmission (NRC) on May 1, 19b5.
3.
Recommendation:
Develop and implement en action plan for reducing the use of conruitants for pro-viding specialized emergency preparedness training.
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'. 0 ch 1 iDock3t Ns. 50-346-1 License No. NPF TSerial No. 1-501-February 28, 1985.
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Response
LA. plan for the reorganization of the Emergency Planning l
' Group has'been submitted to Senior Management for ap-
. proval; -This. reorganization' calls for a technical up-l grade of the Emergency Planning Supervisor position and
-the addition of a-technical Onsite Emergency Planner.
H After.these positions are approved and filled.,an action j;
plan will be developed for the implementation of emer-gency preparedness training taught by the Toledo Edison Emergency. Planning Staff and the phasing out of. general consultant teaching support.
4.-
Recommendation::
Hire one or more qualified instructors to coordinate and administer post-1985 specialized emergency' preparedness training. Assign such personnel to Nuclear Training rather than e s.
Nuclear Services.
Response
iThe' proposed reorganization of the Emergency Planning Group.(see No.l3 above), identifies that the Emergency
['
. Planning Supervisor and Onsite Emergency Planner will assume teaching' duties for a portion of-the emergency plan training program.
p Due to the Nuclear Training Department's near term effort to meet the INPO accreditation goals, it is not' preparing to assume any major responsibility for Jemergency plan training in the 1985-86 period.
5.-
Recommendation:'
Proceduralize the tracking system aspect of the
-emergency planning staff's scheduling and plan-
.ning system, including the administrative mech-anisms intended to ensure that timely corrective actions are taken on all items being tracked.
Response::
As identified in our February 4,1985 SALP response (Serial 1-497)..the Emergency Planning Activity
' Scheduling System is currently under development and
'will,be used to identify and maintain commitments, required activities, and routine activities. The system will be formally implemented for all future commitments by September 30, 1985, and will have in
-place procedures for identification, tracking, and correction of action items.
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l-Docket No. 50-346' l
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'. License No. NPF-3 l
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Serial No. 1-501-(1 - >
February ^ 28. 1985~
Attachment.l.
Page 3
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-Recommendation:
In addition to items identified in NRC inspec-tion reports and the licensee's drill and exer-cise critiques, the emergency planning staff should also track the implementation of correc-tive actions being taken on training session
. recommendations and audit observations.
Response
The Emergency Planning Activity Scheduling System is being designed to-track all emergency preparedness j
- activities including NRC and INPO commitments, drill I
and exercise critique items, required performance.
-tests, required training, and Quality Assurance audit finding reports. When the system is fully utilized, training session recommendations and audit observa-tions identified for inclusion in the emergency i
. planning program will be tracked.
7.
Recommendation:
Adequate performance of emergency duties should be included in the performance objectives of persons assigned to the emergency response organization.
Response
Toledo Edison identified in its SALP presentation to NRC Region III that the Panagement by Objective (MBO) program was being implemented. The program, as imple-mented at Toledo Edison, is used to develop an indi-vidual's performance where changes are required.
A memorandum will be issued by the Assistant Vice President, Nuclear Operations, to the Nuclear Mission Directors identifying that-duties prescribed in the Emergency Plan be discussed during the MBO process and a mutual understanding of Emergency Plan respon-sibilities gained. Additionally, establishment of new objectives for performance changes are necessary when it is identified that satisfactory performance is not being achieved.
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Recommendation:
Timely completion of all emergency preparedness training for staff personnel should be included in the performance objectives of supervisors of i
personnel assigned to the emergency response i
organization.
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. Dock:t N2. 50-346
.c License No. NPF-3
-Serial No. 1-501 l Feb ruary-28 1985 Page 4
Response
On February 4,1985, a memo was sent to all Nuclear Mission employees from the Assistant Vice President, Nuclear Operations, identifying that attendance at all scheduled training classes, including Emergency Plan Training, was required. The Assistant Vice President, Nuclear Operations is to be notified personally of any non-attendance at scheduled training. This action addresses our concern over attendance and timely completion of required training programs, including emergency preparedness.
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