ML20107L002
| ML20107L002 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/31/1984 |
| From: | Crouse R TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20107K981 | List: |
| References | |
| L-473, NUDOCS 8411130376 | |
| Download: ML20107L002 (9) | |
Text
_
a Docket No. 50-346' TOLEDO I!E)lfI()lU License No. NPF-3 RcnMc P. Cnasst Serial No.-1-473 Voe Prese$ent News w ur ne sni October 31, 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 August 27, 1984 Inspection
. Repcrt No. 84-14 (Log No. 1-1023), for the routine inspection of emer-gency preparedness, including the annual radiological emergency exer-cise at the Davis-Besse Nuclear Power Station, Unit 1.
Following receipt of the inspection report. Toledo Edison emergency pre-paredness personnel met on October 11, 1984, with Messrs. J. Patterson and M. Phillips, at your Regional offices, for discussion and clarifica-tion of issues in the report. The enclosed responses are provided based upon these discussions and clarifications.
Responses to specific identified weaknesses are provided in the attachment to this letter. Two general items mentioned in your letter, however, arc discussed directly. The first item identifies what you consider poor per-formance during this year's annual exercise. We consider this comment to be partially the result of our efforts to take advantage of this year's limited participation (" utility only") exercise.
This is the first such annual exercise since 1980 and will be the last for several years. Given this condition. Toledo Edison made a conscious de-cision to exercise a number of alternate personnel throughout key emergency response positions.
In general, these persons were placed in alternate positions to be able to observe and critique their performance under pres-sure, which was in this case provided by the fact that this was an externally graded exercise.
This oppol tt aity is unavailable in normal training situations and actual emergency cot.ditions where we rarely have significant key personnel absences.
The benefit of this lies in the opportunity to provide evaluation and im-provement of our training program for alternate positions. Again, this opportunity was uniquely available this year.
8411130376 841107 gDRADOCK 05000346 FDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUE TOLEDO, OHIO 43652 2 1964 80N
g 17 Dock:t N3. 50-346
' License No. NPF-3 Serial No. 1-473 October 31, 1984
- Page 2 The'second item relates to the comments that the emergency preparedness program has been faltering as previously alleged in your March 23,.1984
, letter (Log No. 1-936). When discussed in our October 11, 1984 meeting, although no specific criteria were related to this determination, your staff's comments focused on exercise performance, " responsiveness", and inspection findings. Exercise performance is responded to in the attach-ment.
The few issces mentioned in the area of responsiveness tended to relate to supportive programs like the Integrated Living Schedule and Quality Assurance Programs. _ Problems in these areas of inter-program coordination and interface are items being evaluated under the Toledo Edison Performance Enhancement Program, as identified in our response to your March 23, 1984 letter.
The remaining area deals with inspection results. Over the past several months Toledo Edison has been reviewing NRC inspection results since 1980.
The intent of this review is to more specifically identify any trends of concern in the emergency planning area.
The results are difficult to correlate due to the significant change in NRC. inspection format, techniques, and acceptance criteria, in the emer-8ency preparedness area over these years. A first cut statistical review
-does not show significant trends in any particular areas.
A more detailed review is still underway, however, Toledo Edison feels that efforts resulting from its activities discussed in this response and further implementation of the Performance Enhancement Program will result in the improvement desired by your staff as well as Toledo Edison.
The attachment is separated by exercise weaknesses. NRC recommendations, where provided, are also listed. Each weakness has a Toledo Edison response.
-If there are any questions on the attached response, please contact us.
Very truly yours, O
RPC:JH:nif-cc: DB-1 NRC Resident Inspector Marvin S. Fertel m-
Docket No. 50-346 License No. NPF-3 Serial No. 1-473
- October 31, 1984 Attachment Page 1 RESPONSE TO NRC INSPECTION REPORT 84-14 Toledo Edison herein offers the following information on the identified exercise weaknesses:
1.
Exercise Weakness: The exercise scenario submitted to the NRC was incomplete, and the scenario used for the exer-cise contained several technical errors in data.
(346/84-14-01) (Section 5.a)
NRC Recommended Action:
(Section 5.a)
The licensee should make a more concerted effort to provide the NRC Region III with a complete exercise scenario package following the guidelines of FEMA Guidance Memorandum No. 17 which was in-corporated in a January 12, 1982, letter from James G. Keppler, Regional Administrator, to Toledo Edison.
In addition, scenario development and review should include at least one individual skilled in plant operations, preferably an SRO.
(346/84-14-01)
Response
The final scenario package was submitted within the required 20 days prior to the July 31, 1984 exercise.
The detad' of the submittal made by Toledo Edison was consistent with the detail of previously acceptable packages provided under the guidance of the January 12, 1982 letter issued by James Keppler. Ne believe the scenario package met the requirements of this letter, however, in some cases where plant data sheets were not provided. Toledo Edison failed to identify to the NRC reviewers that missing data was on a linear progression, which would have facilitated the NRC's technical review. Although the 20-day package did contain technical errors, these were corrected in time for telephone discussions with the NRC Emergency Preparedness staff on July 17, 1984, or were identi-fied during that discussion and did not appear in the final observer package issued to the NRC upon their arrival at Davis-Desse on July 30, 1984.
It is our understanding that Region III has decided to revise its January 12, 1982 guidance to emergency preparedness personnel on submittal dates for exercise scenario packages, which should alleviate problems identified in this interaction between the NRC's technical review staff and Toledo Edison personnel.
s
.~
~
Docket No. 50-346 License No. NPF-3 Serial No.1-473 October 31, 1984 Attachment Page 2 Toledo Edison will, however, strive to provide for more timely in-house review of the scenario package prior to the submittals to the NRC.
To specifically respond to the recommendation con-cerning the Toledo Edison scenario review committee, this committee did contain one Senior Reactor Operator (SRO) on a full time basis and two SRO's on a part-tine basis.
2.
Exercise Weakness: Activation of the Technical Support Center, Radiation (sic) Testing Laboratory, Emergency Control Center, and Radiation Monitoring Teams was disorganized to the point where some indi-viduals were attempting to implement conflicting assignments made to them by more than one emer-gency response manager. Even after facilities were officially activated personnel were not functioning in their assigned positions.
(346/84-14-02) (Section 5.c, 5.e and 5.h)
NRC Recommended Action:
(Section 5.c)
TSC activation procedures should clearly indicate how personnel are assigned to their initial posi-tions and tasks so that activation will occur smoothly.
(346/84-14-02)
(Section 5.e)
ECC activation procedures should be modified to include some type of system such as a tag board for assignments that will clearly indicate how personnel are assigned to their initial positions and tasks, and specify the minimum positions which must be filled so that activation will occur in an efficient and timely manner.
(346/84-14-02)
(Section 5.h)
RTL and RMT activation procedures should be developed to include some type of system, such as a tag board for assignments, that will clearly indicate how personnel are assigned to their initial positions and tasks.
(346/84-14-02)
Response
TSC:
The Technical Support Center was activated within 26 minutes of the ALERT declaration. The TSC activation procedure identified required personnel assignments, and the TSC task assignment board was used. However, L
g I.
~
Docket N2. 50-346 License No. NPF-3 Gerial No. 1-473 October 31, 1984 Attachment Page 3 a number of our Nuclear Facility Engineering personnel were assigned by their supervisors to report to the TSC as part of a pool of additional engineering resources. Additionally, several engineers were s
located in the TSC to observe for training. Because they were not f.ssued observer badges, nor was there an identified lor. tion for " pool resource personnel",
e these engineers would have seemed to be unsure of their TSC pcsition or responsibilities. The Emergency Planning Groop will more adequately identify non-essential TSC personnel during exercises and designate such personnel with appropriate badging so as to easily identify those not assigned as TSC staff.
ECC:
The ECC activation procedure identified personnel necessary to implement timely and organized activation of this emergency response facility. Additionally, the procedure provided a step-by-step checklist of the actions to be taken by the Emergency Duty Of ficer (EDO). During this exercise, Toledo Edison management emergency response personnel did identify EDO organi-zational problems and his failure to use available procedures. Toledo Edison considers the emergency exercise a major segment of the annual training program of emergency response personnel. Because of this, it was determined that the EDO wculd be allowed to remain in his position to encourage improved performance once activation was accomplished. This decision contributed to the observation of the weak-ness. Toledo Edison has reviewed the EDO list in Administrative Memo No. 41 and is revising the personnel identified and trained for that position.
Additionally Toledo Edison will increase the emphasis on the use of the ECC activation procedure and check-list during EDO training. Also, a revised ECC activa-tion procedure stamitted for Station Review Board con-currence on Octot2r 24, 1984, more adequately addresses the minimum required staffing for activation of the ECC.
RTL & RMT:
Following the 1983 annual emergency exercise, Toledo Edison implemsated an NRC recommendation to add a position of Radiological Testing Laboratory Coordinator to facilitate the activation of the RTL and Radiation Monitoring Teams (RMT's). Therefore, during the July 31, 1984 exercise, the positions were actually being graded for the first time. Additionally, to provide the most experienced monitoring response in the field,
(
l Dock t No. 50-346 License No. NPF-3 Serial No. 1-473 October 31, 1984 Attachment Page 4 the initially assigned pairing of personnel for Radiation Monitoring Teams was changed prior to their move to the field. This personnel switch between the teams created what appeared to be confusion in the checkout of team equipment, but in actuality was an effort by the two Chemistry & Health Physics (C&HP) team members to ensure each team had a full RMT kit.
Toledo Edison is revising the RTL activation procedure to more clearly specify the delineation of duties among the RMT and RTL coordinators.
3.
Exercise Weakness: Technical Support Center communications with the Co,ntrol Room were not sufficiently coordinated to ensure that each group was fully aware of plant status until the differences in data became so disparate that the TSC was told to stop partici-pating.
(346/84-14-03) (Section 5.c)
NRC Recommended Actions:
(Section 5.c)
TSC and Control Room communications need to be sufficiently coordinated to ensure that each group is aware of piant status and the status of actions to mitigate the consequences of the event (e.g., TSC is aware of Control Room valve lineup changes, etc.).
(346/84-14-03)
Response
During our critique of the July 31, 1984 emergency exercise, Toledo Edison TSC management personnel identified that communications between the TSC and Control Room needed some improvement, particularly in the area of technical information transmitted and management discussion. TSC and Control Room personnel are working with the Emergency Planning Group on a method to increase and improve the communication between these two critical emergency response facil-ities.
An improved methodology will be developed and incor-porated into the training for Control Room and TSC personnel in late 1984 and 1985.
It is expected, however, that this methodology may be revised again based on its adequacy as shcwn in the 1985 annual exercise.
This communication coordination, however, was not the reason for halting TSC participation in the July 31, 1984 exercise. The TSC was asked to halt its activity toward cooldown and de-escalation, due to the failure
- w.. :
EDocket:No. 50-346 rp c iLicense No. NPF-3' Serial No. 1-473 October 31, 1984L 3'
-Attachment Page 5 l-
'of the'ECC to declare a General Emergency as scheduled in the scenario. ~The exercise controllers decided to have the ECC go to the General Emergency to allow them to test the EDO and requisite protective actions
+
identified in the ECC and General Emergency procedures and checklists.
l 4..
Exercise Weakness:- Neither the Technical Support Center nor the Emergency Control Center trended critical plant
-data which would impact on offsite releases such as the primary to secondary leak rate and radio-y
~ nuclide composition of the release. Neither-facility maintained a record involving the total.
L.
-material released.
(346/84-14-04) (Section 5.3 and 5.e)
NRC Recommended Actions:
=(Section 5.c)
All critical pltnt data, including that which must be calculated such as primary to secondary leak rate, should be trended during an event to evaluate whether conditions are degrading or off-site releases are increasing.
(346/84-14-04) l(Section 5.e)
Critical data affecting offsite protective action' recommendations,>such as release rate and radio-nuclide' composition, should be plotted during an event so that-evaluations-involving total-material released and potential offsite dose can be made.
(346/84-14-04)
Response
The Data Acquisition and Display System (DADS) does provide trending of critical instrumented plant parameters and this' data is available in the compu-terized DADS-histo'rical files. To more specifically guide the staff, EI'1300.08 has been revised to
-identify the need for~ trending of data and allow for calculation of total population exposure.
'5.
LExercise Weakness: No inplant radiation monitoring data was supplied to the Operational (sic) Support Center, while some team members left the OSC without an accom-panying Chemistry and Radiation Tester to monitor doses, without a prescribed dose allowable to com-plate the assignment and without a briefing of routes to follow and other actions to minimize team dose.
(346/84-14-05) (Section 5.d) 5
/~, e [g Docket No.f50-346
- License-No.'NPF-3 3 gg H ~.
' Serial No.: 1-473 October 31;:1984 A(
Attachment "Lf
- Page'6 NRC Recommended Action
7 ~
Procedures should be developed to ensure that all
~
teams dispatched into the plant during an emergency are accompanied by a C&RT person and are provided with a detailed briefing on a maximum dose allow-7 able for the task, anticipaced dose rates, and appropriate ALARA considerations such as routes to follow to minimize dose.
(346/84-14-05)
Response
The Davis-Besse Operations Support Center (OSC) is divided into several distinct areas including the Fifth Floor Conference-Room where-the OSC Manager is
' located, the Turbine Deck where Repair Teams assemble, and the Health Physics Monitoring Room, where-Chemistry C
& Health Physics (C&HP) personnel assemble. With this format, the OSC Manager communicates with the Health Physics Monitoring Foom on the required repair needs and locations and with the Turbine Deck for Repair Team members. The Repair _ Teams are dispatched from the Turbine Deck and Chemistry & Radiation Testers
-(C&RT's) from the Health Physics Monitoring Room. The
-C&RT's have available.all ALARA information and meet
-the Repair Teams at a pre-determined location based on known in-plant radiological data. Upon meeting with the Repair Teams, the C&RT's provide all ALARA'informa-
. tion and then identify the route to be taken to the repair location, based on ALARA considerations. This procedure was followed and observed by the Operations Support Center.
i 6.
Exercise Weakness:- The' Emergency Duty Officer at the ECC failed to determine if any nonessential personnel were at the plant; and, therefore, a decision to evacuate them was never considered.
(346/84-14-06) i (Section 5.e)
NRC Recommended Action:
The ED0's procedure for Site Area or General Emergency should clearly indicate that a deter-mination of nonessential personnel will be made
.after accountability is completed and fur:her indicate that these personnel will then be evacuated unless radiological or environmental conditions prohibit an evacuation.
(346/84-14-06)
g
_p,
% % g '
.~
- Docket'N). 50-346 j
License No.1NPF-3>
Serial No..1-473 g
g October.31,11984 y
Attachment
.Page:7 6
n
Response
EI 1300.08 does identify that the EDO will consider
.non-essential _ personnel and their subsequent evacua-
.,A
. tion..:Because the EDO failed to use the ECC proce-dures.fthis item was not addressed. Emphasis will be
..placed on the use of procedures during the EDO training.
l:
E Toledo Edison lherein offers the following information on the'. identified comments during the exit interview.
" Statement:.
Your inspection report states that the most recent revision to the Davis-Besse Emergency Plan had deleted a description of the public information program as this had been included in the recently issued Public Information Plan for emergen-J cies. Since this area is. required to be included in the Emergency Plan to meet 10 CFR 50.47(b)(7) requirements, the licensee agreed to submit three controlled copies of this
.public information plan to Region III and two copies to NRC Headquarters to comply with 10 CFR 50.54 (q) requirements.
)
Response
Sections 5.3, 7.1.2.6, 7.4, and 8.2 have not been deleted
~from.the Davis-Besse Emergency Plan and still provide the
' description of the public information program per 10 CFR 1
50.47 (b) (7). In May, 1984, Toledo Edison issued the Corporate j
~
Radiological Emergency Response, which provides the plan for the activation of the Corporate organization to support the needs of Davis-Besse in the event of an emergency requiring activation 'of the Davis-Besse Emergency Plan.. Included as a part of this Plan is the Public Information Implementing Procedures, which: replaces a document, "Public Information Policies and' Procedures", previously issued by the Public.
-Relations Department.
~
)
Under separate cover two controlled copies have been sent
'to.NRC Headquarters (Serial No. 1088) and one to you (Serial No.1-467), per CFR 50.54(q). Additionally, two extra controlled copies were sent to you per.the verbal
_m request of your emergency preparedness staff.
4 I
JH:nif j
i l