ML20133E651

Insp Rept 50-346/96-11 on 961104-08 & 1218.Deviations Noted. Major Areas Inspected:Review of EP Program & Plant Support

ML20133E651
Person / Time
Site:	Davis Besse
Issue date:	01/06/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133E630	List: ML20133E625 ML20133E639 ML20133E651
References
50-346-96-11, NUDOCS 9701130096
Download: ML20133E651 (11)

See also: IR 05000346/1996011

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION 111

Docket No: 50-346

License No: NPF-3

Rcport No: 50-346/96011(DRS)

Licensee: Toledo Edison Company

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Facility: Davis-Besse Nuclear Power Station

Location: 5503 N. State Route 2

Oak Harbor, OH 43449

Dates: November 4 8 and December 18,1996

Inspectors: R. Jickling, Emergency Preparedness Analyst l

J. Foster, Sr. Emergency Preparedness Analyst j

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Approved by: James R. Creed, Chief, Plant Support Branch 1 l

Division of Reactor Safety I

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9701130096 970106

PDR ADOCK 05000346

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EXECUTIVE SUMMARY

Davis Besse Nuclear Power Station

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NRC Inspection Report 50-346/96011

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! This inspection included a review of the Emergency Preparedness (EP) program, an aspect

i of Plant Support. This was an announced inspection conducted by two regional

emergency preparedness analysts.

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The overall effectiveness of the licensee's emergency preparedness facilities,

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equipment, trainin0, and organization was very good. (Sections P2.1, P3, P5, and

P6)

Emergency response facilities were in very good material condition and equipment

was available and operable. The licensee provided good response to the inspectors'

identification of an air sampler having the intake and outlet directed toward the

same area. (Section P2.1)

A deviation was identified for failure to provide for a backup Emergency Operations

Facility and modify the Emergency Plan to identify the location of the facility.

(Section P2.1)

A recent revision to the initial notification form was easy to use and provided clear

information to the offsite authorities. The emergency event procedures did not

include the reason for emergency declarations during plant emergency event

announcements. (Section P3)

Overall EP training was good, with challenging drills and performance based training

sessions. Interviewed key response personnel were knowledgeable of their

emergency responsibilities and procedures. Training information related to NRC and

Department of Emergency incident response was not adequately informative or

current. The licensee's Emergency Plan conflicts with NUREG 0654 guidance

concerning response times of certain key emergency response personnel. (Section

PS)

• The requirements of Temporary Instruction (TI) 2515/134, "Onsite Dose

Assessment" were met. The Tl is closed. (Section P8.1)

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Reoort Details

P2 Status of EP Facilities, Equipment, and Resources

P2.1 Material Condition of Emeraency Resoonse Facilities

l a. Insoection Scooe (82701)

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The inspectors toured the Control Room, Technical Support Center (TSC),

Operations Support Center (OSC), Radiological Testing Laboratory (RTL),

Emergency Control Center (ECC), Site Emergency Operations Center (SEOC),

radiation monitoring team (RMT) vehicles, and assessed their material condition. In

each facility, associated equipment, procedures, telephones, and instrumentation

were inspected. Also, the inspectors reviewed provisions for use of a backup

Fmergency Oparations Facility (EOF). The inspectors discussed the matter with

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licenseo representatives and reviewed the following documents:

I a Davis-Besse Emergency Plan j

• Letter dated May 27,1981 (Toledo Edison to NRC) l

• Correspondence dated December 6,1982 (Toledo Edison facsimile to NRC)

. * SECY-83-191. " Backup Emergency Operations Facility for the Davis-Besse l

Nuclear Power Station", dated May 19,1983

• Letter dated June 28,1983 (NRC to Toledo Edison)

i b. Findinas and Observations

Each facility was well maintained and in a very good operational state of readiness.

Copies of the Emergency Plan, Emergency Plan Implementing Procedures and

, appropriate forms were present in each facility, as required. The inspector l

requested numerous pieces of equipment (survey equipment, computers, and RMT

vehicles) to be operated. No problems were observed.

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During the inspection of the RTL, the inspectors identified that a portable RAP-1 air 1

sampler was configured so that the exhaust was discharging into the intake area. I

This air sampler configuration could prevent a representative sample from being

obtained. The issue was discussed with health physics personnel and resulted in

the RAP 1 air sampler from the RTL being takan out of service until further

information could be obtained. The licensee initiated a potential condition adverse

to quality report (961422). Radiation Protection personnel checked other air

samplers at the plant to determine if this configuration was present on other

equipment. One other air sampler was located with a similar configuration.

During the inspection, the inspectors were informed the licensee did not have a

backup Emergency Operations Facility. It had been the inspectors' understanding

that the backup Emergency Operations Facility was the Toledo Edison corporate

office, in Toledo, Ohio.

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In reviewing this matter, the inspectors noted the following points:

Toledo Edison letter dated May 27,1981 (No. 719), responding to NRC

Generic Letter 81-10, describing the primary emergency facilities for the

Davis-Besse Nuclear Power Station. This letter did not specify a backup

EOF, but referenced an emergency support conter consisting of " designated

areas of Toledo Edison's offices in the Edison Plaza located in Toledo, Ohio,

approximately 21 miles from Davis-Besse."

Toledo Edison correspondence (facsimile), dated December 6,1982,

indicated that the backup EOF was located approximately 21. miles from the

i reactor in an existing office structure of glass and steel. Discussion

] identified this as the Toledo Edison corporate building in Toledo, Ohio.

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The Commission approved the Toledo Edison corporate office as the backup

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for the Emergency Operations Facility in SECY-83-191, " Backup Emergency

l Operations Facility for the Davis-Besse Nuclear Power Station", dated

i May 18,1983. The above two pieces of correspondence were referred to

l and attached to the SECY paper.

) * On June 28,1983, Toledo Edison was informed by letter of the

Commission's approval of the Toledo Edison corporate headquarters facility

l as the backup Emergency Operations Facility location. This letter was

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received by Toledo Edison July 1,1983. NRC records did not indicate that

there was any response to this letter.

I * The Davis-Besse Emergency Plan did not identify the Toledo Edison

j headquarters facility as the backup EOF location. The Emergency Plan

[ contained no reference to a backup EOF.

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j On December 18,1996, subsequent to the November 8,1996, exit meeting, the

j inspectors were informed that the licensees' licensing staff had failed to identify

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any documents allowing deviation from the commitment for a backup EOF made by

Toledo Edison management in the December 6,1982, correspondence. The failure

j to satisfy a commitment was identified as a deviation (50-346/96011-01).

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c. Conclusions

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Overall, emergency response facilities were in very good material condition;

however, a deviation was identified for failure to satisfy a commitment to provide

! for a backup Emergency Operations Facility and to modify the Emergency Man to

! identify the location of the backup Emergency Operations Facility.

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P3 EP Procedures and Documentation

a. Insoection Scoce (82701)

The inspector reviewed select licensee emergency plan sections and emergency

plan implementing procedures (EPIPs).

b. Findinas and Observations

Emergency implementing Procedure HS-EP-02245, Revision 4, " Protective Action ,

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Guidelines," was reviewed. This procedure defines guidelines for determining

protective action recommendations (PARS) for omergencies involving abnormal

radiological releases from the plant. The procedure identified options for providing

a PAR if wind direction was not able to be determined and incorporated a PAR flow

chart for core melt sequences which provided clear guidani.e for recommendations

to the State authorities.

Emergency implementing Procedure RA-EP-02110, Revision 0, " Emergency

Notification," was recently revised. The Initial Notification Form had been changed

to provide clear, consistent information to the Stato of Ohio and the local counties,

in a format simihr to Perry Nuclear Power Plant's initial Notification Form. This

form provided excellent clarity to offsite authorities for unplanned radiological

releases, plant prognosis, and transitory events.

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Emergency Implementing Procedure HS-EP-01500, Revision 1, " Emergency l

Classification" and the event procedures: HS-EP-01600, 01700, 01800, and  !

01900, revisions 0, " Unusual Event," " Alert," " Site Area Emergency," and " General  !

Emergency," were reviewed. The event procedures used an effective checklist  ;

format. The inspectors identified the event procedures did not include the reason

for declaring the emergency classification during the plant event announcements.

c. Conclusions

The new initial notification form for offsite emergency notifications was clear and

easy to use. The PAR Flow chart for core melt sequences provided clear guidance

for protective action recommendations to the State. No problems were identified in

the procedures and documentation reviewed.

P5 Staff Training and Qualification in EP

a. insoection Scooe (82701)

The inspector reviewed the licensee's EP training program. This included interviews

with selected key individuals: Emergency Plant Manager, Emergency Director, and

Shift Supervisor. Also reviewed were documentation for the August 14,1996

Semi-annual Augmentation drill, training documents which included training l

feedback forms and critiques, class attendance records and the current Emergency I

Plan Telephone Directory of qualified emergency response organization (ERO) l

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personnel. Additionally, select training lesson plans were reviewed, including ,

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facility walkthrough packages for the TSC, OEC, and ECC.

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l b. Findinas and Observations

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Records indicated that drills, exercises and other training were formally critiqued

! and that significant critique items were appropriately selected for corrective action.

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l Records from the training tracking program were compared with the " Davis-Besse l

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Emergency Telephone Directory," which verified EHO personnel were qualified. No

ERO personnel reviewed were out of qualification, j

interviews were conducted with the three key ERO persons. The persons  ;

interviewed demonstrated very good knowledge of their emergency responsibilities

and procedures.

Discussion with emergency management and a review of training documents

indicated little information was available concerning the current NRC and

Department of Energy incident response programs. A review of training materials

indicated insufficient, outdated information was used. The licensee's evaluation of

this issue and incorporation of appropriate NRC and Department of Energy incident

response information into training will be tracked as an inspection Followup Item

(50-346/96011-02(DRS)).

The semiannual augmentation drill checklist indicated that some positions were

expected to respond to the plant within 60 minutes; other positions had a

designated response time of 120 minutes. This matched the commitments in Table j

5-1 of the Emergency Plan, which provided for some positions to be filled j

immediately from on shift personnel, and positions with a 30 minute response

during day shift hours (60 minutes off hours). Other positions had an indicat9d

response time of between 1-2 hours.

NUREG 0654, Table B-1, indicated minimum staffing requirements for emergencies

and capabilities for augmenting the onshift staff during an emergency. Table B-1

indicated minimum onshift staffing and 30 and 60 minute onshift augmentation

times for specific ERO positions. The Davis-Besse Emergency Plan, Revision 19, j

Section 5, Table 5-1, indicated response times of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the ECC Emergency  ;

Director,1-2 hours for Chemistry and Radiation Protection Technicians, and 1-2 l

hours for Electrical and Mechanical Engineers. NUREG 0654 specifies 60 minutes  !

capability for an Emcrgency Director,60 minutes for Chemistry and Radiation

Technicians and GO minutes for Electrical and Mechanical technical support. The

licensee's actio'is to address emergency response time inconsistencies will be

tracked as an 'nspection Followup Item (50-346/96011-03(DRS)).

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c. Conclusions

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l Overall, EP training was considered good, with challenging drills and performance

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based facility walkthroughs. Critique documentation was available and critique

forms were adequately detailed. Training records were complete. Interviewed

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individuals were knowledgeable about their ERO responsibilities. NRC and

Department of Energy incident response information provided to key ERO personnel

. was not adequately informative or current.

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! P6 EP Organization and Administration (82701)

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} The Nuclear Emergency Preparedness organization continued to report to the Vice

President Nuclear through the Director of Engineering and Services and the Manager

j of Regulatory Affairs.

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{ The EP group had two less planners and one less clerical position than it did during

j the last routine inspection. To provide some additional support to the EP group

assistance was provided by the Training Department in the form of a Senior Nuclear

! General Programs Instructor. The Administrative Department also supported the EP

program in the form of the Senior Administrative Clerk, although EP document

! control was now assumed by EP.

! Specific ERO positions have been deleted or combined. The TSC's Chemistry

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Advisor position was deleted and the function was added to the Radiation

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Protection Advisor. The Fire Protection Advisor was deleted from the OSC. Plant

support to the EP program had been maintained, although the plant reorganization

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had decreased plant resources. No problems were identified related to EP

organization staffing.

1 P7 Quality Assurance in EP Activities

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P7.1 Audits (82701)

a. Insnection Scooe (82701)

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The inspector reviewed Toledo Edison Quality Assessment Audit AR-96-EMPRP-01,

i " Emergency Preparedness & Emergency Response Organization," dated

February 15,1996. Also reviewed was Surveillance Number SR-96-EMPRP-01,

, " Emergency Preparedness'" conducted to evaluate the effectiveness of the

l Emergency Response Organization during the October 2,1996 Integrated Drill.

j b. Findinas and Observations

] The audit was performed by three individuals during January 15-25,1996. The

audit team concluded the EP program was effectively implemented and identified a

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number of strengths within the program. The audit identified two areas which

should be evaluated for improvement. The auditors had visited and interviewed

j offsite authorities to assess the effectiveness of the offsite interface, as required by

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, 10 CFR 50.54(t), and determined that the positive offsite relationship was a

strength.

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Surveillance SR-96-EMPRP-01 was performed by a single individual evaluating drill

performance in the TSC and ECC. Overall performance in the facilities was

considered satisfactory, and no observations or findings were associated with the

surveillance. Areas for improvement identified weak facility briefings and internal

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and interfacility communications.

i c. Conclusions

i The annual audit of the EP program was well detailed and met the requirements of

i 10 CFR 50.54(t).

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f P8 Miscellaneous EP issues

, P8.1 Temocrarv Instruction (TI) 2515/134 On-shift Dose Assessment

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The inspector discussed dose assessment capability and provisions with licensee l

! personnel, reviewed the Emergency Plan and EPIPs, and inspected equipment in

response facilities. Training plans for dose assessment were also reviewed,

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l b. Findinas and Observations I

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The Emergency Plan contained provisions for on-shift dose assessment in Section

i 6, " Emergency Measures." Section 6.1, " Shift Supervisor / Control Room

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Operators," item 6.1.1.b.2 provided for the Shif t Supervisor (initial Emergency )

) Director) to implement the applicable Emergency Plan Procedure.

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! The inspector reviewed Emergency Plan Implementing Procedure HS-EP-02240,

j "Offsite Dose Assessment," Revision 4, dated December 29,1993. Section 4.1.1

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of the procedure indicated that the Emergency Director shall " direct calculation of

j the release and dose rates using available qualified dose assessment personnel

l including Licensed Reactor Operators and Senior Operators." Section 5.0,

, " Initiating Conditions", stated that the procedure shall be implemented "at the

i request of the Emergency Director or Dose Assessment Coordinator when an

j accidental airborne re! ease of radioactivity is in progress or imminent."

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i The normal dose assessment method was via the Data Acquisition and Display

System (DADS), which automatically calculated offsite doses via inputs from plant

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monitors and meteorological data from the plant's meteorological tower. The

j DADS system utilized the Station Vent Monitors, main steam radiation monitors, or

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containment monitors; the alternate calculation method would be utilized for other

release paths. The system could also utilize field monitoring team data. After data

l entry, the system could provide a PAR. A hand calculation and nomogram method

3 were provided in case of failure of the DADS system or alternate release path.

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The inspector reviewed lesson plan EPT-CDA-101.00, " Control Room Dose

Assessment", Revision 1, dated April,1988. The lesson plan referenced section

6.0 of the EPIPS, and involved problems using the DADS system and backup

calculation methodology. Discussion with licensee personnel indicated that this

lesson plan was in the process of revision and updating.

c. Conclusions

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The Emergency Plan and EPIPS contained provisions for on-shift dose assessment.

Appropriate equipment and personnel training were provided. Personnel were

knowledgeable of their responsibilities for performing dose assessment. All of the

acceptance criteria for the Tl were met and this Tl is closed. Documentation as to

these findings is attached as Attachment A.

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P8.2 Review of USAR Commitments

a. Insoection Scooe

A discovery of a licensee operating their facility in a manner contrary to the

Updated Safety Analysis Report (USAR) description highlighted the need for a

special focused review that compares plant practices, procedures, and parameters

to the USAR descriptions. While performing the inspections discussed in this

report, the inspector reviewed the applicable portions of the USAR that related to

Emergency Preparedness.

b. Observations and Findinas

Section 13.3 of the Updated Final Safety Analysis Report addressed the Davis-

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Besse Emergency Plan. Statements in the UFSAR were consistent with plant

activities and procedures. A brief overview of the plan was provided,

c. Conclusions

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The relevant UFSAR section was consistent with plant equipment and practices.

X1 Exit Meeting Summary

The inspector presented the inspection results to members of licensee management

at the conclusion of the inspection on November 8,1996. As a result of a

telephone conference with licensee staff on December 18,1996, it was determined

that the licensee failed to identify any documents allowing deviation from the

commitment for a backup EOF. The licensee acknowledged the findings presented.

The inspector asked the licensee whether any materials examined during the

inspection should be considered proprietary. No proprietary information was

identified.

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1 PARTIAL LIST OF PERSONS CONTACTED

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Licensee

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B. Donnellon, Director - Engineering and Services

R. Coad, Superintendent - Radiation Protection

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J. Reddington, Superintendent - Mechanical Maintenance

D. Imlay, Superintendent - Operations

i J. Rogers, Manager - Plant Engineering

J. Feels, Manager - Regulatory Affairs

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J. Syrowski, Supervisor - Emergency Preparedness

i S. Cope, Senior Specialist - Emergency Preparedness

i J. Teal, Senior Specialist - Emergency Preparedness

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P. Timmerman, Senior Specialist - Emergency Preparedness

! D. Gordon, Specialist - Emergency Preparedness

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D. Schreiner, Supervisor - ISE

i W. Klippstein, Supervisor - Quality Surveillance

i D. Lickwood, Supervisor - Compliance

, D. Miller, Senior Engineer - Compliance

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S. Stasek, Senior Resident inspector, Davis-Besse

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K. Sellers, Resident Inspector, Davis-Besse

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INSPECTION PROCEDURES USED

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IP 82701 Operational Status of the Emergency Preparedness Program l

Tl 2515/134 Temporary Instruction, On-shift Dose Assessment i

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ITEMS OPENED

Ooened

50-346/96011-01 DEV Failure to provide for a backup Emergency Operations Facility

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and modify the Emergency Plan to designate the backup

Emergency Operations Facility location. (Section P2)

50-346/96011-02 IFl Training information related to NRC and Department of

Emergency incident response was not adequately informative

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or current.

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50-346/96011-03 IFl Emergency response time differences between the Emergency

Plan and NUREG 0654, Table B-1 onshift staff augmentation

times.

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LIST OF ACRONYMS USED  ;

CFR Code of Federal Regulations

CANS Computerized Automated Notification System

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DADS Data Acquisition and Display System

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DRS Division of Reactor Safety i

DPR Demonstration Power Reactor

DRP Division of Reactor Projects l

EAL Emergency Action Level I

EP Emergency Preparedness

ECC Emergency Control Center

EOF Emergency Operations Facility

EPIP Emergency Plan Implementing Procedure

ERO Emergency Response Organization

IFl Inspection Followup Item

INPO Institute for Nuclear Power Operations

JPIC Joint Public Information Center

NPF Nuclear Power Facility

NRC Nuclear Regulatory Commission

NUREG Nuclear Regulatory Commission document

OSC Operational Support Center

PAR Protective Action Recommendation

RO Reactor Operator

RMT Radiation Monitoring Team (

RTL Radiological Testing Laboratory

PDR Public Document Room

SECY NRC Policy Paper

SEOC Site Emergency Operations Center

SRO Senior Reactor Operator

STA Shift Technical Advisor

Tl Temporary Instruction

TSC Technical Support Center

UFSAR Updated Final Safety Analysis Report

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FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY

Davis-Besse Nuclear Power Station / Unit 1/50-346 Centerior Service Comoany 10/03/96 i

SITE / UNIT / DOCKET #s LICENSEE DATE

4.01 DOSE ASSESSMENT COMMITMENT IN EMERGENCY PLAN

Acc ptance Criteria Person (s) Con- Position Title (s) Plan Section Revision Meets acceptan-

(Refer to page 1 of this Appendix for tacted containing No. ce criteria?

further detail on the acceptance criteria) commitment and Date

Section 4.01 Item 1 B. Cope Onsite EP Sections 5.1.3; Rev.19, Yes

Emergency Plan contains commitment for Supervisor 6.2.2; 6.2.3; 6.2.4; 8/96

on-shift dose assessment capability. 7.1.2.5

Section 4.01 Item 2 B. Cope Onsite EP Sections 6.1.2.f; Rev.19, Yes

Emergency Plan contains commitment for Supervisor 7.1.2.5 8/96 ,

backup dose assessment capability. p

04.02 ON-SHIFT DOSE ASSESSMENT EMERGENCY PLAN IMPLEMENTING PROCEDURE

Person (s) con- Position Title (s) Procedure / Indication Revision Meets acceptan-

tacted No. ce criteria?

and Date

Section 4.02 Item 1 B. Cope Onsite EP HS-EP-01700, Step Rev.00, Yes

Procedure initiates dose assessment Supervisor 6.8. HS-EP-01800, 8/96 for all

Step 6.8, HS-EP- 3 EPIPs

01900, Step 6.10

Section 4.02 Item 2 8. Cope Onsite EP HS-EP-02240, Rev.4; Yes

Indications initiate dose assessment Supervisor Attach.1 through 6 12/93

Section 4.02 Item 3 B. Cope Onsite EP HS-EP-02240, Rev.4, Yes l

Procedure for performing dose assessment Supervisor Attach.1 through 6 12/93

available.

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04.03 ON-SHIFT DOSE ASSESSMENT TRAINING

Person (s) con- Position Title (s) Personnel Trained Meets acceptan-

tacted (Title /#1 ce criteria?

Section 4.03 Item 1 B. Cope Onsite EP Shift Manager /STA; n/a Yes

On-shift Personnel trained for dose Supervisor SROs; ROs; total 78 l

assessment

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