ML20133E651
| 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: |
| 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:
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
J. Foster, Sr. Emergency Preparedness Analyst
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Approved by:
James R. Creed, Chief, Plant Support Branch 1
Division of Reactor Safety
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9701130096 970106
ADOCK 05000346
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EXECUTIVE SUMMARY
Davis Besse Nuclear Power Station
NRC Inspection Report 50-346/96011
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This inspection included a review of the Emergency Preparedness (EP) program, an aspect
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of Plant Support. This was an announced inspection conducted by two regional
emergency preparedness analysts.
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
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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
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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
licenseo representatives and reviewed the following documents:
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Davis-Besse Emergency Plan
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Letter dated May 27,1981 (Toledo Edison to NRC)
Correspondence dated December 6,1982 (Toledo Edison facsimile to NRC)
SECY-83-191. " Backup Emergency Operations Facility for the Davis-Besse
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Nuclear Power Station", dated May 19,1983
Letter dated June 28,1983 (NRC to Toledo Edison)
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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
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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
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sampler was configured so that the exhaust was discharging into the intake area.
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
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reactor in an existing office structure of glass and steel. Discussion
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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
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Operations Facility for the Davis-Besse Nuclear Power Station", dated
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May 18,1983. The above two pieces of correspondence were referred to
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and attached to the SECY paper.
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On June 28,1983, Toledo Edison was informed by letter of the
Commission's approval of the Toledo Edison corporate headquarters facility
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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.
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The Davis-Besse Emergency Plan did not identify the Toledo Edison
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headquarters facility as the backup EOF location. The Emergency Plan
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contained no reference to a backup EOF.
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On December 18,1996, subsequent to the November 8,1996, exit meeting, the
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inspectors were informed that the licensees' licensing staff had failed to identify
any documents allowing deviation from the commitment for a backup EOF made by
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Toledo Edison management in the December 6,1982, correspondence. The failure
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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
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for a backup Emergency Operations Facility and to modify the Emergency Man to
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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
Guidelines," was reviewed. This procedure defines guidelines for determining
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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
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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
feedback forms and critiques, class attendance records and the current Emergency
Plan Telephone Directory of qualified emergency response organization (ERO)
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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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b.
Findinas and Observations
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Records indicated that drills, exercises and other training were formally critiqued
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and that significant critique items were appropriately selected for corrective action.
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Records from the training tracking program were compared with the " Davis-Besse
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Emergency Telephone Directory," which verified EHO personnel were qualified. No
ERO personnel reviewed were out of qualification,
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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
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5-1 of the Emergency Plan, which provided for some positions to be filled
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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,
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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
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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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
individuals were knowledgeable about their ERO responsibilities. NRC and
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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
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of Regulatory Affairs.
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The EP group had two less planners and one less clerical position than it did during
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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
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General Programs Instructor. The Administrative Department also supported the EP
program in the form of the Senior Administrative Clerk, although EP document
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control was now assumed by EP.
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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
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support to the EP program had been maintained, although the plant reorganization
had decreased plant resources. No problems were identified related to EP
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organization staffing.
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P7
Quality Assurance in EP Activities
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P7.1
Audits (82701)
a.
Insnection Scooe (82701)
The inspector reviewed Toledo Edison Quality Assessment Audit AR-96-EMPRP-01,
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" 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
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Emergency Response Organization during the October 2,1996 Integrated Drill.
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b.
Findinas and Observations
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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
number of strengths within the program. The audit identified two areas which
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should be evaluated for improvement. The auditors had visited and interviewed
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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
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strength.
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Surveillance SR-96-EMPRP-01 was performed by a single individual evaluating drill
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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.
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c.
Conclusions
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The annual audit of the EP program was well detailed and met the requirements of
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P8
Miscellaneous EP issues
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P8.1 Temocrarv Instruction (TI) 2515/134 On-shift Dose Assessment
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a.
insoection Scooe
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The inspector discussed dose assessment capability and provisions with licensee
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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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b.
Findinas and Observations
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The Emergency Plan contained provisions for on-shift dose assessment in Section
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
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Director) to implement the applicable Emergency Plan Procedure.
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The inspector reviewed Emergency Plan Implementing Procedure HS-EP-02240,
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"Offsite Dose Assessment," Revision 4, dated December 29,1993. Section 4.1.1
of the procedure indicated that the Emergency Director shall " direct calculation of
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the release and dose rates using available qualified dose assessment personnel
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including Licensed Reactor Operators and Senior Operators." Section 5.0,
" Initiating Conditions", stated that the procedure shall be implemented "at the
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request of the Emergency Director or Dose Assessment Coordinator when an
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accidental airborne re! ease of radioactivity is in progress or imminent."
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The normal dose assessment method was via the Data Acquisition and Display
System (DADS), which automatically calculated offsite doses via inputs from plant
monitors and meteorological data from the plant's meteorological tower. The
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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
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entry, the system could provide a PAR. A hand calculation and nomogram method
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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
b.
Observations and Findinas
Section 13.3 of the Updated Final Safety Analysis Report addressed the Davis-
Besse Emergency Plan. Statements in the UFSAR were consistent with plant
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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.
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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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PARTIAL LIST OF PERSONS CONTACTED
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
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J. Rogers, Manager - Plant Engineering
J. Feels, Manager - Regulatory Affairs
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J. Syrowski, Supervisor - Emergency Preparedness
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S. Cope, Senior Specialist - Emergency Preparedness
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J. Teal, Senior Specialist - Emergency Preparedness
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P. Timmerman, Senior Specialist - Emergency Preparedness
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D. Gordon, Specialist - Emergency Preparedness
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D. Schreiner, Supervisor - ISE
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W. Klippstein, Supervisor - Quality Surveillance
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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
Operational Status of the Emergency Preparedness Program
Tl 2515/134
Temporary Instruction, On-shift Dose Assessment
ITEMS OPENED
Ooened
50-346/96011-01
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Failure to provide for a backup Emergency Operations Facility
and modify the Emergency Plan to designate the backup
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Emergency Operations Facility location. (Section P2)
50-346/96011-02
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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
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Emergency response time differences between the Emergency
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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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Division of Reactor Safety
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Demonstration Power Reactor
Division of Reactor Projects
Emergency Action Level
Emergency Control Center
Emergency Plan Implementing Procedure
Emergency Response Organization
IFl
Inspection Followup Item
Institute for Nuclear Power Operations
JPIC
Joint Public Information Center
NPF
Nuclear Power Facility
NRC
Nuclear Regulatory Commission
Nuclear Regulatory Commission document
Operational Support Center
Protective Action Recommendation
Reactor Operator
RMT
Radiation Monitoring Team
Radiological Testing Laboratory
Public Document Room
SECY
NRC Policy Paper
Site Emergency Operations Center
Senior Reactor Operator
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Temporary Instruction
Updated Final Safety Analysis Report
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FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY
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Davis-Besse Nuclear Power Station / Unit 1/50-346
Centerior Service Comoany
10/03/96
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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
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backup dose assessment capability.
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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
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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-
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tacted
(Title /#1
ce criteria?
Section 4.03 Item 1
B. Cope
Onsite EP
Shift Manager /STA;
n/a
Yes
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On-shift Personnel trained for dose
Supervisor
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assessment
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