IR 05000341/1985034
| ML20135H705 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 09/17/1985 |
| From: | Marks M, Patterson J, Phillips M, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20135H672 | List: |
| References | |
| 50-341-85-34, NUDOCS 8509240147 | |
| Download: ML20135H705 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
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Report No. 50-341/85034(DRSS)
Docket No. 50-341 License No. NPF-33
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Licensee: The Detroit Edison Company 6400 North Dixie Highway Newport, MI 48166 Facility Name:
Enrico Fermi Atomic Power Plant, Unit 2 Inspection At:
Fermi 2 Site, Monroe, MI Inspection Conducted:
August 5-9, 1985 79edn
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f. R. Williamsen I/
Inspectors:
N Team Leader Date '
7l/7lff l
M. %L. Har s
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Date 3.f-9. P. Patterson
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Date Approved By:
Chief
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Emergency Preparedness Section Date Inspection Summary Inspection on August 5-9, 1985 (Report No. 50-341/85034(DRSS))
Areas Inspected:
Routine unannounced inspection of the following areas of the emergency preparedness program:
detection and classification of emergencies; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift. staffing and augmentation; knowledge and performance of duties (training); dose calculation and assessment; public information program; licensee audits; and maintaining emergency preparedness.
The inspection involved 150 inspector-hours onsite by_ three NRC inspectors and three consultants.
Results: Of the ten areas inspected, one apparent violation was-identified in one area: failure to submit procedures (changes to the emergency preparedness-program).
No violations or deviations were identified in the remaining nine areas.
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DETAILS
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Persons Contacted
- W. Jens, Vice President, Nuclear Operations
- F. Agosti~, Manager, Nuclear Operations
- J. Leman, Superintendent,. Maintenance and Materials
- T. Randazzo, Director, Regulatory Affairs'
- R. McLeod, Assistant Director, Nuclear Training
- J. Petoskey, Associate Nuclear Training Specialist
- E. Madsen, Principal Engineer, Radiological Emergency Response Program
- J. Conen, Engineer
- M. Cooley, Emergency Response Planner
- E. Griffing, Assistant Manager, Regulation and Compliance
- J. Piana, General Director, Nuclear Operations Services P. Perchard, Maintenance General Foreman L. Esau, Nuclear I & C Engineer B. Wood, Engineering Technician D. Jondle, Nuclear Fuels Engineer M. Lico, Nuclear Fuels Engineer R. Lightfoot, Nuclear Shift Supervisor D. Aniol, Nuclear Shift Supervisor J. Flint, Nuclear Assistant Shift Supervisor R. Eberhardt, Rad-Chem Engineer J. Plona, Technical Engineer R. Loverne, Assistant Maintenance Engineer D. McCracken, Shift Technical Advisor L. Clark, Nuclear Shift Supervisor W. Ostrom, Nuclear Assistant Shift Supervisor L. Delucia, Nuclear Assistant Shift Supervisor H. Higgens, Health Physics Supervisor E. Wilds, Engineer J. Guzman, RERP Instructor
- 8. Harris, RERP Instructor G. Ohlemacher, Shift Technical Advisor J. Dewes, Shift Technical Advisor J. Hughes, Lead Plant Support Engineer J. Rogers,-Emergency Communications Planner K. Heil, Supervisor Records Management (Nuclear Administration Information System--NAIS)
T. Schehr, Nuclear Shift Supervisor C. Effan, Nuclear ~ Assistant Shift Supervisor W.-Collonello, Shift Technical Advisor.
T. Dong, Shift Technical Advisor V. Manta, Senior QA Specialist
'J. Nyquist,' Nuclear Shift Supervisor
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S. Kormos, Training Clerk J. Green, Engineering Staff A. Peluso, Engineering Staff
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2.
Detection and Classification (82201)'
The inspector reviewed the Plan and Implementing Procedures and interviewed a total of fifteen people including four each of Nuclear Shift Supervisors, Nuclear Assistant Shift Supervisors, and Shift Technical Assistants; to determine that they'used and understood a standard emergency classification and action level scheme.
The licensee had an emergency classification and action level scheme which was consistent with the guidance'in Appendix 1 of NUREG-0654, Revision 1.
Further, the licensee was capable of analyzing and assessing emergency conditions on a twenty-four hour basis.
However, the classification of emergencies procedure, EP-101, is organized in such a way that Nuclear Shift Supervisors had difficulty locating the appropriate EAls because they had to search through lengthy lists of similar events relating to different classification levels.
This is especially time consuming when considering upgrades (or downgrades) and induced substantial delays in making decisions during the walkthroughs.
The emergency classification procedure, EP-101, was reviewed and compared with NUREG 0654, Appendix 1 guidance example initiating conditions for each emergency classification.
The following problems were identified:
a.
Tab 4, Page 5, Item 1.a of EP-101 implied that two HPCI subsystems must be inoperable to reach the Unusual Event classification, whereas technical specification 3.5.1 implied that HPCI does not have two subsystems and the limiting conditions of operation are reached when the HPCI system is inoperable.
This' indication should be clarified as to what is meant by "inoperability of the HPCI system."
b.
Procedure EP-101 provides conditions and indications for the emergency classification of fires in such a way that.a potentially serious or significant fire might NOT be classified as an Unusual Event or Alert, contrary to the guidance in NUREG 0654 Appendix 1.
First, NUREG 0654 Appendix 1, Page 9, Item 13 guidance is that any fire potentially affecting safety systems should be classified as an Alert.
Fermi 2 EP-101 indications for this event qualifies these indications by stating that the fire must burn out of control for longer than 10 minutes in addition to being in a location to potentially affect safety systems. This implies that a fire in a vital switchgear area that is immediately extinguished by the automatic fire suppression system does NOT result in the declaration of an Alert even though the potential to degrade safety systems is high and the extent of damage to safety systems may be unknown.
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c.
Other NUREG 0654 Appendix.1 guidance examples that could not be appropriately classified using EP-101 were the following:
.(1) Complete loss of any function needed for plant hot shutdown should be a Site Area Emergency.
(2) Turbine failure causing casing penetration should be an alert.
(3) Loss of torus water level below the drywell or SRV downcomer outlet level should be an Unusual Event.
Even though there is a technical specification (314.5.3) limiting condition of operation on torus water level, all but one of the operators interviewed failed to classify this condition as an Unusual Event.
(4) Loss of plant process computer, safety parameter display system or all meteorological instrumentation should be an Unusual Event.
(5) A shutdown that exceeds the technical specification normal controlled shutdown cooldown rates should be an Unusual Event.
d.
The indicators for conditions of failure of two fission product barriers and then either POTENTIAL or ACTUAL loss of the third barrier were sometimes confusing in EP-101 as well as confusing to the Shift Supervisors.
Most operators interviewed had an intuitive feeling for these conditions and were able to classify events more readily when they did NOT refer to the EAL table indications for guidance. Three examples follow:
(1) Tab 9, pages 15 and 16:
The indications listed on page 16 were supposed to be a potential loss of primary containment.
However Section A described an actual loss of containment.
(2) Tab 9, Page 18:
The indications (8, C, and D) that were supposed to describe a potential loss actually described an existing loss of primary coolant boundary.
(3) Conversely, Tab 9, Page 17; and (4) Page 20: The indicators that were supposed to describe an actual loss of primary containment (B, C, and D) described a potential loss.
The inspectors also checked for consistency between the EALs and the RERP plan. Table D-1 in the RERP Plan contained classification conditions and ir.dications (EALs) that were one revision out of date when compared to EP-101.
The next plan and EP-101 revision must correct the above items. This will be tracked as Open Item No. 341/85034-01.
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The inspectors verified that a review of the EALs was held.with state and local authorities in April 1985.
The inspectors compared the EAL matrix values against the control room instrumentation.
No inconsistencies were discovered.
No violations or deviations were identified in this area.
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3.
Protective Action Decisionmaking (82202)
Through walkthroughs as well as a review of the PERP Plan and Procedures, the insepctors determined that the authority and responsibility to classify incidents and to make protective action recommendations was unambiguous.
Personnel followed the procedures and had no trouble in correctly making protective action recommendations. There was an adequate knowledge of the relationship between plant conditions in relation to possible offsite consequences and the effectiveness of protective measures.
The protective action recommendation procedure, EP-545, did not contain NUREG-0654 Appendix 1, guidance regarding a precautionary 2-mile radius
evacuation if-the plant had experienced a loss of physical security control.
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This should be incorporated in the next revision to the plan and appropriate procedures.
No violations or deviations were identified in this area.
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4.
Notifications and Communications (82203)
A review of procedures and interviews with the RERP staff and those-
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personnel that have notifications or communications responsibilities, indicated that the licensee had the capability to notify and communicate among the appropriate licensee personnel, offsite agencies and authorities, and the general public in the event of a radiological emergency.
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The " Michigan Notification Form," is a complete _ questionnaire for the entry of data regarding a radiological emergency which contained all of the information specified in NUREG-0654, Revision 1.
The public within the EPZ could be notified via thirty-six sirens.-The sirens were installed and were maintained by Detroit Edison.
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reviewed the records of the bimonthly tests and concluded that their i
operability was adequate.
Communications within the generating plant could be by telephone, PA system, or the intercom (HiCom).
Communications offsite were diverse and redundant utilizing cable, microwave, and fiber optics.
Connections were utilized to both the local phone company and Michigan Bell Telephone.
A computerized branch exchange handled phone traffic and allowed direct inward dialing to Fermi-2 telephones.
Facsimile service was provided between the Control Room, TSC, EOF, JPIC, and the Detroit Edison general offices. The E0F Security Advisor had direct radio contact with the Michigan State Police and the Monroe County Sheriff. Additionally, the CAS and SAS had patching capability so that telephone-to radio communication could be established.
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The inspector reviewed the monthly phone drills (including telecommunication)
and concluded they were adequate.
Offsite radio communication to the Radiological Emergency Teams (RETs) was from the EOF. Dispatch Room b" UHF radio in customer-service trucks through the Wayne-Monroe Division.
These trucks and the radios were in daily use during the week and so were always in a state of readiness.
There was backup power for the communications systems.
The plant and EOF both had diesel generators.
In addition, the E0F had an eight-hour backup battery supply.
No violations or deviations were identified in this area.
5.
Changes to the Emergency Preparedness Program (82204)
Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E, Sections IV and V, this area was reviewed to determine whether changes were properly made to the program and documentation and distribution were implemented.
The Vice President - Nuclear Operations had the overall authority and responsibility for the Radiological Emergency Response Program (RERP).
Development, updating, and revisions to the RERP Plan and its implementing and administrative procedures.were the direct responsibility of the RERP Supervisor.
Prior to approval all changes were reviewed, including an internal review by the RERP group, one by the RERP Committee, and a
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technical review. These reviews were followed by a final review by the Onsite Review Organization.
The inspector concluded that although the review process appeared to be thorough, it was sometimes quite lengthy.
In some instances the final issue of a procedure had been delayed for two or more months from the time the procedure entered the review process.
Actual distribution of the changes was administered through the Nuclear Administration Information System (NAIS).
To identify who were recipients of the RERP plan and procedures: one had to know the so-called " recipient number," which was hand-written within a printed stamp put on the cover sheet of the document.
The computarized system revolved around this recipient number.
After a review ot lists of recipient numbers, the inspector, with aid from the RERP Supervisor and NAIS staff, concluded that NRC copies were not on the file system for updating.
This failure included revisions which should have been sent to NRC-Headquarters as well as NRC Region III. Although a controlled copy number was assigned to Region III~ copies, these copies had no recipient number and hence were untraceable with the present NAIS format.
The result of this omission was that the following portions of the Plan and the Procedures were out of-dat! in the Region III. copies until August 8, 1985 (the NAIS distribut.9n date is shown in parentheses):
a.
The RERP Plan:
Appendix 1-(Revision 3, October 7, 1984)
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b.
RERP Procedures, Book 1:
EP-101 (Revision 1, 11/27/84); EP-110 (Revision 1, 12/13/84); EP-111 (Revision 1, 10/13/84); EP-201-1 (Revision 1, 11/28/84); EP-201-2 (Revision 2, 11/28/84); EP-201-3 (Revision 1, 12/13/84); EP-202-1
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(Revision 0 cancelled, 02/02/84); EP-202-2 (Prior Revision cancelled, 01/26/84); EP-202-3 (Revision 1, 09/19/84); EP-202-4 (Revision 1, 09/19/84); EP-204-1 (Revision 1, 12/19/84); EP-204-2~(Revision 2, 04/04/85); EP-210-1 (Revision 1, 11/30/84); EP-210-2 (Revision 1, 11/30/84); EP-290 (Revision 1, 11/21/84); EP-291 (Revision 1, 02/14/85); EP-292 (Revision 1, 12/07/84); EP-293 (Revision 1, 12/07/84); EP-301-1 (Revision 1, 12/07/84); EP-301-2 (Revision 2, 12/19/84); EP-303-2 (Revision 1, 12/19/84).
c.
RERP Procedures, Book 2:
EP-401 (cancelled Revision 0, 07/03/84); EP-402 (Revision 1, 10/19/84); EP-540 (Revision 2, 07/03/85; and the following administrative procedures:
EPA-1 (Revision 1, 04/25/84); EPA-3 (Revision 1, 04/23/84); EPA-4 (Revision 1, 12/07/84); EPA-6 (Revision 1, 11/23/84); EPA-ll (Cancelled Revision 0, 10/30/84).
The above omission is contrary to the licensee's RERP Administrative Procedures No. EPA-1 and EPA-3, as well as being contrary to NRC requirements specified in 10 CFR 50, Appendix E, which states, in part, that licensees shall submit one copy of any changes to the i
emergency plan or implementing procedures to the appropriate NRC regional office and two copies to the NRC document Control Desk within thirty days of such changes. This violation of NRC requirements will be tracked as item No. 341/85034-02.
Before the inspection team left the site, the licensee initiated changes so that the NRC copies of plans and procedures were within the Automatic Records Management System (ARMS).
This was directly observed by'the cognizant NRC inspector.
Sets of current copies of both the RERP Plan and Procedures were given.to the inspector to take back to Region III.
Updated copies were also'sent to NRC-Headquarters on August 12, 1985.
One apparent: violation of NRC. requirements was identified in this area.
6.
Shift Staffing and Augmentation (82205)
The inspector reviewed the minimum shift staffing and the functional capabilities for all shifts and concluded that the emergency response organization as outlined in Table B-l'of the RERP Plan met the guidelines of Table B-1 of NUREG-0654, Revision 1.
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confirmed that an administrative system was in place to assure that l
offsite emergency response personnel were available as needed to meet the 30 and 60 minute response times.
Table B-2 of the RERP Plan listed the functional position, alternate, reporting function, emergency response location, and the emergency responsibilities for each position.
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From current interviews with RERP staff which included discussion of plans for sdditional drills prior to the scheduled 1985 exercise in October, the inspectors concluded that the licensee had taken steps to improve the efficiency of the shift augmentation drills.
An updated call-out list of emergency personnel was distributed weekly to
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Procedure EPA-7 outlined the procedure for updating the call-out list.
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The inspector concluded that licensee personnel met the functional
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requirements for staffing by assigning emergency tasks to personnel whose normal duties were similar or related to their emergency position.
The Nuclear Shift Supervisor (NSS) is the initial Emergency Director when an emergency occurs.
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The notification system and call-out procedures to implement shift augmentation were described in EP-290 and EP-291. One important RERP assignment was that of On-Call Plant Supervisor (0 CPS).
In the event of an emergency, the OCPS was responsible for notifying the Detroit Division Dispatch Center and for. initiating shift augmentation.
The OCPS could be reached by pager at all times. Although twelve individuals. shared the
OCPS duties, only seven were listed in the training matrix for this
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position.
In addition, the RERP Plan made no reference to this position.
No violations or deviations were identified in this area; however, the following items should be considered for improvement.
All twelve individuals who share OCPS duties should be listed on the
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training matrix for this position and apprcpriately trained prior to assuming OCPS duties.
The RERP Plan should be revised to describe the duties and
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responsibilities of the On-Call Plant Supervisor.
7.
Knowledge and Performance of Duties (82206)
The licensee had a formal program for RERP training and qualification.
This training included drills and exercises as part of the integrated program.
Sections 0 and N of the RERP plan described this program which employed a matrix to identify qualification requirements for each position
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in the emergency organization. A computerized tracking system provided qualification /requalification status for each individual assigned a position in the emergency organization.
Emergency Plan Administrative Procedures, EPA-4 and EPA-8, established the details of the qualification program.and assigned responsibilities for implementing the program. The Supervisor, RERP, was responsible for the RERP training program.
Of the eighteen training units in the RERP program, two were new additions and were not available (IBM computer dose assessment and ERIS).
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The inspectors conducted a review to determine if the individuals assigned positions in the emergency organization were fulfilling the established training requirements.
The results of this audit indicated that only 740 of the 789 training units required were current.
Furthermore, a review of the requirements for the individuals assigned decisionmaking positions revealed that 37 of 212 requirements were not current.
Positions considered to establish the 212 requirements included E0F Coordinator, EOF RAD Protection Coordinator, TSC Nuclear Safety Advisor, TSC Rad Protection Advisor, NSS, NASS, and OSC Coordinator. The licensee's internal audit coramittee had already made a similar determination and there was an internal commitment to rectify this situation by October 2, 1985.
This failure to requalify personnel on an annual basis was a violation of NRC requirements and would normally result in the issuance of a Notice of Violation.
However, the licensee's actions met the provisions of 10 CFR 2, Appendix C, Section IV.A.
Since the licensee had identified the failure, the violation would have been at Severity Level IV, could not have been previously identified, and steps were being taken to correct it, no Notice of Violation will be issued and the completion of corrective actions will be tracked as Open Item No. 341/85034-03.
The training matrix used was different than that which had been approved and was in the RERP and the associated RERP administrative procedures.
The matrix used had not been formally approved; however, it did include all of the requirements of the approved and published matrices.
The RERP training program functioned as designed to incorporate new training requirements.
Each of two past changes to the training requirements, one in the examination requirements for dose projection and one from the last annual drill involving changes to event classification procedures, had been incorporated and retraining conducted for those emergency response positions affected.
Course material for five units, including examinations, were reviewed.
The material was complete, had been reviewed on an annual basis, and had been updated to incorporate new requirements and changes to RERP procedures.
No violations or deviations were identified in this area.
8.
Dose Calculation and Assessment (82207)
The inspector reviewed the facilities, equipment and procedures to be used for dose assessment, and conducted walkthroughs with key personnel responsible for dose assessment.
The primary dose assessment method was a manual technique contained in procedure EP-540 Revision 2, " Manual Calculation of Offsite Radiological Dose Rates and Doses - Airborne Releases,"
and was used in conjunction with EP-544, " Meteorological Data Assessment,'.'
and EP-548, " Manual Calculation of Dose Adjustment Factor for Lake Breeze Conditions." Previously the primary dose assessment procedure was EP-542,
" Apple Computer Offsite Radiological Dose Assessment Calculational Procedure - Airborne Releases.",This procedure was recently tsken out-of service due to modifications and changes to the basic calculational techniques used. These changes had been incorporated into the manual procedure but not the Apple computer code since a revised code was being
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developed to run on an IBM computer.
The inspector was informed that the new code should be finished and implemented prior to the next emergency preparedness exercise.
Hardware and software for the new system will be available in the Control Room, TSC, and EOF.
Eventually the primary dose assessment system will be contained on the Emergency Response Information System (ERIS).
ERIS will operate the Safety Parameter Display System (SPDS), Me+eorology Assessment, and Dose Assessment.
The dose assessment code currently being developed for the IBM computer will be implemented on the ERIS system. The inspector was informed that the ERIS system should be fully operational in December 1985.
The manual dose assessment procedure, the IBM computer code, and the code to be implemented on ERIS were based on a straight line Gaussian plume model utilizing the semi-infinite cloud equation for a ground level release and incorporating correction factors for finite cloud, building wake effect, and lake breeze effect.
This method provided centerline doses by sector but did not spatially integrate doses during wind shifts The meteorological assessment module on ERIS contained a modified segmented plume model which was currently being used to aid in plume tracking, but there were no plans to add dose assessment capabilities to this model.
The dose assessment procedures were consistent with the dose assessment model and were capable of calculating doses for both monitored and unmonitored release pathways.
Procedure EP-545 " Protective Action Guidelines Recommendations" specified that field team results were to be considered in protective action recommendations, if available; however, dose assessment procedures did not provide a means of'using field monitoring team results to modify dose projection calculations.
EP-545 also provided criteria for making protective action recommendations based on plant conditions.
The importance of making recommendations based on plant conditions was stressed in training, and the walkthrough results verified the ability of the shift supervisors, acting as the emergency director, to make recommendations based on plant conditions.
The methodology for plume analysis was developed in conjunction with other utilities in the State of Michigan and accepted by the State's Bureau of Radiological Health. The models used by the State and licensee were originally consistent; however, the licensee had recently modified their methodology and it did not appear that the State had incorporated-all of the modifications (e.g., lake breeze effect) into their model.
In addition the State was in the process of computerizing their manual dose assessment procedure.
No recent tests had been conducted to verify consistency or identify differences in the models.
Discussions.with licensee personnel concerning meteorological instrumentation used for dose assessment revealed that the booms supporting the 10-meter and 60-meter instrumentation on the primary meterological tower were located on the northeast side of the tower.
The primary wind direction for the site is from the southwest and Regulatory Guide 1.23 specifies that instrumentation should be located on booms oriented into the prevailing wind direction.
The inspector was told that orders to correct this anomaly were already being processed.
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A selection of personnel responsible for perfou:ing' dose assessment
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calculations were individually interviewed and. presented with sample accident data and asked to perform dose calculatians.
All personnel had been recently trained on the manual dose assessment method and all successfully completed the calculations.
However the following observa-tions were made during the walkthroughs:
(a) There were no dose assessment worksheet forms available'or handheld calculators available in the CR, TSC, or EOF for dose assessment personnel; (b) The time required to perform the manual calculation ranged from 13-31 minutes; (c) Four of five interviewed made minor calculational errors; and (d) there were two places in the lake breeze effect procedure where instructions seemed to be unclear.
No violations or deviations were identified in this area; however, the following items should be considered for improvement:
Dose calculation capabilities should be added to the segmented plume
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model presently implemented on ERIS to provide spatial integration of dose during wind shift situations and to enhance plume modeling.
The manual dose assessment procedure should be modified and
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additional emphaiis should be placed in training on these steps in order to avoid' confusion in calculations of offsite doses.
9.
Public Information Program (82209)
The brochure titled "9 hat to do in Case of an Emergency at a Nuclear Power Plant" was being reissued by the licensee.
This brochure was to be sent out for printing August 8,1985 with distribution tentatively scheduled for completion by October 2, 1985.
From a distribution standpoint this would meet the required annual dissemination of information to the public regarding how they will be notified and what actions to take in an emergency, as stipulated in NUREG-0654, Revision 1.
The inspector's review of this brochure confirmed that information included i description of the major' evacuation routes within the 10 mile EPZ, a brief description of the four emergency classi_fications, description of the prompt public notification systui (sirens, Emergency Broadcast System, special siren for boaters on Lake Erie), list of reception centers and their street locations, plus instructions for studentsiho might be in school when a protective action were given. Also includad were instructions for those individuals without private transportation. Telephone numbers to contact, i.e., Monroe County and Wayne County Emergency Offices, were also listed; however, the telephone number listed in the brochure for Wayne County was incorrect.
Since printing was scheduled during the week of the inspection but had not yet started,-the licensee ag, reed to correct' this number before printing.
The Emergency Communications Planner informed the inspector that another planned part of the public information program would include a page in the local telephone directories identifying locations within the 10 mile EPZ and a brief synopsis of key emergency notification information and telephone numbers. This additiion was scheduled for insertion in the 1985-86 local telephone directories.
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Other public information distributed throughout the EPZ included 8" x 11" posters and 3" x 5" stickers containing information about the EBS and
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provided emergency information to the transient population.
These posters and stickers were placed in areas within the EPZ such as hospitals, State and county parks and hotels.
-No violations or deviations were identified in this area; however, the following item should be considered for. improvement:
The current correct telephone number for the Wayne County Emergency
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Management Division should be included in the 1985 emergency brochure awaiting distribution.
10.
Licensee Audits (82210)
The inspector's verified that an independent annual review of the Emergency Preparedness Program had been conducted within the last 12 months, specifically from February 18-28, 1985.
This annual review met the requirements of 10 CFR 50.54(t).
The review was conducted by the Nuclear Quality Assurance Department (NQAD) which has a separate, independent reporting organization from the RERP group.
The inspector observed that three deficiencies were reported in the review.
One.of these findings included a compilation of emergency response training for personnel assigned to either the EOF, TSC, or OSC.
From this audit finding an internal commitment of October 2, 1985 was established for completion of all their required training modules.
This NQAD finding was identified as No. A-QS-P-85-07-01. This is also discussed in Section 7 of this report.
The February 1985 audit contained an evalua, tion of the adequacy of the interfaces with State and local governments and also an evaluation of licensee drills, exercises, capabilities, and procedures.
The part of the audit relating to State and local governments was made available to these agencies as required by 10 CFR 50.54(t).
Responses concerning these agencies have also been addressed as followup to this audit.
The inspector noted that recommendations for improvements (which were made by the NQAD reviewers) were documented and reported to plant management as well as corporate management.
These items and other audit findings will remain on file for five years according to Detroit Edison Procedure No. NOIP-11049.
Recommendations made by licensee management were duly considered by the concerned departments.
A standard form, "Aud.it Finding Evaluation and Corrective Action Sheet" is used for this purpose. The inspector verified that the licensee had a program for identifying deficiencies and weaknesses resulting from drills and exercises and also a procedure for appropriate corrective actions.
These measures are outlined in Procedure NQAD-1801.
No violations or deviations were identified in this area.
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11. Maintaining Emergency Preparedness The inspector reviewed the letters of agreement contained in the Emergency Plan, Appendix A, and found that the following letters were more than two years old:
MET, Incorporated (Ambulance Service),1981; Frenchman Fire Department, 1981; BWR - General Electric Company,1981; Monroe County Community College, 1981; Peoples Community Hospital, 1981; and Department of Energy, 1981.
However, all of the letters had automatic continuation clauses except'the General Electric letter.
No provisions were found in either the RERP Plan nor the procedures to specifically ensure that letters of agreement would be updated and renewed periodically.
However, since the letters of agreement were part of the Plan, they would have to be reviewed every twelve months.
The Plan specified the frequency with which the following drills were to be conducted:
Communications, Fire, Medical Emergency, Radiological Monitoring, and Health Physics.
The records of these drills were kept by the emergency preparedness staff and were reviewed by the inspectors.
All required drills had been completed and documented with the exception of the Health Physics drill.
Since the Plant had been operational only for a few weeks, the drill schedule for Radiological Monitoring was still being developed.
Inventorying of Health Physics Emergency kits was covered under Procedure No. 69.000.25. The inventory records for 1984 and 1985 were checked and the results indicated that the inventories had been conducted at the frequencies specified in the procedure.
E0F and OSC emergency kits and supplies were examined and all supplies and equipment listed on the
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inventory sheets were present and the equipment was within calibration.
No violations or deviations were identified in this area; however, the following item should be considered for improvement.
Letter of agreement should be formally updated at least every two
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12.
Exit Interview The inspectors held an exit interview on August 9, 1985.with those individuals identified in Section 1.
The inspectors discussed the scope and preliminary findings of the inspection. The licensee agreed to consider the items discussed.
The inspectors discussed the likely nature of the report and determined from the licensee that none of the information discussed was proprietary or safeguards in nature.
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