IR 05000341/1997006

Insp Rept 50-341/97-06 on 970428-0502.No Violations Noted. Major Areas Inspected:Insp Included Review of Radiological Emergency Response Preparedness Program

ML20141K439
Person / Time
Site:	Fermi
Issue date:	05/21/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141K438	List: IR 05000341/1997006 ML20141K433
References
50-341-97-06, 50-341-97-6, NUDOCS 9705290112
Download: ML20141K439 (11)

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. U.S. NUCLEAR REGULATORY COMMISSION REGION lil ,

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Docket No: 50-341 l License No: NPF-43 i

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Report No: 50-341/97006(DRS) l

Licensee: Detroit Edison Facility: Fermi 2 Nuclear Power Plant i

Location: 6400 North Dixie Highway Newport, MI 48166 l

Dates: April 28 - May 2,1997

l laspector: Robert D. Jickling, Emergency Preparedness Analyst l l l Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety i

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PDR ADOCK 05000341 G PDR

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, EXECUTIVE SUMMARY l l

Fermi 2 i NRC Inspection Report 50-341/97006 This inspection included a review of the Radiological Emergency Response Preparedness l

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(RERP) program, an aspect of Plant Support. This was an announced inspection conducted by a regional emergency preparedness analys i

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The RERP program was effective in maintaining the operational readiness of your emergency response facilities, equipment, and personnel. Emergency response facilities, equipment, and supplies were in a very good state of operational readiness. Interviews *

with emergency response organization personnel demonstrated very good knowledge of emergency implementing procedures and responsibilities. Management support was stron l l

• The overall effectiveness of the licensee's emergency preparedness facilities, equipment, training, and organization was very good. (Sections P2.1, P3, P5, and P6)

Licensee personnel appropriately declared two Unusual Events during actual activations of the RERP Plan. Emergency classifications had been made correctly and offsite notifications had been made in a timely manner. (Section P1.1)

The emergency response facilities were well maintained and in very good material l condition. (Section P2.1)

Interviews with key emergency response organization personnel demonstrated very good knowledge of the emergency implementing procedures and their  :

responsibilities. (Section PS) '

Management support for the RERP program was identified as a strength by the j RERP Supervisor. The RERP staff was proactive in maintaining and improving the program and responsive to identified issues. (Section P6)

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• The audits of RERP activities satisfied the requirements of 10 CFR 50.54(t) and l were excellent in scope and detail. (Section P7) l

• The inspector completed Temporary Instruction 2515/134 "Onshift Dose Assessment Capabilities" and verified that the licensee's capabilities met requirer.ients. (Section PS)

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Report Details IV. Plant Suncort P1 Conduct of Emergency Preparedness (EP) Activities i P1.1 Actual Emeroency Plan Activations insoection Scone (82701)

The inspector reviewed records and documentation packages regarding plant responses for two actual emergency events which occurred during 1995 and 199 I Observations and Findinas An Unusual Event was declared at 3:03 p.m. on April 9,1995, due to a valid initiation signal to High Pressure Core Injection (HPCI) and Reactor Core Isolation System (RCIC), start up of both systems, and injection to the reactor vessel by RCIC. The plant was manually scrammed at 3:01 p.m. from 80 percent power in order to monitor the vibration levels of the main turbine during coast down. The Unusual Event was terminated at 5:02 p.m. when reactor recirculation flow was re-establishe An Unusual Event was declared at 2:12 a.m. on March 27,1996, due to a Technical Specification requirement to shutdown the reactor when both divisions of Emergency Equipment Cooling Water (EECW) were inoperable. The Unusual Event was terminated at 1:50 p.m. when the reactor was placed in cold shutdow The two actual events had been reviewed and event packages were compiled by the Radiological Emergency Response Preparedness (RERP) staff to document the reviews. The event packages contained descriptions of the events, assessments of the response, observations, and areas for improvement. The event packages were detailed and self-critica Conclusions The inspector concluded that the licensee had appropriately implemented the emergency plan in declaring two Unusual Events. Emergency classifications had been made correctly and offsite notifications had been made in a timely manne l P2 Status of EP Facilities, Equipment, and Resources '

P2.1 Material Condition of Emeraency Resoonse Facilities Insoection Scone (82701)

The inspector evaluated the material condition of the Control Room, Technical Support Center (TSC), Operational Support Center (OSC), Alternate OSC (AOSC),

Emergency Operations Facility (EOF), and Alternate EOF (AEOF). The offsite team kits were also inspected. The licensee demonstrated the operability of numerous

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pieces of equipment, including radiological survey equipment, communications j equipment, offsite Radiological Emergency Team (RET) vehicle, and corrf uter terminal Observations and Findinos Copies of the Emergency Plan implementing Procedures (EPlPs) were current and available in the Control Room. The TSC and RET kits were in a state of operational i readiness and the facility, status boards, and equipment were in excellent material l condition. The OSC was in good material condition and newly revised status 1 boards were readily available. The AOSC had been relocated to an upper level of i the Office Services Building Machine Shop and was equipped with the new OSC 1 emergency team status boards. The EOF was in very good material condition and l RET kit instruments and equipment were calibrated, functional, and in very good !

order. The dose assessment computers and printers were verified operable and !

communications systems were functional in the TSC, EOF and AEO The AEOF had been relocated to a new location in the same building at the Western Wayne Center. The new location afforded more inan doubled the old area available ;

for EOF staff to perform their emergency response function l The inspector identified three EPIPs that were outdated in the AEOF. The RERP Supervisor immediately replaced the three EPIPs with the correct revisions and initiated a Deviation Event Report (DER) to evaluate and correct the cause of the outdated EPIP revisions. . RERP staff performed demonstrations of the offsite RET .

vehicle, radiological survey equipment, communications lines, and computer i terminals for displaying plant data and dose assessment program Records for the Prompt Notification System sirens for 1995 and 1996 were reviewed by the inspector. Reported annual operability for 1995 was 98.64 percent, with the lowest month's average reported as 93.12 percent. Reported ,

annual operability for 1996 was 98.94 percent, with the lowest month's average '

reported as 97.06 percent. Siren operability exceeded the acceptability limit of greater than or equal to 90 percen .

l Conclusions i Overall, the emergency response facilities were in very good material condition and l

! in a state of operational readiness. Immediate corrective actions were initiated by the RERP Supervisor for several minor procedural revision inconsistencie Numerous instruments and equipment were operated by the RERP staff and found ,

to be functional. The Prompt Notification System sirens had been appropriately l maintained in 1995 and 1996 as indicated by the reported availability average J P3 EP Procedures and Documentation  ;

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The inspector reviewed a selection of RERP Plan sections and EPIPs. EPIPs and l RERP Plan sections reviewed including RERP Plan Section 0, Rsvision 18, "RERP

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, Training," RERP Plan Section B, Revision 18, " Emergency Response Organization,"

EP-102, Revision 12, " Unusual Event," EP-290, Revision 31, " Emergency Notifications," EP-292, Revision 18, " Emergency Call-Out-Backup Method," and EP-545, Revision 10, " Protective Action Recommendations." Observations and Findinas Discussion with the RERP Supervisor indicated that the State of Michigan was l working with the nuclear power plants in the state to develop and implement a new t

Protective Action Recommendations format. The new format would utilize subareas rather than affected sectors and would facilitate local government determination of areas to be evacuated or sheltered, using geopolitical boundarie Conclusions l

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! The EPIPs were clear and easy to use. No problems were identified in the l

procedures or documents reviewed.

l l P5 Staff Training and Qualification in EP l Insoection Scone (82701)

The inspector interviewed four key emergency response organization (ERO)

personnel and reviewed training attendance records and the Emergency Notification l Duty Roster, dated April 30,1997. Also, selected training instructor's guides were reviewed by the inspector, including CP-10-17-OO-01, "TSC Walkthrough" and

" EOF Walkthrough." Observations and Findinas Interviews with key ERO personnel included the EOF's Emergency Officer, Control Room's Nuclear Supervising Operator who could act as a communicator, Nuclear Shift Supervisor who would act as the Emergency Director until the TSC's Emergency Director assumed command and control of the emergency, and the TSC's Emergency Director. Interviews with these ERO personnel indicated very good knowledge of emergency procedures and responsibilitie Knowledge related to the NRC's and Department of Energy's incident response was demonstrated by the Emergency Officer. Federalincident response information had been incorporated into the licensee's training instructor guides for TSC and EOF Walkthroughs. Also, training had been provided to key ERO personnel by the RERP Supervisor and an NRC incident Response Coordinator. TSC and EOF Walkthrough instructor guides included NRC and Federalincident response information.

May 1,1997 training records were reviewed and compared to the Emergency l Notification Duty Roster. Records and documents indicated all ERO personnel j reviewed were currently qualified.

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l l Discussion with the EP Supervisor indicated that new quarterly drills and tabletop l* training had been conducted which received positive feedback from ERO personnel interviewe Conclusions Overall, EP training was considered very good. Training and drill critiaue documentation was available and critique forms were adequately detailed. Training records were complete and interviewed individuals were knowledgeable about their ERO responsibilities. Interviewed key personnel were knowledgeable of NRC and Federalincident response information related to NRC and Federalincident response was included in training and instructor guide P6 EP Organization and Administration (82701)

a. Insoection Scoce (82701)

The inspector and RERP Supervisor discussed the current station organization and changes to the organization and progra b. Observations and Findinos The RERP Supervisor reported to a new Director of Nuclear Licensing, who reported to the Nuclear Assessment Manager, who reported to the Senior Vice President of Nuclear Generation. Discussion with the RERP Supervisor indicated that management support for the EP program was excellent under the current plant organization. Also, management support to the RERP program was indicated by the relocation of the alternate OSC and EOF to improved or larger areas as well as other enhancements to the progra The RERP staff displayed a proactive attitude which was demonstrated by program upgrades which included approval and use of the new emergency action level procedures and charts, initiation of an improvement item Program for evaluation and tracking items from drills, exercises, and training, and participation and observation of other utilities' emergency exercises. Also, the RERP staff had been l responsive to identified issues. Examples of the staff's responsivenens included the DER initiated for the outdated EPIP revisions found in the AEOF and the improved emergency team status boards in the OSC and alternate OS c. Conclusions l l

Management support to the RERP program was identified as a strength by the RERP l Supervisor. The RERP staff was proactive in maintaining and improving the !

program and responsive to identified issue l l

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P7 Quality Assurance in EP Activities i

P7.1 Audits (82701)

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! Insoection Scone (82701)

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The inspector reviewed Nuclear Quality Assurance audits for 1995 and 199 I t

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l The inspector reviewed QA-95-0124, " Quality Assurance Audit of the Emergency l Preparedness Program, Audit 95-0112," dated June 9,1995 and Nuclear Quality l Assurance Audit Report 96-0116, " Emergency Preparedness Program," conducted l May 20 through 31,1996.

l The 1995 audit identified strengths which included improved pre-drill briefings, drill scenario packages, facility and equipment readiness, and interface with offsite l organizations. Weakness identified included discrepancies located in RERP procedures, problems identified during the May 1995 drill, and lack of a testing program for the EOF emergency lighting syste The 1996 audit identified excellent interface with offsite agencies as a strength and l several weaknesses which included the failure of Nuclear Security to implement a

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change to the RERP Plan, informal transfer of ERO duty assignments, and some uncompleted ERO training.

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The licensee's 1995 and 1996 audits of RERP activities were effective and satisfied the requirements of 10 CFR 50.54(t). The audits were excellent in scope and detail. Strengths and weaknesses were well supported and corrective actions from previous year's findings were identifie P8 Miscellaneous EP issues (Closed) Insoection Fol!owun item 50-341/95004-04: Training did not include j information related to NRC or other Federal agencies incident response program '

Training had been provided to key ERO personnel and training instructor guides for TSC and EOF walkthroughs included adequate information related to NRC and Federalincident response, interviews with key ERO personnel identified adequate knowledge of NRC and Federalincident response information had been provide This item is close i (Ocen) Insoection Followun item 50-341/96006-09: During the 1996 emergency i exercise TSC failed to man the Health Physics Network when requested by the i NRC. Corrective actions in progress were discussed with the RERP staff. This item i will remain open pending completion of corrective actions and appropriate

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(Ooen) Insoection Followuo item 50-341/96006-11: During the 1996 emergency exercise select status boards in the EOF were inadequate. Corrective actions in progress were discussed with RERP staff. This item will remain open pending '

completion of corrective actions and appropriate demonstratio P9 Temporary instruction (TI) 2515/134 Onshift Dose Assessment The inspectors discussed onshift dose assessment capability and provisions with ,

licensee personnel, reviewed the RERP Plan and EPIPs, and inspected the equipment :

utilized for dose assessment. The RERP Plan and EPIPS contained provisions for onshift dose assessment. Necessary equipment and personnel training were available and provided. Personnel were knowledgeable of their responsibilities and how to perform dose assessment. The acceptance criteria for the Tl were met and this Tl is closed. Documentation as to these findings is attached as Attachment P10 Review of UFSAR Commitments Insoection Scone

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A discovery of a licensee operating their facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures, and parameters to the UFSAR descriptions. While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the Fermi 2 UFSAR that related to Emergency Preparednes , Observations and Findinas UFSAR Chapter 13, " Emergency Planning," Section 13.3, pertained to Emergency Planning. Section 13.5.5, " Radiological Emergency Response Preparedness implementing Procedures," incorporated the RERP Plan by reference. UFSAR Section 7.8 pertained to the specifics involving the emergency response facilitie Conclusions Overall maintenance of the Emergency Preparedness sections of the UFSAR was ,

good. Licensee actions were consistent with UFSAR commitment X1 Exit Meeting Summary The inspectors presented the inspection results to members of licenses management at the l conclusion of the inspection on May 2,1997. The licensee acknowledged the findings i presente The inspectors 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 A. Antrassian, Compliance Engineer J. Baum, Specialist, Radiological Emergency Response Preparedness R. Eberhardt, Director, Nuclear Training D. Gipson, Sr. Vice President, Nuclear Goneration R. Gummaraju, Auditor, Nuclear Quality Assurance J. Kauffman, Specialist, Radiological Emergency Response Preparedness K. Morris, Supervisor, Radiological Emergency Response Preparedness J. Moyers, Director, Nuclear Quality Assurance N. Peterson, Supervisor, Compliance P. Smith, Director, Nuclear Licensing J. Sweeney, Group Lead, Nuclear Quality Assurance R. Webster, Specialist, Radiological Emergency Response Preparedness INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program Tl 2515/134 Temporary instruction, Onshift Dose Assessment i ITEMS OPENED, CLOSED, AND DISCUSSED l

OPEN None CLOSEQ 50-341/95004-04 IFl Federal incident response information needed in trainin DISCUSSED

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50-341/96006-09 IFl Failure to man the TSC HPN when requested by NR /96006-11 IFl Inadequate status boards identified in the EOF.

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j, LIST OF ACRONYMS USED AEOF Alternate Emergency Operations Facility AOSC Alternate Operational Support Center CFR Code of Federal Regulations DER Deviation Event Report EAL Emergency Action Level EECW Emergency Equipment Cooling Water EP Emergency Preparedness ENS Emergency Notification System l EOF Emergency Operations Facility EPIP Emergency Plan implementing Procedure ERO Emergency Response Organization HPCI High Pressure Core injection HPN Health Physics Network IR Inspection Report

! IFl inspection Followup item

! NRC Nuclear Regulatory Commission OSC Operational Support Center RERP Radiological Emergency Response Preparedness RET Radiological Emergency Team RCIC Reactor Core isolation System TS Technical Specification TSC Technical Support Center UFSAR Updated Final Safety Analysis Report I

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FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY i

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Fermi / Unit 1/50-341 Detroit Edison Company 10/04/96 SITE / UNIT / DOCKET #s LICENSEE DATE 'l

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E4.01! :lDOSE ASSESSMENT COMMITMENT IN EMERGENCY PLAN -

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Acceptance Criteria Person (s) Contacted Position Title (s) Plan Secten Revision N Meets acceptance !

(Refer to page 1 of this Appendix for containing and Date cetterie?

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further detail on the acceptance criteria) commitment i Kevin Morris EP Supervisor Section B, Table B-2 Rev.16, Yes Section 4.01 Item 1 for Shift Technical 11/95 t Emergency Plan contams commstment for on- Advisor positen i shift dose assessment capabilit Kevin Morris EP Supervisor Section 1, paragraphs Rev.16 Yes #

l' Section 4.01 Item 2 1.3.1.1 and 1.3.1. /95 I Em;-;;n;; '";n ;;n:::n; ;;.c ~; ..;n: for .

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r i 04.02 ON-SHIFT DOSE ASSESSMENT EMERGENCY PLAN IMPLEMENTING PROCEDURE Person (s) contacted Position Title (s) Procedurellndicaten Revision N Meets acceptance i and Date criteria?  !

Kevin Morris EP Supervisor Attachment 1 of: EP- Rev.11, Yes Section 4.02 Item 1 102 through EP-105 9/95 Procedure initiates dose assessment Kevin Morris EP Supervisor EP-542 Rev. 4, 8/90 Yes ,

Section 4.02 item 2 indications initiate dose assessment  !

Kevin Morris EP Supervisor EP-542 Rev. 4, 8/90 Yes  !

Section 4.02 Item 3 Procedure for performing dose assessment j availabl ,

e 104.03 !ON-SHIFT DOSE ASSESSMENT TRAINING

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Person (s) contacted Position Title (s) Personnel Trained Meets acceptance (Title /#1 cntena?  !

Kevin Morris EP Supervisor Shift Technical n/a Yes Section 4.03 ltem 1 Advisor; 8 (

On-shift Personnel trained for dose assessment l

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I in=aactor: Thomas Ploski, Raa'- -i lit DRS. Plant 9maart B l l

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