View source for NRC-90-0071, Responds to NRC 900316 Ltr Re Violations Noted in Insp Rept 50-341/90-03 Re Emergency Preparedness Exercise Weaknesses. Corrective Actions:Case Studies Will Be Developed & Presented in Licensed Operator Requalification Training

{{Adams
| number = ML20042F360
| issue date = 04/30/1990
| title = Responds to NRC 900316 Ltr Re Violations Noted in Insp Rept 50-341/90-03 Re Emergency Preparedness Exercise Weaknesses. Corrective Actions:Case Studies Will Be Developed & Presented in Licensed Operator Requalification Training
| author name = Sylvia B
| author affiliation = DETROIT EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000341
| license number = 
| contact person = 
| case reference number = CON-NRC-90-0071, CON-NRC-90-71
| document report number = NUDOCS 9005080231
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 6
}}

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B. ROlph Sylcia t,enion vic.e Prmace 6
                                       =r-Edison ~;4i.O North D mie Highway April 30, 1990 NRC-90-0071 U. 3. Nuclear Regulatory Commission Attn Document Control Desk Washington, D. C. 20555                                                                        .

==References:==
: 1)    Fermi 2 NRC Docket No. 50-341 NRC License No. NPF-43
: 2)     NRC Inspection Report No.
50-341/90003 (DRS), dated                                     3 MLrch 16, 1990.                                               W

==Subject:==
Response to 1990 Fermi 2 Emergency Preparedness Exercise Weaknesses. Items 90-003-01 and 90-0,03-04 Reference 2 provided Detroit Edison with the results of the NRC's                               5 routine safety inspection conducted February 12 through 16, 1990, related to the Fermi 2 Emergency Preparedness Exercise (FERMEX '90).
In that report, the NRC staff identified two Exercise Weaknesses. As required by 10 CFR 50, Appendix E, Item IV.F.5, any Weaknesses that are identified must be corrected.                     Accordingly, attaehed is Detroit Edison's response to these Weaknesses.                     Our response describes the results of our evaluations and corrective actions tNan and being taken to resolve these concerns.
If you have any questions on the response provided, please contact J.
Mulvehill, Supervisor, Radiological Emergency Response Program, at (313) 586-4326, or T. L. Riley, Supervisor, Compliance and Special Projects, at (313) 586-1684.
Sincerely, Attachment oc:      A. B. Davis R. W. DeFayette W. O. Rogers J. F. Stang Region III h
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NRC-90-0071 Page 1 of 5                                                                       i
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Responses to 1990 Fermi 2 Emergency Preparedness Exercise (FERMEX '90) Weaknesses from NRC Inspection Report No.'50-341/90003 (DnSS)
Provided below is Detroit Edison's response to two Exercise Weaknesses
                . from NRC Inspection Report No. 50-341/90003 (DRSS). Per 10 CFR 50, Appendix E, Item IV.F.5, actions being taken to correct these                    '
weaknesses are identified.
1 NRC Statement of Exercise Weakness No. 1 (90003-01)                               )
                       "The Nuclear Shift Supevisor did not recognize that conditions             ]
!                      satisfying an Emergency Action Level (EAL) existed when the Off            ;
Gas   Radiation Monitor High-High alarm was confirmed at                   ;
I                      approximately 0736. As a result, the Notification of Unusual Event (NUE) was never declared. .There was no record of any log            .
entry by the NSS or his assistant that indicated that the - EALs were ever referred to when these scenario conditions occurred.
Also, when the Alert .Netification was made to the NRC following          '
e declaration at 0750, no information was provided by the Centrol Room to indicate that the conditions for the NUE had been recognized or acknowledged."                                             l Detroit Edison Response to Weakness 90003-01 l                Investigation of this Weakness included. a review of procedures, all l                pertinent exercise documentation, and interviews of involved                   t personnel. The undeclared Unusual Event Emergency Action Level is clearly stated in EP-101, tab 9, page 3 of 35             The . conditions for :
,                classification were met at approximately 0736. The control room crew l                immediately took action in accordance- with applicable Alarm Response
!                Procedures and Abnormal Opc: Ming Procedures. These actions included decreasing reactor power, @ich resulted in the Unusual- Event conditions clearing.         Emergency Operating Procedures (EOP) were entered with the receipt of turbine . building area radiation alarms.
The Nuclear Shift Supervisor was supervising the shift response in accordance with the' E0Ps and ordered evacuation of the turbine l                building. At 0742, the simulator malfunction severity was increased causing the conditions requiring Unusual Event declaration to again be         ,
present. At 0748, the reactor scrammed on high main steam line radiation. The Nuclear Shift Supervisor declared an Alert at 0749              .
based on severe fuel clad failure (reference EP-101, tab 9, page 4 of 35).
Detroit Edison acknowledges that the Unusual Event declaration was             !
missed. In this rapidly moving scenario, the control room crew analyzed the consequences and took appropriate actions to protect the
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             . Attachment NRC-90-0071 Page 2 of 5 health and safety of the public and plant employes.            The Alert classification at 0749 (versus 0750 noted in the report) followed closely after the time that it would have been most appropriate ' to declare an Unusual Event (0742). Therefore, missing the declaration of the Unusual Event seems moot. We are confident that had conditions not continued to escalate,         the Unusual Event would have been classified. The timely Alert classification serves to indicate that this is not a programmatic problem.
In any case, the timely and accurate classification of emergencies is key to activation of the emergency plan. The following steps will be taken to increase the emphasis on emergency classifications:
o     Abnormal Operating Procedures (AOPs) currently contain the immediate action statement: " Notify the NSS of the event, actions taken, and that it may be required to classify the event in accordance with with EP-101, Classifications of Emergencies".
AOPs   will   be   reviewed     to determine   if  more    specific classification direction is appropriate. AOPs will be reviewed and an action plan to revise them developed by May 18, 1990, if necessary.
o      Simulator training and evaluation scenarios performed aft.er July 9, 1990, will require a review of classification requirements anytime an AOP is entered.
o      Since some Emergency Action levels _ cannot be easily reflected using the current simulator program,        case studies will be developed and presented in Licensed Operator- Requalification Training to allow more comprehensive training on emergency          '
classifications. These case studies will be included in emergency plan training for each training cycle starting July 9,     ;
1990,   The effectiveness of this program will be reviewed for continuation on an annual basis.
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          . Attachment NRC-90-0071                                                                                                      !
Page 3 of 5
                                                                                                                          . I NRC Statenent of Exercise Weakness No. 2 (90003-04)
                    "During the s.edical - drill, the licensee failed to adequately demonstrate    the    monitoring-. of   personnel          exposure.      The                            ;
contaminated injured ' victim and. ambulance personnel were not provided with proper dosimetry to record a permanent record of exposure during transportation to offsite medical facilities.                                            7 These were required by Procedure EP-225, Radiological Medical .
Emergencies. The area in which the medical drill was staged was not posted " Airborne Radioactivitiy Area" as required by the '                                          ;
scenario. The radiological' information as conveyed to _ the medical personnel was not documented at the accident scene. A                                            >
body map was not provided to ambulance personnel when the victim                                         ;
was transferred as required by Procedure EP-225                   Also' the                              ;
                                                                                                                             ~
scenario lacked sufficient radiological data and Controller expertise."
These specific items plus others identified in Section 5.f contributed to an inadequate performance of this medical drill.
The NRC further noted the following items, in . Section 5.f of                                           r their report, which should be considered for improvement:
o        The scenario should be given more care in preparation to include sufficient radiological data for contamination levels on the responders who entered the posted area and                                        '
directly handled the victim.
o        Controllers should have been more aggressive and actively i
involved as much as their role permits.
Detroit Edison Response to Weakness 90003-04 In order to effectively assess the problems experienced in the Medical Drill,   a    Hunn    Performance   Evaluation Study           (HPES)   is     being performed. The preliminary results of that HPES have been categorized                                          '
into three primary areas of concern:      controller involvement, scenario content, and radiological procedural adherence.
The concern on controller involvement is attributed to two factors.
The Lead Controller was an outside ' consultant.             Coordination between the consultant and Detroit Edison controllers was not adequately established' because the consultant was not available onsite prior to the day of the. drill.      Second, the Detroit Edison controllers served as escort for outside evaluators during the drill. This arrangement restricted the movement of the Detroit Edison controllers and inhibited their interaction with the consultant and the drill 3                                                                                                                        '?
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      .       NRC-90-0071                                                                  :
Page 4 of 5 i
participants.      The following corrective actions have been/will be takent i
o     Detroit Edison has now established a practice that requires the Lead Controller for Medical Exercises to be a Detroit Edison employe.                                                              :
o     Controller training will be reinforced and will incitide but not be limited to;      establishment of controller roles, detailing responsibilities, discussion of scenario materials, and drill action and development. .                                             ,
o      In future exercises,' the practice of. restricting controller mobility will be avoided.
In the second area of concern, inconsistencies in the scenario caused confusion for the Radiation Protection (RP) personnel participating in
;             the drill.      The confusion arose because the scenario, provided by the outside consultant, and the radiological survey information, provided by the RP department, contained' data which was inconsistent.          The 1            amount of radiological data provided in the scenario was inadequate
/            and due to these inadequacies, initial survey data was supplemented with actual plant conditions.                                                -
l To address the scenario concern, the RERP staff will coordinate the development of a scenario review group which incorporates the                ;
expertise of the consulting firm and the knowledge of the onsite organizations, such as;       Medical, Radiation Protection, Operations,     ,
and other organizations.       Future scenarios will be developed and/or reviewed more thoroughly by Detroit Edison.. We have retained the consulting firm; but the previous consultant ~ has been replaced by a more experienced representative.                                              ,
The    two   procedural    requirements  which   were   omitted  included:
replacement of the victim's TLD with an ambulance kit TLD, per Step 5.8 3 2 of EP-225, and providing a Body Map, per Step 6.3.E of the           -
same procedure. These errors have been traced to a similar cause; i.e., unfamiliarity with EP-225.                                             ,
We believe a twofold approach to this problem is appropriate.
Additional training in the area of compliance with EP-225 for RP personnel is needed and the current EP-225 will be included in the medical kits to allow a copy of the body map to be more readily available at the accident scene..
Although performed, a radio 1%ical survey was not documented at the accident scene. Instead, the RP technicians thoroughly assessed the conditions and took the necessary contamination control actions. This        *
            .was appropriate for an emergency situation, but documentation of the survey should have been made.

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       .       NRC-90-0071                                                                                          i Page 5 of 5
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The scenario, as it was established and allowed to develop, presented no radiological condition which, by procedure, would have required an.
               " Airborne Radioactivity Area" posting.
The Inspection Report sites an additional procedural item which was not applicable. Step 6 31.2 of EP-225 states that dosimetry (TLDs) may be provided to the Emergency Medical Technicians (EMTs). The                                     ;
scenario did not require or allow ambulance personnel' to enter the Radiologically Controlled Area and the contamination levels on the patient were extremely low; therefore, the RP technicians correctly-determined that TLDs were not required for the EMTs.
In summary, the following immediate corrective actions are being taken to address the areas of concern prior to redemonstration of the Medical Exercise by August 1, 1990:
o     Controller functions and scenario development will be coordinated by Detroit Edison with less reliance on consultants.
o     Required reading of the Emergency Medical Procedure (EP-225) by the Radiation Protection Organization. This is to be . completed by May 31, 1990, o     Additional distribution of copies of EP-225 will be made' to the medical kits. This is to be completed by May 31           1990.                              -
Additionally, we have identified a long-term corrective action:
o     EP-225 requirements will be incorporated into .the Radiological Emergency Response Program Initial and Requalification Training for Radiation Protection technicians.- This will be completed and the appropriate personnel retrained as part of requalification training by September 30, 1990, t-i r
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