ML20072C690

Responds to NRC Re Violations Noted in IE Insp Rept 50-346/83-03.Corrective Actions:Procedures Revised to Reemphasize Methods Available for Contacting Ottawa County Sheriff & Shift Supervisor Provided with Addl Guidance

ML20072C690
Person / Time
Site:	Davis Besse
Issue date:	05/20/1983
From:	Crouse R TOLEDO EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20072C681	List: ML20072C690
References
1-358, NUDOCS 8306210170
Download: ML20072C690 (7)

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Docket No. 50-346

' 1DLEDO License No. NPF-3 E!EllEit)lWI Serial No. 1-358 Fh>AAo P. C AOUSE gs.m v

May 20, 1983 num assuai Mr. James G. Keppler, Regional Administrator ,

United States Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Dear Mr. Keppler:

Toledo Edison acknowledges receipt of your April 22, 1983 letter (Log No.

1-775, Inspection Report No. 50-346/83-03), referencing deficiencies in the emergency preparedness program for the Davis-Besse Nuclear Power Station, Unit No. 1.

Following an examination of the items of concern in Appendix A, Toledo Edison herein offers information regarding each item.

Deficiency: 10 CFR 50, Appendix E, Section IV.D.3 requires that licensees have the capability to:

Notify responsible State and local govern-mental agencies within 15 minutes after declaring an emergency.

Furthermore, 10 CFR 50.47, Paragraph (b)(5) requires that:

Procedures have been established for notifi-cation, by the licensee, of State and local response organizations...the content of initial and followup messages to response organizations and the public has been estab-l lished; and means to provide early notifica-

tion and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established.

Sections 5 and 6 of the licensee's Emergency Plan

! identify the Shift Supervisor as interim Emergency L Duty Officer (EDO) and summarize his duties in an

emergency situation, with reference to applicable l Emergency Plan Implementing Procedures (EPIPs).

THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MAD! SON AVENUE TOLEDO OHIO 43652 l 8306210170 830615 *'

(DRADEK 0500034

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Dockst No. 50-346 4

Liczn=e Ns. NPF-3 Serial No. 1-358

. May 20, 1983 Page 2 i .-

1 Contrary to the above, the following deficiencies were identified:

' Procedures EI 1300.02 through 1300.05, and associated checklists, do not provide assurance that the interim EDO has the 24-hour capability of adequately accomplishing all initial and followup notifications to offsite authorities for any Emergency Action Level (EAL) until properly relieved of such responsibility.

Procedure EI 1300.02 does not provide adequate guidance regarding contents of initial and followup messages to offsite authorities and a mechanism for documenting message content.

Checklists associated with Procedures EI 1300.01 through 1300.05 contain no provisions for docu-menting when the Ottawa County Sheriff was initially notified of an Emergency Action Lev,el (EAL) declaration; who received initial and followup notification at the Sheriff's Office and at the NRC; and no reminder that the Sheriff's Office must be notified within 15 minutes of an l EAL declaration.

The licensee has no procedure whereby initial and followup offsite agency notifications of an emergency declaration are adequately documented when such notifications accomplished by the Station Superintendent or Shift Supervisor.

J Response: 1.) The interim EDO has full capabilities to accomplish 24-hour notifications and follow up messages. The Ottawa County Sheriff is notified by phone through his dispatcher, which is a 24-hour position. An unlisted phone number is also provided for this notification.

In the even't that both the normal and unlisted line are unavailable, a back-up radio link is provided.

Procedures EI 1300.02 through 1300.05 vill be revised to re-emphasize the methods available for contacting the Ottawa County Sheriff.

Checklists for EI 1300.02 through 1300.05 will also be revised to include provisicas for documenting notifi-cations to the Ottawa County Sheriff, who received the message, and message content. Provisions will also be added to notify the Sheriff within 15 minutes of an emergency declaration.

__ . . _ _ _ __ _ _ _ __ _ ~ _ _ _ _ _ .

. Dock:t Ns. 50-346 License Ns. NPF-3 Serial No. 1-358 May 20, 1983 Page 3 4

2.) Training on the above revisions will be given to the Shift Supervisors and ED0's in the form of required reading and as classroom instruction during the annual Emergency Plan Training.

3.) The above procedure revisions will be completed by September 1, 1983. Annual Emergency Plan Training for the Operations Group has been scheduled to be com-pleted by November 30, 1983.

Deficiency: 10 CFR 50.47, Paragraph (b)(10), requires that:

A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, con-sistent with Federal guidance, are developed and in place.

Section 6 of the licensee's Emergency Plan states the emergency duties of the Shift Supervisor (interim EDO) include recommending protective actions for public protection as needed prior to the arrival of the EDO.

Contrary to the above, the following deficiency was identified:

The interim EDO (Shift Supervisor) is provided with inadequate guidance in Procedure EI 1300.05 regarding Protective Action Recommendation de-cision making with particular attention to de-cision making during the first hour of an emer-gency.

Response: 1.) This guidance in EI 1300.05, General Emergency, is adequate for the Shift Supervisors to provide recom-mendations for offsite protective actions in the

, absence of the Emergency Duty Officer. However, a flow chart, as identified in IE Information Notice No. 83-28, providing additional guidance to the Shift Superviso'r will be developed for plant specific data and included in EI 1300.05.

2.) The above item will be emphasized during the annual Emergency Plan Training for Shift Supervisors.

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. Dock t Ns. 50-346 License No. NPF-3 Serial No. 1-358 May 20, 1983 Page 4 3.) With the coordination necessary between Toledo Edison and offsite government agencies to develop a plant specific flow chart to be used for making immediate offsite recommendations, the revision to EI 1300.05 will be completed by January 1, 1984.

Deficiency: 10 CFR 50.47, Paragraph (b)(9), requires that:

Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emer-gency condition are in use.

Section 6 of the licensee's Emergency Plan states that the emergency duties of the Shift Supervisor (interim EDO) include dispatching radiation monitoring teams to onsite locations. Section 6 also addresses the need

-for calculating radiological dose estimates and pro-jections for licensee and offsite agency use in deter-mining the necessity for protective actions.

Contrary to the above, the following deficiencies were identified:

The Shift Supervisor (interim EDO) is provided l with inadequate guidance for the first hour of an emergency regarding task prioritization and l

onsite sampling and monitoring requirements to be accomplished by Chemistry and Radiation Testers for carious emergency conditions.

The licensee has not made adequate provisions to ensure that dose assessment can be made based on potential offsite consequences from various onsite radiological parameters such as the high range containment dome monitors and containment i atmosphere sample system.

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Response: 1.) A revision to EI 1300.05 will be made to provide the Shift Supervisor guidance regarding prioritization of responsibilities of the Chemistry & Radiation Tester (C&RT) and to ensure that the primary responsibility of the C&RT is to assist in preventing releases from the Station or exposure to individuals in the Station.

In addition, EI 1300.07 has been modified to include provisions to make dose assessments based on potential offsite consequences from the high range containment radiation monitor readings.

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D:ck t Ns. 50-346 LicInsa Ns. NPF-3 Serial No. 1-358 May 20, 1983 Page 5 s

2.) Training on the above revisions will be given in the form of required reading and as classroom instruction during annual Emergency Plan Training.

3.) The revision to EI 1300.05 will be completed by September 1, 1983. Annual Emergency Plan Training for the Operations Group has been scheduled to be com-pleted by November 30, 1983.

Following an examination of the items of concern in Appendix B, Toledo Edison herein offers information regarding each item.

Deviation: In Appendix B to the letter dated April 20, 1982, from R. P. Crouse, Vice President, Nuclear to J. G. Keppler, Regional Administrator, NRC, the licensee committed to make the following emergency preparedness improvements pursuant to the NRC Emergency Preparedness Appraisal of February 8-19, 1982:

Item 4 (Appendix B) The OSC should be equipped with fixed emergency lighting.

Commitment A Facility Change Request will be prepared to install eight hour battery pack emergency lighting.

Item 5 (Appendix B) All primary coolant sample lines at the rear of the emergency sample module should be provided with shielding.

Commitment The shielding portion (of this work) will be completed by January 1, 1983.

Item 20 (Appendix B) Procedure HP/1602-01, External Personnel Monitoring, should be replaced by emergency personnel monitoring procedures.....in-cluding provision for TSC, ECC, and OSC personnel.

. Dockst No. 50-346 License No. NPF-3 -

Serial No. 1-358 May 20, 1983 Page 6 f

Commitment Toledo Edison will develop new personnel monitoring procedures which will be in use by September 1, 1982.

ll Contrary to the above, during the inspection conducted

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March 15-18, 1983, the following deviations were identified:

Item 4 Although a Facility Change Request was submitted, emergency lighting was not installed. The licensee established a 1

January 1, 1983 deadline for completing this task; however this was not done. ,

Further, this item was given a low priority and no new completion date has been established.

i Item 5 Shielding of the primary coolant sample

lines was not completed at the time of the inspection.

Item 20 Emergency personnel monitoring procedures

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were not developed for Control Room and OSC personnel.

Response: Item 4 The priority on this item has been discussed during Toledo Edison's prioriti-zation activity and included.in our Integrated Living Schedule Program (ILSP) for 1984 activities. However, in lieu of fixed emergency lighting, portable lighting will be added to the equipment for the OSC.

This will be submitted for reprioritization i and installed in 1983.

! Item 5 The sample lines on the interim primary i coolant lines have been shielded with lead bricks and lead blankets.

4 Item 20 Personnel in the Control Room and in the OSC are provided dosimetry per procedure HP 1602.01, External Personnel Radiation Exposure Monitoring. This procedure is being revised such that all Station person-

' nel will be issued TLD's, as well as self-reading dosimetry, upon entering the Protected Area. Thus, for an emergency condition, all Station personnel will have

Dock::t No. 50-346 Lic nsa N3. NPF-3 Serial No. 1-358

. - May 20, 1983 Page 7 emergency dosimetry already in their possession. This procedure revision will be completed by September 1, 1983.

If you have any questions, please contact Judith Hirsch, Emergency Planning Supervisor.

Very truly yours, ffk;; : =

RPC:WLY:nlf cc: DB-1 NRC Resident Inspector I

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