IR 05000237/1986022

Insp Repts 50-237/86-22 & 50-249/86-27 on 861020-24.No Violations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Emergency Plan & Implementing Procedures & Emergency Facilities

ML20213E024
Person / Time
Site:	Dresden
Issue date:	11/06/1986
From:	Allen T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213E013	List: IR 05000237/1986022 ML20213E009
References
50-237-86-22, 50-249-86-27, NUDOCS 8611120374
Download: ML20213E024 (8)

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m U.S. NUCLEAR REGULATORY COMISSION

REGION III

Reports No. 50-237/86022(DRSS); 50-249/86027(DRSS)

Docket Nos. 50-237; 50-249 Licenses No. DRP-19; DRP-25 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago,-IL 60690 Facility Name: Dresden Nuclear Generating Station, Units 2 and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted: October 20-24, 1986 Inspectors:

7~ 7M T. E. Allen Ddte'

$f Marcia J. Smith

^/ g Approved By: Wil m Chi Emergency Preparedness Date Section Inspection Summary Inspection on October 20-24, 1986 (Reports No. 50-237/86022(DRSS);

50-249/86027(DRSS))

Areas Inspected: Routine, unannounced inspection of the Dresden Station's emergency preparedness program: Licensee actions on previously identified items; emergency plan activations; and the operational status of the emergency preparedness program. Portions of the program inspected for operational status included: emergency plan and implementing procedures; emergency facilities, equipment, instrumentation and supplies; organization and management control; training; and independent reviews and audit Results: No violations of NRC requirements were identified during this inspection.

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l DETAILS 1. . Persons Contacted Commonwealth Edison Company E. Eenigenburg, Station Manager J. Wujciga, Production Superintendent

• R. Flessner, Services Superintendent J. Brunner, Assistant Superintendent, Technical Services T. Ciesla, Assistant Superintendent, Operations

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• R. Stols, Lead Quality Assurance Engineer

• D. Adam, Regulatory Assurance Supervisor

• R. Holman, GSEP Coordinator D. Drousfeldt, Shift Engineer R. Facchina, Shift Engineer R. Mitzel, Shift Engineer M. Korchynsky, Station Control Room Engineer (SCRE)

T. Mohr, SCRE T. Polauyk, SCRE J. Bobica, Shift Foreman L. Coyle, Shift Foreman M. Parce11, Shift Foreman T. Ziakis, General Foreman D. Ambler, Radiation Engineer D. Saccomendo, Radiation Protection T. Britt, Instructor D. Ringo, Procedure Coordinator

• Indicates those who attend the October 24, 1986, exit intervie . Licensee Actions on Previously Identified Items (Closed) Items No. 237/82024-03 and No. 249/82024-03: The licensee did not follow the preplanned requirements defined in Procedure No. EPIP 200-11, which required the units to be brought to cold shutdown, during the Alert

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declared on December 3, 1982. The licensee correctly followed applicable EPIPs during activations of the Emergency Plan since 1982 and had revised EPIP 200-11 to provide additional guidance for the prompt shutdown and cooldown of the reactor units. This item is close (0 pen) Items No. 237/85013-01 and No. 249/85012-01: Revise Emergency Action Level (EAL) Condition No. 12 for General Emergency to indicate that this emergency class can also be declared based on environs measurements. The revision had been incorporated into the Dresden Annex to the GSEP but had not been included in EPIP 200. This item remains ope .-- -- .

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. Emergency Plan Activations The inspectors reviewed documents related to eight emergency plan ,

activations which occurred between August 30, 1984, and August 27, 19864 The documents reviewed included: Licensee Event Reports (LERs); Shift Engineer's Logs; Nuclear Accident Reporting System (NARS) forms; licensee Event Notification Worksheets; and NRC Headquarters Duty Officer record The inspectors determined that the licensee had correctly evaluated and classified the seven Unusual Events and one Alert. The licensee had completed required notifications to responsible State and local government agencies and the NRC within the required time periods following each emergency declaration. Followup notifications were also completed in a timely manner after a significant change in the event and each event termination. The inspectors reviewed other LERs and did not find any plant conditions which warranted emergency plan activation Based on,the above findings, this portion of the licensee's program was

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acceptaoi . Emergency Plan and Implementing Procedures (82701)

The inspectors reviewed portions of the Generating Stations Emergency Plan (GSEP), Dresden Annex to the GSEP, Emergency Plan Implementing Procedures (EPIPs), and other relevant procedure documents. The Dresden Annex and EPIPs were consistent with the current GSEP. An inconsistency was detected between EPIP 100-C2, " Operations Director," checklist and EPIP 400-2,

" Operations Support Center," in that EPIP 400 does not contain all of the responsibilities listed in the EPIP 100-C2 checklis The inspector reviewed the licensee's provisions for preparing, internal reviewing, and distributing new and revised EPIPs. These provisions were unchanged from the previous inspection and were considered adequate. The inspector selected several recent EPIP changes at random and determined that the established preparation, review, and distribution procedures had been followed. A review of the procedure sign-off sheets showed that the i changes had been reviewed and approved as required by the licensee's l Technical Specifications. The revisions had been distributed to licensee

! personnel within one week after approval and to the NRC within 30 days after approva The licensee maintained listings of individuals, organizations, and work i

locations assigned controlled copies of EPIPs. Administrative procedures L required the custodian of any controlled EPIP copy to acknowledge in writing

the receipt of the procedure revision. Followup action was required if the acknowledgement was not returned to document control within a reasonable

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time. The inspectors determined that adequate quantities of the current revision of the EPIPs and Emergency Plans were maintained in the licensee's

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i l Emergency Response Facilities (ERFs) and the Control Room.

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l Based on the above findings, this portion of the licensee's program was l acceptable; however, the following item should be considered for I improvement:

• The EPIP checklists should be compared with the corresponding EPIP procedures and inconsistencies eliminated.

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T Emergency Facilities, Equipment, Instrumentation and Supplies.(82701)

TheJinspectors verified that the Emergency Notification System (ENS) and Health Physics Network (HPN) telephones were operational in all ERFs and the Control Room. The. inspectors reviewed repcrts of monthly, quarterly, and annual communication systems tests'and drills conducted during the

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-period of December 1985 through September 1986. The tests and drills had been conducted in accordance with regulatory requirements and the GSEP and EPIP commitments. The tests and drills were adequately documented and corrective action had been taken in a timely manner except for a communication system microwave uni The microwave unit, which was specified in the Dresden Annex as a necessary communication system link for the Control Room,. Technical Support Center (TSC) and Corporate. Command Center, had not been operational since January 1986. A licensee representative reported that repairs had been requested in January, but had not been completed because maintenance personnel were uncertain who had responsibility for the system and by the lack of management followup on repair progress. The microwave communication system inustu ' e repaired or replaced to assure adequate emergency communications. This is an Open Item (237/86022-01 and 249/86027-01).

Inspectors examined records of emergency equipment and supply inventories performed during the first nine months of 1986, and determined that all inventories specified in EPIPs had been completed on schedule and were

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-adequately documente The inventory records indicated that item deficiencies were promptly corrected. An inspector conducted spot checks of inventory quantities specified in EPIPs-against the quantities present at the TSC, OSC, and St. Joseph Hospital. The inspector noted that emergency equipment and supplies for the TSC were not locked and that four items were missing from the TSC supplies. It was'also noted that inventory lists were not available at the emergency supply-locations. Readily accessible lists can be useful for personnel needing the supplies during an emergenc The licensee's Post Accident Sampling System (PASS) has not been acceptabl functional for several months. The NRC's inspection report of July 25, 1986, and the licensee's Quality Assurance Department surveillance of the Semi Annual Health Physics Drill on August 14, 1986, reported the inoperability of the PASS. The licensee indicated that the PASS had not received the management and supervisory involvement necessary to assure timely repairs. The licensee initiated action during this inspection to prioritize and expedite " pairs to the PASS. The licensee must return the PASS to an acceptable functional level. This is an Open Item (237/86022-02 and 249/86027-02).

The inspector determined that the siren system for alerting offsite personnel has been tested on the first Tuesday of each month by the Grundy County Sheriff's Office. Any malfunctions were reported to the licensee for corrective action. A FEMA representative responsible for siren capabilities reported that siren tests and maintenance were conducted in an adequate and timely manne . . .---- . _ -

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' In iddition to the'above open items, the-following items-should be considered for improvement:

-* - Emergency equipment and supplies should be locked to prevent-loss.

4 *- The inventory list-should be posted with or.near emergency supplies to-aid users in determining what supplies are available.

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, Organization and Management' Control-(82701)

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Several changes had been made to the_ licensee's emergency organization and management control during about July through September 1986. The changes included new persons in.the positions'of Station Manager, GSEP Coordinator, Rad Chem Supervisor, and Rad Chem Foreman.= The changes-appear to have been conducted with reasonable turnovers, appropriately experienced personnel,

- and with individuals who understood Emergency Preparedness (EP) goals, priorities, and their functional EP responsibilities. -None of the individuals in new positions had been assigned EP responsibilities for f wisicii Liney were nul Lrdiried or qualii'ied.

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The personnel changes did result in the licensee's onsite emergency response organization ~not being adequately covered by qualified personnel for the Rad Chem Director and Environs Director positions specified in GSEP~

Paragraph 4.4 and EPIP 300-1, Table No. II for staff augmentation. The

- inspectors determined that the Dresden Station Group Directory listed

. the same three individuals for the two Director positions. The inadequate coverage provided by only three persons was exemplified during the

inspection when one of the three was off work due to illness and the second person was away from work on travel. Thus, only one of the Director positions could have been staffed. . Discussions with licensee personnel

. indicated that the licensee had been aware of the emergency staff shortage

but had not taken action to qualify additional personnel for-the positions.

The licensee must promptly train enough personnel to meet the staff requirements of the licensee's GSEP'and EPIP. This is an Open Item (237/86022-03~and 249/86027-03).

The inspector attended the annual meeting of offsite support organizations for the Dresden and Braidwood Stations held at the Mazon facility on 4

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October 23, 198 The agenda included a review of the GESP and Emergency

Action Levels,.Chernobyl overview, Dresden Station milestones, and the 4 availability of Quality Assurance audits related to Emergency Preparedness.

[ The inspector did not find any attendees who were dissatisfied with the organization and management support provided by the licensee.

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Training (82701)

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The inspectors reviewed the Station's emergency preparedness (EP) training program for licensed and non-licensed personnel who had key roles in the

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onsite emergency organization. The licensee's Production Training Center

had overall responsibility for ensuring that licensee, contractor, and

! other personnel granted unescorted access to the Station receive annual

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training of general aspects of the GSEP and Dresden Annex. The Station Training Depar,tment had administered that training and additional annual training to persons assigned specific positions in the onsite emergency organization. Procedure revisions relevant to the emergency plan were

routed to persons assigned key positions in the emergency organization.

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About ten . training _ records for~ persons assigned to key emergency-response positions were checked and each record was complete and up to date. . Statio Director training was being provided to Shift Engineers and other personnel 1 in the line of succession to Acting Station Director; ..The.1986 annual

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emergency response training.was scheduled to-be completed by December 198 The inspectors conducted walkthroughs'or interviews with one Recovery

Manager, three~ Station Directors, three teams of one Shift Engineer (SE)

, and one Station Control Room Engineer (SCRE), three OSC Directors, two Environs Directors and one Rad Chem Director. All persons interviewed e demonstrated an adequate understanding of the purpose of the emergency plan, the levels of emergency classification,_and their emergency response duties

, and authority. They demonstrated the use of appropriate procedures and i that they understood the interfaces of their positions with other response-positions.

.l' The teams of SEs and SCREs were able to demonstrate adequate familiarity a with the GSEP, Dresden Annex, EPIPs, CALs and notification equipinent ant forms. They were presented conditions requiring an understanding of all four levels of classification. The teams correctly ' classified the events .

i presented and demonstrated the capability to function as.a team. They also demonstrated the capability to make correct onsite protective action decisions and to formulate offsite protective action recommendations. They

, utilized meteorological data and evacuation time projections in determining the proper action. It was clear that they understood, that as Actin Station Director, the SE had the ultimate responsibility for declaring an  :

emergency and the responsibility and authority to issue offsite

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recommendation l

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Some of the SE/SCRE team members indicated that team training on the use of EALs, EPIPs, and decisionmaking related to their Acting Station Director h responsibilities would be beneficial if provided more often than the 2 current six month frequency.

Based on the above-findings, this portion of the licensee's program-r was acceptable; however, the following item should be considered for improvemen i l

l' * Consider increasing the frequency of GSEP training provided to i Shift Engineers and-Station Control Room Engineers.

F j Independent Reviews / Audits (82701)

f- The inspector reviewed the records of the Quality Assurance (QA) Department audits and surveillances of the Station's emergency preparedness program conducted since November 1985. All records were complete and readily i available. Onsite Audit No. QAA 12-86-26 and Offsite Audit No. 12-86-II

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were adequate in scope and depth regarding the regulatory requirements of 10 CFR 50.54(t). The QA Department had adequately tracked corrective t actions taken on the audit's findings and recommendations. The adequacy of

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the Station's interface with offsite support agencies was addressed in a

number of audit questions.

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Four surveillances conducted since November 1985 were reviewed by the inspector. -Two involved an auditor attending an offsite support agency meeting and a training session for offsite support agencies. One involved QA observation of the 1986 Annual Communication Drill and the other involved several QA observers at the 1986 practice drill and annual exercise. The level of QA involvement in the practice drill and annual exercise was appropriate. Auditor comments not only addressed the participant's technical performance, but also addressed the conduct of exercise controller critique The QA program for followup on findings and recommendations appeared to be adequate for assuring that corrective action was taken and reported within reasonable times. A report of action taken or planned is required within 30 days and the QA Department conducts a followup within 90 days to evaluate the effectiveness of action take The GSEP Coordinator conducts evaluations of records generated by the

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Staliuri dur iiig GSEP everiL3. Tiie cuisipielerie>> orid tiriieliiie33 of oi offsite notifications were evaluated. The inspector's determined that the GSEP Coordinator had performed the evaluations in a satisfactory manne Based on the above findings, this portion of the licensee's program was acceptabl . Exit Interview The inspectors met with licensee representatives identified in Section 1 on October 24, 1986, to discuss the preliminary inspection findings. The licensee indicated that prompt action would be taken to correct the items

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discussed. The licensee stated that none of the material discussed was proprietary in nature.

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l INSPECTION FINDINGS - OPEN ITEMS The microwave communications system, specified in the Dresden Annex to the GSEP as a necessary communication system link for the Control Room, Technical Support Center, and Corporate Command Center, had not been operational since January 1986. Repairs were requested in January, but management had not provided the followup necessary to assure completion of repairs in a timely manner. (237/86022-01; 249/86027-01) (Section 5) The Post Accident Sampling System (PASS) had not been acceptably functional for several months. The inoperability of the PASS was reported to the licensee by the NRC in July 1986, and by the licensee's. Quality Assurance Department in August 1986. PASS repairs had not been prioritized nor provided sufficient management review to assure a timely return to servic (237/86022-02; 249/86027-02) (Section 5) The licensee's onsite emergency response ~ organization was nut, odequately covered by qualified and designated personnel for the positions of Rad Chem Director and Environs Director. Licensee personnel were aware of the staff shortage, but had not taken corrective actio (237/86022-03; 249/86027-03) (Section 6)

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