IR 05000237/1986029
| ML20207M867 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/05/1987 |
| From: | Ploski T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207M841 | List: |
| References | |
| 50-237-86-29, 50-249-86-34, NUDOCS 8701130316 | |
| Download: ML20207M867 (6) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-237/86029(DRSS); 50-249/86034(DRSS)
Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name:
Dresden Generating Station; Units 2 and 3 Inspection At:
Dresden Site, Morris, Illinois Production Training Center, Braidwood, Illinois Inspection Conducted:
December 17-18, 1986
) /7 Inspectors:
T.
o Date
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M. J. Smith
.G. d Wi(A)iam Snell, Chief
,/f/.n Approved By:
ll Emergency Preparedness Dat'e Section Inspection Summary Inspection on December 17-18, 1986 (Reports No. 50-237/86029(DRSS) and No. 50-249/86034(DRSS))
Areas Inspected: Special, unannounced inspection of the following aspects of the Dresden Station's emergency preparedness program:
licensee actions on previously identified items; emergency plan activations; training; and licensee audits.
At the licensee's Production Training Center, some aspects of the licensee's program for identifying adequate numbers of qualified personnel for the offsite emergency organization were evaluated.
Results:
No violations of NRC requirements were identified during the inspection. An Unresolved Item is discussed in Section 3 of this report.
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DETAILS 1.
Persons Contacted
- E. Eenigenburg, Station Manager
- R. Flessner, Services Superintendent
- J. Wujciga, Production Superintendent R. Ragan, Superintendent, Production Training Center (PTC)
- D. Adam, Regulatory Assurance Supervisor
- J. Kotowski, Assistant Superintendent - Operations
- R. Zentner, Assistant Superintendent - Maintenance
- R. Holman, GSEP Coordinator A. Mosel, GSEP Instructor, PTC
- S.
Stile, Principal Instructor J. Gilligan, Shift Engineer (SE)
R. Facchina, SE T. Mohr, Station Control Room Engireer (SCRE)
T. Palanyk, SCRE
- Indicates those who attended the December 18, 1986 exit interview.
2.
Licensee Actions On Previously Identified Items (0 pen) Item 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 EAL revision has already been incorporated into the Dresden Annex to the generic emergency plan.
Although a procedure change request had been submitted in mid-October 1986, the revision to EPIP 200-1 had not yet been completed.
This item remains open.
(Closed) Item No. 237/86022-01 and No. 249/86027-01:
The microwave communication 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.
The microwave communication system was repaired and tested by Illinois Bell Telephone on November 23, 1986.
The GSEP Coordinator conducted a monthly communication test on December 2,1986 and found all systems operational.
This item is closed.
(Closed) Item No. 237/86022-03 and No. 249/86027-03:
The licensee's onsite emergency response organization was not adequately covered for the positions of Rad Chem and Environs Directors.
Licensee management had been aware of this shortage, but had not taken corrective action.
The inspector determined that adequate numbers of persons had recently completed training requirements for the Rad Chem Director and Environs Director positions and were added to the Station Group in mid-December 1986.
The GSEP coordinator has developed a training tracking form to better ensure that shortages of qualified personnel for onsite emergency organization positions will not recur.
This item is closed.
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a 3.
Emergency Plan Activations The inspectors reviewed documents related to three emergency plan activations which occurred between August 28 and December 15, 1986.
The documents reviewed included:
Shift Engineer's Logs; Nuclear Accident Reporting System (NARS) forms; Licensee Event Reports (LERs); and the GSEP Coordinator's "GSEP Event Checklist" for each event.
The inspectors concluded that the licensee had correctly evaluated and classified all these situations as Unusual Events.
The licensee initially notified the appropriate state agencies and the NRC Headquarters Duty Officer within the required time limits following each emergency declaration.
The GSEP Coordinator was responsible for compiling documentation associated with each emergency plan activation, such as NARs forms and excerpts from the Shift Engineer's log.
The coordinator also completed a "GSEP Event Checklist" to assist him in evaluating the adequacy of the Station's response to each emergency declaration.
The checklist's focus was on the timeliness of certain response actions such as:
initial offsite notifications; emergency responders'
arrivals onsite; and emergency response facility activation.
The checklist did not, however, address whether the emergency declaration was warranted, and whether the abnormal situation was correctly and quickly classified.
The inspectors were concerned, however, regarding the timeliness of the Unusual Event declaration made on November 29, 1986.
Procedures for deinerting the Unit 2 primary containment were begin at 1220 hours0.0141 days <br />0.339 hours <br />0.00202 weeks <br />4.6421e-4 months <br /> on November 28 for a scheduled shutdown.
However, based on records reviews and interviews with cognizant licensee personnel, the inspectors learned that the containment atmosphere did not exceed four percent oxygen content until around 1450 to 1520 hours0.0176 days <br />0.422 hours <br />0.00251 weeks <br />5.7836e-4 months <br /> on November 28.
The licensee then maintained reactor power at 15 percent in order to complete scheduled testing of the High Pressure Coolant Injection (HPCI) system.
Testing continued longer than had been planned, and was not co~ b ted until after 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> on November 29.
The unit mode switch was moved out of the Run position around 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br /> on November 29.
Technical Specification (Tech Spec) 3.7.A.S.a states, in part, that the primary containment atmosphere shall be reduced to less than four percent oxygen content during power operation.
Tech Spec 3.7.A.S.b states, in part, that containment deinerting may commence 24-hours prior to a shutdown.
The Shift Engineer (SE) and Station Control Room Engineer (SCRE) of the swing shift, upon reporting to work on November 29, noted that the HPCI tests were still in progress.
Following shift turnover, they determined that Emergency Action Level 3.1 was applicable to the Unit 2 operating condition.
The SE declared an Unusual Event at 1545 hours0.0179 days <br />0.429 hours <br />0.00255 weeks <br />5.878725e-4 months <br /> on November 29 since, as noted in the licensee's Deviation Report (DVR), testing had continued past the 24-hour time band to be deinerted while in the Run Mode.
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Based on interviews with the SE and SCRE who were on day shift on November 28 and 29, the inspector concluded that it was not clear to the day shift personnel while they were on-shift that a 24-hour time limit was in effect for operating in Run Mode with primary containment atmosphere at or above four percent oxygen concentration. The inspector concluded that on November 29 the oncoming swing shift SE and SCRE correctly evaluated the situation as satisfying an Unusual Event EAL and made the appropriate declaration.
From an emergency preparedness standpoint, the adequacy of the timeliness of the Unusual Event declaration on November 29 is linked to the applicability and interpretation of Tech Spec 3.7.A.5 and possibly to Tech Spec 3.0.A.
Other Region III staff are evaluating these Tech Spec issues.
Pending completion of their evaluation and the evaluation of other relevant records to be submitted by the licensee, the timeliness of the Unusual Event declaration on November 29, 1986 remains an Unresolved Item (234/86029-03)
The GSEP Coordinator was responsible for compiling documentation associated with each emergency plan activation, such as NARs forms and excerpts from the Shift Engineer's log. The coordinator also completed a "GSEP Event Checklist" to assist him in evaluating the adequacy of the Station's response to each emergency declaration.
The checklist's focus was on the timeliness of certain response actions such as:
initial offsite notifications; emergency responders'
arrivals onsite; and emergency response facility activation. The checklist did not, however, address whether the emergency declaration was warranted, and whether the abnormal situation was correctly and quickly classified.
In addition to the Unresolved Item, the following item should be considered for improvement:
To enhance the internal evaluation of actual emergency plan activations, the "GSEP Event Checklist" should be revised to also address the following questions: was the emergency declaration warranted; was the event properly classified; and was the classification made in a timely manner after event occurrence.
4.
Training (82701)
At the licensee's Production Training Center (PTC), the inspectors reviewed records associated with the 1986 specialized emergency preparedness training provided to members of the offsite emergency organizaticn.
Specifically, the inspectors determined whether those individuals identified as fully trained emergency responders in the l
fourth quarter edition of the "GSEP Telephone Directory" had, in fact, completed all training requirements within an annual period. The
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inspectors also discussed aspects of the training program for offsite emergency organization personnel with cognizant PTC staff.
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The PTC has'been responsible for the development of training materials, including examinations, associated with the offsite
- emergency organization.' Corporate Emergency Planning (EP) staff has been responsible for maintaining adequate numbers of qualified persons
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- in the offsite emergency organization;. scheduling their training; and for ensuring that a member's training either remains current or that the member is deleted from the organization until all periodic training requirements have again been satisfied.
Once scheduled by corporate EP
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staff, the training sessions have been conducted by PTC staff or staff of a generating station's Training Department..The PTC would then be-
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responsible for maintaining the training records for all members of the
- offsite emergency organization.
In early October 1986, PTC staff began sending quarterly memos to corporate EP staff to inform the latter of those emergency organization
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personnel whose training was still current or who would require requali-fication training during the next calendar quarter.
Previously such information was informally communicated to corporate EP staff.
The information would then be used in updating the "GSEP Telephone Directory"
and for scheduling retraining.
Based on records reviews, the inspectors noted that several persons identified as fully qualified emergency responders in the fourth quarter edition of the directory had not i
successfully completed all training requirements within the last twelve months.
The licensee's Quality Assurance (QA) Department had recently arrived at the same conclusion, as evident from Finding No. 2 in Audit
Report CE-86-09, dated October 24, 1986.
An audit observation also indicated that several telephone number inconsistencies were in the
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directory.
The inspectors reviewed the PTC's proposed responses to relevant audit findings and observations, plus.the final responses to
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the QA Department that were submitted by corporate EP staff in i
mid-November 1986.
The proposed corrective actions, including scheduled.
i implementation dates, were acceptable to the inspectors.
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Because the NRC wants to encourage and support licensee initiatives for L
- self-identification and correction of problems, NRC may not issue a Notice of Violation for'a situation in which the criteria listed in 10 CFR Part 2, Appendix C.V.A have been satisfied.
These criteria have been satisfied in the aforementioned situation.
Therefore, a Notice
of Violation will not be issued.
However, the staff will monitor the
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implementation of internally required corrective actions and their
' effectiveness regarding the accuracy of personnel qualification and telephone number.information provided in the quarterly "GSEP Telephone Directory." This is an Open Item (237/86029-01 and 249/86034-01)
The licensee planned to implement Revision 6 to the generic Generating Stations Emergency Plan (GSEP) in early February 1987.
The revision,
. currently under review by NRC staff, included changes to the offsite emergency organization. Among the proposed changes were the deletion of the Medical, Legal, and Accounting Director positions.
Such positions were no longer considered as necessary for the offsite emergency organization, as.the licensee perceived that the emergency duties of persons providing medical, legal, and accounting services to the
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emergency organization were essentially unchanged from their normal l
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In Inspection Reports No. 456/86021 and No. 457/86019, the. staff-expressed a concern, in the form of an improvement item, that " personnel, whose positions may be deleted from the offsite emergency. organization in future GSEP. revisions, should continue to receive annual overview
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training on the GSEP so that they better understand the emergency, response organization with which they may still have to interface."
By correspondence dated October 2, 1986, the. licensee committed that such personnel would receive an annual reading package describing the GSEP program, including their interface with that emergency response organization.
During this inspection, however, the inspectors were informed that the PTC had not yet been instructed to provide any future emergency' preparedness training to licensee staff who would provide medical, legal, or accounting services to the emergency organization.
The licensee must establish and implement annual training on the GESP program, including relevant organizational interface information, to its personnel who would provide medical, legal, or accounting services to the emergency response organization.
This is an Open Item (237/86029-02 and 249/86034-02)
5.
Independent Reviews / Audits (82701)
.The inspectors determined that all required 1986 emergency preparedness drills and the annual exercise had been conducted and internally critiqued.
The GSEP Coordinator's records of actions taken on critique items and items resulting from NRC inspections were adequately detailed and complete.
Based on the above findings, this portion of the licensee's program was acceptable.
6.
Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable, violations, or deviations.
An Unresolved Item identified during this inspection is discussed in Section 3.
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7.
Exit Interview
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On December 18, 1986 the inspectors met with those licensee
representatives denoted in Paragraph 1 to present their preliminary inspection findings.
The licensee agreed to consider the items discussed
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and indicated that none of the matters were proprietary in nature.
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