IR 05000237/1990002
| ML17202G771 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/30/1990 |
| From: | Dan Barss, Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202G770 | List: |
| References | |
| 50-237-90-02, 50-237-90-2, 50-249-90-02, 50-249-90-2, NUDOCS 9002090002 | |
| Download: ML17202G771 (8) | |
Text
U. S. NUCLEAR REGULATORY COMMISSION REGION I II Reports No; 50-237/90002(DRSS); 50-249/90002(DRSS)
Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensee:
Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:
Dresden Nuclear Generating Station, Units 2 and 3 Inspection At:
Dresden Station, Morris, Illinois Inspection Conducted:
January 9-12 r11-*- -
and January 24, 1990 Inspectors:
Accompanying Personne 1:
Approved By:
)'I * J *. tJ.J..U'~,
.
G. Patterson t 81
<<.., Cf-""V\\.,,.._/.
D. Barss
~~ s..dt wWam Sne 11' Chief Radiological Controls and*
Emergency Preparedness Section Inspection Summary Date Inspection on January 9-12 and January 24, 1990 (Reports No. 50-237/90002(DRSS);
No. 50-249/90002(DRSS))
Areas Inspected:
Routine announced inspection of the following areas of the Dresden Station 1 s emergency preparedness program:
emergency plan activations (IP 92700); operational status of the program (IP 82701), including emergency plan and implementing procedures, emergency facilities and equipment, training, organization and management, and independent audit Results:
No violations, deficiencies or deviations were identified during the inspectio Management involvement continues on a high level; however, a lapse in coordination between onsite and offsite groups to assure that all Emergency Plan Implementing Procedures were reviewed on a two year basis was identifie GSEP training was very well don Documentation related to GSEP related records needs improving.
9002090002 900131 PDR ADOCK 05000137 Q
- DETAILS Persons Contacted
- E. Eenigenburg, Station Manager
- J. Kotowski, Production Superintendent
- L. Gerner, Technical Superintendent
- K. Peterman, Regulatory Assurance Supervisor
- R. Falbo, Regulatory Assurance Assistant
- T. Gilman, Emergency Preparedness Supervisor - Corporate
- R. Carson, Onsite Program Coordinator - Corporate
- D. Sharper, GSEP Coordinator
- R. Holman, GSEP Coordinator Assistant
- M. Evans, GSEP Trainer, Training Department - Dresden
- F. Bevington, Quality Assurance Inspector for Dresden G. Smith, Operations Superintendent E. Martel, Services Director R. Burns, Rad/Chem Training Instructor L. Sebby, Staff Supervisor, Maintenance R. Geier, Master Mechanic
- Indicated those who attended the January 12, 1990 exit intervie.
Emergency Plan Activations (IP 92700)
A review of licensee and NRC records indicated that there were six activations of the licensee's Generating Station Emergency Plan (GSEP) since the previous inspection of January 9-12, 198 On February 3, 1989 a Notification of an Unusual Event (NUE) was declared based on a potentially contaminated injured man requiring treatment at an offsite facilit The event was declared at 0840 hours0.00972 days <br />0.233 hours <br />0.00139 weeks <br />3.1962e-4 months <br /> and terminated at 1032 hours0.0119 days <br />0.287 hours <br />0.00171 weeks <br />3.92676e-4 months <br /> the same da On March 25, 1989 an Alert was delcared based on a loss of all annunciators on Control R6om ECtS Panel #902-3 for greater than 30 minute The event was declared at 0435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br /> when the problem was identified and terminated at 0440 hour0.00509 days <br />0.122 hours <br />7.275132e-4 weeks <br />1.6742e-4 months <br /> On July 7, 1989, an NUE was declared based on initiation of a reduction in reactor power due to Technical Specification requirements relative to turbine stop valve scram signal test The event was declared at 0410 hours0.00475 days <br />0.114 hours <br />6.779101e-4 weeks <br />1.56005e-4 months <br />
- and terminated at 0610 hour0.00706 days <br />0.169 hours <br />0.00101 weeks <br />2.32105e-4 months <br /> On September 24, 1989 an NUE was declared based on a loss of all emergency notification systems and commercial telephone line The event was declared at 1152 hours0.0133 days <br />0.32 hours <br />0.0019 weeks <br />4.38336e-4 months <br /> and terminated at 1807 hour0.0209 days <br />0.502 hours <br />0.00299 weeks <br />6.875635e-4 months <br /> On October 31, 1989 an NUE was declared based on initiation of a reactor shutdown due to Technical Specifications requirements related to the High Pressure Coolant Injection (HPCI) system being declared inoperabl The event was declared at 0800 and terminated at 1126 hours0.013 days <br />0.313 hours <br />0.00186 weeks <br />4.28443e-4 months <br />.
- On December 10, 1989 an NUE was declared based on a reactor shutdown due to Technical Specifications related to a failure of a leak rate test on the drywell personnel air loc The event was declared at 0505 hours0.00584 days <br />0.14 hours <br />8.349868e-4 weeks <br />1.921525e-4 months <br /> and terminated 092 Documentation related to each GSEP activation had been organized into a file specific to the activatio Included in each event documentation package were Notification Sheets, Shift Logs, Licensee Event Reports and other doc~mentation as appropriate.. In accordance with Emergency Plan Implementing Procedure (EPIP) 500-S4, Event Investigation Report, licensee personnel evaluated each GSEP activatio This evaluation included a review to ensure that notifications had been made in a timely
.manner, classifications were correct, facilities were appropriately activated and corrective actions determined as necessar A review of the licensee's GSEP activation packages indicated that for each of the events, license~ actions had been appropriate, timely, and in accordance with established procedure The Technical Support Center was activated and utilized extensively during the event on March 25, 198 The licensee effectively utilized the emergency facilities, procedures and organization to evaluate plant conditions and anticipated actions to successfully mitigate the consequences of event The GSEP Coordinator was directly involved in this event and contributed to evaluating the event from an emergency standpoin A special safety inspection, Inspection Report Nos. 50-237/89012 and No. 50-249/89011, of the events was conducted by Region III staff in coordination with the Resident Inspector From an emergency preparedness evaluation of the March occurrences, the events were properly identified and categorized accurately using the EALs applicable at that tim Based on the above findings this portion of the licensee program was acceptabl.
Operational Status of the Emergency Preparedness Program (IP 82701) Emergency Plan and Implementing Procedures As required by Section 8.5 of the Generating Station Emergency Plan (GSEP), each GSEP Manual observed has been assigned a serial numbe A computerized record is maintained of each manual identifying to whom it has been assigne There has been no revision to the GSEP Manual's generic section since the last routine inspection in January 198 As specified by the GSEP a record of Certification of Currency was completed on November 1, 1988, for the year 1989, and January 10, 1990, for the the year 1990.
- The Dresden Annex of the GSEP, Revision 5b was issued in January 198 By letter dated March 8, 1989, NRC Region III staff reviewed and approved Revision 5b of the GSEP Dresden Anne Appropriate documentation of onsite and offsite reviews were available and reviewed for Revision 5b of the GSEP Dresden Anne The cover page for the GSEP manual contained the appropriate signatures, by title, for review, approval and authorizatio It was noted by the inspector that several figures or sketches in the Dresden Annex were of very poor print quality and nearly impossible to rea (For example:
Page DA 1-5, Figure DA-1-1; Page DA-1-7, Figure DA-1-2; and Page DA 7-19, Figure 7-3a.)
Additionally, it was not readily apparent from the GSEP Index or cover pages what was the current revision numbe By scanning the index and cover pages, it appeared that Revision S was the most curren However, several pages were identified as Revision 6A or 6B and dated more than one year late It is recommended that the cu~rent revision number be readily identifiable in the index so that manual users may be certain that they have a complete and current copy of the GSEP Manua It is also recommended that all figures should be of sufficient print quality that they are useful to the use Section 8.5.7 of the GSEP requires the Emergency Plan Implementing Procedures (EPIPs) to be reviewed every two year An examination of documentation verified that the EPIP 1s had been reviewed in 1987 and 198 The 1989 *review was a major revision in which all EPIPs except t~ree were issued as new, Revision These new EPIPs provided position specific procedures for each Director along with a check list to follow to ensure correct implementation of procedural step Procedures have also been shortened by removal of unnecessary operator actions whi*ch are more appropriately addressed in 6ther existing procedure As required by 10 CFR 50.54(q) and 10 CFR 50, Appendix E, Paragraph V, copies of the revised EPIP 1 s were submitted to the NRC, both Region III and Headquarters, within 30 days of their effective dat Based on the above findings, this portion of the licensee's program was acceptable; however, the following items should be considered for improvement:*
.. The drawings or maps listed in the Dresden Annex were difficult to read due to poor print qualit The current revision* number of the GSEP was not readily apparent.
Emergency Facilities~ Equipment, Instrumentation, and Supplies Selected Emergency Response Facilities (ERF 1s) were reviewed which included the Technical Support Center (TSC), Operational Support Center (OSC), and the Control Roo These facilities were maintained in an adequate state of operational readiness; As
appropriate, current copies of plans, procedures and drawings were available for use in these facilitie Emergency communication equipment was operable and adequate emergency supplies were*
availabl A surveillance procedure was developed and implemented to ensure the ERF's were maintained in a ready stat Since th~ last inspection several improvements had been made to the ERF's to upgrade or enhance the equipment and its availabilit For example, Tektronix Terminals h~d been installed in the TSC to replace the old Ramtex Terminal These new terminals provide enhanced computer graphics capabilities and hardcopy printouts of data previously only available by on-screen display Laser printers have replaced dot matrix printers allowing production of much cleaner printout Several WYSE terminals have been added so that most Directors in the TSC now have direct access to computer service Administrative supplies have been prepackaged for quick and convenient distribution to response personne Electronic copy boards have been purchased and placed in the TS An area has been designated and setup to provide an Administrative Auxiliary Support work area complete with a WYSE terminal, typewriter and FAX machin TSC status boards have been redesigned as appropriate from information obtained through "lessons learned" in drills, exercises and real event Large wall mounted emergency telephone directories have been posted in the TSC and OSC providing a ready reference for personne New Dresden Emergency Operating Procedures (DEOP's) were available in the Control Room in a large flow chart forma GSEP and EPIP books were current and available in the Control Room, as well as multiple co.pies of appropriate notification form The licensee had identified a problem on October 18, 1989 with the Emergency Notification Phone (ENS) located in the Control Roo The phone operates correctly on outgoing calls but not on incoming call The phone does not provide an adequate ring or light indicatio The licensee has reported this as required and parts are currently on order for its repai This repair work is the responsibility of the NR A complete inventory was conducted by the inspector of the GSEP Van using Procedure EPGR-OP-0401, Revision 0, GSEP Van and Environs Field Team Equipment Inventor Two items, a tripod and a calculator, required by the inventory procedure were not found in the va The tripod, for holding the air sampler, was available in a nearby storage area; and the missing calculator was promptly replaced by licensee personne Overall, the GSEP van was maintained in a good state of readiness and was available for prompt response as neede Documents were reviewed which indicated that copies of the annual public information pamphlet were distributed to households, businesses, schools and facilities which would be used by transient individuals such as hotel, campgrounds and marina' Based on the above findings, this portion of the licensee's program was acceptabl * Organization and Management Control The present organization specifies that the GSEP Coordinator reports directly to the Technical Superintendent. who in turn reports to the Station Manage This reporting order should continue to provide ready access to upper management whenever the GSEP Coordinator has an issue he feels deserves their immediate attentio From information received during this inspection, there was no doubt that plant management was kept informed by the GSEP Coordinator on a very timely basis, when warrante Some changes in the EOF and TSC organizations are planned as part of Revision 7 of the GSE These include the position of Health Physics Director, who will report to the Protective Measures Director, rather than to Technical Suppor The position of Radiation Analytical Coordinator will be eliminate For the TSC, the Station Director Communicator position will be eliminate An Assistant Station Director will be adde Also, a dedicated ENS communicator position will be established in the TS These changes are planned based on reviews of annual exercises and practice drills with input from participants, site and corporate training department The changes should improve the operating efficiency and interactions within and.outside of these two emergency response facilitie Based on the above findings, this portion of the licensee 1 s program was acceptabl Training Training records for 45 individuals with emergency response functions in the GSEP organization were ~andomly selected to determine if each individual had completed all required training module No discrepancies were identified, and all names selected had completed their annually required EP training on tim Training records were meticulously maintained, readily accessible and retrievable with littl.e effor An appropriate training matrix had been established and implemente Prior to the major change in th Dresden EPIPs issued in September 1989 (Reference Section 3.a.),
GSEP trained individuals were provided with instruction on the revised EPIP that related to their emergency positio This instruction was in addition to the annual retraining as required by the training matri Interviews were conducted with the following emergency response personnel:
One Operations Superintendent, one TSC Communicator and two Maintenance Director All did very well in demonstrating their proficiencies and.knowledge of the GSEP eme~gency response organizatio These interviews were a positive indication of the training and attitudes of the individual The prior inspection in January 1989 (Report Nos. 50-237/89002 and 50-249/89002) had
identified some marginally ~dequate responses by maintenance technicians on general radiation safety/emergency response questions when interviewed. *To correct this weakness, the Training Department had developed and implemented a new training module, which had been given to these maintenance technicians as verified by the inspector Th~ following EP drills were conducted and successfully met the requirements of the GSEP including critiques:
2 - Health Physics Drills (one on Post Accident Sampling)
1 - Environs Drill 1 - Medical Drill 1 - Assembly/Accountability Drill 4 - Shift Augmentation Drills 1 - Communicator Drill The assembly/accountability drill in October 1989 resulted in seve~al suggestions to improve the existing procedure, in addition to confirming that in certain areas onsite the siren system could not be hear (i.e., the Administration Building, Shift Engineer's Office, Operations Staging Room and the Instrument Maintenance Shop area).
To assure adequate coverage in the future the GSEP Coordinator arranged through the Security Department to have security personnel patrol these areas with a 11 bull 11 horn announcing assembly/evacuation instruction This method of notification will continue until another more permanent means can be devise Although the quality of these drills appeared to be more than adequate, the documentation related to the drills and the retrievability of this documentation definitely needs improvemen Computer generated information on the drills is available; however, adequate written copies are neede The GSEP Coordinators were encouraged to include a cover sheet with a brief synopsis of the specific drill results for each type of dril Documentation of critiques also could be improve Based upon the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvement:
- *
Documentation of drill records and other related EP items as well as retrievability of these document Independent Reviews/Audits Reviews were.made of 1989 Quality Assurance (QA) Department audits and surveillance Audits conducted included two relating to onsite
.activities, one related to offsite activities, and one related to the corporate EP activitie Several surveillances were also reviewe All documentation was complete and readily availabl **
QA Audit No. 12-89-50 conducted in April 1989, included followup on a finding from a previous QA surveillance which identified a lack of Instrument Maintenance calibrations on one of the High Radiation Sampling System (Post Accident Sampling System) sampling panel Acceptance of corrective actions on this item, which included calibrations required and revised procedures, was listed as July 28, 198 Another finding from a July 1989 audit, Audit No. 12-89-20, identified the fact that all EP!Ps were at that time undergoing the revision/review proces Our review of the audit did not identify any acknowledgement by QA that the two year review requirement (Reference Section 3a) could possibly be exceeded for some of the EP!P Another QA conclusion was based on surveillance of one of the two Health Physics Drill The performance of the participants was judged to be of high qualit Other findings, observations and related surveillances were evaluated and found to be meaningful, with corrective actions being initiated where neede The Station's interface with offsite support organizations was
- evaluated and reported as part of the QA audit conducted in April 198 That portion the audit which related to these offsite agencies was made available to them as required by 10 CFR Part 50.54(t).
Training records for offsite agencies were also included in the audi No problems were identified in either are The annual meeting with offsite agencies was held in May 1989 and did include a review of EALs as they relate to responses by State and countie This meeting also constituted a QA surveillanc Overall, the QA audit program is thorough and well manage More detailed review of the links between Corporate, Station, and Document Control to develop a more efficient and coordinated effort to meet the GSEP requirements of Section 8.5.7, namely the two year review requirement, would be helpful, howeve Based on the above findings, this portion of the licensee's program was acceptable. * Exit Interview The inspectors met on January 12, 1990 with those licensee representatives identified in Section 1 of this repor The scope and preliminary inspection findings were summarize No violations were identifie Improvement is in order for the mechanisms needed to assure that all revised EPIPs are consistent with the GSEP (Section 9.2) and the req~irements of Section 8.5.7 are met, which requires that a two year review be conducte Corrective actions were taken during this inspection on three procedures to assure that the review commitment was mad Many areas of the EP program were being well conducted, especially onsite GSEP trainin Documentation of drills and retrievability of drill records and other key issues of the GSEP need improvement, howeve Followup on GSEP activations was evaluated as being thorough and provided adequate documentatio The licensee indicated that none of the items discussed were proprietar