IR 05000237/1991008
| ML17202V028 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 03/11/1991 |
| From: | Dan Barss, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17202V027 | List: |
| References | |
| 50-237-91-08, 50-237-91-8, 50-249-91-07, 50-249-91-7, NUDOCS 9103200066 | |
| Download: ML17202V028 (9) | |
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U.S. NUCLEAR REGULATORY COMMISSION REG ION I I I Report Nos. 50-237 /91008( PRSS); -50-.249/91007 (DRSS)
Dotket Nos. 50-237; 50-249 License Nos. DPR-19; DPR-25 Licensee~ Commonwealth Edison Company Opus West HI 1400 Opus Placf!
Downers Grove, IL 60515 Facility Name:
Dresden Nuclear Power Station, Units 2 and 3 Inspection At:
Dresden Site, Morris, Illinois Inspection Conducted; February 25-28, March 1, 1991 1/~tWl(3~
Inspector:
D. M.*Barss*
3/11 /'1 (
. Da'te '
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~*-,,~:a~~~?
Approved ~.
~i l '. iam ~nE 11, Chief
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- Rad1olog1cal Controls ~nd
Emergency Preparedness Section Inspection Summa~
Ins ettion on Februar* 25-28 and March 1 1991 (Re art Nos. 50-237/91008(DRSS)~
50-24S/91007 DRSS
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Areas Inspected:
Routine, un~nnounced inspection of the following areas of the Dresden Nuclear Power Station's emergency preparedness program:
followup of lice~see actions on previously iden~ified items (IP.92701); followup on
_actual emergency plan activations (IP 92700); and operational status of the emergency preparedness program (IP 82701). This inspection involved one NRC inspecto *
Results:
No violations, deficiencies or deviations were identified during th inspectfo One open item concerning the updating of drawing apeture cards in the Emergency Operations Facility was identified. The licensee has a well maintained emergency preparedness program, which they continue to improve through self evaluation and additional refinements as necessary.
9103200066 910312 PDR ADOCK 05000237 G
- DETAILS Persons Contacted E. D. Eenigenburg, St~tion Manager L. Gerner, Technital Superintendent D. Sharper, Lead Emergency Preparedness Coordinator*
R. Holman, Emergency Preparedness Coordinator _
L. M.. Kline, Regulatory Assurance
S. Stiles, Training Supervisor M *. Evans, Emergency Preparedness Trainer
- J *. Kuczynski; Emergency Preparedness Trainer M. Reagan, Central Files Supervisor S. Becker, Central Files Supervisor E. Mantel, Services Directo L. Decarlo, Support Services Group Leade~
I. M. Johnson, Nuclear Services E.P. Director All of the above listed individuals attended the NRC exit interview held orr March 1, 199 The inspectors also contacted other licensee personnel during the course of the inspection. -
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Licensee Action on ~reviously Identified Items (IP 92701)
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lQ~Open Item No. 237/90007-03:
This item is a generic concern regarding the restrictive criteria used to determine emergency action levels (EAL) for failure of fission product barriers and reactor coolant system (RCS) integrity for several of the licensee's sites. Th ljcensee's corporate emergency planing staff is coordinating response to this ite Dresden Station has developed revised EALs to address the con~er~s of this ite Dresden's revis~d EALs are currently in the review process. Other stations are still developing appropriate
. re~isions to their respective EAL This.item will remain ope.
Emergency Plan Activations (IP 92700)
At 1748 hrs on January 16, 1990, the licensee declared an Unusual Event (UE) based on Emergency Action Level (EAL) 3.D, "Loss of normal power t6 Unit 4-KV ECCS bus with the Unit not in Cold Shutdown or Refuel".
The Technical Support Center (TSC) was manned -and used by station management personnel to assess activities during the event, though the TSC was not formally activated. The event was terminated at 0605 hrs on Janu~ry 17, 1990~
At 2150 hrs on February 23, 1990, the.1 i censee declared an UE based on EAL 3.A, "Equipment described in the Technical Specifications is degraded such that a limiting condition of operation requires a shutdown and power decrease for a reactor shutdowr1 has commenced".
The event was terminated at 0859 hrs on February 24, 199 At 1340 hrs on July 20, 1990, the licensee again declared an UE based bn EAL The event was terminated at 1937 hr~ the same da *,;*
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At 0135 hrs or1 August 2, 1990; the 1 i ce11see declared an LJE.. based on EAL 2.F, "failure: of.a primary system relief valve to close with the Unit greater than 212 degrees F. and ~uppre~sion pool bulk temperatu~e
~annot be maintained less than 110 degrees F."
Th~ event was terminated at 0530 hrs.the same da *.
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The licensee's records for each of the above emergency plan activations were reviewe For each event an appropriate classification was made and notifications to State officials and the NRC were acc*omplished within required time limit The licensee conducted a Generating Station Emergency Plan (GSEP) event review for each GSEP activation. This review included gathering copies of applicable documents such as Shift Engineer's Logs, GSEP Log*s; Nuclear Accident Reporting System (NARS) forms, Emergency Notification System (ENS) notification worksheets, Deviation Reports and Licensee Event Reports (LER).
An evaluation was then made to determine if the class~fication was pertinent, notification timely and if the GSEP and associated procedures were properly implemente Problems identified through these reviews were of a minor nature and have been corrected by the licensee. This pr.actice of self evaluation following actual GSEP activations has proven to.assist the licensee in-improving their emergE:ncy plan progra *
No violations or deviations were identified in the review of this program area.
4. * Operational Status of the Emergency Prep a redness Program (IP 82701) Er.Jergency Plan and Implementing Procedures On March 1~ 1991, the licensee implemented Revision 7 of the generic Generating Statiun Emergency Plan (GSEP).
This revision included many changes to the structure of the plan*, clarification of tommitment~ and policies, new forms and enhancements to the structure of the response organization in both the Technical Support Center (TSC) and the Emergency Operations Facility (EDF).
The location and name of the Corporate EOF was changed and response organization titles revised to be consistent with site EOF Enhancements were also made to the structure and responsibilities of the Emergency News Center response organization *. None of these chcnges downgrade the effectiveness of the licensee's emergency response capabilities. A complete review of the changes implemented with Revision 7 of the generic GSEP was beyond the scope of this
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inspection and will be addressed separately under other correspondenc The GSEP Dresden Annex is currently under revie0 and revision to iricorpor~te changes implement~d with Revision 7 of the generic GESP as well as other chan~es and enhancements made to the stations emergency preparedness program since the last revisio The GSEP Dresden Annex has been reviewed annually as required by procedure~
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- The imp1ementation of Revision 7 of the gener{c GSEP ha neces~itated a major eftort to r~view and revise Dresden 1 s Emergency Plan Implementing Procedures (EPIP).
Virtually all
. of the stations EPIPs are being revised and several new prdcedures are being developed to support Rev. 7 change The inspector revie'r'J~ci documentaticin that indicated this effort was being
- conducted in a systematic manner and in accordance with approved
- station administrative procedures.. Independent reviewer, verifier and subjett expert reviews are in~luded in the revision proces The licensee 1 s records pertaining to the transmittal of procedtire revisions to affected procedure holders were reviewed. This review
. indtcated that revisions have been sent as appropriate, including copies to the NRC within 30 days of the change Current copies of the emergency plan and implementing procedures were found to be maintained and readily available in the emergency r~sponse facilities and the control roo *
The Corporate emergency planning staff was aware of minor errors in the Dresden Public Information Brochure ider.tified by the Federal Emergency Management Agency (FEMA).
Considering the minor nature of the errors, corrections to the brochure are appropriately planned to be made in the next revi~io No violations or deViations were identified.in the review of this prograiT1 are Emergency Facilitie5, Equipment, Instrumentation and Supplies An inspection tour was conducted through the Technical Support.
Center (TSC), Operational Support Center (OSC), backup OSC, Emergency Operations Facility (EOF) and the Control Room (CR).
These facilities were found to be generally as described in the*
Dresden Annex of the Generating Station Emergency Plan (GSEP).
The OSC has been relocated and modified fro~ that which is currently desc~ibed i~ the GSEP Dresden Anne The TSC has also received minor modifications. * These changes are reflected in appropriate EPIPs and are planned to be incorporated into the Dresden Annex along with changes currently being implemented as a result of Rev. 7 to the generic GSEP. *
During the inspection tour of the CR, it was noted that forms needed by control room personnel during emergency events are stored in two different file location Two Shift Control Room Engineers (SCRE) were briefly interviewed and asked about the availability of procedures and forms; each went to one or the other cf the two possible choice Although both locations
. contained current files, one was obviously more well stocked and the redundant files could be consolidated. Dedicated emergency phones in the CR were well identified. These phones were tightly tucked in the same cramped area with comput~r terminals, printers and other miscell~neous equipmen The licensee is
rurrently remodeling t~e control rccm complex e~d has identified
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the* need for better work s_pace for emergency communication equipmen Thermcluminescent Dosimeters (TLDs) are stored in the OSC for use by emergency responders. There was no provision for identifying a control TLD to establish a baseline dose.for these badges which are stored for extended periods. It is recommended that the licensee establish.a method for identifying a control TLD for badges stored ir1 Emergency Response Facilitie *
The licensee h~s provided a decontamination table for use in emergency situations. This table is stored in a remote area of the plant and was found to be in an unacceptable state of readine5 The license_e shol!ld consider appropriate measures to ensure this equipment is readi.ly accessible and available for us While touring the fOF th~ inspector observed that self reading dosimeters (SRD) stored in the health physics (HP) cabinet were*
three weeks past their calibration due date. The licensee*
identified the same problem in the July 1990 Nuclear Quality Programs (NQP) Audi In accordance with EPGR~OP 0202, R~vision 0,
11 Emergency Response Facility Responsibility Guidelines
, issued ir; September_ 1990, Dresden Station is tasked with responsibility for maintenance of HP suppli~s in the EO In response to the.
NQP Audit findirigs, and to meet the guidance of EPGR-OP 0202, the EP Coordinator issued a memorandum to the HP Supervisor in Octcber.
1990 outlining requirements and requesting suppor The HP Supervisor responded by memorandu.m in early February 1991 committing to support the dosimetry needs identified by the EP progra Procedure EPIP 0600-SlO, "Health Physics Cabinet Checklist", was approved on February* 11, 1991 formally proceduralizing inventory requirements. This new quarterly
- inventory ~;as scheduled to be conducted the same day the inspector identified the out of calibration SRD In light of the new inventory requirements, and considering the EP programs excellent past performance record of* completing required surveillances in a timely manner, the licensee has implemented adequate controls to ensure HP equipment in the EOF is maintained in a state of readines The inspector randomly selected a small sample of drawing aperture cards from the EOF files. It was determined that 12 percent of. the sample was not the current revisio The licensee *had identified in the July 1990 NQP Audit a general problem with superseded references and forms in the EO In accordance with EPGR-OP 0202, Revision 0, 11 Emergency Response Facility Responsibility Guidelines 11, issued in Septer;:ber 1990, Dresden Station is tasked with responsibility for the maintenance of documents in the EO In response to the NQP Audit findings, and to meet the guidance of EPGR-OP 0202, the EP Coordinator issued a memorandum to the Office Supervisor in October 1_990 outlining requirements and requesting suppor The Office Supervisor responded by memorandum in October 1990 committing to support the docum~ntation needs identified by the EP progra **
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Procedure EPIP 0600-S8, 11 Procedure and Aperture Card Reyision *
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Checkl i st
, was approved on February 5, 1991 forma J ly procedural izi ng requirements. This r.ew quarter*iy inventory had not.been scheduled or conducted as of the end of the inspection. The maintenance of current aperture card revisi6ns in the EOF *is considered an Open Item (No. 50-237/91008.. Ql).
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The licensee has made some major additions as well as minor fmprovements to emergency response facilities. A GSEP garage has been built to provide protected storage space for the dedicated GSEP Van as well as equipment and supplies to outfit a second environmental monitoring tea An intercom type phone circuit has been added to provide an additional common communication link
. between key managers in each emergency response facility (ERF).
Instrument respon~e check sources have been added to ERF supplies
. to allow for verification of proper operation of stored radiological monitoring etjuipmen *
- The lice~see has voluntarily participated in ih~ inst~llatiori of the NRC 1 s Err1ergency Response -Data System (EROS).
As of January 1991 the system was fully implemented and available for use when require *
Emergency communications systems surveillance records.for the emergency respons~ facilities were rev*iewed and found to be co~plete and thorou~h. These surveillances are conducted monthly an.d include the Nuclear Accident Reporting System (NARS) phones, GSEP radios, GSEP microwave phone system connections, NRG Emergency Notification System (ENS) and Health Physics Network (HPN) phones ar1ci other in-plant phone system extensions maintained for emergency use and not used in normal work activitie The 1ice:nsee 1 s inventory records for emergency supplies were reviewed and found to have been completed as detailed in *
appropriate procedures. These inventories included supplies for first aid, environmental sampling, decontamination facilities, TSC, OSC and an hospita i emrgency ki No viblations or deviations were identified in the review of this program are Organization and Management Control Overall organization and management control of the Emergency Preparedness (EP) program is unchanged from the last routine inspection. The EP Coordinator reports to the Technical-Superintendent who reports to the Station Manage No major changes have been made in the responsibilities and authorities of onzite EP program personnel. A member of the corporate EP Staff has been assigned to be a point of contact for Dresdeh Station concerns, to improve effectiveness of station rind corporate interfac Interface with cffsite agencies is generally coordinated by the corporate EF' Staf *
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An new instructor, dedicated to GSEP training responsibilitie~,
has been add~d to the lraining Depart~ent staff. A second instructo*r, primarily responsible for Operator GSEP training, has been retained.
. With the implementation.of Rev. 7 of the generic GSEP, several emerge~cy response organization (ERO) positions have change The transition. to this new structure is the result of an effort to standardize and improve efficiency of the ERO from lessons learned through drill and ex~rcise experience from all of the*
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In the TSC the following positions were added:
Assistant Station Director, Technical Communicator to EDF, Technical Status Board.*
Recorder, Offsjte Dose Calculation System (ODCS) Specialist, and ENS, HPN and CR Communicators. * The Rad/Chem Director position duties have been split into a Rad Protection Director and a Chemistry Directo In the EOF the following positions were added:
Assistant Manager of Emergency Operations (MEO), Technical Status Board Recorder, HPN Communicator,- Computer Specialist and a Station Senior Reactor*
Operator (SRO).
Protective Measures has been made an independent group with the Health Physics Director assigned to it. The Administrative Support Directer position is renamed Manpower and Logistics Direttor. Also, State Governmental and Department -0f *
Nuclear Safety Communicator duties have bee*n combined into State Environs Coordinato Adequate numbers of personnel have been identified for specific lead and support positior1s in the onsite ER The licensee maintains at least three qualified individuals to fill ERO position *
lhe notification phone list for the on~ite ERO has be~n updated*
on *quarterly basis. The licensee verifies response time capabilities as part, of this quarterly updat The notification process was recently revised to enhance the augmentation response tim Stati6n EP surveillance requirements have been incorporated into the Dresden General Surveillance Schedul The station surveillance coordinator issues, and tracks response to, scheduled surveillance commitment No violations or deviations were identified in the revie~ of this program are Eme:rgency Preparedness Training The current GSEP onsite training program was reviewed with the GSEP Training Instructors, including a review of the training matrix requirements, lesson plans and training record,,...
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- A massive training effort was being conductea to inform personnel assigned to the mo of the reievant changes implemented with the issuance of Rev. 7 *of the generic GSE The inspector sat in on two classes and obs~rved that the material was presented in a clear and:understandable manne Inforrnatfon.obtained by a review of training records indicated that personnel assigned to the ERO.had been trained in accordance with the established training matri *
Records of drills and exercises conducted in 1990 were reviewed and 1ndicated that these activities were conducted as required by
- procedura*l commitments. *Training is enhanced by including relevant
. * findings originating from drill and exercise critiques in the annual retraining progra As part of a company \\dde effort, training requirements for the EP
.program are being revised and consolidated in to an Administrative Courst: Management Information (ACM!) documen Concurrent with development of the ACM! the station Training Department Instruction (TOI) is also being rewritte *
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The licensee has a procedure, EPIP 710-2, "Qualification Requirements for GSEP Coordinator and Staff", which outlines requireri1e1its for qualifications for GSEP trainers as* well as other EP staff positions. It was determined through discussions with cognizant licensee personnel that a newly appointed GSEP trainer had n0t completed the documentation of qualifications in accordance with this procedur Further discussions indicated that the individual did meet the identified qualifications and actions wer~ initiated to appropriately document qualification in accordance with established procedure A.brief interview was conducted with a SCRE concerning activation of ERO From the iliterview it was determined that procedures and hardware were in place and personnel had been trained on the
activation of the.EROS syste No violations or deviations were identified in the review of this program are Independent Reviews/Audits Records of the Nuclear Quality Programs (NQP) Audit and surveillances done in 1990 were reviewe These included the annual u.udit, (NQP P.udit Report No. 12-90-]5), which fulfilled the requirements of 10 CFR 50.54(t), one corpo~ate assessmerit, and two surveillances, (QAS No. 12-90-31A and 12-90-21A), of 1990 GSEP exercises and drills. All records were readily available and complet The auditor 1 s checklists for the annual audit was reviewe The audit checklists were appropriately filled out and had informbtive supporting evidence to back up their evaluation of whether an it~m was acceptable or deficient.. This audit fulfilled all the requirements of 10 CFR 50.54(t) including an
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evaluation of the adequacies of the ihterf~ce betw~en-State and local government The auditors check~d letters of agreement, verified. that *letters of invita(ion* were issued to support
. organizations for discussion of.emergency planning issues, and in one audit it was noted that emergency action levels were reviewed ~ith the state at a meeting *. The audit was made available to the State and local governments and disttibuted to appropriate management personnel. Audit findings are reviewed each month until an item is closed. The closure is evaluated by the cognizant QA inspecto*r and reviewed by QA management. *
Items 1dentified in drill criti~u~~ are entered on the Nuclear Tracking System to ensure they are followed.up* and completed in a timely manne *
No violations or devi~tions were -identified in the revie~ of this program are Exit I nterv i e\\'1 The* inspector met with licensee representatives denoted in Paragraph 1, on March 1,.199 The inspector reviewed the scope and findings of the inspection and indicated.the licensee continues to have a well
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maintained emergency plan.* The licensee was informed of the *open item.
identified in section 4b and the status of the open item discussed in Section 2 of this reporti-The licensee indicated that th~ information di~cussed was not of a proprietary nature *