IR 05000237/1992022
| ML17177A605 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 08/14/1992 |
| From: | Cox C, Mccormick, Ploski T, Simons H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17177A603 | List: |
| References | |
| 50-237-92-22, 50-249-92-22, 50-254-92-19, 50-265-92-19, 50-295-92-20, 50-304-92-20, 50-373-92-17, 50-374-92-17, 50-454-92-14, 50-455-92-14, 50-456-92-16, 50-457-92-16, NUDOCS 9208280091 | |
| Download: ML17177A605 (9) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Report No REGION I I I 50-237/92022{PRSS); 50-249/92022{DRSS) *
50-254/92019{DRSS);* 50..:265/~2019{DRSS) /92020{DRSS)~50-!04/92020{DRSS):
. 50-373/92017{DRSS);P50-374/92017{DRSS)
50-454/92014{DRSS}; 50-455/92014{DRSS)
50-456/92016{DRSS); 50-457/92016{DRSS)
Docket Nos. 50-237; 50-249; 50-254; 50-265; 50~295; 50-304; 50-373; 50-374; 50-454; 50-455; 50..:456; 50-457 License Nos. DPR-19; DPR-25;
- DPR-29* DPR-30* DPR-39*
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DPR-48; NPF-11; NPF~l8; NPF~37; NPF-66; NPF-72;
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Licensee:
Commonwealth.Edison Company Opus West III
. 1400 Opus Pl ace Downers Grove, IL 60515 j
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Facility Name:
Nuclear Safety and Emergency Preparedness Department
- .. Inspection At:
Chicago, Illinois lns~ection Conducted:
July.27-29~ 1992 Inspectors:JJtt~A..,,f1
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. Approved By: c%:f. ~~~~ief
Non-Power Reactor Section Insoection Summary *
Inspection on July 27~29~ )992 <Report Nos. 50~237/92022CDRSSl: 50-
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249/92022CDRSS};
so~254/92019CDRSS}; 50-265/92019CDRSS};
50~295/92020CDRSS};
50-304/92020CDRSS}; 50-373/92017CDRSS}; so:...374/92017CDRSS}; 50-454/92014 CDRSS}~ 50-455/92014CDRSS}; 50-456/92016CDRSS}; 50-457/92016CDRSSll Areas Inspected:
Routine,* anno_unced"tnspecttonc oL.the.activit_ies :oLthe...
licensee's corporate Emergency Preparedness {EP) staff {IP 82701) by three NR inspector * * *
9"'108280091 920820-- -~*'*..
PDR ADOCK 0500~B~7.
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Results:* One non-cited violation was jdentified relat~d to the corporate EP traini~g program (Section 3.d). A significant issue was identified concerning the.licensee'.~ abilfty to activate their Emergency Operation Facilities (EOF}
in a timely ~anner (Section 3.c}. Recent augmentation drills indicate that minimum staffing would take at least two to three hours after staff member were notified and complete staff augmentation-w6uld tike as Jong ~s fotir houts *. *
Other* aspects of the emergency preparedne$s program which the corporate staff are responsible for remained ~ell maintaine *
DETAILS. Pe~sons Contacted aw Licensee Representatives tontacted I. Johnson, Emergency Preparedness (EP) Director.*
L. Holden, EP Supervisor T. Blackmon, EP Supervisor M. Pavey, Emergency Planner K. Steele, EP Instructor D. Silcox, EP Instructor Others Contacted*
. J. Bradley, Murray and Trettel, Inc.*
The above licensee representatives attended the NRC exit interview on July 29, 199 The inspectors also contacted other licensee personnel*
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Licerisee Action on lnspecti-0n Followup Items CIP 82701)
(Closed) Inspection Followup Item No. 454/92004-01 and 455/92004-01:
The licensee failed to revise the emergency implemeriting procedure
. pertaining to emergency action levels following a revision to the Byron
'Annex to the Gener~ting Stations Emergency Plan (GSEP).
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lhe licensee had completed the corrective actions on this violation~ An administrative procedure for ~pdating and revising the station annexe to the GSEP*had been written and approve One corporate emergency planning speciali~t was responsible for toordinating annex revisions.
. The Byron Annex was revised to be consistent with the GSE This i tern is close * Operati6nal StatOs of the Emergencv Preparednes~ CEPl Program CtP 82701)
- Emergency Pl an and Implementing Procedures
. Several Corporate Emergency Plan Implementing Procedutes (CEPIPs)
were reviewe All CEPIPs had been revised following the
implementation of Revision 7 of the GSE The CEPIPs were well structured into poiition specific instructions for use during an emergenc.
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A revi*w of 1992 CEPIP revisions indicated that, with one minor exception, they had been submitted to the NRC-within 30 days of their final approvals, per the requirements of 10 CFR 50.4 and 10
'CFR SO, Appendix E,.Paragraph No violations or deviations were identified.
- Emergency Response Facility. Equipment and Supplies
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The Zion Station's Backup Emergency Operations Facility (BEOF) was located in the licensee's downtown Chicago offices. Records
review and a tour of this facility indicated that it has been maintained in an adequate state of operational.readiness. The liCensee planned to request NRC approval in order to change the*
Zion Station's BEOF to the Corporate EOF, which was constructed in 1991 at the licensee's newer corporate offices in Downers Grove, Illinoi *
The public notification systems for the six stations' plume pathway Emergency Planning Zones (EPZs) were discussed with
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cognizant staff and appeared to be adequate. Outdoor sirens were the *principal means of alerting the public within the EPZs while.
.. route alerting by local officfals would be utilized for rural portions of some EPZ *
A contractor had performed semi-annual preventive maintenance and emergency maintenance on the outdoor siren system, including the equipment.which the local officials used to activate the syste The contractor had begun installing telemetry equip_ment on most of the 396 sirens in the six stations' EPZs as another means to
better assure siren system operability. The telemetry installation project was scheduled for completion by 199 The licensee indicated that its contractor would perform daily telemetry checks on each sire The licensee recently developed reference documents for each EPZ's
- siren system. These do~uments contained basic information on each siren, including maps illustrating each siren's zone of c.overag Controlled copies of these reference documents were provided to local officials for use in their Emergency Operations Center No violations or deviations were identifie Organization and Management Contra 1 The Corporate EP Director and her staff reported to the Senior Vice President ~ Nuclear Operations through the General Manager of the Nuclear Safety and Emergency Preparedness Departmen Th corporate EP staff's responsibilities were as described in Chapter 8.of the GSE Although there were* a number of personnel changes
- in recent years, the corporate EP staff's size and internal
.organization remained largely unthanged sin~e mid-198 The licensee has increased the number of its co~porate staff having responsibilities for interfacing with state and local officials in a variety of matt~rs, including the maintenance of counties' radiological emergency response plans and procedures,**
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and the conduct of related training. Corporate staff previously utilized contractors to a great,extent on such offsite EP matter The licensee utilized seve~al formal mechanisms to share information between corporate and station-based EP staf Counterpart meetings involving corporate EP staff and the stations' EP coordin~tors and instructors had occurred severa times per year for over four years. Since the late 1980s, corporate staff had issued several categoties of "SAlP l lessons learned letters" to the stations' management and EP coordinator As was being done in-other functional areas, quarterly "Executive Summary/Window Reports" had been issued regarding each station's EP progra Corporate staff were responsible for maintaining letters of Agreement {lOAs) with support organizations which were common to*
al1 six ~uclear stations. These lOAs were updated in 199 The GSEP Telephone Directory, which listed corporate and station-based personnel assigned to positions in the licensee's offsite Emergency Response Organization {ERO), was well maintained and revised quarterly. Review of the current and recent revisions of the directory indicated that the licensee maintained excellent
.numbers of personnel for all key and support positions in its offsite ER *
The 1 i censee' s approved GSEP did not i nc-1 ude a ti me commi"tment by.
which its personnel would.be expected to staff a station's EOF or Joint Public Information Center {JPIC) following any Sit.e Area Emergency,. General Emerg~ncy declaration, o~ a decision to activate the facility. _Since the licensee typically prepo~itioned its EOF and JPIC" responders at local motels for annual EP exercises, the timeframes needed to adequately staff any statibn's
-~ EOF during norma 1 and offhours in the event of an actua 1 Site Area or General Emergency declaration remained uncertai The current Revision 7 to the GSEP included a new commitment that the licensee would conduct semi-annual, off-hours notification drills of its offsite ER Each drill would be based on the decision to activate one station's EOF and JPI Persons contacted were required to provide estimated times of arrival at their assigned ~esponse facility, rather than having to actually report to that location. Offsite ERO's notification drill~ had been conducted on three occasions per procedur Records reviewed identified several concerns regarding the evaluation and* conduct of these notification drills. The criteria for evaluating a drill's success or failure did not include the timeliness of adequately staffing an EOF or a JPI Instead, the drills'
objectives were limited to the timeliness of completing the notification call tree and the ability to contact sufficient personnel to fill an EOF's "minimum staff" and "complete staff" positions..
Drill records indicated some problems with call tree implementation and some lack of documentation of estimated arrival times by persons implementing the call tree. There were apparent delays in submitting call records to corporate EP staff so that the drill~ could be eval~ated within a reasonable timeframe and*
issued within the 30 days required per procedure.
. *Records indicated that the June 1991 notification drill for the Mazon EOF shared by the Dresden, LaSalle County and Braidwood Stations was considered acceptable by the licensee, although about 47-minutes were needed to contact persons qualified for each.*
- "minimum staff" position and five of the six persons contacted indicated that their estimated arrival times were two to three*
hours after being notifie The December 1991 drill for the Byron Station's, EOF was also. -
considered to be acceptable. That drill's report indicated that the "minimum staff" would have ~rri~ed at the EOF within about two hours *after being notified, while the "complete staff" would have arrived within about four hour The draft evaluation report for the May 1992 notification drill for the Zion Station's EOF indicated that drill was unsµccessful due to problems in implementing the call tree. The inspectors noted that four of six persons, who were qualified to fill the
- EOF's "minimum staff" po~itions, estimated*theii arrivals as two to three ho~rs after being notifie *
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The inspectors' review ~f drill records indicated the -need for the*
following: additional training on implementing the call tree; more
- timely submittal of complete notification drill _records for evaluation; revision ofthe timeliness criterion for conducting a remedial drill; and reassessment of the ~rill's objective In
. addftion, corporate EP staff should ensure that each station's*
onsite ERO is informed of. the available time estimates for staffing their station's EO Further, drill records should be evaluated to determine the adequacy of the licensee's method for ensuring minimum staffirig of the applicable EOF in about one hour of the appropriate emergency declaratio The need to further review the licensee's provisions for timely staffing of its EOFs and its notification drills for ~ffsite ERO personnel will be track~d as Inspection Follow-up Item Nos. *
237/92022-01; 249/92022-01; 254/92019-01; 265/92019-bl; 295/92020-01; 304/92020-01; 373/92017-01~ 374/92017-01; 454/92014~01; 455/92014-01; 456/92016-01; and 457/92016-0 No violations or deviations were identified;.however, one inspection follow-up item was identifie EP Training Prbqram
. The EP training program for the Corporafe ERO was reviewed..
Corporate EP staff is responsible for providing training to personnel assigned to the EOF, the CEOF,,and the JPI The licensee's GSEP required an approved training. matrix and current lesson plans. However, the inspectors found that the licensee was not using an approved training matri In addition, the licensee was not using lesson plans. Since the lesson plans had become *
out-of-date and inaccurate, the EP trainers began training ERO members u~ing the position specific procedur * *
The licensee identified this concern and had all the training modules related to EOF and JPIC training rewritten by a contractor~ These new modules were well written and were excellent in scope and dept Prior to the end of the inspection, the lice~see provided the irispectors with a draft training matrix which was expected to be approve.d and should reflect the actual training given to ERO member The failure to use *an approved training matrix and current lesson plan, as required by the GSEP, appears to be in violation of NRC. *
requirement However, the licensee identified this violation and it is not being cited because the criteria specified in Section VII.B.l of the "General Statement of Policy and Procedures for NR Enforcement Actions," (Enforcement Policy, *10 CFR Part 2, Appendix C (1992)), were satisfie *
Corporate staff were responsible for providi~g initial and
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periodic requalification training to station and ~orporate-based personnel assigned to certain offsite radiological impact assessment positions in.the onsite and offsite EROs; Introductory, advanced and requalification training materials were revised and reformatted-earlier in 199 Persons responsible for tonducting the training had implemented effective administrative mechanisms for informing the stations' and corporate EP staffs of quarterly training-sessions and identifying persons needing and successfully completing the appropriate training modul One non-cited violation was identifie Audits Records review indicated that member~ of the Nuclear Quality Programs (NQP) Department conducted an audit of the corporate EP staff's activities in 1990 and 1991. Corporate EP staff were responsiv.e to the concerns identified during these audit Corporate staff utilized a contractor to conduct detailed audits of the quality of licensee's interfaces with state and local *
support organizations~ These audits included interviews with a
- number of offsite agencies' representatives plus records review. During 1991, such. audits were ~onducted for the Quad Cities and
. Zion Stations, as was described in subsequent NRC inspection reports for these sites. The contractor's 1992 audits of offsite interface were performed for the Dresden,.LaSalle County and
Braidwood Stations. The 1991 and 1992 audits had very good scope and depth and satisfied.the requirements of 10 CFR 5G.54(t}..
Records review and discussions with licensee staff indicated that items identified during the contractor's 1991 audits were tracked and addressed, and that the 1992 audits' findings would be handled in the same manne The licensee currently planned to have its contractor audit offsite interfaces.for the Byron Station.during 199.
No vi-0lations or deviations were id~ntifie Met~orologic~l Monitoring and Off~ite Dose Assessment Ongoing projects regarding the six stations' meteorological monitoring programs were discussed with an EP Supervisor and a representative of the licensee's meteorological ~ervices contractor~
- The contractor was in the midst of a study to determine the affects of recent building construction at the LaSalle Station on that site's meteorological sensors. The ltudy was scheduled for completion by October 1992. Preliminary results.indicated that onsite structures were ~ffecting so~e wind speed and direction measurem~nts. After review of the study, the licensee planned to meet with NRC staff to discuss the situation and possible trirre~tive actions~
The contractor was continuing the installation of heat lamps, whose heat energy would be directed at the wind sensors mounted on the six stations' meteorological tower The.heat lamp.
. installation project was scheduled for completion at all six stations by the Winter of 199 Plans were underway.to upgrade the lightning protettion equipment for the Braidwood Station's meteorological monitoring syste'! The l{censee continued to work with representatives -0f the Illinois Department of Nuclear Safety (IONS) and Illinois Power Company (IPC} to utilize MESOREM as a common offsite dose projection methodology. A committee has been formed to ensure that any model revisions would be properly coordinated, tested and documented prior to their implementatio The licensee has not yet completed all of its Nuclear Quality Programs (NQP}
Department's requirements in order to imp.lement MESORE The licensee may elect not to implement thh methodology until it has been revised to address the changes in 10 CFR Part 2. ~
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- -\\1 No violations or deviations were identifie.
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Public Information Program A review of records and disc~ssion with crignizant licensee staff indicated that the overall process of developing, reviewing and.*
annually distributing copies of theemergency information brochures to residences; businesses and public use f~cilities within the six nuclear stations' EPZs remairied adequate and largely unchanged in recerit year Improvements in recent yea.rs' editions of the brochures included the upgrading of their maps, increasing the brochures' physical.
dimensions and standardizing their text$ wherever possible~
A total o_f. about 350,000 copies of the six stations' brochures.
were printed_annually for distribution during the third calendar
- quarter. Electric utility customer mailing list~ were utilized for brochure mailings to residences and bulk deliveries were made to businesses and public use facilitie *
No violations or deviations were i~entifie.
Exit Interview The inspectors conducted an exit interview on July 29, 1992, with the licensee representatives.identified in S~ction The inspectors discussed the scope and preliminary findings of.the inspectio The licensee indicated that none of the matters di scus.sed were proprietary in natur