IR 05000237/1999001

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Insp Repts 50-237/99-01 & 50-249/99-01 on 990111-15.No Violations Noted.Major Areas Inspected:Reviewed EP Program, Aspect of Plant Support
ML17191B221
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 01/28/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17191B220 List:
References
50-237-99-01, 50-237-99-1, 50-249-99-01, 50-249-99-1, NUDOCS 9902030252
Download: ML17191B221 (12)
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Text

U.S. NUCLEAR REGULATORY COMMISSION Docket Nos:

License Nos:

Report Nos:

Licensee:

Facility:

Location:

Dates:

Inspectors:

Approved by:

9902030252 990128 PDR ADOCK 05000237 G

PDR REGION Ill 50-237; 50-249 DPR-19; DPR-25 50-237199001 (DRS); 50-249/99001 (DRS)

Commonwealth.Edison Company (ComEd)

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Dresden Nuclear Station, Units 2 and 3 6500 N. Dresden Road Morris, IL 60450 January 11 - 15, 1999 Donald E. Funk Jr., Emergency Preparedness Analyst Robert Jickling, Emergency Preparedness Analyst James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

  • EXECUTIVE SUMMARY Dresden Nuclear Station, Units 2 & 3 NRC Inspection Reports 50-237/99001; 50-249/99001 This inspection reviewed the Emergency Preparedness (EP) program, an aspect of Plant Support. The inspectors selectively evaluated the quality of the EP program, related au.dits and reviews, reviewed the effectiveness of management controls, verified the adequacy of emergency response facilities and equipment, reviewed EP training and qualification activities, and included follow-up on a previous inspection finding. This was an announced inspection conducted by two regional inspector *

Overall, the EP program was in an effective state of operational readines Management support to the program was strong, and interviewed key emergency response personnel demonstrated a good working knowledge of responsibilities and emergency procedures. (X1)

Emergency response facilities, equipment, and supplies were well-maintaine Demonstration of selected emergency response equipment verified that the equipment Was operable. The implementation of the augmentation drill process did not effectively demonstrate the capability to augment the onshift staff in a short period of tim (Section P2.1)

The emergency implementing procedures reviewed were clear and easy to use. The Nuclear Tracking System was an effective method to track and close EP issue (Section P3)

The EP training program appeared effective. Interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedures. A number of plant departments appeared to have few, if any, staff fully qualified for respiratory protection ready to respond in the event of an emergenc (Section PS)

Management support for the program appeared strong as indicated by the successful implementation of a number of program upgrades. The EP trainer position had been filled after a six month vacancy, putting the organization back in line with all other ComEd EP programs. (Section P6)

. The licensee's 1998 Site Quality and Safety Assessment EP program audit and 1998 EP Self-Assessment Report were effective in identifying a number of issues and satisfying the requirements of 1 O CFR 50.54(t). (Section P7)

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Report Details IV. Plant Support P2 Status of EP Facilities, Equipment, and Resources P2. 1 Material Condition of Emergency Response Facilities (ERFs) Inspection Scope (82701)

The inspectors evaluated the material condition of the control room, Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations Facility (EOF)

and the Generating Stations Emergency Plan (GSEP) "barn" and vans. Field monitoring kits were also inspected. The licensee demonstrated the operability of numerous pieces of emergency response equipment, including radiological survey instruments, dose assessment and plant data computer terminals, portable generators, GSEP vans, and communications equipment. Records of periodic inventories and equipment tests were also reviewe Observations and Findings Emergency Response Facilities Material Condition The control room was in a good state of operational readiness. Current Emergency Plan Implementing Procedures (EPIP) were ready and available. The emergency notification system phone was verified operable, and cellular phones were connected to battery chargers and ready to use. The offsite agency notification fax machine was

. energized and available. The licensee provided an efficient demonstration of the dose assessment software on the control room compute During inspection of the ERFs, the inspectors identified that the Emergency Response Facilities Telephone Directory was not current. Also, the latest revision of EPIPs and the first quarter 1999 Augmentation Telephone List were not available in the Mazon EOF. The licensee provided effective immediate response and corrected these items by determining why the most recent revisions were not in place and then replacing the old revisions with the appropriate document The OSC, TSC, and GSEP "barn" were well-maintained. The licensee provided

. demonstrations of the portable generators, GSEP vans, dose assessment computers, and plant data computer The licensee was in the process of changing the layout and floorplan of the TSC. One wall had been removed which significantly increased the usable area and should promote improved communications in the facility. An upgrade of the facility status boards was also being considered. Completion of the TSC upgrade-was currently scheduled for the end of February 1999. All equipment inspected, which included

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phones, dose assessment programs, computers, emergency lights, copy machines, radios, and the facility's microphone and speakers system, were available and operable, even during the TSC modification Prompt alert and notification siren records for 1997 and 1998 were reviewed by the inspectors. Annual operability for 1997 was 98.3 percent with 96.8 percent for the lowest month's average. The 1998 annual operability average was 98.8 percent with 97.7 percent for the lowest month's average. Siren operability exceeded the acceptability limit of an average of 90 percent functional over a 12 month perio Offshift Notification Response Drill The inspectors reviewed records for the semi-annual augmentation drills. Two drills had been conducted.since the last routine NRC inspection, June 27, and September 28, 1998. The June 27 drill was strictly a call-out to document estimated onsite arrival times with no actual travel to the station. The September 28 drill was conducted as part of the annual exercise to demonstrate actual response time to the station. The acceptance criteria, as documented in Emergency Preparedness Maintenance Procedure (EPMP) 0100-04, Revision 5, GSEP Activation Notifications Test states, "This test will be considered acceptable if both minimum staffing and augmented staffing are considered acceptable." Both drills were considered as acceptable by the license Section 8.3.2.7 Offshift Station Augmentation Drill of the station's emergency plan stated that "this drill shall serve to demonstrate the capability to augment the onshift staff in a short period after declaration of an emergency." While the licensee's emergency plan did not specifically define "a short period" it noted the NRC definition, which is 30 and 60 minutes. The licensee's emergency plan provided for minimum staffing requirements for the TSC, CEOF and EOF, as described in Section 4. However, the allowance for a minimum staffing assumes that remaining Directors/Managers and personnel will arrive within a short period of time. The emergency plan further noted, 'The TSC staff will be augmented as determined by the classification of emergency. Guidance for these staffing requirements is given on Table 4.4-3."

Table 4.4-3 Guidance for Augmentation of the Station Emergency Response Organization within 60 minutes provided the numbers of personnel needed for each of the four emergency classifications. The EPMP 0100-04 provided two sets of acceptable criteria, one for minimum staffing of less than 60 minutes but not greater than 75 minutes,.and one for augmented staffing of less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> but not greater than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The relevance of this issue is that augmentation personnel are more critically needed early on in the emergency rather than later so that the entire onsite emergency response burden is not placed on the four minimum responders in the TS Consequently, the inspectors determined that the augmentation drill process did not effectively demonstrate the capability to augment the onshift staff in a short period after declaration of an emergency as required in Section 8.3.2.7 of the emergency pla Implementation of the semi-annual augmentation drills to demonstrate the capability to

augment the onshift staff in a short period after declaration of an emergency will be tracked as an Inspection Followup Item (IFI 50-237/99001-01; 50-249/99001-01(DRS)).

The licensee provided a response to the IFI stating that the emergency plan does not commit to demonstrate implementation of Table 4.4-3 and that the augmentation drill is not a demonstration of their ability to implement this table. The licensee provided several justifications:

The table is guidance only. There may be emergencies where it is justified to have more or less people called in to respond depending on the nature of the emergenc *

Certain personnel on the call list are bargaining unit personnel. It would be a violation of the bargaining unit agreement to call these individuals unless there was a bona fide emergency. *

The GSEP plan discussed on page 4-3 that the time-frames outlined in Table 4.4-3 are goals rather than rigid inviolable requirements. Testing of goals is impracticabl Finally, the licensee said that the Dresden EP staff wrote a different criteria into EPMP 0100-04, the procedure used for augmentation drills. This procedure stated that the

"augmented staff' should be completed within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to be acceptable. It also allowed the Emergency Preparedness Coordinator (EPC) to use discretion in evaluating the drill if "augmented staff' was completed in greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> but less than 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> The term "augmented staffing" was used by the EPC in this procedure to differentiate it from minimum staffing. The licensee said that a better term would have been "full or complete staffing" and that it was not intended to be a direct correlation to the staffing levels identified in Table 4.4-3. The licensee further stated that the purpose of this second criteria was to evaluate the effectiveness of the augmentation process (i:e.,

does the process work in a timely manner for everyone, not just minimum staff). The augmentation drill calls out 33 people while only 12 are required by Table 4.4-3.at an Alert. Therefore, 21 of these people are not 60 minute responders. This extra.criteria was added by the licensee to ensure that the call process worke Prior to the conclusion of the inspection the licensee provided the inspectors with additional information that the criteria discussed above of greater than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> but less than 3 hour~ had been removed from the procedure. This was done because its purpose was not clear and was inconsistent with the way the rest of the company was evalµating augmentation drill Corporate EP personnel also provided information that a similar concern was identified in a self-assessment conducted at another ComEd site. A technologically enhanced system has been contracted and is currently beirig tested which when implemented will result in a consistent activation process and augmentation drill procedure for all ComEd operating sites.

  • * Inventory Records Inventory records of emergency equipment arid supplies for the first thru fourth quarter fiscal year 1998Jwere reviewed.. Licensee procedure EPMP 0100-02 Revision 9, Equipment lnventorv, stated that these inventories shall be conducted at least.once per quarter. The inspector's review determined that all inventory records were completed as required within the appropriate timefram Conclusions Overall, emergency facilities, equipment, and supplies were well-maintained. The licensee rapidly responded to correct some documentation problems. All emergency equipment demonstrated was verified operable. The prompt alert and notification system sirens were well-maintained. Records of periodic tests and drills reviewed were detailed and complete. The implementation of the augmentation drill process did not effectively demonstrate the capability to augment the onshift staff in a short period of tim P3 EP Procedures and Documentation Inspection Scope (82701)

The inspector reviewed a selection of licensee em.ergency plan implementing procedures (EPIPs). Additionally, t~e Dresden Nuclear Tracking System (NTS) was reviewe Observations and Findings The inspectors reviewed Corporate EPIP 3101-01, "Environmental Sample Collection Procedures", revision 14, dated May 15, 1998. The procedure was concise and technically adequate. A previous review of the snow sampling portion of the procedure, revision 12, in Byron inspection report 98002 commented that in section 8.g, it called upon the user to record sampling location and other details in the "comments" section of the attached sampling form but the attached form lacked a "comments" section. This issue had been corrected in the current revisio The inspectors also reviewed the following EPIPs with no significant problems in

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content, format, or revisions identified: EPIP 0100-01, "Acting Station Director,"

revision 10, dated December 23, 1998; EPIP 0160-01, "OSC Director," revision 5, dated August 4, 1997; EPIP 0200-01, "Classification of GSEP Conditions," revision 4, dated July 20, 1997; EPIP 0200-TI, "Dresden Station Hot Initiating Conditions," revision 11, dated August 17, 1998 and EPIP 0500-01, "Recovery Operations," revision 3, dated July 22, 199 The inspector reviewed the NTS (the process that the EP group used to identify, track, and close EP issues) to determine the range of issues identified and the effectiveness of tracking and disposition of the identified issues. The items reviewed were clearly identified by number and description. Cognizant management and responsible

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persons, due dates, and item status were also listed. Seven of the 33 items reviewed on the NTS list were open, which correlated appropriately with a separate open NTS item listin Conclusions The EPIPs reviewed were clear and easy to use. The NTS was an effective method to track and document closure of EP issues. No problems were identified in the documents reviewe PS Staff Training and Qualification in EP Inspection Scope (82701)

The inspector reviewed various aspects of the licensee's training program. The reviews included interviews with selected key emergency response organization (ERO)

personnel including a Station Director, Nuclear Accident Reporting System (NARS)

Communicator, Acting Station Director, and a Radiation Protection Technician, and reviews of attendance records and the First Quarter GSEP Augmentation Telephone List, Revision 0. Respirator and Self-Contained Breathing Apparatus (SCBA)

qualifications of plant personnel were also reviewe Observations* and Findings Interviews with four emergency response personnel indicated appropriate knowledge of procedures and emergency responsibilities. The Station Director effectively demonstrated knowledge of the NRC's incident response program. During the interviews, personnel commented on the responsiveness of the EP group and its open *

attitude regarding questions and concern Records indicated that training was appropriately documented and training and*drills were provided formal feedback opportunity. Training records were compared with the First Quarter GSEP Augmentation Telephone List to verify ERO personnel listed on the call list were qualified. All ERO personnel reviewed were currently qualified for their emergency response position Review of respirator and SCBA qualification documentation provided the following information:

ti DEPARTMENT NUMBER OF TRAINING/MEDICAL RESPIRATOR SCBA QUALIFIED INDIVIDUALS QUALIFIED QUALIFIED Radiation Protection

65/60

9 Operations 135 120/122 102 101 Instrument Maintenance

48/47

1 Electrical Maintenance

52/45

0 Mechanical Maintenance 134 112/102

0 Chemistry

23/19

0 Welders

20/15

0 NRC Information Notice 98-20, "Problems With Emergency Preparedness Respiratory Protection Programs," was issued June 3, 1998. This information notice alerted~

licensees to multiple generic weaknesses in respiratory protection programs supporting emergency preparedness. Respiratory protection qualifications included three parts; respiratory training,. medical testing, and a mask fit. The numbers represented the current respiratory qualifications by department and included supervisors, technicians, schedulers, and planners. The information outlined in the above chart indicated that some departments have few, if any, staff fully qualified for respiratory protection ready to respond in the event of an emergency. Discussions indicated that licensee personnel were aware of the Information Notice and were evaluating its informatio Conclusions Overall, EP training appeared effective. Competent knowledge of emergency responsibilities and procedures was demonstrated by selected ERO personnel. All personnel reviewed listed on the current call-out telephone list were qualified. for their emergency response positions. A number of plant departments appeared to have few, if any, staff fully qualified for respiratory protection ready to respond in the event of an emergenc P6 EP Organization and Administration The 'EP organization had been modified since the last inspection. As of July 1998, the EP Coordinator reports to the Radiation Protection Manager, who in tum reports directly to the Station Manager. The position of EP trainer had been filled after a six month vacancy which has put the organizational structure back in line with all other ComEd EP programs. Currently, management support for the program appeared to be strong as indicated by a number of program upgrades such as the TSC remolding, ERF status boards and filling the EP trainer position vacanc *

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. Quality Assurance in EP Activities Inspection Scope (82701)

The inspectors reviewed the Quality and Safety Assessment (Q&SA) Emergency Planning Audit report QAA ComEd 98-03, dated May 15, 1998. The review included an interview with the plant support lead auditor. Also reviewed was the August 17 - 19, 1998 Emergency Preparedness Program Self-Assessment report, conducted by corporate, Byron, and Dresden EP personnel, and the "Review of EP self-assessments performed at the other ComEd stations" Report Number 237-251-97-0580 Observations and Findings During the period of March 2 to May 5, 1998, a Q&SA audit of EP was performed at ComEd's Nuclear Power Stations and the Corporate Office. The audit was conducted to meet Code of Federal Regulations 10 CFR 50.54(t) requirements. Adequacy of the program and effectiveness of implementation was evaluated. Additionally, portions of the Radiological Environmental Monitoring Program and the use of the Off-Site Dose

. Calculation Manual were,reviewed during the Q&SA audit. Two Level Ill findings were identified at Dresden regarding potassium iodide (Kl) tablets not being stored properly with regard to environmental conditions and regarding improper storage and indexing of quality record The corrective actions reviewed by the inspectors included removing the Kl tablets from the GSEP vans, properly storing and replacing the affected bottles, and revising site specific procedures EPIP 155-01. and EPMP 0100-02 requiring issuance of Kl from the TSC. Corporate EPIP 3005-01 was also revised to consider the special storage requirements of Kl. Corrective actions regarding the indexing and storage of EP quality records included the indexing of EP active files in accordance with Dresden Administrative Procedure 02-03 and storage of the quality records in fire-rated cabinets. These corrective actions were timely and appeared to be sufficient to: correct the problems as well as prevent possible recurrenc Conclusions The licensee's 1998 Q&SA EP program audit and 1998 EP program self-assessment were effective in identifying problems. The audit satisfied the requirements of 10 CFR 50.54(t) to evaluate and document the adequacy of offsite interface with the State and local agencies. The audit and EP program self-assessment were of good scope and depth. Identified issues were appropriately identified, tracked, effectively corrected, and.closed in a timely manne PB Miscellaneous EP Issues P (Closed) Inspection Followup Item No. 50-237197014-01: 50-249/97014-01: During the 1997 emergency exercise the scenario incorrectly interpreted the basis for an Alert emergency action level (EAL). Correctiv.e actions included revising EALs (MU6, MA6

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and MS6) to eliminate the term "non-alarming compensatory indications." This clarified these EALs such that they are less subjective when using. The Dresden GSEP annex and EPIP 200-T1 were also revised to reflect these changes. This item is close V. Management Meeting X1

  • Exit Meeting Summary The inspector presented the inspection results to licensee management at the conclusion of the onsite inspection on January 15, 1999. The licensee acknowledged the findings presented. Overall, the EP program was in an effective state of operational readines Management support to the program was strong, and interviewed key emergency response personnel demonstrated a good working knowledge of responsibilities and emergency procedure The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie,,

PARTIAL LIST OF PERSONS CONTACTED Licensee L. Aldrich, Radiation Protection Manager R. Kelly, NRC Coordinator H. Oclon, EP Coordinator W. Rakes, EP Trainer R. Rysner, Plant Support Lead Auditor, Q & SA F. Spangenberg, Regulatory Assurance Manager

  • P. Swafford, Station Manager M. Vonk, EP Director B. Dixon, Resident Inspector K. Reimer, Senior Resident Inspector D. Roth, Resident Inspector INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program Opened 50-237;249/99001-01 Closed 50-237;249/97014-01 ITEMS OPENED, CLOSED, AND DISCUSSED IFI IFI Implementation of the semi-annual augmentation drills to demonstrate the ~pability to augment the onshift staff in a short period after declaration of an emergenc Dresden exercise related to tracking licensee actions to clarify the Alert EAL basis for loss of control room annunciators.

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