IR 05000254/1986017

Insp Repts 50-254/86-17 & 50-265/86-17 on 861117-21.No Violations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Emergency Plan Activities, Dose Calculation & Assessment & Public Info Program

ML20215B833
Person / Time
Site:	Quad Cities
Issue date:	12/03/1986
From:	Allen T, Patterson J, Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20215B817	List: IR 05000254/1986017 ML20215B814
References
50-254-86-17, 50-265-86-17, NUDOCS 8612120336
Download: ML20215B833 (9)

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U.S. NUCLEAR REGULATORY COMMISSION .

REGION III

Reports No. 50-254/86017(DRSS); 50-265/86017(DRSS)

Docket Nos. 50-254; 50-265 Licenses No. DRP-29; DRP-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Quad Cities Nuclear Generating Station, Units 1 and 2 Inspection At: Quad Cities Station, Cordova, Illinois Inspection Conducted: November 17-21, 1986

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Inspectors: T. A n 53'k /t/1/frc, Lead Inspector Date

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J.jatterson j3 /g Date Ls) Eh N. William n ie/3/s c Date Approved By:

L William Snell, Chief 12/s/a Emergency Preparedness Date Section Inspect. ion Summary Inspection on November 17-21, 1986 (Reports No. 50-254/86017(DRSS);

No. 50-265/86017(DRSS))

Areas Inspected: Routine, unannounced inspecticn of the Quad Cities Station's emergency preparedness program: emergency plan activations; dose calculation and assessment; public information program; and operational status of the emergency preparedness program. Portions of the program inspected for operational status included: emergency plan and implementing procedures; emergency facilities, equipment, instrumentation and supplies; organization and management control; training, and independent reviews and audits. The inspection was conducted by three NRC inspectors and one consultan Results: No violations of NRC requirements were identified during this inspectio PDR ADOCK 05000254 G PDR

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DETAILS Persons Contacted Commonwealth Edison Company

• R. Bax, Station Manager

• T. Tamlyn, Production Superintendent

• Robey, Services Superintendent

• Spedl, Assistant Superintendent, Technical Services

• VanPelt, Assistant Superintendent, Maintenance

• Gibson, Quality Assurance Supervisor

• Norton, Quality Assurance Engineer

• C, Brown, GSEP Coordinator

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• Schnell, Emergency Planner, Corporate F. Geiger, Assistant Superintendent, Work Planning J. Schnitzmeyer, Staff Assistant J. Sirvoy, Rad / Chem Supervisor P. Behrens, Lead Chemist S. Horvath, Lead Health Physicist G. Powell, Health Physicist G. Klone, Shift Engineer (SE) 2 D. McCarthy, SE R. Thompson, SE J. Stortz, Shift Foreman J. Guest, Station Control Room Engineer (SCRE)

F. Niziolek, SCRE J. Neal, Training Supervisor W. Graham, Principal Instructor M. Curtis, Rad / Chem Technician (RCT)

M. DeVault, RCT D. Edwards, RCT D. Kallenbach, RCT R. Buss, Document Control Non-Commonwealth Edison Personnel N. Frederiksen, RN, Trauma Center, Moline Public Hospital

• Indicated those attending the November- 21, 1986 exit meetin . Emergency Plan Activations

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The inspector reviewed and evaluated documents related to six emergency plan activations which occurred between February 1 and October 10, 1986; plus one occurrence on August 16, 1984. The documents reviewed included:

Licensee Event Reports (LERs); Control Room Logs; Nuclear Accident Reporting System (NARS) forms; licensee event worksheets; arid NRC Headquarters Duty Officer records. The inspector determined that the licensee had correctly evaluated.and classified the seven Unusual Events. The licensee had completed required notifications to responsible

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State and local government agencies and the NRC within the required time periods following each emergency declaration. Followup notification were also completed in a timely manner after a significant change in the event and each event termination. The inspector reviewed other LERs and did not find any plant conditions which warranted emergency plan activation. Open Items No. 245/860XX-01, No. 265/840XX-08, No. 265/860XX-01, No. 265/860XX-02, No. 265/860XX-03, and No. 265/860XX-04 are close Based on the above findings, this portion of the licensee's program was acceptabl . Dose Calculations and Assessment (82207)

The licensee's dose calculation and assessment methodologies were reviewed as contained in Emergency Plan (QEP) and Environmental Director (ED)

procedures. The procedures provided instructions for: quantifying gaseous and liquid release rates; changing release locations from ground level to stack elevation; estimating source terms from field measurements; acquiring current and forecast meteorological data; and incorporating offsite dose assessments into offsite protective action recommendations. Methodologies ranged from rapid, conservative estimates employing gross activity source terms and worst-case meteorology to models accommodating specific radionuclide source terms and real time onsite meteorology. Appropriate equipment and decisional aids were available in the TSC and EO Satisfactory operability checks of the TSC equipment and aids were conducte Effluent monitoring data was presented to two Environs Directors (EDs)

for dose calculation and assessment. The EDs were unable to complete the dose assessment in a timely manner using the TSC computer termina Although correct results were obtained, telephone calls for assistance, frequent procedure checks, and program restarts delayed results longer than 15 minutes. Personnel responsible for conducting dose calculations and assessment should be able to get results within 10 minutes. This is an Open Item (No. 254/86017-01 and No. 265/87017-01).

One of the EDs did not understand the effect on dose results of changing a meteorological input parameter such as wind speed. An understanding of the effect of input parameter changes could help operators recognize a program or data input error. Furthermore, one ED did not know if the calculated dose results were dose rates or cumulative doses, which should be understood for protective action consideration In addition to the above open item, the following item should be considered for improvement:

• EDs should be provided training sufficient for an understanding of the effect on dose calculations of parameter input changes and for a clear understanding of the results.

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4. Public Information Program (82209)

The licensee had an emergency information booklet distributed in September and October 1986, to all residents, businesses, and to areas where transient personnel might be, such as parks and campgrounds. The booklet included a map of the 10 mile Emergency Planning Zone (EPZ)

evacuation routes and evacuation centers, identification of local broadcast stations used to disseminate information during an emergency, and basic warning information for a plant emergency. However, there was no point of contact phone number listed in the booklet for information from the licensee. -The address to write for information from the licensee was listed and a phone number was listed for each county in the EPZ. A postcard was included with each booklet for obtaining additional information through the Illinois Emergency Services Disaster Agenc The booklets were prepared and issued by the licensee's corporate offic There was no documentation to show that the Station had exercised their responsibility to review the booklet for correctness prior to annual distributio Based on the above findings this portion of the licensee's program was acceptable; however, the following items should be considered for improvement:

• The Station should document the annual review of the information booklet and any changes requeste . Emergency Plan and Implementing Procedures (82701)

The inspectors reviewed portions of the Generating Stations Emergency Plan (GSEP), Quad Cities Annex to the GSEP, Emergency Plan Implementing Procedures (QEPs), and other relevant procedure documents. The Annex and QEPs were consistent with the program requirements and guidance of the current GSEP. However, some QEP tables and charts were not very readable, so users referred to the Annex or GSEP for clarity. For example, GSEP Figure 6.3-1, " Recommended Protective Actions," was in a two page foldout figure in the GSEP, but the same table in QEP 310 and 350 was difficult, if not impossible, to read as a single page without complete footnote The licensee's provisions for preparing, internal reviewing, and distributing changes to the Quad Cities Annex to the GSEP and QEPs, were reviewed and appeared to be adequate. The inspector randomly selected several recent QEP changes and determined that the established preparation, review, and distribution procedures had been followed for the change The changes had the proper management approval and were distributed to the NRC within 30 days after approva The inspectors determined that adequate quantities of the current revision of the GSEP, Annex, and QEPs were maintained in the licensee's Control Room, TSC, and E0 t

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Based on the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvement:

• The_QEP figures which were reduced from full size GSEP figures should be enlarged as necessary to ensure readability and completenes . Emergency Facility, Equipment, Instrumentation and Supplies (82701)

An inspector reviewed reports of monthly, quarterly, and annual communication systems tests and drills and observed the communication drill of November 18, 1986. The tests and drills had been conducted in accordance with regulatory requirements and licensee commitments. The tests and drills were adequately documented and corrective action appeared to have been taken in a timely manner when neede Inspectors examined records of emergency equipment and supply inventories performed during the last eighteen months and determined that all inventories specified in QEPs had been completed on schedule and were adequately documented and that inventory deficiencies were corrected within reasonable time periods. The inspectors conducted spot checks of inventory quantities specified in QEPs against the quantities present at the TSC, OSC, E0F, and Moline Public Hospital. It was noticed that inventory lists were not available with the TSC and OSC emergency supplies. Readily accessible inventory lists can be useful for personnel needing supplies during an emergenc Adequate supplies of appropriate technical manuals, Station procedures, and status boards were available in the TSC, OSC, and EOF. However, locating vendor and system technical manuals at the TSC appeared to be difficult because there was no master index of available manual Based on the above findings, this portion of the licensee's program was accept.able; however, the following items should be considered for improvement:

• An inventory list should be posted with or near emergency supplies to aid users in determining what supplies are availabl * An index of vendor and technical manuals available at the TSC should be develope . Organization and Management Control (82701)

Six changes had been made to the licensee's emergency organization or management control structure during 1986. The changes included a new Station Manager, GSEP Coordinator, and several superintendents. The changes appear to have been conducted with reasonable turnovers, appropriately experienced personnel, and with Individuals who understood Emergency Preparedness (EP) goals, priorities, and functional EP responsibilitie None of the individuals in new positions had been assigned EP respcnsibilities for which they were not trained or qualified.

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However, the staff changes may have resulted in some decrease in EP program effectiveness. For example, the GSEP Coordinator's review of Station GSEP events had decreased from a fairly thorough review two years ago to no review by the new Coordinator. The GSEP Coordinator should promptly review records generated by the station during a GSEP event to ensure the completeness and accuracy of records, correctness of actions, timeliness of offsite notifications, and to initiate corrective action if warrante The review of GSEP events will be followed as an Open Item (No. 254/86017-02 and No. 265/86017-02).

The new GSEP Coordinator was retained in his previous position within the Rad / Chem Group for supervision and administrative purposes. Thus, the Coordinator had about five levels of lead and supervisory personnel between himself and management at a level sufficient to assure responsible, prompt, and effective EP program suppoi In addition to the open item, the following item should be considered for improvement:

• Provide an organizational pathway for direct communication between the GSEP Coordinator and a level of management sufficient to assure adequate support for EP concern . Training (82701)

The inspectors reviewed the Station's emergency preparedness (EP) training I program for licensed and non-licensed personnel who had key roles in the onsite emergency organization and concluded that there had been no substantive change since the licensee's training program for EP was

! inspected in March 1986. Some cross training had been recently completed for emergency organization directors such as Rad / Chem Directors, Environs Directors, and Technical Director The cross-training consisted of a reading list because the personnel were qualifying for EP positions for which they already had appropriate experienc About fourteen training records for persons assigned to key emergency response positions were checked and each record was complete and up to date. The review found that several Group Director positions required completion of i.he annual training between November 26 and December 26, 198 Four lesson plans, including three for emergency positions responsible for protective action recommendations, were reviewed. The lesson plans appeared to provide meaningful instruction and guidance and when supplemented with drill and exercise practice would adequately qualify individuals for the emergency position. Offsite training to County, State, and local support agencies in radiation protection and safety had been provided by onsite personnel on an annual basis. The last session was held in October 1985 and the next session was scheduled for December 198 Cross-training had been conducted between local fire districts and the station's fire brigad Several offsite support organizations were contacted and they expressed satisfaction with the training sessions and general support provided by the license . _ _ _ _ _ _ _ _ _ _ _

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Environmental monitoring, health physics, assembly and accountability, offsite augmentation and medical drills had been conducted on the required annual or semi-annual schedule. Training for the GSEP Coordinator was specified in QEP 520-3 and an inspector verified that the new Coordinator was completing the required trainin The inspector observed that, contrary to GSEP Section 8.2, Control Room (CR) personnel had not received the required semi-annual training related to immediate Acting Station Director duties. This failure to complete required training was discovered by the licensee during a quality assurance audit in late October 1986. A senior licensee representative stated that the QEP 520-1 training procedure would be revised to require a semi-annual training and the training of CR personnel would be completed by December 31, 198 Since this failure to conduct required training in accordance with the licensee's Emergency Plan was self identified and also because prompt and effective corrective action was committed, no enforcement action was taken by the NRC. However, the completion of the corrective actions will be followed as an Open Item (No. 254/86017-03 and No. 265/86017-03).

Walkthroughs or interviews were conducted with approximately 20 licensee personnel designated as qualified for emergency response position of:

Recovery Manager, Station Director, Shift Engineer (SE), Station Control Room Engineer (SCRE), Shift Foreman (SF), Technical Director, OSC Director, Environs Director, Rad / Chem Director, and Rad / Chem Technicians (RCTs).

The interviewees, in general, demonstrated an adequate understanding of the purpose of the emergency plan, the levels of emergency classification, and their emergency response duties and authority. They demonstrated the use of appropriate procedures and that they understood the interface and communication responsibilities of their position The SEs, SCREs, SF and Station Directors demonstrated very good familiarity with the GSEP, Quad Cities Annex, QEPs, EALs and notification equipment and forms. They were presented conditions requiring an understanding of all four levels of classification. The teams of SEs and SCRE/SFs correctly classified the events presented and demonstrated the capability to function as a tea They also demonstrated the capability to make prompt and correct onsite protective action decisions and to formulate offsite protective recommendation They utilized meteorology data and evacuation time projections in determining the proper action. It was clear that they understood tne responsibilities of the SE as Acting Station Director and the SE had the ultimate responsibility for declaring an emergency and the responsibility and authority to issue offsite protective action recommendation Some of the SE/SCRE/SF team members indicated that table-top practice team training on the use of EALs, QEPs, and decisionmaking aids related to their immediate emergency response duties would be beneficial. A similar request for hands-on training was expressed by most other personnel interviewed. At the exit interview the licensee indicated that practice training sessions were already being planned and agreed to complete the first round of table-top training sessions for Group Directors by March 31, 198 . _ . .

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During the walkthroughs with Contral Room personnel, the SCRE usually took on the tasks of completing the NARS forms, helping with communications, and other administrative duties. The SCRE should assure that he/she is i properly performing the duties of Station Technical Assistant and observing I indicators and evaluating data to determine plant status rather than I becoming tied up in administrative work. A quality assurance audit in July identified this same concer The Rad / Chem and Environs Directors demonstrated adequate knowledge and capabilities during the walkthroughs, except for the slowness in completing offsite dose calculations (See Section 3 for related Open Item).

RCTs demonstrated an adequate understanding of their emergency response duties, where to report, exposure limits and guidance for emergencies, and the different alarms used to signal emergencies. They were familiar with emergency equipment kit locaticns and use of the kit equipment. The walkthroughs showed that the RCTs did not adequately understand the precedural differences between the emergency collection of air samples onsite and the collection of offsite air samples. The RCTs stated that QEP 330-6 which specifies an air sample time of 1 to 5 minutes, was in error and that a 30 cubic foot sample would be collected. The RCTs responsible for collecting emergency air samples should know the correct sample collection procedures. This is an Open Item (No. 254/86017-04 and No. 265/86017-04). Also, one RCT indicated that an air sample reading greater than about 70 mr/hr would be useless for counting, but a health physicist reported that samples measuring several hundred mr/hr could be analyze During the review of emergency equipment at the Moline Public Hospital, the inspectors noticed that the hospital emergency staff did not know the location of the personnel exposure monitoring equipment supplied by the licensee. The hospital emergency staff should know the location of emergency equipment they might need in case a licensee representative

did not arrive at the hospital in time to assist with preparation In addition to the above open items, the following items should be considered for improvement:

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• SCRE/ STAS should be instructed to ensure that they complete their assigned responsibilities regarding plant safety evaluations and avoid becoming involved in administrative duties during GSEP events and exercise * Instruct RCTs regarding the upper limit on radiation level for an acceptable air sampl * Inform appropriate medical assistance personnel of the location of emergency equipmen _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

.. Independent-Reviews / Audits (82701)

The inspector reviewed the records of the Quality Assurance (QA) Department audits and surveillances of the Station's emergency preparedness program conducted since May 1985. The inspector found that audits were done on a regular basis; annually by the onsite QA staff and semi-annually by the offsite staf Surveillances were required only annually, but had been accomplished more frequently. The audit records appeared to be complete and were readily available for revie The QA staff reports directly to Corporate Headquarters and thus is independent from onsite management contro Onsite Audits QAA 04-85-19 and QAA 04-86-26 and offsite Audit 12-86-11 were adequate in scope and depth as related to the regulatory requiremer.ts of 10 CFR 50.54(t). The adequacy of the Station's interface with offs!te support agencies was addressed in a number of audit questions. The failure to conduct required training of Control Roor personnel, discussed in Section 9 above, was identified during QAA 04-86-26 audit of October 28-31, 198 The inspector conducted a thorough review of the QAS 4-86-217, August 1986, surveillance of the licensee's 1986 emergency preparedness exercise. The surveillance report appeared to be thorough and to have covered most aspects of the exercise. This surveillance contained a recommendation that the STA/SCRE more closely follow defined duties and not become involved with forms and notifications, which is similar to the inspection improvement item presented in Section The QA program for followup on findings and recommendations appeared to be adequate for assuring that corrective action was taken and reported within reasonable times. A report of action taken or planned was required in 30 days, and the QA Department conducted a followup within 90 days to evaluate the effectiveness of action take Based on the above findings, this portion of the licensee's program was acceptabl . Exit Interview The inspectors met with licensee representatives identified in Section 1 on November 21, 1986 to discuss the preliminary inspection findings. The licensee indicated that action would be taken to correct the open items discussed and that the improvement items would be carefully considere The licensee stated that none of the material discussed was proprietary in natur . _ - - - . . - - .-. -- - .-. .