IR 05000295/1986007

Insp Repts 50-295/86-07 & 50-304/86-07 on 860324-27.No Violations Noted.Major Areas Inspected:Licensee Actions on Previously Identified Items Re Emergency Preparedness Program & Activation of Emergency Plan

ML20141J510
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/16/1986
From:	Allen T, Ploski T, Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141J480	List: IR 05000295/1986007 ML20141J476
References
50-295-86-07, 50-295-86-7, 50-304-86-07, 50-304-86-7, NUDOCS 8604280160
Download: ML20141J510 (14)

Text

f.-.

.

,

i 0.S. NUCLEAR REGULATORY COMMISSION REGION'III Reports No. 50-295/86007(DRSS); 50-304/86007(DRSS)

! Docket Nos. 50-295; 50-304 Licenses No. OPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 l Facility Name: Zion Nuclear Generating Station, Units 1 and 2 Inspection At: Zion Site, Zion, IL Inspection Conducted: March 24-27, 1986 i

s/- m

[8sy &j' .

Inspectors: T. Ploski Team Leader Date

"

T. Allen M/4/f6 (+

Date'

/ 'ot Approved By: W. Snell, Chi f

'

Emergency Prepardness Dat'e Section

,

Inspection Summary Inspection on March 24-27, 1986 (Reports No. 50-295/86007(DRSS);

No. 50-304/86007(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program: licensee actions on previously identified items; activation of the emergency plan; emergency detection and classification; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); dose assessment and calculation; and maintaining emergency preparednes Results: No violations of NRC requirements were identified during this inspectio l 8604280160 860418 .

l PDR ADOCK 05000295 j G PDR

- . . .. ._- _-- . . , - .

, 4

.. .

I i

l DETAILS 1. Persons Contacted

,

l *T. Rieck, Services Superintendent L *E. Fuerst, Production Superintendent

'

• Budowle, Assistant Superintendent Technical Services

• Kurth, Assistant Superintendent, Operations

• Stone, Quality Assurance Supervisor'

• Carnahan, Training Supervisor

• Schultz, Regulatory Assurance Supervisor

" Ballard, Quality Control Supervisor

• Nykiel, GSEP Coordinator

• Landrum, Training, Operations Group Leader L

• Cramer, Training, Support Group Leader i *L. Lanes, Lead Rad Chem Foreman l W. Otterson, Training Instructor G. Kassner, Health Physicist N. Laucas, Shift Engineer l T. Flowers, Shift Engineer l W. Demo, Shift Engineer .

, K. Bennett, Station Control Room Engineer t l

J. Madden, Station Control Room Engineer l B. Binggeli, Station Control Room Engineer D. Kent, Administrative Assistant, Training D. Capko, Training Instructor R. Leigh, Rad-Chem Foreman

, * Denotes those licensee personnel who attended the March 27, 1986 exit intervie . Licensee Actions on Previously Identified Items (Closed) Open Item No. 295/83009-10 and 304/83009-10: Develop a training l program for Shift Engineers (SEs) similar to that at the Dresden Station to provide adequate training on relevant emergency preparedness topic This item had remained open due to the licensee's inability to locate a copy of 1983 correspondence which described the current and planned emergency preparedness aspects of licensed operator training activities at the Zion Station. The licensee's 1985 emergency preparedness training efforts for Control Room personnel are described in Section 9 of this Inspection l Report. With the exception of the need to better document some training i activities, based on the training program discussed in Section 9, the inspectors concluded that these training efforts were adequate. Thus, the l need to locate the 1983 correspondence was no longer necessar This item is considered close (0 pen) Open Items Nos. 295/84010-01; 295/85008-01; 304/84010-01; and 304/85009-01: These items related to the need for the licensee to reevaluate specific Emergency Action Levels (EALs). The inspectors

,

determined that the licensee's task force effort to revise the EALs of i

- _ -. . . -_ _ ..

. ,

i l its PWR stations had progressed since the previous routine inspection; however, the revised Zion EALs were still undergoing onsite/offsite l review. These items will remain open until the revised EALs have been

approved by NRC staf t

!

,

(Closed) Open Item No. 295/85023-01 and 304/85024-01: The licensee must l ensure that Control Room personnel do not use instrumentation located on i

the ventilation panel for primary data when making protective action recommendations. The instrumentation referred to in this open item consisted of instantaneous wind speed and direction readouts. Based on walkthroughs with Control Room personnel as described in Sections 4 and 5 of this inspection report, the inspectors concluded that personnel had ,

been adequately trained to acquire time-averaged meteorological data using a Control Room computer terminal rather than obtaining instantaneous data from the wind speed and direction dial This item is considered close (Closed) Open Item No. 295/85023-02 and 304/85024-02: The July 1985 semi-annual shift augmentation must be repeated, and the results must be evaluated by the licensee. The inspectors reviewed the records of a remedial augmentation drill conducted in October 1985. Drill records were adequately detailed and included information on the Station Group Directors contacted; the times they were contacted; their estimated arrival times onsite; and the licensee's correct conclusion that the drill adequately demonstrated staff augmentation capabilities. This item is considered closed.

'

(0 pen) Open Items Nos. 295/86001-01; 295/86001-02; 304/86001-01; and 304/86001-02: These items were categorized as weaknesses oaserved during the February 1986 emergency preparedness exercise. As the licensee's proposed corrective actions on these items were not yet due for approval by NRC staff, these items will remain open pending a future inspectio (0 pen) Open Item No. 295/86001-03 and 304/86001-03: In a future exercise, the licensee must demonstrate the adequacy of communications equipment utilized by a containment air sample collection tea Th's item remains open pending successful demonstration of the revised communications equipment during such a sample collectio . Emergency Plan Activations The inspectors reviewed licensee and NRC records associated with all three emergency plan activations which occurred between July 19, 1985 and March 21, 1986. The inspectors concluded that all three events had been properly classified and that the NRC, Illinois Emergency Services and Disaster Agency (IESDA), Illinois Department of Nuclear Safety (IDNS),

and Wisconsin Department of Emergency Government-(WDEG) had all been initially notified in a timely manner following each emergency declaration and event termination. These conclusions were based on a review of the following sources of information: NRC Headquarters Duty Officer records; Zion Station EALs; Licensee Event Reports (LERs); Shift Engineer's Logs; and completed Nuclear Accident Reporting System (NAR5) form .. - ... . . _ .. .

.

.

,

t

. The following table summarizes information regarding the three declarations.

! Additional details'on the December 1985 Alert declaration are available in j Inspection Report No. 295/86001; No. 304/8600 .

GSEP ACTIVATIONS j, July 19, 1985 to March 21, 1986

'

State Agencies NRC l- Declaration Emergency' Initially Initially l Date Time Class Notified Notified

< 12/6/85 1530 Unusual Event 1530 1541 l

l 12/14/85 0410 Alert *

0417 i

2/19/86 2125 Unusual Event 2131 2144

-

"Due to static on the dedicated NARS telephone line, separate calls were made l to IESDA, IDNS, and WDEG between about 0410 and 0435 hours0.00503 days <br />0.121 hours <br />7.19246e-4 weeks <br />1.655175e-4 months <br />.

l~ Based on the above findings, this portion of the licensee's program was l adequate.

! Emeraency Detection and Classification (82201)

'

The' inspectors reviewed portions of the Generating Stations Emergency Plan l (GSEP), Zion Annex to the GSEP, Emergency Plan Implementing Procedures I (EPIPs), and other relevant procedures. Three walkthroughs were conducted ,

with teams of one SE and one Station Control Room Engineer (SCRE) and a  !

walkthrough with one Station Director (SD). These personnel were asked a series of questions relating to the GSEP and/or were presented with a scenario in order to ascertain their ability to properly detect and

classify an emergency; perform required offsite notifications; and make appropriate onsite and offsite protective action decisions. As Acting SD, the SE has responsibility for emergency classification and for making the required offsite notifications and protective action recommendations until l relieved by the SD. The SCRE, who is third in line of succession to the l' SE, acts as the Shift Technical Advisor with responsibilities for assisting the SE in diagnosing and evaluating abnormal conditions. Personnel were able to demonstrate adequate overall familiarity with the EALs, EPIPs, and GSEP during the walkthroughs. While there were no overall weaknesses detected during the walkthroughs, there were several inconsistencies in performanc Each Control Room team was asked the same general questions, given the same scenario, and encouraged to ask questions and to use available documents, i reference materials, and instrumentation for determination of conditions '

and response Nevertheless, one team used an incorrect sender code on the  ;

l l

l

!

L l 4 L

. _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ - - _ - _ - - _ _ _ _ - - _ _ _ _ _ _ - - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - - - - - _ _ _ _ _ _ - - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _

.

NARS when the emergency escalated from Alert to General Emergency and another team took considerable time before choosing the correct code. Two of the teams correctly classified the scenario event as a General Emergency, while one team classified the same conditions as a Site Area Emergency. An apparent contributing factor to the incorrect classification was the team's failure to use available instrumentation to collect ancillary data. Also, one team could not correctly state which facilities must be activated at the Alert level. Two teams did not use the Action and Notification Checklist of EPIP 110-1 for tracking actions. This nonuse of the checklist, which showed which facilities must be activated, was attributed to the checklist not being in EPIP 100-1, the Acting SD procedur The licensee was revising the Station's EALs and revision drafts were not reviewed by the inspectors. However, improvements needed for existing EALs were identified. In EPIP 330-1, Condition 12 (Plant Shutdown Functions) '

refers to "no core damage evident" for a Site Area Emergency classification.

l However, observable plant parameters and acceptable values were not f referenced to assist the classifier in the identification of core damage

! evidenc In the same procedure, for Condition 22 (Loss of Fission Product Barriers) the General Emergency EAL showed that at least 2000 R/ hour in l i

' containment and loss of two fission barriers must exist. In contrast, EAL Condition 23 (Radiation Releases from the Plant) listed a containment activity at least 2000 R/ hour as a single acceptable basis for declaration of a General Emergenc l Based on the above findings, this portion of the licensee's program was adequate; however, the following items should be considered for improvement:

• Upcoming emergency preparedness training for SEs and SCREs should emphasize proper notification codes; utilizing all available ;

information in classifying an event; and what facilities must be )

activated at different emergency classification '

The " Action and Notification Checklist" of EPIP 110-1 should be added to EPIP 100- * The Site Area Emergency EAL for Condition 12 should list example indicators of core damag * Criteria listed in the General Emergenc EALs for Conditions 22 and 23 should be consisten . Protective Action Decisionmaking (82202)

As Acting SD, the SE has the undelegatable responsibility and authority to issue offsite protective action recommendations until properly relieved by the 5 The SEs, SCREs, and 50 interviewed were aware of the responst-bility and the requirement to issue an offsite recommendation within about 15 minutes following any General Emergency declaration. During the walkthroughs, the Acting 50s and SD demonstrated the capabilities to make correct onsite protective action decisions, and to formulate an offsite recommendation. All Acting 50s properly utilized meteorological data from

. ,

the meteorology tower and demonstrated a working knowledge of applicable procedures used for determining the proper protective actio However, several experienced difficulty in formulating an appropriate offsite protective action recommendation for scenario conditions of General Emergenc One team stated that a recommendation was not applicable (as they felt the situation was a Site Area Emergency); another team correctly recommended evacuation of 0-2 miles radius and shelter 2-5 miles downwind; and the third team recommended evacuation of a radius from 0-5 miles and downwind three sectors from 5-10 miles. Some confusion resulted from the presence of undefined footnotes in th' EPIP's " Recommended Protective Actions" figur EPIPs 100-1 and 110 1 contained the GSEP's Figure 6.3-1

"Recoinmended Protective Actions." However, the EPIPs did not also contain footnotes used in GSEP Figure 6.3-1, that are instrumen',al in the correct use of the figure for determining recommendations. The footnotes associated with GSEP Figure 6.3-1 must be included in procedural guidance reproduced in EPIPs 100-1 and 110-1. This is an Open Item (No. 295/86007-01; No. 304/86007-01).

Two of the teams could not perform an evacuation time estimate for sectors that they recommended be evacuate A contributing factor to this short-coming is that GSEP evacuation time estimate data was not referenced in the appropriate EPIP In addition to the open item, the following item should be considered for improvement:

• Upcoming offsite protective action decisionmaking training for SEs and SCREs should emphasize procedural guidance on this topic and also indicate the location of evacuation time estimate data in the Zion Anne . Notifications and Communications (82203)

The Zion 5'ation provisions for accomplishing initial notifications to licensee personnel and to offsite governmental support organizations have been described in Section 6 of the GSEP and Zion Annex; in procedures for the Acting SD and for the 50 (EPIPs 100-1 and 110-1, respectively); and in the Emergency Communications Systems and Operational Tests procedure (EPIP 440-1). For notification of a GSEP activation at the Zion Station, the dedicated NARS has been the primary communications link to the IESDA, DNS, and the WDE In addition, the Station has provisions to utilize the dealcated National Warning System (NAWAS) to similarly notify appropriate local governmental agencies in Wisconsin. Should the dedicated communi-cations networks be inoperable, backup commercial telephone numbers for all appropriate offsite agencies have been provided in the GSEP Telephone Directory and in one or more of the above EPIP The inspectors reviewed reports of monthly and quarterly communications equipment tests conducted during the period July 1985 through March 1986, as well as the annual communications drill conducted on January 14, 198 With the exception of the Health Physics Network (HPN) telephone link, all tests were acceptable. Maintenance of the HPN is the responsibility of the NR This communications link is being phased out. In addition, a spot check of backup commercial phone numbers was mad All numbers checked were correc *

.

The inspectors were apprised that during March 1986 the GSEP coordinator had stapled a copy of an informal, single page "GSEP Callout Checklist" to each copy of the NARS forms kept in the Control Room and TSC. This one page form was a concise and helpful summary of the licensee and offsite support organizations to be notified of emergency plan activations in accordance with EPIPs 100-1, 110-1, 190-1, and 320-1. This checklist also included backup commercial telephone numbers for the offsite support organizations and had provisions for documenting the persons (and times) contacted. The GSEP Coordinator had properly informed the Training Department staff of the checklist so that all licensed personnel could be made aware of its avail-ability through licensed operator training sessions or required reading package A second innovation since the last routine inspection was the inclusion of an NRC Duty Officer's Checklist for Notification of Significant Event This checklist had been included in the Control Room's " Red Phone Call Log" and had the potential of improving communications from the Zion Station Control Room to the hRC Duty Officer. However, the Red Phone Call Log had two differing versions of the checklist: one version was current (per Information Notice 85-78), and a version was several years out-of-date (transmitted by Information Notice 81-03).

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

• Only copies of the current revision to the NRC Headquarters Duty Officer's Checklist for Notification of Significant Events should be available for reference at Emergency Notification System (ENS) tele-phone locations (Control Room, TSC).

7. Changes to the Emergency Preparedness Program (82204)

The GSEP Coordinator's onsite supervisor had been changed from the Assistant Superintendent for Administrative Services to the Supervisor of the Station's Regulatory Assurance G"oup. Since November 1985 the coordinator had also been appointed as the Station's Human Performance Evaluation Systems Coordinator, a newly created position in an INP0 program being implemented on a trial basis at the Zion Station. Program implemen-tation had actually begun in March 1986. The coordinator doubted that his counterparts at the licensee's other nuclear stations would eventually be assigned this additional duty simply because they were already GSEP Coordinators. While the coordinator understood that "GSEP Coordinator" would remain his primary duty, he was unable to estimate how much of his time would be devoted to his INP0 program dutie As indicated in Inspection Report No. 295/86001; No. 304/86001, the licensee was considering relocating a portion of the multi-room, Service Building Operational Support Center (OSC) due to remodeling activitie Although the remodeling was now nearly complete, a final decision on the location of the Service Building OSC had not yet been made. OSC supervisory personnel would likely remain in a small office on the 624-foot elevation; however, OSC technicians could either assemble in a newly created meeting room also on the 624-foot level, or could assemble in the new lunchroom on the 642-foot elevation. The licensee agreed to keep regional emergency preparedness staff informed on the OSC relocation issu . - _ _ _ _ .

.

The GSEP Coordinator indicated that Revision 5 to the Zion Annex had completed cnsite review in December 1985, and was undergoing offsite review prior to submittal to the NR Since the Station's revised EALs were still in the latter stages of onsite review, they would be submitted for NRC review separately from Revision 5 to the Zion Annex and prior to their implementatio Based on the above findings, this portion of the licensee's program was adequate; however, the following items should be considered for improvement:

• The GSEP Coordinator should be given the time and resources necessary so that the Station's emergency preparedness program would not deteriorate as a result of his additional INPO program responsibilit * All Acting SDs, SD, and OSC supervisors and technicians should be kept informed of all areas in the Service Building that would be utilized, on an interim or final basis, as OSC workspace following an appropriate emergency declaratio . Shift Staffing and Augmentation (82205)

The minimum shift staff, outlined in Figure 4.2-3 of Revision 5 to the GSEP met the criteria of Table 8-1 of NUREG-0654, Revision Augmentation of the onsite emergency organization has been accomplished via EPIP 320-1, which identified adequate numbers of qualified and trained individuals for the Station Group Director positions and for the technical, maintenance, and quality assurance staff EPIP 320-1 directed the Acting SD to notify the Security Supervisor of the classification and the EAL number and description; the Security Supervisor will then make the callouts per the procedure. The same procedure / revision also specified those directors who would, in turn, be responsible fo.a notifying their support staffs and the GSEP Coordinato The inspectors reviewed records of two augmentation drills conducted since the August 1985 inspection. The records of the October 1985 remedial drill and the January 1986 drill were adequately detailed and -included: the Station Group Directors contacted; the times they were contacted; and their estimated arrival times onsite. The drill records correctly concluded that the augmentation capabilities were adequately demonstrated. In both drills, one of every type of Station Group director was contacte However, the inspectors noted that the GSEP Callout Checklists used by the communicators (as well as the checklist found in EPIP 320-1, Revision 18)

incorrectly stated that, for any Alert, callout of the Security, Admini-strative, and Stores Directors was optional. This was contrary to Revision 5 to the generic GSEP which stated that one of each type of Group Station director must be called out for an Alert. The licensee must revise the GSEP Callout Checklist, as well as its source document (EPIP 320-1), in order to specify that every type of Station Group director must be called out for any Alert declaratio This is an Open Item (295/66007-02 and 304/86007-02).

_ __

____ - _

'

.

r The inspectors verified that the quarterly update to the callout list was done in a timely fashion for 1985 and the first quarter of 1986. However, two problems were noted. First, one of the commercial phone numbers for a director had been changed on or before October 25, 1985; the new number was incorrect and it had not been amended as of the first 1986 revisions to the GSEP Telephone Directory and EPIP 320-1. Second, from discussions with the GSEP Coordinator, there was no mechanism to make mid quarter corrections to any callout lists, including the informal "Callout Checklist" that the Coordinator had been generating for limited distribution to persons involved in actual callout The 1985 routine Emergency Preparedness inspection had, as an improvement item, that the callout phone numbers for the Rad-Chem Director and for the Communication Director be given higher priority on the callout lists. This had been done on the informal Callout Checklist, but not yet on its source document (EPIP 320-1).

In addition to the Open Item, the following it ms should be considered for improvement:

• Complete the callout prioritization in EPIP 320-1 as was begun in the informal GSEP Callout Checklis * More attention must be paid to the quarterly updates of phone numbers so that incorrect numbers are promplty correcte * A mechanism should be developed for updating the lists of personnel and telephone numbers in EPIP 320-1 and the informal Callout Checklist in between quarterly EPIP revision . Knowledge and Performance of Duties (Training) (82206)

The inspectors reviewed the Station's emergency preparedness training programs for licensed personnel and non-licensed personnel who have key roles in the onsite emergency organization. During annual license requal-ification training, operating shift personnel have received GSEP training on the following topics to enable them to fulfill Acting Station Director responsibilities as needed: purpose of the GSEP; EALs; NARs, NAWAS, and ENS communications systems for offsite notifications; protective action reconnendations; radioactive release rate calculation; and relevant EPIP In addition, some limited GSEP training was included about twice a year during simulator training; however, no formal records of this type of GSEP training have been made. The licensee committed, as of April 1986, to begin keeping formal records of GSEP training received during simulator training sessions. Training staff also stated that remedial training has, in the past, sometimes occurred following evaluations of the Station's responses to actual GSEP event However, not all such training had been documente .. .

.

.

,

Licensed personnel have been made aware of changes to the GSEP and EPIPs between annual training sessions per Training Instruction (TI)-093 which was essentially a required reading package issued at least 10 times a year to each licensed person onsite and senior plant management. Persons receiving these packages were required to return a signed form that acknowledged the information had been reviewe These packages also included new or revised procedures other than EPIPs, relevant IE Information Notices, and portions of publications such as Inside NRC. Administrative controls were in place to ensure that reading materials were reviewed by established deadline During 1985 the licensee's Production Training Center (PTC) issued 18 emergency preparedness training modules to increase the standardization of GSEP training conducted at each of its nuclear generating stations. The PTC also issued guidance regarding which modules were relevant to specific onsite emergency organization positions. At Zion Station, implementation of this PTC training program occurred in the second half of 1985. However, while the PTC's guidance indicated nine of the modules were applicable for SEs and persons in the line of succession to the SEs, the inspectors determined that appropriate individuals had been trained on only five of these nine modules. This apparently occurred based on an informal decision between licensed operator and emergency preparedness training staffs who sought to reduce the duplication of GSEP topics already covered in the existing licensed operator training program. The inspectors were satisfied, however, that onshif t personnel had been trained during 1985 on all relevant emergency preparedness topics, through a combination of the existing ifcensed operator training program, PTC modules, and required reading package Some Station Group directors were also licensed, and therefore, had completed the required reading packages which included emergency preparedness materials. The PTC's standardized training program also included modules for individual ofrector positions and guidance on what other broader scope modules were also required annual training for specific directors. A spot check of training records indicated that non-licensed Station Group directors had been trained on appropriate PTC modules during 1985. However, the inspectors concluded that, sometime af ter the July 1984 routine inspection and the implementation of the PTC standardized modules during 1985, the annual required reading of all (changed or unchanged)

relevant EPIPs had become less formal. Greater reliance had been placed on PTC modules to adequately cover each director's responsibilities. The

'

inspectors had understood from previous discussions with PTC staff and training staffs at several of the licensee's other stations that the PTC modules and station-specific EPIPs were both meant to be included in the annual training of key personnel. At Zion, however, Training Department staff were unable to produce documentation that all Station Group directors had been trained during 1985 on all station-specific EPIPs that were relevant to their positions, either by required reading or by inclusion in PTC module presentation The licensee committed to ensure annual GSEP training for all Station Group directors would include appropriate PTC I

.. .. .-- . . - - . . .- - . . . _ . . .-

'

,

'* >

,

,

i l

l

[  ;

standardized modules plus station-specific EPIPs relevant to each director .

position. The inspectors were also advised that the position-specific EPIPs would remain annual required training for all directors, whether or not a director would be allowed to take a test (every other year) on

! relevant PTC modules in lieu of attending training sessions on those module The inspectors made a selective review of lesson plans and training records for the Fire Brigade and for the First Aid and Rescue team The First Aid lesson plan utilized " Multimedia Standard First Aid" lesson plans from the American Red Cross, dated 1982. The training included two film Additionally, the teams received instruction per lesson plan LPBI-7, which

,

included training on Self-Contained Breathing Apparatus (SCBA), handling l charged hose,' rope and knots, etc.

! i At the time of inspection, training per lesson plan LPBI-8 had been given to the Fire Brigade, the First Aid'and Rescue team, Rad Chem Technicians, and all operating department personnel except Nuclear Station Operators, t

The training matrix was to be revised in 1986 so that NS0s will also receive rescue training. A spot check of the person / position training matrix indicated that appropriate personnel had received the training.

I In addition to the two commitments described in this section of the report, the following items should be considered for improvement: ,

• The licensee should document corrective actions taken, such as remedial training, as a result of internal evaluations of the Station's responses to actual GSEP event ,

• The Training Department should formally document how annual GSEP training given SEs, and persons in the line of succession to the SEs, will be completed using PTC modules and existing licensed operator training progra * Annual training on relevant EPIPs should be a requirement whether or not an individual passes a test on relevant PTC module . Dose Assessment and Calculation (82207) . +

The license's dose calculation and assessment methodologies were reviewed, ,

as contained on Environmental Director (ED-series) procedures, copies of which were maintained in the TSC and E0F. Topics addressed in the procedures includeo: quantifying gaseous and liquid release rates; estimating source terms from field measurements; and acquiring current and forecast meteorological information. Methodologies ranged from rapid, conservative estimates employing gross activity source terms and worst-case meteorology to models accommodating nuclide-specific source terms and real- ,

time meteorology, with options available for plume tracking and lake breeze effect Computerized models could be run using the Station's computer or .

a computer at the licensee's corporate office The licensee's dose  !

calculation methodologies wlR1 be reviewed for technical adequacy in  ;

greater detail during a future appraisa l

11  !

!

. . _ _ _ . . _ _ ___ _ _ _ __ _ _ _ _- _ - _ ______ _ _ _ _ _-_- --_ ___ - ___ __ _ _______ _ ____ -

a '.

,

The inspectors conducted a walkthrough with an ED and determined that the TSC's dose calculation computer equipment was operable and could be used to access the Station or corporate office's compute The individual was proficient in operating the computer equipment and was readily able to interpret system outputs of meteorological and offsite dose projection data, and could also relate offsite dose projections to procedural guidance on protective action recommendation Based on the above findings, this purtion of the licensee's program was adequat . Licensee Audits (82210)

The inspectors examined Quality Assurance (QA) Department records of independent audits and surveillances of the Station's emergency preparedness program which occurred since March 1985. The annual onsite audit was conducted in April and May 1985 by QA personnel based at the Zion Station. Audit records indicated what corrective actions would be taken on the one negative finding. Auditor followup actions to ensure those actions had been implemented were alsu adequately documented. The annual offsite audit was conducted during September 1985 by QA personnel not based at Zion Station. No negative items were fuentified, and records of both audits were complete and readily availabl Audit reference documents included the emergency plan, its implementing procedures, the Station's technical specifications, and previous internal audit report Both audits satisfied the regulatory requirements of 10 CFR 50.54(t)

regarding audit frequency and scop The inspectors reviewed records of the four emergency preparedness surveillances performed since March 1985, and discussed surveillance efforts with the Station's QA Superviso All surveillance records were complete, readily available, and specific regarding what aspects of program activities had been observed by the auditor Two surveillances dealt with the 1985 and 1986 exercises. One surveillance addressed operational and onsite radiation protecticn concerns associated with an emergency plan activation. The fourth surveillance was the observation of the December 1985 environmental monitoring drill. The inspectors noted that drill and exercise surveillances dealt mainly with participant performance, although the QA Supervisor indicated that an auditor attended the exercise critique While the surveillance report of the environmental monitorirg drill indicated no corrective actions were deemed appropriate, the GSEP Coordinator's drill records included some negative critique items and noted that corrective actions were being considered for several item Drill and exercise surveillance records did not indicate that the auditors had also addressed the tracking of corrective actions on critique item The QA Supervisor indicated his staff would continue using actual GSEP events and emergency preparedness drills and exercises as surveillance topic _ _ _ _ _ _ _ _ . _ _ . - _ _ _ __ - _ - _ __ ____ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _

. _ - . .

.. . .

.

p .

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

• In addition to observing drills and exercises as surveillances of the emergency preparedness program, auditors should alsc evaluate critiques of these events and monitor corrective actions being taken as a result of these critique . Maintaining Emergency Preparedness The inspectors reviewed records of 1985 and first quarter 1986 emergency prtparedness drills. All drills were conducted on schedule and critiqued in accordance with regulatory requirements and emergency plan commitment Drill records were adequately detailed and included documentation of corrective actions.in progress or completed. A complete 1986 drill

, schedule was also reviewe The inspectors examined records associated with annual offsite agencies'

training and discussed this effort with the CSEP Coordinator. The 1985 media briefing occurred in early March 1985. The 1986 media briefing was not yet scheduled. Site access and personal radiation protection topics were incitded in training associated with the annual medical drill that took pl". in September 1965. The annual offsite agency meeting and optional plant tour took place in October 1985. Records of these events included a listing of invited organizations, responses from some of these organizations, an agenda, and an attendee sign-in sheet. Agenda topics included emergency classes, example EALs, offsite notification provisions, State agency emergency roles, and the identification of a local library where NRC inspection. reports were kep The inspectors examined records of emergency equipment inventories performed since July 1985 and determined that all had been completed per the requirements of EPIPs 550-2 through 550-6, with two minor exceptions related to EPIP 550-2 and an environmental monitoring kit. The procedure stated that the Radiation Chemistry Foreman was responsible for having any missing or defective items repaired or replaced "as soon as possible."

A physical examination of one kit revealed one of its two onsite maps was nissing, as had been identified in a December 1985 inventory. Records of two inventories done in June and September 1985 indicated a plastic container identified as missing in the June inventory was not replaced until the September inventory. The inspectors concluded that Station personnel had been considering it satisfactory to replace items identified as missing at any time prior to or during the next inventory rather than

"as soon as possible."

The inspectors determined that the dedicated GSEP Van used by er"'.ons teams was stored indoors at the Station to better ensure it and 16 gasoline and battery powered equipment would be operable in cold weathe The licensee indicated that the van and environs kits would eventually be kept in a heated garage under construction onsite, i

13 I i

!

_]

. ,__-__ - -

,- .

.

Based on the above findings, this portion of the licensee's program was adequate; however, the following items should t>e considered for improvement:

• A topic for a future annual offsite support agency meeting should be the QA audits of the emergency preparedness program, and how audit findings regarding the adequacy of interface with offsite groups are made available to these group I i

• Items identified as missing or defective during emergency supplies inventories should be promptly replace '

13. Exit Interview The inspectors met with licensee representatives identified in Section 1 on March 27, 1986 to discuss the preliminary inspection findings. The licensee agreed to consider the items discussed and made two commitments regarding training, as described in Section 9 of this report. The licensee indicated that none of the matters discussed were proprietary in nature.

'

>

I

,

14 0 ~