IR 05000295/1987007

Insp Repts 50-295/87-07 & 50-304/87-09 on 870622-26.No Violations,Deviations or Deficiencies Noted.Major Areas Inspected:Emergency Preparedness Exercise.Rev 7 to Federal Field Exercise 2 Objectives Encl

ML20235V888
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	07/13/1987
From:	Christoffer G, Hironori Peterson, Petterson J, Ploski T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235V806	List: IR 05000295/1987007 ML20235V803
References
50-295-87-07, 50-295-87-7, 50-304-87-09, 50-304-87-9, NUDOCS 8707230338
Download: ML20235V888 (23)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/87007(DRSS); 50-304/87009(DRSS)

Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Zion Nuclear Generating Station, Units 1 and 2 Inspection At: Zion site, Zion, Illinois Inspection Conducted: June 22-26, 1987 Insnectors: nuvM7 '

3 7 Thomas J. Ploski Date '

Team Leader

. l{. uit b 7 /0fy G. M. Christoffer 6h Date adffun JWfnes P. Patter Date 7/o/17

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//deifftch h);1r Hitonori Pete'rson 0"'f/0f&

t Dath ll_) e$ 2/0/33 Marcia J. Smith / Date ~

Approved By: /4) a ~7 3/B 7 Wifliam Snell, Chief Date Emergency Preparedness Section Inspection Summary Inspection on June 22-26, 1987 (Reports No. 50-295/87007(DRSS); i No. 50-304/87009(ORSS)) l Areas Inspected: Routine, announced inspection of June 23 activities during the Zion Station's emergency preparedness exercise, involving observations by nine NRC representatives of key functions and locations during the exercis The inspection involved six NRC inspectors and three consultant Results: No violations, deviations, or deficiencies were identified during the inspectio PDR ADOCK 05000295 G PDR

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DETAILS l

- I 1. Persons Contacted j NRC Observers and Areas Observed T. Ploski, Control Room (CR), Technical Support Center (TSC),

Emergency Operations Facility (EOF)

J. Jamison, CR, Operational Support Center (OSC) and Inplant Teams F. McManus, TSC M. Smith, TSC, EOF H. Peterson, OSC and Inplant Teams W. Snell, EOF G. Christoffer, Joint Public Information Center (JPIC)

J. Patterson, Corporate Command Center (CCC)

G. Stoetzel, Offsite Radiological Monitoring Team Commonwealth Edison W. Worden, Chief Controller T. Rieck, Services Superintendent J. Golden, Supervisor of Emergency Planning T. Blackmon, Emergency Planning Supervisor A. Nykiel, GSEP Coordinator R. Mika, Lead CR Controller L. Holden, Lead TSC Controller D. Finch, OSC Controller M. DiPonzio, EOF Controller M. Carnahan, EOF Controller K. Licari, Lead JPIC Controller R. Landrum, Shift Engineer K. Moser, Station Control Room Engineer R. Thornton, Shift Foreman G. Trzyna, Rad Chem Supervisor W. Kurth, Assistant Superintendent, Operations T. Broccolo, Assistant To Assistant Superintendent, Operations P. Zwilling, Chemist M. Finney, Rad Protection Foreman P. LeBlond, Licensing Staff R. Principe, Assistant ALARA Coordinator J. Brandes, Training Instructor M. Berlin, Corporate Emergency Planner J. Barr, Emergency Planning Supervisor G. Denenberg, Quality Assurance Engineer L. Oberembt, Quality Assurance Engineer The above persons attended the June 26, 1987 exit intervie __ __ . _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ -

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l Licensee Action on Previously Identified Items

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(Closed) Item 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 and revise specific Emergency Action Levels (EALs) for the Zion Station. In late 1986, the licensee submitted for NRC review a substantially revised set of Zion Station EALs, which Region III staff, with contractor assistance, evaluated versus the guidance in NUREG-0654, Revision 1. During the period January - April 1987, the licensee resolved all the staff's concerns on the proposed EAls, including those !

which had been tracked as the aforementioned Open Items. The approved 1 Zion Station EALs have been issued as Emergency-Plan Implementing Procedure (EPIP) 330-1, Revision 1. These items are close ]

l (Closed) Item Nos. 295/86001-01 and 304/86001-01: During the 1986 !

exercise, the licensee failed to demonstrate the exercise objective of notifying the NRC Operations Center within one hour of the initial emergency classification. As indicated in Paragraph 5.a and 5.b of this l report, the NRC Operations Center was adequately notified of emergency

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classifications by Control Room and Technical Support Center (TSC)

staff This item is close (Closed) Items No. 295/86001-02 and No. 304/86001-02: During the 1986 exercise, excessive time was taken to declare the Emergency Operations Facility (E0F) fully operational and in command of emergency response <

activitie As indicated in Paragraph 5.f of this report, EOF activation was adequately demonstrated during the 1987 exercis This item is close . General An exercise of the licensee's Generating Stations Emergency Plan (GSEP)

was conducted at the Zion Station on June 23-25, 198 The licensee's exercise was integrated with a test of the Federal Radiological Emergency Response Plan (FRERP), and the radiological emergency plans of the States of Illinois and Wisconsin, Lake County (Illinois), and Kenosha County (Wisconsin). This was a full participation exercise for both States and both counties. The exercise te.sted the licensee's and offsite support organization's capabilities to respond to a hypothetical accident scenario involving a simulated radiological release to the environmen This report addresses the activities of the licensee's emergency response organization on June 23 of the FRERP Field Exercise (FFE-2). The attachment to this report dc3cribes the licensee's exercise objectives and the accident scenario for June 23 of the FF ___ - ___

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4. General Observations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the GSEP, Zion Annex to the GSEP, and the emergency plan implementing procedures of the licensee's onsite and offsite emergency organizations, i l Licensee Response The licensee's response was coordinated, orderly, and timely. Had these events been real, the actions taken by the licensee would have been sufficient to allow State and local authorities to take appropriate actions to protect the public health and safety, Observers Licensee observers monitored and critiqued exercise activities on June 23 along with nine NRC observers and a number of Federal Emergency Management Agency (FEMA) observer FEMA observations on the June 23 responses of State and local governmental agencies will be documented in a separate report. In addition, over 80 controller / evaluators monitored the entire FFE-2. The overall evaluation of FFE-2 will be documented in a " lessons learned" report to be issued later this yea Exercise Critiques The licensee held critiques following the exercis The NRC critique was conducted on June 26, 1987 at the Zion Station's Emergency Operations Facility (EOF). A joint public critique was held in Waukegan, Illinois later that day to present the preliminary onsite and offsite findings for the June 23 exercise activities, as made by the NRC and FEMA observers, respectivel . Specific Observations Control Room The Shift Engineer (SE) and Station Control Room Engineer (SCRE)

demonstrated good proficiency in using relevant Emergency Plan Implementing Procedures (EPIPs), Technical Specifications, and Abnormal Operating Procedures. The SE correctly classified abnormal plant conditions which warranted Unusual Event and Alert declarations. The associated initial notification calls to Illinois, Wisconsin, Kenosha County, and the NRC Operations Center were all completed in a timely and accurate manner through the use of dedicated communications equipment. Notification information was adequately documented. The Station's emergency organization was also initially notified and activated following both emergency declarations in accordance with procedure _

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Shortly after the Alert declaration, the individual who wou~1d soon function as Station Director (50) in the Technical Support Center (TSC) arrived in the Control' Room at about the same time as the NRC Resident Inspectors. The SE gave an adequately detailed initial briefing to these persons regarding the chronology of scenario events and associated emergency response efforts. The onsite Emergency Response Facilities (ERFs).and the Corporate Command Center (CCC) were activated after the Alert declaration. Control Room personnel were informed when these facilities reached fully operational status and when the TSC's SD had assumed overal command and control of onsite activitie The SE and SCRE utilized a computer terminal to trend critical plant parameters and to acquire onsite meteorological data. A communicator arrived to relieve them of offsite agency communications responsibilities so that they could better focus their attention on changing plant condition At first, this individual did not appear to have been trained for his intended role. The SCRE gave him some terse instructions while allowing him to function as the Emergency Notification System (ENS) communicator. The individual's trformance improved as the exercise progressed, and was adequate by toe time the offsite communications responsibilities were transferred from the Control Roo Based on the above findings, this portion of the licensee's program is acceptabl b. Technical Support Center (TSC)

The TSC was fully staffed and operational within 45 minutes after the Alert declaration. TSC staff efficiently established and maintained adequate communications lines with the licensee's other ERFs, the NRC's Operations Center and Incident Response Center, and with appropriate State and county emergency response center Due to the existence of multiple abnormal plant conditions, the SD and CCC Director conservatively elected to activate the Emergency Operations Facility (EOF) about one hour prior to the Site Area Emergency (SAE) declaration, which would have necessitated E0F activatio The Station and CCC Directors then made the correct and conservative decision to declare a SAE due to the existence of several distinct plant conditions which each warranted an Alert declaration, plus the high probability that containment radiation levels would justify a SAE declaration within an hour. All initial offsite notifications for the SAE declaration were adequately complete TSC and CCC staff formulated an offsite protective action recommendation for the SAE in accordance with procedure guidance and did not dispute the States' decisions to implement more conservative protective action The simulated assembly and accountability of all onsite personnel was promptly ordered after the SAE declaratio TSC staff chose the correct evacuation route for nonessentf=1 onsite personnel based on meteorological consideration _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

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Throughout the exercise, the TSC staff did a good job in monitoring

.the availability of and repair efforts on various plant system Appropriate directors carefully evaluated the' potential consequences before placing the Residual Heat Removal system in the recirculation mode. Offsite dose projections were adequately generated prior to the release. The SD moderated frequent status briefings involving all his directors, which served to establish common priorities on activities as well as keeping all TSC staff adequately informed of scenario events and major decisions made onsite and offsit Adequately detailed logs were maintained for each director to permit reconstruction of their activitie The SD's log was very detailed and was kept by a staff advisor who also monitored the EPIPs for applicability to the changing scenario condition However, the SD's log was kept on separate sheets of pape Internal message flow was adequate in the TS Status board information was generally accurate and timel Status board information was promptly typed, with copies of the typed information being distributed to each directo Critical plant parameters were trended on a computerized display located behind the SD's workstation for easy referenc NRC Site Team personnel and representatives from the Illinois Department of Nuclear Safety (IDNS) arrived in the TSC between about 9:45 to 10:15 a.m. TSC staff interfaced adequately with these groups during the exercise. The initial briefing given to the Site Team.in the.TSC was thorough and accurat An actual shift change of key TSC staff was adequately demonstrated after the EOF staff had assumed lead responsibility for the licensee's response effort Based on the above findings, this portion of the licensee's program is acceptable; however, the following item shall be considered for improvement:

• The SD's log should be kept in a bound recordboo c. Operational Support Center (OSC) and Inplant Teams Facility activation was timely. Dedicated communications lines were quickly established with the Control Room and the TSC. The OSC Director typically manned these telephones in addition to his other duties. At times, he could have benefited from more help with the telephones from other supervisory personnel at his workstatio The OSC Supervisor maintained an adequately detailed log of OSC activitie In contrast, status boards in the OSC were generally maintained too casually. The variuus status boards were not always kept up to date, while erroneous information sometimes found on the status boards was not always corrected after discovery. For example, the Events Update status board in the teams' staging area was not updated after 10:40 a.m., and did not even indicate that a J

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I General Emergency had been declared some minutes earlie A flip chart was used to list which technicians had been assigned to certain inplant teams. On one occasion, the same person was listed as a member of two inplant teams. On several occasions, certain status boards, such as the plant equiprsent status board, were not updated for several hour Teams were briefed to varying extents on inplant radiation levels they might encounter upon leaving the OSC are A Radiological Survey status board was available, but was not effectively utilized in these briefings as its summary information was usually incomplete or out of date. Greater reliance was placed on the review of radiation survey sheets completed by returning inplant team i

"ALARA photos" of various plant areas and equipment were available, '

but were not consistently used when briefing inplant team Plant layout maps and Area Radiation Monitor (ARM) data could also have  ;

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been utilized to better brief the teams on potential radiation hazards along their inplant routes and to help determine the optimum routes to minimize worker exposure l The decision to simulate relocation of the OSC should have been made soone Procedural provisions called for facility relocation if its radiation levels reached about 100 mR/hr. However, radiation levels on the order of 10 mR/hr had existed since late morning, with levels increasing to about 50 mR/hr for several hours prior to the simulated relocation Facility relocation was eventually ordered when radiation levels in the OSC increased to about 90 mR/hr, with further increases expecte A frisker station had been established at one of the entrances to the OSC work area. It was eventually ignored, probably due to the higher than normal background readings present in the general area by late morning. OSC habitability surveys were periodically done and were adequate to characterize the simulated radiological conditions in the OSC are OSC supervisory personnel did a good job in tracking the simulated exposures to OSC personnel. As the exercise progressed, concern was expressed about some persons' accumulated exposures approaching the administrative limits that had been established. Despite the inconsistencies in the quality of the radiation protection briefings given to inplant teams and the tardy decision to finally relocate the OSC to an area having lower radiation levels, no OSC staff received simulated exposures in excess of administrative or regulatory limit Proceduralized "05C Task Assignment" forms were utilized as a checklist when briefing an inplant team; to document the topics addressed in the briefing and the results of the team's activities; and to indicate whether the team had been debriefed. Although these forms were used throughout the exercise, they were not always

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y filled out correctl For example, the form listed twelve possible p items to be covered in a briefing, with provisions to indicate is whether or not the topic had been addressed or was not applicabl Not all of the checklists contained an entry for each of the twelve 1 item While the form included provisions for a " task number" and a j time entry, this information was not always complete Also, it was unclear whether the time entry corresponded to the time ,

of the briefing or the time that a team left the OS The " task l number" system apparently was not being tracke i A shift change of some OSC supervisory personnel was adequately demonstrated during the exercise. Both teams of supervisory personnel demonstrated an intimate knowledge of inplant areas, i equipment locations, and relevant procedures, j Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

• The OSC Director should have more assistance in maintaining open, dedicated communications lines with other ERF * All OSC status boards should be kept up to dat Any erroneous

' information should be promptly correcte * "ALARA photos," plant layout drawings, and ARM data should be consistently used when briefing inplant teams in order to improve the likelihood of minimizing the teams exposure * The licensee should consider basing a decision to relocate the OSC based on accumulated exposures to persons remaining in the facility versus current radiation level * "05C Task Assignment" forms should be properly completed in order to provide a more complete record of the briefings, debriefings, and the results of work attempted by inplant teams, d. High Radiation Sampling System (HRSS1 Early in the exercise, an inspector observed the collection and analysis of a reactor coolant sampl Later, the collection and analysis of a containment air sample was observe An HRSS team was dispatched to collect a RCS Iiquid santple prior to the OSC becoming fully operational. A post-accident sample was requested after the Alert declaration. The team of two Radiation Chemistry Technicians (RCTs) assembled in the isad Protection Office The team displayed good coordination in reviewing their procedures and assembling their equipment. There was ccasiderable delay in organizing and eventually dispatching the team to the HRSS campling

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i room. The delay was due to the complaints \of an RCT, not associated with the HRSS team, about demonstrating thd use of protective clothing and Self Contained Breathing Apparatus (SCBA) when collecting an HRSS sample. The matter was eventually settled by a forema The team adequately demonstrated the use of protective clothing and SCBA's. The team also demonstrated good use of remote communications equipment throughout the sampling while wearing SCBA' The team was organized so that one RCT entered the HRSS Room and drew the liquid sample at the Liquid Sampling Panel (LSP), while the l second RCT performed as the procedure reader and control panel operator outside the HRSS Room. Radiation monitoring and exposure control by the HRSS team was generally good. The procedure reader conducted periodic habitability surveys and directed radiological control step The RCT taking the sample monitored the LSP at required and appropriate times. He also displayed good ALARA practices while sampling the LSP while purging. Appropriate tools were used and the sample was properly transported using a lead pig and a dumb waiter. Throughout the sample and analysis, the RCT's also demonstrated adequate contamination contro The use of the procedure was generally adequat The procedure reader would check off, on the space provided, each step at it was completed. However, it became apparent that the reader was blindly following the steps without recognizing the reason for the step For example, one procedural step (10 d), instructed the reader to go to Step 12g if panel pressure on a gauge is greater than 1000 ps The RCT recorded 2000 psi and proceeded to and performed Step 10g instead of Step 12g. The RCT opened Valve IXCV-PW-786, which is required to line up flushing water to the LSP. .The RCT did not realize his mistake or action even though the previous Step 10d noted that by going to Step 12g the flushing portion of the procedure is to be eliminated. Step 12g instructed the operator to disconnect the flush hose between OPW-300 and 1PW-30 The RCT began giving the directions to the other RCT to continue in the procedure, when this action was noticed by the NRC evaluator as being odd and who instructed the RCT to stop and review the procedure. It was pointed out to the RCT that he had performed the wrong step and he was instructed to rectify the mistake. The Valve IXCV-PW-786 was reclosed and the sampling recommenced at the correct procedural ste The improper opening of this valve did not pose an immediate danger, for two inline Valves OPW-300 and IPW-301 would had to have been opened to create any path from the flushing water to the sampling system. Nevertheless, the lack of awareness and failure to comprehend and follow procedural steps during sample collection is an Open Item (50-295/87007-01; 50-304/87009-01).

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After the procedural correction the post-accident sample collection

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proceeded without further mishaps. The analysis portion of the -

sample was conducted- by a chemist in the chemistry lab. The f", performances in preparing and counting the RCS liquid sample was adequate. However, in the counting room, counting procedure

.(ZCP-711-5) was not available for reference. Also, a non player was assisting in setting up the equipmen This same individual later assisted in preparing the equipment and counting the containment ~ air sample, i

The containment Air' Sampling Panel (CASP) team'was dispatched to

. collect a post-accident Containment Air Sample (CAS) at approximately 11:00 a.m. The team, consisting of two RCT's, again-

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assembled at the Rad Protection office to obtain the procedure and to perform their briefing and equipment checks prior to samplin This demonstrated a lack of ALARA awareness, for'the office was by now in a 70 mR/hr field. Prior to dispatching the CASP team, the OSC was fully operational. The CASP team should have briefed

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and organized necessary procedure and equipment at the OSC or at least staged their actions.in an area with a lower radiation fiel The team did exhibit good use of their procedure and coordination of their actions. The CASP facilities are located in two remote locations on different levels and.thereby requires reliable voice communications equipment. The team demonstrated effective use o sound powered telephones between the two remote. locations. Also, throughout the sampling, the team dr.monstrated good professionalis '

Adequate contamination control. practices were also demonstrated with

'the' exception of taking the lead pig (with a sample reading 35 mR/hr

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on contact), into the OSC area and leaving it next to the entrance-of the team staging room. If it was necessary to bring the sample to the OSC, due to higher radiation levels in the Aux Building's counting room, the pig should have been placed in an area out of the -

way of OSC activities. Instead it was located in a highly congested area and was left unattende [

The CAS in the lead pig was later transferred to the back-up counting equipment room called the PARAPS. When the RCT with the sample. arrived at the PARAPS Room, the same individual (non player)

who was at the counting room for the RSC liquid sample was already in the room setting up the detector and computer system. This non player assisted the RCT in analyzing the sample. The RCT and the non-player did not demonstrate good familiarity with the mechanicttof counting the iodine cartridge. They first removed the cartridge out of its plastic container which is.used for contamination control. Believing that the cartridge was to be removed fr.)m the plastic container, they placed the cartridge in the holder. The cartridge then fell through the hole in the holder and dropped in the detector plenum. (The cartridge is to be counted within the plastic container.) They were also unaware that they

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were counting it upside down, as the flow inlet side is to be facing the detector. The team's unfamiliarity with how to properly mount the sample cartridge in the PARAPS room's counting equipment is an Open Item (295/87007-02 and 304/87009-02). ,

There was a lack of adequate tools to facilitate the sample analysis. There were no tongs to handle a hot sample, so the RCT found a pair of needle nose pliers. This made it difficult to hcndle the sample, and eventually they used their hands. In sunmary, the following poor ALARA practices exhibited by the CASP team together also constitute an Open Item (295/87007-03 and 304/67009-03):

• Conducting procedure review and equipment check activities in an elevated radiation field;

• Leaving a lead pig, with a sample having an elevated contact dose rate, unattended in a congested work area; and

• In the counting room, handling a simulated hot sample without the use of tools to reduce personal exposur Finally, there was no approved PARAPS procedure. There was only a procedure that was not numbered or documented. It was only a computer printout of instructions. There must be approved procedures for use of the counting equipment in the PARAPs roo This is an Open Item (295/97007-04 and 304/87009-04).

In addition to the aforementioned Open Items, the following item should be considered for improvement:

• Non players shculd not assist participants in setting up l equipment or in assisting tSem in using the equipmen !

e. Corporate Command Center (CCC) f The CCC was activated following the Alert declaration in accordance with procedures. Following the conservative decision to activate the EOF prior to the SAE declaration, the CCC Director established and maintained radio communications with the Manager of Emergency Operations (MEO) while the later was enroute to the EOF. The CCC Director provided a detailed initial briefing to his staff during facility activation, and also concurred in the SD's conservative decision to declare a SA The Intelligence Director did a good job in reviewing the Zion Station's EALs for applicability as the scenario progresse From about 9:05 a.m. to 9:50 a.m., the CCC Director assumed overall command and control of the licensee's emergency response efforts, in accordance with the emergency plan and procedures. Transfe. of

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responsibilities from the TSC's staff to the CCC staff was smoot However, the TSC appropriately retained responsibilities for ENS communications and control of the licensee's field survey team '

\ Subsequent transfer of command and control from the CCC Director to

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the EOF's ME0 also was well don The CCC Director did an exceptional job in utilizing his staff to support their TSC and EOF counterparts. He kept his staff 1

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adequately informed of major decisions and had various members of his staff remain involved in trending plant parameters, generating offsite dose projections, and dealing with specific points of concern such as: verifying the preliminary estimate of core damage; refilling the reactor water storage tank; and seeking E0F staff concurrence to energize the containment's hydrogen recombiners before hydrogen levels would become prohibitive. CCC staff also anticipated the need to relocate the EOF due to prohibitive dose rates within that facilit EOF evacuation was later simulated per procedure The CCC Director and his dose assessment staf f also remained very actively involved with the EOF counterparts in the emergency reclassification and protective action decisionmaking. CCC staff demonstrated the capability to acquire a weather forecast from the licensee's contractor who would provide such information in an actual emergency situation. Through no fault of the CCC staff, the contractor provided the actual forecast instead of the pre-scripted scenario forecast. The licensee's EOF staff and NRC Site Team personnel soon recognized the differences in these two weather forecasts and corrected the problem. Exercise controllers showed proper restraint in allowing exercise participants to identify and resolve the problems of persons trying to utilize different weather forecasts in the protective action decisionmaking proces Status boards were adequately utili7ed in the CCC. Typed copies of status board information were generated and made available to each technical group leader during the exercis Dose assessment staff did a good job in monitoring the activities of the Station's field survey teams and in plotting the approximate l progress of the plume through the 10 mile EPZ. However, the staff ,

did not plot on their EPZ map the locations where field samples had been taken. CCC staff also did not recognize that a second, unmonitored release path had developed late in the exercise. As ,

indicated in Paragraph 5f of this report, some EOF dose assessment I staff did recognize this possibility and had alerted the ME Based on the above findings, this portion of the licensee's program

. is acceptabl Emergency Operations Facility (EOF)

The Manager of Emergency Operations (MEO) assumec overall command and control of the licensee's emergency response efforts from the nearsite E0F approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 10 minutes after the SAE

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' declaration. His. assump' t lon of lead responsibilities .was correctl delayed for a short time while his. staf f determined the States'

rationale for implementing very cea ervative offsite protective'

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actions-(evacuation out to two miles in all sectors'and sheltering from two to five miles in downwind sectors) following the SAE

' declaration. The EOF .was quickly brought to. a fully operational

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statu Personnel used checklists to' ensure task completion,and est,ablished communications with their TSC and CCC counterpart Adequate facility security was established and maintaine Throughout the exercise, the E0F staff did a good job of anticipating the information needs of the ME0 and were usually prepared t provide him with sound recommendation The only major exception to this was the failure to recognize the future likelihood to activate the containment's hydrogen recombiners, as was anticipated to a greater degree by at least some CCC and TSC staff. The EOF staff focused more of its attention on plant systems restoration and maintaining adequate' coolant level in the reactor vassel and reactor wat'er storage tank. By the time the need to start the recombiners was fully appreciated in the EOF, containment hydrogen concentration

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had risen to a sufficiently high level to make recombiner startup unreasonabl The EOF's engineering and environmental staffs adeque*,ely interfaced during the ' exercise to ensure that changing and potential. plant conditions were factored into riose projections and offsite protective action decisionmaking. The EOF. staff also interfaced well with NRC Site Team personnel in all areas of concern. The ME0 and several dedicated communicators provided timely and accurate emergency classification, protective action recommendations, emergency response efforts, and plant status information to both States over dedicated communications lines.

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The escalation of the event to a General Emergency was given considerable attention and was well thought out. Early concerns to upgrade to a General Emergency were correctly rejected by the ME0 due to insufficient technical basis for this upgrade. The MEO later correctly declared a General Emergency based on the existence of several distinct plant conditions which satisfied multiple EALs associated with a SAE classific;i'o The licensee adequately inc.orporated evacuation time estimates, and current and forecast weather conditions into its protective action decisionmaking. Recommendations to the States were in accordance with procedural guidance and were well documented. NRC Site Team personnel were kept adequately informed of the licensee's recommendations. On several occasions when the States chose to implement more conservative recommendations, the ME0 did a very good job in encouraging all parties' technical staffs and managers to maintain open communications when evaluating the potential for revising the protective actions already being implemente .

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t-The environmental staff did a good job in generating offsite dose projections based on either containment radiation levels, monitored release rates, or data reported by offsite survey teams. The staff recognized an error in one early calculation based on release rates, as the results were inconsistent with current or projected containment radiation levels. They correctly determined that the dose projection error was due to an error in hand calculations necessary to compute some input parameters to the computerized dose projection program. Late in the exercise, the EOF Environs Director and several colleagues correctly suspected that a second, unmonitored release pathway had somehow begun. This deduction was based on several field survey team measurements which remained too high versus those expected based en recent containment vent stack measurements. Steps were taken to verify the unexpectedly high offsite measurements. The MEO was alerted to the possibility of a second release path, and actions were initiated to dispatch a survey team outdoors within the protected area. Meanwhile, the HE0 correctly decided to inform the States that the release was stiil censidered to be in progress until the known release pathway could be sealed and the existence of a second pathway could be conclusively proven or disproven. Following that decision, exercise controllers issued a contingency message indicating that the release had ended; however, the intent of this message was merely to suspend exercise activities for the da Adequately detailed records of EOF activities were maintained by individual directors, communicators, and work groups to permit later reconstruction of their activities and decisions. The ME0 utilized a dedicated logkeeper, who was also readily available to the MEO as a technical advisor in the emergency planning area of expertis Habitability monitoring in the E0F was adequate. During the exercise, a correct decision to evacuate E0F staff was made in accordance with procedural guidelines. The facility's evacuation was simulate Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement:

• The licensee's dose assessment software should be refined to eliminate or minimize the potential for human error in calculating input parameters to the computerized mode * The licensee should consider normalizing the position of dedicated recordskeeper for the MEO, preferably to be filled by persons having emergency planning expertis l

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g. Radiological Environmental Monitoring Teams The licensee dispatched two field survey teams from the Zion Station during the first day of the exercis An inspector accompanied the team which used the dedicated "GSEP Van." This inspector and others located in the TSC and EOF were also able to monitor some of the activities of the second team which utilized a pickup. truck. The GSEP Van was well equipped with multiple air samplers and associated portable. power supplies, multiple radios., and the keys to the various owner controlled area gates. The three person team using the pickup truck was also adequately equipped. However, an open-bed vehicle is less desirable for carrving three persons and their supplies, especially in the event of adverse weather condition The team that was accompanied by an inspector maintained a very detailed log of their activities and their accumulated exposure The log proved to be particularly useful when the team members later briefed personnel dispatched to relieve them. The team also adequately labeled the various samples they collected to permit later time and location identification in the laborator The team collected cir, soil, and vegetation samples. Although the team generally followed procedural guidance in collecting such samples, the following problems were noted. At one sampling location, the team positioned an air sampler atop an air conditioning unit located next to a buildin With the airflow around the sampler being disrupted by the operation of the air conditioning unit, the representativeness of the air sample would be questionable. When collecting soil and vegetation samples in plastic containers, the team typically placed the containers directly on the ground and then placed the unbagged containers in the van's' storage area. This practice could have introduced l contamination into the vehicle. Contrary to the guidance in Procedure EG-11, on several occasions the team collected rocks instead of soil when the latter was not present at predesignated sampling point The procedure indicates not to collect a sample in that situation. The team also did not attempt to clean sample collection tools to prevent cross-contamination of sample Contrary to Procedure EG-13, air sample cartridges were not always smear-checked for contamination prior to giving the samples to a messenger for transport to the laborator The failure of an offsite monitoring team to follow guidance in Procedure EG-11 and EG-13, regarding soil sample collection ,

techniques, cleaning sample collection tools between uses, and '

taking smear samples before transferring samples to a messenger, together constitutes on Open Item (295/87007-05 and 304/87009-05). .

l l The teams were kept adequately informed of relevant plant status l information and offsite protective actions by persons directing l their movements from the TSC and EO Transfer of team control l l

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between TSC and EOF staffs was smooth, even when control of one team was temporarily returned to the TSC so that the team could survey within the protected area for evidence of a releas In addition to the Open Item, the following items should be considered for improvement:

• Sample containers should not be placed in direct contact with the ground, to reduce the potential for spreading ground contamination into the vehicle's sample storage are * Air samplers should be positioned such that operating equipment does not adversely affect the representativeness of the sample being collecte Joint Public Information Center (JPIC)

The JPIC was located in Highland Park, Illinoi This was the first exercise during which the licensee has used this building as the Zion Station's JPIC. The layout of the facility was adequat Separate entrances were provided for the media and for public information staffs. Working space for the licensee's and other organizations' staff was somewhat cramped, but satisfactory. The media briefing area was adequate in size. The spokespersons on stage were readily visible to the audience. There was sufficient seating room for the media plus additional space for several camera crew The briefing area's sound system and acoustics were good. A sufficient number of telephones were available for media use in a small room located at the rear of the briefing are In general, access control to the JPIC's offsite and briefing areas was adequate; however, security guards were initially somewhat slow in processing media representatives into the facilit Press packets were provided to the medi Based on comments from the media, a 10-mile Emergency Planning Zone (EPZ) map would have been a useful addition to the otherwise satisfactory contents of the press packet The licensee participated in an adequate number of press briefings and issued a satisfactory number of approved press releases during the exercise. The contents of both were coordinated with information issued by other organizations' public-affairs staff The licensee's press releases and the speakers' podium were clearly labeled "This is a drill." The licensee's public information staff made good efforts to avoid using unexplained technical jargon or acronyms in press releases and briefings. The licensee's spokespersons adequately responded to media questions. With tho very minor errors, the licensee's hardcopy news releases contained accurate information. The two errors were promptly correcte . - _ _ _ - _ -_- . _ _

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Although the licensee' utilized several~ visual. aids during the press briefings, such as an EPZ map and plant systems drawings, they were

difficult to read by persons not seated in the first row of th audience. Press releases were distributedEto the media and were also. posted in several location Based on the above findings, this portion of the licensee's program is' acceptable; however, the following items should be considered for

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improvement:

'* Properly labeled 10-mile EPZ maps should be'added to the press information packets.

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• Visual aids cused in media briefings sheuld be: legible- to all .

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persons in the media seating are . Exit Interview

.On June 26,~1987, the inspectors met with those licensee. individuals identified in Paragraph 1 to present the preliminary findings. The licensee -indicated that none of the matters discussed wera proprietary in natur Attachments: Licensee's Exercise Scope and Objectives Scenario Narrative Summary

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Revision 7 FEDERAL FIELD EXERCISE 2 OBJECTIVES June, 1987 OBJECTIVES PRIMARY OBJECTIVE:

Demonstrate the capability to implement the Commonwealth Edison Generating Station's Emergency Plan in cooperation with the Illinois Plan for Radiological Accidents and the Wisconsin Radiological Emergency Response Plan to protect the public in the event of a major accident at Zion Statio Day 1 Evaluated Obiectives 1) Incident Assessment and Classification Demonstrate the capability to assess the accident conditions, to determine which Emergency Action Level (EAL) has been reached, and to classify the accident level correctly in accordance with GSE (Control Room, TSC, CCC and EOF.) Demonstrate the process by which a decision to' relocate to the Backup EOF would occu ) Notification and Communication Demonstrate the capability to notify the principal offsite organizations via NARS and NAWAS within 15 minutes of classificatio (Control Room, TSC/CCC ano EOF.) Demonstrate the ability to notify the NRC within one hour of incident occurenc (Control Room, TSC/CCC or EOF.) Demonstrate the capability to contact organizations that would normally assist in an emergency, but are not participating in this exercise (i.e., Sargent & Lundy, General Electric, INPO and ANI.) (TSC, CCC, and BOF.) Demonstrate the capability to interface with NRC Region III Site Team and the NRC Incident Response Cente (TSC, CCC and EOF) Demonstrate the ability to notify stato agencies with hourly plant status followup informatio (TSC, CCC, and EOF)

3) Radiological Assessment Demonstrate the cepability to calculate offsite dose projections. (TSC, CCC and EOF)

G-1-2 6892E/6

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, 3) Radiological Assessment.(cont'd) ,

, Demonstrate the. capability of Environmental Field Teams to conduct field radiation surveys, collect air, liquid, vegetation and soil samples when neede (Environs Team.) Demonstrate the capability to conduct in-plant radiation protection activitie (OSC/ Health Physics Teams.) Demonstrate the ability to collect and ccenduct analysis of'

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. air or liquid samples on-site via.HRSS.- (OSC/ Rad. Chem.)- Demonstrate the ability to perform calculations with radiological survey information, trend this information, and make appropriate recommendations concerning protective actions.-(TSC, CCC, and EOF)

4) .EmeroencY Facility Manning- Demonstrate the ability to activate the emergency organization and staff the nuclear station Emergency Response Facilities in accordance with procedure (Control Room, TSC, CCC, EOF, OSC/ General Plant and JPIC.) Simulate the capability to provide timely and accurate on-site personnel accountabliity in accordance with-procedures. (TSC)

5) Emergency' Direction and Control Demonstrate the ability of the Directors toruanage the emergency organizations in the implementation t of the GSE (TSC, CCC and EOF)

6) _P,u_blic Information Demonstrate the ability to provide accurate and timely information so reports may be made to the Joint Public Information Center (JPIC) for press releases. (JPIC) . Demonstrate the ability of the News Information Center to control, or clarify, rumors that have been generated offsit (Communication Services) Demonstrate the ability of the News Information Center to monitor the medi (Communication Services)

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G-1-3 6892E/7

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NARRATIVE SUMMARN Zion Unit I has been operating at 99% power for 2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after a ramp up from 80% power at a rate of 1%/ min. . Unit I had been at 80% power since 0200 on June 20, 1987. Previous to this, Unit I was ramped down from l 99.5% power where it had operated for 53 days.

l Zion Unit 2 is on the 30th day of a Refueling Outage in mode 6. Reactor cavity ' level is 614'4", Spent Fuel Pit level is 614'4", and RWST level is 10 feet. The fuel shuffle has been completed and modifications to the reactor vessel's upper internals package are in progress.

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l SERVICE REPORT Unit 1 Equipment OOS

- 1A Main Feed Water Pump is Out of Service (OOS) for motor overhau IB DG is OOS for replacement of the bearing trip mechanism IC Charging Pump is DOS for modifications to the stuffing boxe RT-AR04 A and B are OOS for detector tube replacemen AOV-RVI,2,3, and 4 are OOS closed for Actuator Repair / replacemen RV1 and RV3 are deenergized and failed closed. RV2 and RV4 have their actuators removed and mechanical Jacks holding these valves close A Purge supply fan 1RV006 is DOS and racked out for Motor Replacemen A & IB Purge exhause fans IRV008 & 9 are OOS and racked to test for motor inspectio Unit 2 Equipment DOS:

- All major equipment except Residual Heat R,emoval (RHR)

- 2A Diesel Generator is OOS per 3L and 4R cylinder and liner replacement 3286D/7

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Unusual Event - EAL # T = 0 (0515) __

Rad Chem department reports that U1 Reactor Coolant System (RCS) sample results indicate 50 uci/ml equivalent of Iodine-131.

1 T = 445 (0700)

RCS leakage of approximately 30 gpm is indicated based on charging flow and increasing containment activit Alert - EAL # T = +60 (0715)

Increased RCS leakage of approximately 70 gpm is indicated based on charping flo T = +135 (0830)

RCS leakage has increased to 300 gpm. Maximum charging flow is indicated (meter pegged at 200 gpm) and pressurizer level is decreasin T = +150 (0845)

The Reactor has been manually or automatically tripped and Safety Injection (SI) has been initiated due to decreasing pressurizer level and RCS pressur Bus 142 has failed to transfer to the System Aux Transformer and "O" Diesel Generator (DG) is supplying Bus 14 T = +165 (0900)

Due to a fault on Bus 147 the bus sheds all loads. This results in the loss of IB Charging Pump, lA SI Pump, lA Containment Spray (CS) Pump, OE Component Cooling (CC) Pump, lA Service Water (SW) Pump, and 1C Reactor Containment Fan Cooler (RCFC).

Site Emergency - EAL # T = +180 (0915)

Unit 1 Containment Activity is 470 R/ hour as indicated by 1RT-AR02. The System Aux. Transformer deluge activates, the transformer is on fire. This results in the loss of all offsite power to Unit Bus 148 is energized by 1A D Bus 149 is de-energized due to IB DG being OOS 1C AFW Pump, lA RHR Pump, OC CC Pump, 1C SW Pump, 1B and lE RCFC's are inoperabl D/8

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T = +195 (0930)

The 1A Aux Feed Water Pump shaft seizes due to the failure of the shaft driven oil pum T = +240 (1015)

The IB Aux Feed Water Pump is lost due to breaker failure. No Aux Feed Water Pumps are operabl T = +270 (1045)

The IB Aux Feed Water Pump is restored to operable status. The breaker was replaced with a spar T = +315 (1130)

The IB Aux Feed Water Pump shaft shears, this results in the loss of all Aux Feed Water. The IB Residual Heat Removal Pump is running with erratic Amp indication. The IB Residual Heat Removal Pump is inoperable at T=325 (1140).

T = +345 (120f))

RCS leakage has increased to the design basis accident value, RCS pressure is decreasing rapidl General Emergency - EAL 3.0 or T = +360 (1215)

Loss of all Feed Water and all Auxiliary Feedwater and the RHR system has been oos for 45 minute T = +390 (1245)

Unit 1 Containment Radiation levels are 30,000 R/ hour. Evacuation recommendations should be mad l T = +540 (1515)  !

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Unit 1 Containment is released to the environment via IA0V-RV0001 and 2 l through the purge supply duct to the vacuum and pressure relief line to the j Aux Bldg. Exhaust Stack. The mechanical Jack holding RV2 closed has fallen off l and RV1 is not properly seated due to containment pressure caused by the Loc '

The Linkage on 1*CV RV85B has slipped and this valve is failed ope T = +630 (1645)

The inspection hatch for 1 ROV-RV0002 has opened. This hatch is located in the RV valve house outside containment. The hatch had not been properly reclosed due to the ongoing inspections and maintenance being performed on RV2. This results in a non-monitored release to the environmen D/9

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Unit 1 Containment release. stops. Containment pressure has fallen to 1 PSIG and in0V-RV0001 reseats due to the lower pressure isolating the release path.--

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T = ~ +',e$ (1900)

Day 1 Federal Field Exercise 2 activities are stoppe .(

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