IR 05000295/1989006

Insp Repts 50-295/89-06 & 50-304/89-06 on 890214-17.Major Areas Inspected:Emergency Preparedness Program,Licensee Action on Previously Identified Items,Emergency Plan Activations & Operational Status of Program

ML20235Y676
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/03/1989
From:	Ploski T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235Y672	List: IR 05000295/1989006 ML20235Y668
References
50-295-89-06, 50-295-89-6, 50-304-89-06, 50-304-89-6, NUDOCS 8903140489
Download: ML20235Y676 (13)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-295/89006(DRSS); 50-304/89006(DRSS)-

Docket Nos. 50-L95; 50-304 Licenses No. DPR-39; DPR-48 Licensee: Commonwealth Edison Company

Post.0ffice Box 767'

L Chicago, IL-' 60690 b Facility Name: Zion Nuclear Generating Station, Units 1 and . Inspection At: Zion Station,' Zion, Illinois

' Inspection Conducted: February -14-17,1989 Inspectors: T 1 3/3/3p Date~

Ld D M. Smith / s/2/a)

. Date

(1).M W. Snell, Chief Apprcved By: s/s/af Emergency. Preparedness and Date Effluents Section Inspection Summary

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Inspection on February 14-17, 1989 (Reports No. 50-295/89006(DRSS);

50-304/89006(DRSS))

Areas Inspected: Routine, announced inspection of the following areas of the Zion Station's Emergency Preparedness (EP) program: licensee action on previously identified items (IP 92701); emergency plan activations (IP 92700);

operational' status of the program (IP 82701); and training (IP 82206).

Section 5 includes an update on the status of the Safety Issues Management System (SIMS) items. The inspection involved two NRC inspector <:

89031404s9 s90306 PDR ADOCK (>5000,g5 Q

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Results: Management attention to the onsite program has begun to increas This increase is largely due to a July 1988 corporate assessment of the Station's program and the large number of items identified by NRC and licensee evaluators during the September 1988 exercise. While some progress has already been made on previously identified NRC concerns and some self-identified concerns, increased mar.agement attention is still necessary to ensure the timely completion of corrective actions on the remaining items. The inspectors also encouraged management support for the quarterly tabletop drills that have begun and are to continue to at least the end of 198 Due to changes in the normal station organization, some changes will likely occur in the Technical Support Center's (TSC's) organization during the first quarter of 1989. The licensee committed that those persons, whose emergency positions would be changing, would complete training requirements for t'neir new positions by April 1989. The licensee's commitment to the State of Illinois to upgrade training to technicians, who would assist hospital staff in responding to a radiologically contaminated accident victim, will also be tracked by Region III staff.

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~ DETAILS

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• T.fJoyce,StationMandger

• T. Rieck, Services Superintendent

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• D. Budowle, Services. Director .

.- *W. Cramer, Traini_ng Supervisor (Non-licensed)

L L*T. Vandervoot, Quality Assurance Supervisor

.*W. Stone, Regulatory Assurance S4 ervisor

• A. Nykiel, GSEP Coordinator

• V. Williams, Lead Health Physicist.-

• R. Carson, Corporate Emergency Planner J. Johnson, GSEP Training Instructor R. Palatine, Tech Staff Engineer K. Landrum,: Shift Engineer-J. Madden, Shift Control Room Engineer C. Moser, Shift Control Room Engineer

• These persons attended the February 17,-1989 exit intervie . Licensee' Action on Previously Identified Items (IP 92701)

-(Closed) Open Item No. 295/87002-02; No. 304/87002-03: To better ensure-adequate 24-hour staffing capability in the Technical Support Center (TSC), the licensee should identify at least three qualified persons for each director-level positio Based on a' review of quarterly revisions to the onsite emergency organization callout procedure (EPIP 320-1),.three persons were listed for all director-level positions in the TSC organization with the exception of the Operations Director. .Four persons were listed as qualified Operations Directors. No individual was listed for more than one director-level position. These numbers of personnel are sufficient to better ensure 24-hour staffing capability. This item is close (0 pen) Open Item No. 295/87007-01; No. 304/87009-01: -During the 1987 exercise, an inplant team failed to comprehend and to follow several procedural steps during liquid sample collection using the High Range Sampling System (HRSS).

Records indicated that HP.SS equipment problems resulted in the June 1988 liquid sample collection drill to be unsuccessful. Another equipment problem and several ALARA concerns were identified during the December 1988 remedial drill. The next liquid sample collection and analysis drill is scheduled in March 1989. This item will remain open pending successful use of the HRSS to collect a liquid sampl . _ - _ _ _ _ _ - _ - _ - _ _ _ _ _

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(Closed) Open Item No. 295/87002-02; No. 304/87009-02: During the 1987 exercise, the inplant team dispatched to collect and analyze a containment atmosphere sample did not demonstrate adequate familiarity with the Post-Accident Radionuclides Analysis Portable System (PARAPS)

utilized to count the sampl Additional training on the use of the PARAPS was provided to all Radiation Chemistry Technicians (RCTs) in May and June 198 The lesson plan adequately addressed system limitations, sample positioning, system operation, and ALARA considerations while using the PARAP The PARAPS was then successfully used during a June 1988 dril This item is close (Closed) Open Item No. 295/87007-03; No. 304/87009-03: During the 1987 exercise, the inplant team dispatched to collect and analyze a containment atmosphere sample demonstrated poor ALARA practices during sample collection, transport, and analysi Training on the use of the HRSS to obtain a containment atmosphere sample was conducted in May and June 198 The lesson plan adequately addressed good ALARA practices during sample collection, transport, and analysi The internal critique of the June 1988 containment atmosphere sample collection and analysis drill indicated that the RCTs demonstrated good ALARA practices throughout the drill. This item is close (Closed) Open Item No. 295/87007-05; No. 304/87009-05: During the 1987 j exercise, a field survey team failed to adequately follow procedural 1 guidance on soil sample collection techniques, including the need to  !

clean sample collection tools after use and the need to take smear samples of sample containers before giving the containers to a messenge Records indicated that the problems identified during the 1987 exercise were adequately addressed in the 1988 requalification training given to technicians who could be assigned to field survey teams. These problems were not identified during the subsequent environmental monitoring dril This item is close (0 pen) Open Item Nos 295/88006-01: The licensee must repair and periodically test the Emergency Operations Facility's (E0F's) emergency ventilation system and associated radiation detection equipmen The Particulate, Ic, dine, and Noble Gas (PING) monitor had been electronically upgraded during 1988 and was now operable. However, it had not yet been calibrated. A procedure addressing the need to perform periodic PING calibrations and to periodically functionally test the PING and the E0F's ventilation system in the recirculation mode was in the onsite review process. The licensee indicated that its plans had not been finalized regarding: who would be responsible for generating Werk Requests if the PING or ventilation system was found to be inoperable; who would ensure that necessary repairs would be completed; and what priority would be assigned to such Work Requests. This item remains open

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pending calibration of the PING and approval of one or more procedures that provide adequate assurance that the EOF's. PING and the facility's emergency. ventilation system well remain' adequately maintaine (Closed) Open Item No. 295/88006-02: The licensee must develop interim measures for continually assessing the EOF's habitability in the event that the E0F's PING or the emergency ventilation system does not properly operat Procedures EP-ERF-405 and NST-EOF-13 adequately addressed measures for continually assessing the EOF's habitability in the event of such equipment failures while the E0F is activated. This item is close (Closed) Open Item No. 295/88006-03: The onsite emergency organization's 1988 training program must be conducted utilizing a matrix of position-specific training requirements. The matrix, training modules, and examinations must have the required internal approval This item resulted from the fact that the 1988 training program had not been fully re-defined as of February 1988. Records indicated that Training Department staff had incorporated standardized training modules, provided through the corporate emergency planning staff, into the 1988 onsite training program. The matrix of position-specific training requirements was also finalized. The matrix, modules, and examinations received the required internal approvals prior to the beginning of the training program in the Summer of 1988. This item is close (Closed) Open Item No. 295/88006-04: The licensee must ensure that corrective actions are completed on the onsite problems evident in the internal critique of the 1987 medical dril While a number of onsite contamination control problems had been identified in the licensee's drill critique, many had initially been dismissed in the final report as being " acceptable" for a drill situatio Records review indicated that the licensee had reevaluated the 1987 critique and had adequately addressed onsite contamination control techniques in the 1988 onsite medical response training program. This item is close (0 pen) Open Item No. 295/88018-01: During the 1988 exercise, licensee staff failed to adequately inform Illinois officials of a Transportation Accident which involved the discharge of simulated dry active waste from its containers, and the simulated contamination and/or injury of roleplayers involved in the acciden The licensee has proceduralized the State of Illinois' "IESDA Hazardous Materials Radiological Questionnaire." This form contains guidance for informing State officials of an accident involving the offsite transport of radioactive material. The licensee's capability to adequately inform State officials of a Transportation Accident will be evaluated by NRC staff during a remedial drill currently scheduled for April 1989. This item remains ope ,

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r (Closed) Open Item No. 295/88018-02: During the September PSiexercise, i- neither Control Room staff nor the Technical Support Centet cTSC's)

Station Director declared a Site. Area Emergency in a timel

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une During the fourth quarter of 1988, Control Room crews and appropriate members of the TSC staff completed a " Team Training / Accident Management" training program which~ addressed emergency classification, offsite notification requirements, protective action decisionrraking, and Control Room-TSC interface. Each session of the classroom training-lasted about 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and included procedure review and a review of NRC evaluations of Control Room and TSC staff performance during exercises. The simulator portion of the training involved the response to a modified version of the 1987 exercise scenario. A response cell of controllers, simulating NRC and State duty officers, accepted calls from the participants as the scenario progresse During this inspection, one Shift Engineer (SE) and two Shift Control Room Engineers (SCREs) were interviewed as potential Acting Station Directors. The duties of this position includo emergency classification, protective action decisionmaking, and offsite agency notification. All interviewees demonstrated adequate familiarity with relevant procedural guidance on these responsibilitie .

This item is' close (0 pen) 0)en Item No. 295/88018-03: During the September 1988 exercise, TSC and EOF staffs failed to provide simulated NRC duty officers with adequately detailed information on plant conditions associated with the Site Area and General Emergency declaration During the fourth quarter of 1988, Control Room crews and appropriate TSC staff completed a " Team Training / Accident Management" program which included training on emergency classification and offsite notificatio The NRC s Event Notification Worksheet has been proceduralized at the Zion Station to better ensure that licensee communicators understand the NRC's information needs. Review of the licensee's internal critique of the September 1988 exercise indicated that EOF staff had some difficulties in gaining a full understanding of degrading plant conditions'and the continuing response to the Transportation Acciden Thus, the recently-arrived E0F staff had difficulty in satisfying the remaining information needs of simulated NRC duty officers, who had previously been in contact with TSC communicator l This item will remain open pending an exercise demonstration of the TSC and EOF staffs' capabilities to adequately inform simulated NRC staff of changing plant condition (0 pen) Open Item No. 295/88018-04: During the September 1988 exercise, the licensee's overall response to the Transportation Accident, which included a simulated medical emergency with contamination complications, was inadequat ;

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A remedial demonstration of response capabilities to an analogous situation is currently scheduled to take place during April 198 NRC staff will evaluate this demonstration. This item remains ope (Closed) Open Item No. 295/88018-05: The licensee must conduct a successful onsite assembly drill during 198 The assembly drill conducted as part of the 1988 pre-exercise was considered unsuccessful by licensee controllers and by NRC inspectors who reviewed records of the pre exercise drill. The licensee was allowed to delete the onsite assembly drill from the 1988 exercise objective Records indicated that a successful onsite assembly drill was conducted in December 1988 to fulfill the annual commitment in the Emergency Pla This item is close . Emergency Plan Activations (IP 92700)

NRC and licensee records associated with all emergency plan activations that occurred since the February 1988 routine inspection were reviewe These records included: records generated by NRC Headquarters and Region III Duty Officers; Control Room logs; Nuclear Accident Reporting System (NARS) forms and other forms completed by onshift personnel; and evaluations of licensee records that were performed by the GSEP Coordinato Between February 1988 and mid-February 1989, onshift personnel correctly declared two Unusual Events. Both declarations were due to commencement of reactor shutdown per Technical Specification requirements. Illinois, Wisconsin, and NRC officials were initially notified of both declarations in a timely manner. Comparison of licensee and NRC records of each event indicated that the NRC was accurately informed of the circumstances which led to the Unusual Event declarations. The GSEP Coordinator's evaluations of licensee records were adequat Based on the above findings, this portion of the licensee's program was acceptabl . Operational Status of the Emergency Preparedness Program (IP 82701) Emergency Plan and Implementing Procedures By letter dated August 31, 1988, NRC Region III staff approved Revision 6B to the Generating Stations Emergency Plan (GSEP). This revision had undergone the required onsite and offsite reviews prior to being submitted for NRC approval. The Zion Station Annex to the 1 generic GSEP was being revised during this inspection. The  !

relatively minor changes included identification of the Corporate I Command Center in Chicago, Illinois as the approved backup Emergency Operations Facility (E0F) for the Zion Station. The licensce planned to submit the annex revision for NRC review following completion of the internal review proces _ _ _ ..

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Revisions to' Emergency-Plan Implementing Procedures (CPIPs) have- j L been reviewed on an ongoing basis since the' 1988 routine inspection-by'the Region.III Emergency Preparedness Analyst assigned to the

, Zion, Station. These~ revisions accurately reflected the commitments fmade:in the approved GSEP and Zion Station ~ Annex to the GSE The GSEP' Coordinator h 'ad revised, or was in the process.of revising, a number of EPIP Revisions which had already been approved included proceduralization of the NRC's Event. Notification Worksheet-andithe State of Illinois' "IESDA Hazardeus Materials Radiological Questionnaire." The latter form would be used to assist station-staff in satisfying the information needs of State officials in the event.of a Transportation Accident involving radiological material ..

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EPIP_ revisions in progress were largely the results of a July 1988 corporate self-assessment of the. Station's program and the large number of 1988 September itemsexercis identified by the NRC and:the licensee during'the For example, one of the coordinator s supervisors had become involved with the development of a coordinated plan for responding to a Transportation Accident.within

.the city limits of Zion, Illinoi Additional EPIP.-revisions were anticipated as a result of 1989 tabletop drill critiques.

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. Based on the above findings, this portion of the licensee's program was acceptabl Emergency Facilities, Equipment, and Supplies A tour of the TSC, Operational Support Center (OSC), the onsite

. assembly area, and the nearsite E0F indicated that all were being maintained on an adequate state of readiness, with the exception of the E0F's PING and emergency ventilation system. The status of the licensee's progress cn ensuring the operational readiness of the EOF's PING and emergency ventilation system is provided in

Section 2 of this repor The readiness of the emergency response facilities, communications equipment, and supplies was also evident from a review of periodic equipment test and inventory records. All procedurally required 1988 communications tests and inventories had been conducted and adequately documented. Documentation included evidence that identified problems had been corrected in a timely manne The licensee has made progress on plans to construct a new TSC; I however, the target date for project completion has slipped from June 1990 to January 199 The engineering contract was awarded in April 1988 and design work was in progress. The TSC's design i is similar to that of the TSCs at the licensee's Byron and '

Braidwood Stations. It will be located along the northeast side of the Turbine Building. The new TSC will be spacious compared to the relatively cramped workspace which is presently used as a TS l l

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The licensee was constructing an addition to.the Service Building during this inspection. The addition was expected to be ready for occupancy in the first quarter of 1990. The licensee planned to remodel a portion of the existing Service Building into a meeting room capable of accommodating about 140 persons. The GSEP Coordinator provided information which indicated that this meeting room would be utilized as the primary OSC in an emergency situation. The size 'and ' location of this proposed OSC represents a significant improvement over the workspaces that currently must be reconfigure into an OS Based on the 'above-findings, this portion of the licensee's program was acceptabl c. Organization and Management Control The GSEP Coordinator position was a non-supervisory, full-time assignment. The Coordinator's reporting chain to the new Station Manager was uncertain at the time of this inspection, mainly due to the "Introspect Program," which is an effort intended to reduce-the number of levels of supervisory positions at the licensee's-nuclear stations and the corporate office. Despite the short-term uncertainty in the coordinator's reporting chain and the recent

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appointment of a new Station Manager, there were no indications ,

of a decline in the increased management attention to the Station's i emergency preparedness progra The onsite emergency organization's staffing had increased slightly !

during 1988. There were currently three, and infrequently four, i persons identified for each director-level position, with no cases of an individual being listed for more than one position in the callout procedure. However, a number of changes to the callout roster were anticipated during the first quarter of 1989 due to the arrival of the new Station Manager, the "Introspect Program," and the ;

reorganization of the Radiation Chemistry Department into the i Radiation Protection and Chemistry Department The GSEP !

Coordinator anticipated that such changes in the normal organization '

would affect some assignments to the following positions in the onsite emergency organization: Station Director, Operations Director, Rad Chem Director, and Environs Director. The coordinator indicated that many of the current emergency organization members who should soon be eligible for new emergency organization positions lacked only position specific training for the new positions. This training would include tabletop drill experience in their new positions. The next tabletop drills were scheduled for March 1989. To better ensure the continuation of adequate staffing for all TSC director-level positions, the licensee committed at the exit interview that all persons eligible for different director-level positions during the first quarter of 1989 would complete all training requirements by April 1989. This commitment will be tracked as Open Item No. 295/89006-0 _ _ _ _

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i The: license has continued the practice of conducting semiannual off-hours drills to demonstrate the capability of key TSC staff 1 to augment onshift personnel in a timely manner. Successful augmentation drills were conducted in February and September 198 Records in'dicated that the GSEP Coordinator had been effectively utilizing the Station's Nuclear Tracking System to document progress made on NRC and self-identified action item With the exception of one Open Item, this portion of the licensee's ;

program was acceptabl Trai_ning (Also IP 82206)

The Station's Training Department was responsible for providing and tracking initial qualifying and annual requalifying training for the onsite emergency organization. The 1988 training was a mixture of :

classroom training on relevant modules and required readings of relevant EPIPs. The training modules were revised during 1988 to incorporate earlier refinements made by Braidwood Station staff to the " generic" modules in use at the Zion Station. Records review indicated that all members of the onsite emergency organization had completed their 1988 training requirements. The matrices listing the position-specific classroom modules and reading assignments had been approved. The revised training modules had been approved during 198 Although the Station's annual emergency preparedness training program had been conducted, a number of items were identified during the September 1988 exercise whose corrective actions included upgrades to EPIPs and/or the Station's training program. As one method of improving the onsite emergency organization's training, the licensee planned to conduct quarterly tabletop drills during 198 Each tabletop session would be offered twice each quarter. TSC director-level personnel and OSC supervisory personnel would be expected to observe or participate in two tabletop drills during 198 Thus far, the Station's Training Department had arranged for the development of six tabletop drill scenarios. Tabletop drills for the first quarter of 1989 had been conducted and critiqued in late January and early February. Since the annual exercise and a remedial response to a Transportation Accident situation were scheduled for April and May, the next tabletop drills were scheduled for late March 1989. Future tabletop drills had been tentatively scheduled for August and November 1989. The feasibility of conducting a tabletop drill in conjunction with a periodically required drill, such as an inplant Health Physics drill, was being considere l

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The 1989 annual training program was scheduled to take place during the Summer. The licensee planned to have the EPIP revisions currently in progress and lesson plan revisions completed prior j to conducting the 1989. classroom training session Records review indicated that all required emergency preparedness drills had been conducted and critiqued during 1988. The internal I critique from the September 1988 exercise was reviewed. This critique was thorough and objective, and addressed the root causes for the significant performance problems that were identified by licensee and.NRC evaluators during the exercis As indicated in Section 2', the licensee reevaluated the critique from the 1987 medical drill and upgraded the 1988 training given  :

to RCis with respect to their onsite response to a medical emergency with contamination complications. A. representative from the Federal Emergency Management Agency (FEMA) Region V office observed th performance of hospital and ambulance staffs and Zion Station RCTs at the local hospital during the 1988 medical drill. In the drill evaluation report forwarded to the State of Illinois, FEMA identified several contamination control problems at the hospital which were related to the performance of the RCTs. The licensee has committed ,

to the State of Illinois that the RCTs' training would be upgraded during 1989 regarding their responsibilities at the local hospita This commitment to the State of Illinois will be tracked as Open Item No. 295/89006-0 Interviews were conducted with a Shift Engineer (SE) and two Shift Control Room Engineers (SCREs) regarding the responsibilities of the Acting Station Director. All interviewees were adequately familiar with procedural guidance regarding: the undelegatable responsibilities of that position; emergency notification requirements; and various aspects of onsite and offsite protectiv action decisionmaking. They were also able to properly classify several abnormal situations using the Station's Emergency Action Levels (EALs). Control Room crews had participated in classroom and simulator training sessions during late 1988 which addressed the topics covered in these interview Interviews were also conducted with nine individuals who could be assigned to supervisory positions in the OSC or to inplant repair teams. These individuals were adequately familiar with their responsibilities as members of the onsite emergency organizatio '

The annual meeting with members of offsite support organizations was conducted in late 1988. The Station's EALs were discussed at that meeting. Attendees were also informed on how to obtain a copy of the Quality Assurance (QA) Department's annual evaluation of the Station's interface with offsite support organization l

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With the. exception of one Open Item,Lthis portion of the licensee's program was acceptabl ,

l 'e . ' Audits Records of 1988 QA' Department' audits and surveillance of the Station's program were reviewed. All records ~were complete and readily available. The 1988' audits were adequate.in scope, and-satisfied the requirements of 10 CFR 50.54(t). Surveillance No. QAS-22-89-007 was a good' evaluation of the'Etation's interface with State and' local offsite support agencie A'self-assessment of the Zion. Station's emergency preparedness program'was conducted in July 1988 by corporate emergency planners and a'GSEP Coordinator from one of the licensee's other nuclear

' stations. This assessment.was in addition to and independent of the efforts of the Quality Assurance:(QA) Department. Corporate staff were tracking the Station's progress on " Category I and II'

improvement items." These items included.the need for a number of EPIP revisions, improved operability of the HRSS, and upgrades to the annual training progra Based on the above findings, this portion of the licensee's program was acceptabl > TMI' Safety Issues Management Systems (SIMS) Items

- On October 31, 1980, the NRC issued NUREG-0737, which incorporated into'one document all TMI-related items' approved for implementation N by the Commission at that time. On December 17, 1982, the NRC issued Supplement 1.to NUREG-0737 to provide. additional' clarification regarding

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Regulatory Guide 1.97 (Revision 2) - Application to Emergency Response Facilities, and Meteorological Data, as well as other areas. The status of the completion of these TMI SIMS items are internally tracked by the NR The' October 26, 1988 Inspection Report (No. 295/88018;304/88018)

provided a status listing of the SIMS Items related to emergency preparedness. The following listing provides an updated status of those SIMS items that were "open" in the October 26, 1988 Report. The listing indicates how the item was tracked on SIMS as of February 23, 198 II Current Status: Closed This item has been determined to be no longer applicable and has been administrative 1y close III.A. Current Status: Closed This item has been determined to be no longer applicable and has been administrative 1y close >

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III.A.28 Current Status: ' Closed!

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applicable-and has been l administrative 1y, close IIL A. ' Current Status: , Closed .

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. applicable and has been' administratively closed.

v I IILA.2.8- . Current? Status: ' Closed Thisitemhasbeendeterminedtobeno' longer applicable and has'been administratively close MPA-F-63 Current Status: Open:

This item:irvolves-a review ofsthe;TSC during- >

a future inspectio . s ,

-MPA-F-65 Current Status: Open This item involves a review of the E0F during'

a future inspectio f

' Exit Interview

, On February 17, 1989, the inspectors met with those. licensee representatives

listed in Section 1 to present their preliminary inspection findings. The-licensee indicated that none of the matters discussed were proprietary in natur The licensee also committed that those TSC. directors, whose'

positions would be changing during the first quarter of 1989, would'

complete'all training requirements for their new positions by April 198 The inspectors acknowledged that increased management attention to the Station's emergency preparedness program was evident'since'the July 1988 corporate assessment and the September 1988 exercise. However, increased management attention remained necessary to ensure timely completion of  !

corret:tive actions in progress on remaining items that were identified during previous NRC inspections and the corporate assessmen The plan to conduct quarterly tabletop drills during 1989 was also supported by the inspector !

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