IR 05000295/1997008

Insp Repts 50-295/97-08 & 50-304/97-08 on 970317-21. Violations Noted.Major Areas Inspected:Insp Included Review of EP Program,Aspect of Plant Support

ML20140G042
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	04/30/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20140G029	List: IR 05000295/1997008 ML20140G026 ML20140G037
References
50-295-97-08, 50-295-97-8, 50-304-97-08, 50-304-97-8, NUDOCS 9705060222
Download: ML20140G042 (20)

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U.S. NUCLEAR REGULATORY COMMISSION REGION 111 l

Docket Nos: 50-295; 50-304 i l Licenses No: DPR-39; DPR-48 Reports No: 50-295/97008(DRS); 50-304/97008(DRS)

Licensee: Commonwealth Edison Company (Comed)

Facility: Zion Generating Station, Units 1 and 2 l

Location: 101 Shiloh Blv Zion, IL 60099 4 Dates: March 17-21,1997 Inspectors: James E. Foster, Sr. Emergency Preparedness Analyst Robert D. Jickling, Emergency Preparedness Analyst Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

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PDR ADOCK 05000295 G PDR

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EXECUTIVE SUMMARY Zion Generating Station, Units 1 and 2 NRC Inspection Reports 50-295/97008; 50-304/97008 This inspection included a review of the Emergency Preparedness (EP) program, an aspect of Plant Support. This was an announced inspection conducted by two regional Emergency Preparedness Analyst The overall effectiveness of your emergency preparedness facilities, equipment, training, and functional organization was good. We are, however, concerned that line management attention to the program has been lacking. Plant personnel had performed conservatively during actual activations of the Emergency Plan, and emergency response facilities were

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well-maintained. Quality assurance oversight of the program was also generally good.

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• The overall effectiveness of the licensee's emergency preparedness facilities, equipment, training, and organization was good. (Sections P2.1, P3, P5, and P6)

• Licensee personnel performed conservatively during three actual activations of the Emergency Plan that were classified as unusual events. However, some weaknesses in the performance of some individuals implementing EP activities were noted. (Section P1.b)

• Emergency response facilities were well-maintained and generally in an excellent state of readiness, with minor problems identified by the NRC inspector. (Section P2.1)

Quality assurance oversight of the EP program was generally good. (Section P7)

A violation was identified in that the annual audits conducted in 1995 and 1996 did not assess the adequacy of the interface with the State of Illinois. (Section P7)

• The inspectors completed Temporary Instruction 2515/134 "Onshift Dose Assessment" and verified that the licensee's capabilities met requirement (Section P9)

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, Report Details IV. Plant Suonort P1 Conduct of Emergency Preparedness (EP) Activities l

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P1.1 Actual Emamancy Plan Activation a. Insoection Scone (82701)

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The inspectors reviewed the three actual classifiable events which occurred since the last routine inspection. Also reviewed was the procedure for performing reviews of actual events.

l b. Observations and Findinas l An Unusual Event was declared at 7:00 p.m. on February 24,1997, when Zion i Unit 1 was unable to reach the mode of operation required by Technical Specifications. Unit 1 reactor coolant flow transmitters had been taken out of service on February 22,1997. Per Zion Technical Specification (TS) 3.1.3, the unit was allowed to remain in Hot Shutdown for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, after which it was required to be in Cold Shutdown within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The licensee's sequence of events indicated that Unit 1 was required to reach Cold Shutdown on February 24,1997, at approximately 2:45 p.m., but this was not recognized until 7:00 p.m. during TS review. Unit 1 was not able to reach mode 5 within the required time, which met Emergency Action Level (EAL) MU-10, " Technical Specification Time Limit Expired."

The event was terminated at 9:22 p.m. on February 25,1997, when the Unit entered mode 5 (cold shutdown) as required by TS.

f The review of the event conducted by the Emergency Preparedness Coordinator (EPC) noted that the Bulk Power Operations (BPO) officer did not answer the Illinois Nuclear Accident Reporting System (NARS) telephone. The Control Room Communicator had followed his procedure and subsequently contacted the BPO staff via commercial telephone, which was answered. Overall response was not significantly delayed, and this was not identified as a significant problem, although this failure was similar to an event which had delayed response at the Quad cities station during the May 10,1996 Alert. Despite the fact that there were no

, emergency plan or procedural requirements for this process, the licansee decided to I

take corrective action. Discussion with corporate personnelindicated that contracting with the Community Alert Network (CAN) would obviate the need for calling the BPO officer. The CAN equipment was described as in place and undergoing testing. Failure of the BPO staff to answer the NARS phone was documented on a Problem identification Form (PIF). Corrective actions in response to this PlF will be an inspection Followup item No. 50-295/304/97008-01.

, A second Unusual Event was declared at 11:10 a.m. on February 28,1997, when i

a U.S. National Weather Service " radiosonde" (weather balloon instrumentation l package) landed across the Unit 2 Switchyard System Auxiliary Transformer (SAT)

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disconnects. The presence of the parachute and attached device on the

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transformer was detected at approximately 8:45 a.m. and tentatively identified as a weather data gathering device. However, as the nature of the device was not

positively known, local police agencies and fire departments were contacted as a

! conservative measure. The Unusual Event was declared due to the unconfirmed

! nature of the device and the requests for offsite agencies to respond to the site.

I These conditions met EAL HU2, " Conditions Indicate Potential Degradation in the I Level of Safety of the Plant." The initial NARS notification form indicated "None" in l block 10 (" Additional Information"), which was inadequate to inform offsite

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i The initial callback from the State of Wisconsin Duty Officer to the Control Room at j 11:26 a.m. inappropriately received the response that no additional information j would be provided. The Wisconsin Duty Officer log / report for February 28,1997

indicated that the Duty Officer " told him that I had nothing under number 10.

Additional information. I asked if there was any additional information. He said, j "None that we're giving out."

) The inspectors contacted State of Wisconsin representatives to discuss the issu '

They indicated that the initial notification call went to a receptionist, who filled in the NARS form information. The form was then passed to the State of Wisconsin

Duty Officer, who called the station to verify the information on the NARS for The Duty Officer's procedure called for him to inquire whether any additional j information was available. The Duty Officer then called the State Radiological i Coordinator (SRC) whose duties included evaluation of more technically-oriented

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information and the situation assessment. The SRC called the station at j approximately 12:05 p.m. and obtained additional information. Wisconsin

representatives' stated that their perspective was that appropriate information had l been provided at the appropriate level, and that the initial responders' " choice of

words could have been better." Discussion with the Control Room Communicator j

indicated that there was a separate sheet of information to provide to individuals !

i that called back, but he was initially unaware of the shee '

l EPIP 190-2, " Communicators," Appendix A, " Zion Station - NARS Reporting i Instructions," provided guidance for completing the NARS form. Item 10 of I j Attachment A, "NARS Form, Instructions for Use," indicated that the individual

completing the form should, in the additional information section of the form, ,

j " provide additional information that will be helpful to personnel evaluating the event j (e.g., Unit Number)." The licensee had recognized that the communicator's  ;

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response was improper and had written a PlF. Corrective actions in response to this PIF will be an inspection Followup item (IFI) Nos. 50-295/304/97008-02.

i j A discretionary activation and transfer of Command and Control to the Technical j Support Center (TSC) took place at approximately 1:15 p.m. This was to support communications, reduce congestion in the Control Room, and aid in gathering facts

and response plan assessment. The switchyard was evacuated and entry to the

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relay house halted. The event was terminated at 10:15 p.m. when the device was a

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positively identified by a representative of the National Weather Service. The

! device was subsequently retrieved.

i i A third Unusual Event (UE) was declared at 4:18 p.m. on March 11,1997, when i Unit 1 lost offsite power for greater than fifteen minutes. Both units were in cold

shutdown at the, time of the event. The Station Auxiliary Transformer (SAT) had

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tripped due to the failure of a pressure sensor at approximately 3:53 p.m., causing loss of offsite power. The Unusual Event was appropriately declared in accordance

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with EAL MU-1, " Loss of All Offsite Power for a: 15 Minutes." Shutdown cooling ,

l was lost with the loss of offsite power. The diesel generators started, sequenced, !

l and supplied electrical buses as designed. Shutdown cooling was restored at !

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approximately 4:02 p.m.

At the same time offsite power was lost, commercial telephone service was also

! lost. The Emergency Notification System (ENS) and Nuclear Accident Reporting

] System (NARS) telephones remained available. Commercial telephone service was

) restored at approximately 6:19 p.m. The TSC was requested to be activated, a ,

j discretionary action at the Unusual Event level. Security personnel erroneously i

notified responding personnel that the plant had declared an Alert but referenced j the appropriate EAL of MU-1, causing some confusion. The TSC assumed

{ Command-and-Control of response to the event at 9:10 p.m. The Unusual Event !

i was terminated at 3:45 p.m. on March 15,1997, when a reliable power supply for j essential service buses was reestablished. An event time line from an emergency j preparedness perspective was developed and is attached as Attachment B.

i i The initial NARS notification form contained adequate information in block 10,

" Additional information," to acquaint offsite agencies with site events, including the fact that shutdown cooling had been restored. The termination NARS message also

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i During TSC response to this UE, a Plant Offsite Review Committee (PORC) was i being held in a room adjacent to the TSC. The Station Director visited this meeting

! during the response. Discussion with the EP staff and a review of documentation

! was performed to determine if the PORC meetings and discussions had negatively l impacted the Station Director or the overall activities in the TSC. A review of the l Station Director's log indicated little PORC involvement. The log also indicated that i eventr. had generally progressed slowly, so that individuals were not overstressed.

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The inspectors concluded that the PORC activities did not represent a significant

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activation of the TSC at the Unusual Event was discretionary, and events progressed slowly. At a higher event classification or under circumstances where events were progressing more rapidly, possible distractions to the Emergency Response Organization responders would have to be seriously considered and any such distractions removed if identifie Discussion with the EP staff indicated that there was no emergency plan requirement nor a formal procedure for the review of performance during actual classifiable events, nor to provide a summary report from the EP group to plant

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management describing the results of the review and performance during the event.

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An event review checklist provided in corporate guidance had been informally

utilized for event review. Actual emergency events provide opportunities to i evaluate the EP program and Emergency Response Organization response and to correct any identified weaknesses.

j Records reviewed indicated that the classifications were conservative, and

notifications had been made in a timely manner. From discussion with the NRC

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Senior Resident inspector, the two activations of the TSC had effectively reduced

! congestion in the Control Room. The documentation package for the first event was adequate; for the subsequent events, the documents retained were extensive

and were still being reviewed. Logs and other documentation for the response to

the failed SAT were highly detailed, and excellent lookeeping was evident.

l Conclusions

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! The inspectors concluded that the licensee had properly implemented the j emergency plan in declaring three Unusual Events. Conservative decisions were

made to activate the TSC for two evonts. The licensee's review of two of the !

l events was still in progres l

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P2 Status of EP Facilities, Equipment, and Resources  !

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P2.1 Material Condition of Emeraency Resoonse Facilities l

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!  ! losoection Scone (82701)

! The inspectors toured the Technical Support Center (TSC), Operational Support

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! Center (OSC), and Emergency Operations Facility (EOF) and assessed their material l condition. The field team monitoring kits were also inspected. The inspectors

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requested numerous pieces of equipment (survey equipment, computers) to be

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The Control Room was in good material condition with procedures available and i current. The FTS 2000 phone line had been tested within one hour of the facility j inspection and was operable.

! TSC material condition was excellent. All FTS phone lines were operable.

! Demonstrations were provided for three Offsite Dose Calculation System (ODCS)

} terminals using the B and C-models. All plant data monitors and Human

! Management Interface (HMI) plant process monitors were operable. Status boards

! were available and easily readable from most locations in the facility.

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The GSEP van was observed to be in excellent material condition. Supplies and l j equipment were available and operable. Instrument and air sampler calibration

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dates were current. The operability of the van and gasoline generators was tested.

l Procedures reviewed were current.

l The environmental emergency kits in the GSEP garage were inspected, and i problems were identified. Two of the equipment cases inspected were found to

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contain standing water. A leak in the building allowed rain to come into contact j with the cases and leak through the hinges. Supplies inside the kits were in various i

stages of wetness. A Problem identification Form (PlF) was initiated immediately i and the roof repair was initiated the next day. The EP staff discussed changing the

[ cases to be more resistant to weather and easier to carry. Licensee response to the j NRC inspector's observation was immediat ;

The EOF was generally in satisfactory material condition. Telephones, computer

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terminals, and other equipment were demonstrated to be operable. Supplies were i available, and the facility was in a very good state of readiness. However, the key

, to the EOF health physics cabinet was not in the facility. The lock had been

changed and the key had not been added to the key lock box. The EP Coordinator i corrected this by obtaining the correct key from the health physics group the next

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Control Room emergency preparedness implementing procedures and communica-

! tions equipment were current and operable. Form files containing notification forms I and checklists were well organized and current. No problems were identifie i

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During the NRC inspector's tour of the OSC, two OSC status boards (white boards) '

j were discovered on the third floor of the West Service building. The status boards l_ were not intended to be removed from the OSC for any reason, and were l

permanently labeled as GSEP equipment. The condition was quickly corrected by j having the status boards returned to the OSC.

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l Current copies of the Emergency Plan, Emergency Plan implementing Procedures

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(EPIPs), and appropriate forms were present in each facility, as required. Minor l additional enhancements intended to improve performance were noted in various

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facilities. No significant problems were identifie I

Records for Zion's prompt alert and notification siren system were reviewed by the

! inspectors. Documentation indicated that siren availability for 1996 averaged 97.4 i

percent, with the lowest month reported as 94.4 percent available. The everage

for 1995 was reported as 97 percent available, and the low month average was i reported as 92.4 percent available. These averages exceeded the criteria for l acceptability averaged over a 12-month period.

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i Overall, emergency response facilities were in very good material conditio ,

j Several minor facility enhancements were noted in each facilit !

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P3 EP Procedures and Documentation a. Insnection Scone (82701)

The inspectors reviewed a selection of licensee emergency procedures and EPIP Problem Identification Forms (PlF) assigned to the Emergency Planning Group were also reviewe b. Observations and Findinas Procedures EPIP 320-1, " Activation Of The GSEP Station Group,* Revision 12, and EPIP 600-1, "GSEP Responder Training Program," Revision 2, were reviewed. An inconsistency was noted in which EPIP 600-1 indicated that the Station Director's l approval was required for allowing a candidate to participate in an emergency l event, and EPIP 320-1 indicated that the approval of an " unqualified" individual to I be used for GSEP exercises or emergency events must be approved by the Station Director, Manager of Emergency Operations in the EOF or CEOF. However, NOD-t EP.02 provided for exceptions for unqualified personnel to participate in GSEP

exercises and candidates being used in actual emergencies as approved by the EP l Supervisors, Station Director, or Manager of Emergency Operations EOF or CEOF.

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A review of recent PlFs did not indicate any problems. Discussion with the EP

._ coordinator and EP trainer indicated that they had increased their usage of the PlF l

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system and their threshold for writing a PlF had diminished considerabl c. Conclusions

! Procedure reviews did not indicate any significant problems. Problem identification

! documentation indicated that the EP staff had significantly increased their usage of the PIF syste P5 Staff Training and Qualification in EP a. Insoection Scone (82701)

The inspectors reviewad the licensee's EP training program. This included interviews with selected key individuals and review of course critique forms, attendance records, and the Emergency Plan Telephone Book for emergency response organization (ERO) personnel. Records from the training tracking program l were compared with the Emergency Telephone Book (issued quarterly) to verify

that ERO personnel listed in the book were qualified. Additionally, selected training l instructor's guides were reviewed, including the Emergency Federal Response and facility walk through guides for the TSC, OSC, and the EOF.

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Records indicated that drills and exercises were formally critiqued. Training had been provided which included formal critiques, and selected critique items were documented for corrective action. Critique forms consistently indicated EP training was effective and showed improvement.

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An interview was conducted with an ERO member. The individual interviewed demonstrated knowledge of his emergency responsibilities and procedure The inspector observed one-on-one EP training for the B-model and C-model offsite dose assessment programs. The training observed was detailed performance-based training with the student practicing numerous dose assessments using multiple problem sets.

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l Key ERO personnel qualifications were verified as current by review of the GSEP l Callout Checklist and training documents (attendance records, tests, and critique forms). The GSEP Callout Checklist was updated and sent to security as changes in the plant staffing occurred. The checklist was the document that was used to update the callout system for declared emergencies or drills. Also, there was a GSEP Callout Checklist provided in EPlP 320-0, " Activation Of The GSEP Station Group," which was updated quarterly. All key ERO personnel reviewed were i

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currently qualified for their position A policy statement in Emergency Planning Guidance Recommendation (EPGR) TR-l 0201, " Emergency Preparadoass Training Administrative and Course Mariagement i

Information," Revision 5, indicated, "!! an individual's GSEP training requiraments are not met, the EP Coordinator and Station Manager shall be notified in writing by the EP Trainer." This guidance had not been the practice of the EP staff in the l past; however, discussion with EP personnel indicated their intent to imploraent this polic The inspectors reviewed training modules S-5, " Assessment, Classification, and Notification," dated July 19,1996, S-25, "TSC ODCS Specialist," dated June 19, 1992; and S-100, "'A' Model Training," dated August 7,1991. Two of these training modules reviewed (S-25 and S-100) had not been revised for over four year Conclusions Overall, the EP training program was considered good, and included drills which provided performance-based requalification training for the ERO personnel. Critique documentation was available, and critique forms were adequately detailed. Training records were complete, and an interviewed individual waa knowledgeable about his ERO responsibilities.

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P6 EP Organization and Administration (82701)

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The inspectors conducted discussions with the EP staff regarding the current station organization and reviewed the current organizational chart. Portions of a recent consultant's report dealing with the station's EP organization were reviewe The Health Physics Supervisor was interviewed.

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b. Observations and Findinos The overall organization and management structure of the EP function was unchanged from the last routine inspection and was unaffected by the broader l reorganization. The Emergency Planning Coordinator (EPC) and EP Trainer reported directly to the Health Physics Supervisor /RP Manager, who reported to the Plant General Manager, who reported to the Site Vice President. The EPC retained responsibility for the Radiological Environmental Monitoring Program (REMP), the Meteorological Tower, and the Severe Accident Management (SAM) program. The SAM program had required considerable resources in recent month The Zion Station had reorganized to a " unitized management structure." The organization included a Plant General Manager / Plant Manager reporting to the Site Vice President and a Unit Manager, Operations Mrsger, and Maintenance Manager for each unit. The Unit Managers reported to the Plant General Manager / Plant Manager. The EPC had performed a 10 CFR 50.54(q) review, per CEPIP 1000-05 and determined that the change did not represent a decrease in the effectiveness of the Emergency Plan. Numerous changes in plant staff had occurred in recent months, such that the GSEP Callout list, implemented by security officers in case of an event, required frequent revisions to keep track of changing plant staf Discussion with the Health Physics Supervisor indicated that his primary emphasis had been the plant radiological protection program, such that the two individuals involved in the Emergency Preparedness program were running that program on their own. Additional discussion with the EP Coordinator and EP trainer confirmed that line management attention to the EP program was lacking.

c. Conclusions The structure of the EP function was unchanged from the last routine inspectio The EP Coordinator had properly performed a review and determined that the site organization changes did not represent a decrease in the effectiveness of the Emergency Plan. While the overall EP program was considered to be good, as noted in other sections, line management attention to the program was found to be lacking.

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! The audit checklist and record sheet provided for verification of offsite interfaces with state and local agencies. The method for selection of agencies to contact ,

included a review of letters of agreement and the list of interfaces in the GSE l l However, the NRC inspectors noted that the contacts evaluated were local and I county personnel only. Contacts with state representatives were not documented; l therefore the scope of the evaluation was inadequate. Discussion with licensee l audit staff indicated that other contacts were made with state of lilinois representatives but had not been formally evaluated. Licensee personnel indicated that interface with State of Illinois authorities would be best evaluated at the I

corporate level. This was identified as a Violation of 10 CFR Part 50.54(t), as j described in the attached Notice of Violation. (Nos. 50-295/304/97008-03)

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) The inspectors reviewed the Emergency Preparedness Program Peer Review report

! for the Peer Review conducted October 14-17,1996. The base document for this l review was NRC inspection module 82701. The Peer Review concluded that "the l Zion EP program is maintained in very good condition. Changes over the last two l years have been implemented at the station to continuously maintain and improve l the program." The Peer Review also evaluated the Zion UFSAR Section 13.3, l " Emergency Planning," and identified a word processing discrepancy whereby the

final third of a paragraph in Section 13.3.2.2.5 was missing. A PlF and QA Tracking Number were generated to document this discrepancy.

l The inspectors also reviewed a special assessment of the Zion EP program j

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performed by five individuals from Paradigm Consulting Services, Inc., during the l l period February 24,1997 through March 7,1997. The report was formally issued l i

March 13,1997, and was still in the review and response process at the site. As a i

, result, none of the findings of the report had yet been placed into the corrective I l action program. The special assessment resulted in findings of four strengths, five issues of concern, and sixteen improvement items. The five issues of concem  :

i included lack of line manager oversight of the program, lack of senior management l l representation in the ERO, the EP staff not utilizing the PlF program, training deficiencies, and call-out list concern l The'1995 and 1996 audits of the EP program generally satisfied the requirements

, of 10 CFR 50.54(t) with respect to scope. Considerable review of the program had l l taken place in 1996, including the annual review, Peer Review, and consultant's

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assessment. Discussion also indicated that the licensee had fulfilled the

requirement to make relevant audit results available to State and county officials.

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The licensee's 1995 and 1996 audits of EP activities were generally effective and 1 satisfied the requirements of 10 CFR 50.54(t). Considerable review of the program j had taken place in 1996, including the annual review, Peer Review, and consultant's assessment. A violation was identified for failure to adequately l evaluate the offsite interface during the 1995 and 1996 annual reviews of the l

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P7 Quality Assurance in EP Activities

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P7.1 Audits (82701)

j Inanection Scone (82701)

i i The inspector reviewed Quality Assurance Department Audits which have been l performed since the last routine inspectio Observations and Findinas

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The inspectors reviewed Zion Site Quality Verification Audit QAA 22-95-04, j " Generating Station Emergency Plan," dated July 28,1995. This audit was

conducted by four individuals with an observer between June 12,1995, and i June 27,1995. Two Corrective Action Requests resulted from the audit, related to

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training and equipment inventories. The audit concluded that the " Station

maintains a sound GSEP program." However, the audit also noted that tho

deficiencies were " indicators that the program may have slipped over the last year."

The audit included a review of the adequacy of offsite interfaces, and assessments ,

l of interfaces with the State of Wisconsin and local governments were performed.

An evaluation of the adequacy of offsite interface with the two State of Illinois

< agencies, Illinois Department of Nuclear Safety (IDNS) and the lilinois Emergency j Management Agency (IEMA), were not conducted.

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The inspectors reviewed Site Quality Verification OAA 22-96-08, " Audit of

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Generating Station Emergency Plan (GSEP)," dated July 25,1996. The audit was j conducted by two individuals between June 24 and July 1,1996, and resulted in j one finding. Field Monitoring Report conclusions were summarized and

incorporated into the audit report. The audit concluded that the station met j regulatory requirements and continued to maintain a sound GSEP program.

Records and procedures were reviewed, and drill performance was observed and

evaluated during the audit. A short, standardized questionnaire was utilized for

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interviews with offsite authorities in assessing the adequacy of offsite interfac l The Audit checklist and record sheet also provided for assessment of self-l assessment methods partially by determining whether conditions adverse to quality

! are identified through the appropriate corrective process such as the PIF progra At the time of the audit the EP staff had issued two PlFs relative to GSEP van l

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maintenance. Backup documentation (objective evidence) for the audit was highly j detailed and comprehensive. The overall audit effort was adequat ;

i The 1996 Zion EP audit contained an evaluation of the effectiveness of offsite j interfaces as required by 10 CFR 50.54(t). Evaluation of the adequacy of offsite j interface had been accomplished by review of training records, face to face or j telephone interviews, review of communications drill records and observation of a communications drill. A standardized list of questions had been utilized during the j interview !

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P8 Miscellaneous EP lasues

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j (Closed) Insoection Follow-uo item 50-295/304/95005-01: Need for development

of a procedure for the Recovery Phase: EPIP 100-3, " Recovery and Termination,"

j Revision 2, contains adequate guidance for the entry into the Recovery phase of an

! accident. Discussion indicated that corporate personnel were working on additional

guidance for actions during the Recovery phase which would be applicable to all

stations. This item is closed.

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(Closed) Insoection Follow-uo item 50-295/304-95008-03: Improvement needed in

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timeliness of NRC notification. The training module for communicators included l guidance that the NRC notification will occur as soon as possible following State i and local notifications, but within one hour in any case. This item is closed.

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) (Closed) Insoection Followuo item 50-295/304/93012-01: Plant emergency I announcement procedure needed to include more information. EPIP 100-1, " Acting Station Director / Station Director," Section G.7.a, provides guidance that a plant

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announcement shall be made of the GSEP classification, including the reason for the

classification. Attachment "1" to this procedure also included this guidance as

checklist item "l." This item is closed.

l P9 Temporary instruction 2515/134 Onshift Dose Assessment i

a. Insoection Scone l~ The inspector discussed onshift dose assessment capability and provisions with licensee personnel, reviewed the Emergency Plan and Emergency Plan Implementing

Procedures (EPIPs), and inspected the equipment utilized for dose assessment.

t I b. Observations and Findinas

] The Generating Stations Emergency Plan (GSEP), Section 7.3.3 "Offsite Dose Calculations," addressed dose assessment capabilities. The GSEP indicated control room personnel would rely on the Class A computer model (A-model) for offsite dose assessmen Zion and the other Comed sites used three dose assessment models:

A-model: Ran continuously with control room printout B-model: "MESOREM96," primary accident offsite dose model C-model: Utilized to back-calculate releases from field team measurements Procedure EPIP 100-1, " Acting Station Director / Station Director," dated April 15, 1996, described control room response to determine protective action recommendations by using an attached gaseous release conditions table and ODCS A-modelinformation, if available. If the A-model was not available, Health Physics would be requested to perform dose assessmen . - . _ ~ - . _ ~ - _ _ - ~. - . - . -..-_._ - .. . .. - .. - - . . . . - - . . - . - - --

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The A-model system was designed to run continuously, assessing containment I radiation levels, vent stack release rates and meteorological conditions, comparing l them with appropriate Emergency Action Level (EAL) values. The program would

then provide an event classification, downwind dose and dose rate projections at  :

j predetermined distances. The system would automatically print out alarm  !

messages, informational messages and reports in the control roo Procedure EPIP 180-4, "TSC ODCS Specialist," dated October 24,1994, provided TSC ODCS Specialist responsibilities for using the ODCS computer models during l t an emergency.

Procedure EPlP 350-1, " Preliminary Calculation Of Station Noble Gas Release Rate l l To Determine GSEP Classification," dated December 20,1996, provided a method

to estimate a noble gas release rate when the A-model was unavailable. This l procedure could provide release rates for noble gas releases from the Auxiliary

{ Building, Containment Vent / Purge, Air Ejector, Gas Decay Tank, and Steam l Generator Relief Valves.

Procedure EPIP 350-1 A, " Calculation Of Station Noble Gas Release Rate and Release Quantity," dated April 26,1993, provided a followup, detailed calculation method to estimate noble gas release rates and quantities once the initial release rate and classification had been completed using EPIP 350-1 and 330-1,

" Classification Of GSEP Conditions."

Procedure EPIP 350-2, " Calculation Of Noble Gas Release Rates Via The Vent Stacks Using SPING Monitor RIA-PR49 Readings," dated August 3,1994, provided a method to calculate noble gas release rates using Vent Stack SPING monitors to {

determine accident classification and offsite dose projection Procedure EPIP 350-5, "A-Model Status And Interactions," dated July 9,1996, provided control room methodology for use of the Offsite Dose Calculation System Control Room (ODCSR) Progra Procedure CEPIP 3220-01, " Dose Assessment B-Model, (MESOREM96, Revision l 2)," dated October 10,1996, provided guidelines for the B-Model computer code which can be used for environs radiation dose assessmen i Training module S-5, described the A-Model and B-Model offsite dose calculation systems for making dose projections and the differences. Questions and notes were included in the informative module outline. The A-Model program was also discussed for control room personnel, items discussed included the release points that are continuously monitored, the four hour report, and the system alarm Training module S-25, described the TSC ODCS Specialist's equipment, responsibilities, initial actions, procedures, and interface Training Module S-100, described the A-Model program, which included the purpose, requirements, capabilities, and plant parameters monitore _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ -. _ .

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The Emergency Plan and EPIPS contained provisions for onshift dose assessment.

l Needed equipment and personnel training were provided. Personnel were  !

l knowledgeable of their responsibilities and how to perform dose assessment. The

acceptance criteria for the Tl were met and this Tl is closed. Docurnentation as to these findings is attached as Attachment A.

P10 Review of UFSAR Commitments l

l Insoection Scone l A discovery of a licensee operating its facility in a manner contrary to the Updated Final Safety Analysis Report (UFSAR) description highlighted the need for a special focused review that compares plant practices, procedures, and parameters to the UFSAR descriptions. While performing the inspections discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to Emergency ;

Preparednes I Observations and Findinas UFSAR Section 13.3 pertains to Emergency Planning. Section 13.3.2, " Emergency Plan" correctly indicated that emergency and evacuation procedures have been ,

developed for Zion, implementing the Generating Stations's Emergency Plan (GSEP). l Also referenced was the Zion annex to the GSEP. Section 13.3.2.1 addressed i Supervision in emergencie i Other subsections of Section 13.3.2, while apparently correct, were not directly related to Emergency Planning. These included Sections 13.3.2.2, " Site Radiation Incidents," 13.3.2.2.1, " Abnormal Personnel Exposures," 13.3.2.2.2, " Accidental Releases of Radioactivity," 13.3.2.2.3, "High Radiation During Fuel Handling," l 13.3.2.2.4, " Personal injuries," 13.3.2.2.5, "High Radiation Evacuation," and Section 13.3.2.2.6, " Action To Be Taken in The Event A Safety Limit is Exceeded."

As noted in report Section P7.1, the UFSAR was also reviewed during the Peer Review conducted at Zio Corporate EP personnel had developed a generic UFSAR Section 13.3 applicable to all six nuclear generating stations, which provided reference to the GSEP and the Emergency Planning aspects of classification, notifications, facilities, and trainin The section had been reviewed to ensure it met regulatory requirements and ,

removed unnecessary verbiage. Discussion indicated that this generic section would be placed into the Zion UFSAR in the near futur Conclusions Overall maintenance of the Emergency Preparedness sections of the UFSAR was excellent. Licensee actions were consistent with UFSAR commitment _- -. - _ - - _ _ . . _ - - - _ . .. _ . .. _ _ _ . ..

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V. Manaaement Meetinas

X1 Exit Meeting Summary

l The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on March 21,1997. The licensee acknowledged the findings

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presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie Attachments: 1. Form For Documentation of On-shift Dose Assessment j 2. Short Chronology of Events During Loss of Station Auxiliary Transformer

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PARTIAL LIST OF PERSONS CONTACTED Licensee R. Starkey, Plant General Manager R. Godiev, Regulatory Assurance Manager R. Smith, Regulatory Assurance L. Lanes, Emergency Preparedness Coordinator R. Johnson, Emergency Preparedness M. Vonk, Nuclear Operations Department, EP D. Stobaugh, Corporate EP G. Schwartz, Site Quality Verification W. Stone, Regulatory Assurance

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L. Minejevs, Site Quality Verification i R. Smith, Regulatory Assurance J W. Strodi, Health Physics Supervisor

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HEC Anton Vogel, Senior Resident inspector, Zion Eugene Cobey, Resident inspector, Zion Desiree Calhoun, Resident inspector, Zion l INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program Tl 2515/134 Temporary Instruction, Onshift Dose Assessment ITEMS OPENED AND CLOSED l Ooened 50-295/304/97008-01 IFl Bulk Power Operations officer did not answer the NARS telephon /304/97008-02 IFl Corrective actions on Communicator responsa to

Wisconsi /304/97008-03 VIO Lack of evaluation of adequacy of offsite interface in annual EP program review, i

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l Closed l 50-295/304-95008-03 IFl Timeliness of NRC notificatio i 50-295/304/93012-01 IFl Announcement procedure to be modified.

i i 50-295/304/95005-01 IFl Procedure for Recovery Phase,

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LIST OF ACRONYMS USED l

CANS Computerized Automated Notification System l CEOF Corporate Emergency Operations Center l CEPIP Corporate Em6 gency Plan implementing Procedure )

, CFR Code of Federal riegulations i

EAL Emergency Action Level i

EP Emergency Preparedness l EPC Emergency Planning Coordinator ENS Emergency Notification System i EPGR Emergency Planning Guidance Recommendation EOF Emergency Operations Facility EPIP Emergency Plan implementing Procedure ERO Emergency Response Organization i GSEP Generating Stations Emergency Plan HMI Human Management Interface IDNS lllinois Department of Nuclear Safety LEMA lilinois Emergency Management Agency IR Inspection Report IFl Inspection Followup Item MESOREM96 lilinois Dose Assessment Computer Program NARS Nuclear Accident Reporting System l NRC Nuclear Regulatory Commission l NUREG Nuclear Regulatory Commission document OSC Operational Support Center PORC Plant Offsite Review Committee PlF Problem identification Form i SAM Severe Accident Management SAT System Auxiliary Transformer SRC State Radiological Coordinator

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SOV Site Quality Verification TS Technical Specification TSC Technical Support Center

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UFSAR Updated Final Safety Analysis Report

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ATTACHMENT A FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY ,M#*

Zion / Units 1 & 2 /50-295. 50-304 Commonwealth Edison Company (Comed) 10/16/96 SITE / UNIT / DOCKET #s LICENSEE DATE 4.01 . DOSE ASSESSMENT COMMITMENT IN EMERGENCY PLAN Acceptance Criteria Person (s) Contacted Position Title (s) Plan Secten Revision N Meets acceptance (Refer to page 1 of this Appendix for containing and Date criteria?

further detail on the acceptance criteria) commetrrent Section 4.01 Item 1 Lee Lanes EP Coordinator GSEP 7. Rev.7F Ye Emergency Plan contains commitment for on- 11/20/95 shift dose assessment capabilit Section 4.01 Item 2 Lee Lanes EP Coordinator GSEP 7.3.3, would Rev.?! Yes.

j Emergency Plan contains commitment for call personnel to use 11/20/96

backup dose assessment capabilit "B" model

GSEP 6.3.1, PAR flowchar .02 ON-SHIFT DOSE ASSESSMENT EMERGENCY PLAN IMPLEMENTING PROCEDURE -

Ferson(s) contacted Position Title (s) Procedure / indication Revision N Meets acceptance and Dato criteria?

Section 4.02 Item 1 Lee Lanes EP Coordinator EPIP 100-1; " Acting Re Ye Procedure initiates dose assessment Sta Dir.", section 04/15/96 G.3.b, & table 6.3-1, 350-5, "A-model*.

Section 4.02 Item 2 Lee Lanes EP Coordinator None "A model" N/A Ye Indications initiate dose assessment operates continuously, unless INO Section 4.02 Item 3 Lee Lanes EP Coordinator EPIP 350-1, " Preli Rev.6, Ye Procedure for performing dose assessment Noble Gas Rel. Calc."; 9/25/92; availabl , " Calc Noble Rev.1, Gas Rei Via Vent"; 4/26/93; 350-1 A, " Calc Noble Rev.0 8/3/94 Gas Rel. Rate.", 350- Rev 2,4/96, 5, "A-model";CEPIP Rev 8,2/96 3220, CEPIP 3502-01 04.03 ON-SHIFT DOSE ASSESSMENT TRAINING Person (s) contacted Position Title (s) Personnel Treened Meets acceptance (Title /#) criteria?

Section 4.03 Item 1 Lee Lanes EP Coordinator On - Shift SROs, N/A Ye On-shift Personnel trained for dose assessment SCREs, Unit Supts.,

Shift Engineers; approx. 24 individuals inspector: James E. Foster. Reaion Ill. DFS. Plant Sunoort B _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _