IR 05000295/1997029
| ML20198K836 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 01/09/1998 |
| From: | Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198K792 | List: |
| References | |
| 50-295-97-29, 50-304-97-29, NUDOCS 9801150110 | |
| Download: ML20198K836 (13) | |
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. U. S. NUCLEAR REGULATORY COMMISSION -
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REGION lil:
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Docket Nas:?
. 50-295:50-304 License Nos:
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Repyt Nos:
50-295/97029(DRS); 50-304/97029(DRS)
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Commonwealth Edison Company (Comed).
Ucensee:
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Facility:
Zion Generating Station, Units 1 & 2-j d
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Location:
101 Shiloh Boulevard
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. Zion, IL-60099 i
Dates:
December 2-5,1997 j
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.j Inspectors:
James Foster, Senior Emergency Preparedness Analyst i
linmas Ploski, Emergency Response Coordinator
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Robert Jickling, Emergency Preparedness Analyst Donatid Funk, E7mrgency Preparedness Analyst Eugene Cobey, Acting Senior Resident inspector
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4-Approved by:
James R. Creed, Chief, Plant Support Branch 1
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Division of Reactor Safety
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9901150110 990109
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PDR ADOCK 05000295
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EXECUTIVE SUMMARY Zion Generating Station, Units 1 & 2 NRC Inspection Reports No. 50 295/97029; 50-304/97029 This inspection conslated of evaluation of the licensee's performance during the plant's biennial exercise of the Emergency Plan. It was conducted by regional emergency preparedness inspectors and resident inspector staff from Zion. No violations of NRC requirements were identified.
Plant Sucoort Overall performance during the 1997 Emergency Preparedness exercise demonstrated that emergency plan implementation was effective. Licensee personnel demonstrated their abilities to implement the plan by cc,,;tly classifying scenario emergencies, notifying offsite agencies of classified events, activating emergency facilities, providing protective action recommendations when warranted, and taking accident mitigation actions. Interfacility transfers of command and control of event response were orderly and timely.
The Control Room Cimulator crew effectively used abnormal operating procedures and
assessments of Technical Specifications ia their well-coordinated responses to degrading plant conditions. (P4.1.b.1)
The Technical Support Center (TSC) staff's responses were well-coordinated and
effectively addressed protective actions for onsite personnel as well as degraded equipment. (P4.1.b.2)
Operations Support Center management effectively used available resources and
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correctly understood revised priorities determined by TSC decision makers in response to changing plant conditions. Inplant teams were effectively briefed and debriefed on their assignments and associated radiological concems. (P4.1.b.3)
Emergency Operations Facility (EOF) responders effectively communicated with State
counterpartL on offsite protective actions, offsite dose projections, radiological survey results, and degraded plant conditions. The possibility of evacuating the EOF was thoroughly assessed. (P4.1.b.4)
The scenario was very challenging. While overall ei. ctse control was adequate, the
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inspectors noted several deficiencies with the control cf the exercise and the over-simulation of activities. (Section P4.1.b.5)
The licensee's self-assessment was in close agreement with the NRC evaluation team's
conclusions. (Section P4.1.b.5)
Event classifications were correct and timely. Offsite notificaSons and offsite protective
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action recommendations were also correct and timely. Inplant activities were properly prioritized. Transfers of command and control were orderly and timely. (Section P4.1.c)
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Report Details IV. Plant Sunnort
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P3.
Emergency Properedness Procedures and Documentation P3.1 Review of Exercise Oblectives and Scenario (82302)
The inspectors reviewed the 1997 exercise objectives and scenario and Jetermined that they were acceptable. The scenario provided an appropriate framevork to support -
demonstration of the licensee's capabilities to implement its emergency plan.- The scenario included a radiological release and several equipment failures, The 1997
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scenario was especially challenging in that significant emergency conditions existed at both units simultaneously.
P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 1997 Eval; Agd Biennial Emergencv Precaredness Exercise
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a, insoeciion Scoce (82301)
On Decemb3r 3,1997, the licensee conducted a biennial exercise involving the States of Illinois and Wisconsin and the local counties of Lake (Illinois) and Kenosha (Wisconsin) This exercise was conducted to test major portions of the onsite and offsite emergency response capabilities, Onsite and offsite emergency response organizations and emergency response facilities were activated.
The inspectors evaluated performance in the following emergency response faci!ities:
Control Room Simulator (CRS)
e Technical Support Center (TSC)
e Operational Support Center (OSC)
Emergency Operations Facility (COF)
The inspectors assessed the licensee's recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, developtrent of protective action recommendations, command and control, communications, and the overall implementation of the emergency plan. In addition, the inspectors attended the post-exercise critiques in each of the above facilities to evaluate the licensee's self-assessment of exercise performance, b,
Emergency Resoonse Facility Observations and Findings b,1 Control Room Simulator (CRS)
Overall performance in the CRS was very effective. The Shift Manager (SM), who becomes the Acting Station Director upon classification of an emergency, maintained
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effective command and control of CRS activities. Th SM kept the Unit 1 crew well informed of the bases of his decisions and priorities related to either or both Units, including his emergency declarations and several possibilities that would either warrant
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operator actions or emergency reclassifications for either Unit.
The SM and Unit 1 Supervisor expected that they and other CRS personnel utilize 3-way communication " repeat backs" to better ensure that all verbal communicatior's were correctly understood. On several occasions, the consistent use of this " repeat back"
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technique by various CRS personnel was effective in promptly identifying and correcting misstaternents before related actions were initiated.
The SM frequently reviewed the Station's proceduralized Emergency Action Levels (EALs) and quhkiy and correctly classified an Unusual Event and an Alert related to Unit 2. The SM ensured that communicators initiated related notifications of licensee, NRC, and offsite organizatbnc and approved associated message forms. Although the NRC resident inspector was notified of the Alert declaration, the resident inspector was not notified of the earlier UnuJual Event declaration.
The SM was well aware of the potential to declare an Unusual Event for Unit 1 oue to a possible fire in a cable spreading room, which was later determined by the Station's fire brigade to be an apparent false actuation of a fire detector. As a result of degraced pov.'cr supplies to Unit 2 and (no possible fire affecting Unit 1's equipment, the SM made a prudent and cor.servative decision to activate the TSC and OSC while the highest emergency classification remained an Unusual Event, so that add!tional Station resources could be hsed on these situations.
As degraded ccnditions were reported for Unit 2 and as requested by the Ur.it i Supervisor, the STA assessed the Technical Specifications and briefed the SM and Unit 1 Supervisor on his sssessments. On several occasions, reviews of Unit 1 Technical Specifications and implementation of an Abnormal Operating Procedure were correctly recognized as justifying a decision to trip the Unit i reactor. On these occasions, exercise controllers blocked decisions by the SM and Unit 1 Supervisor to trip Unit 1 in order to allow the exercise scenario to continue as designed. Early tripping of the reactor would have substant! ally reduced the radioactive release included as a subsequent portion of the exercise. The operators demonstrated conservative decisionmaking in their determinations to trip the reactor; Appropriate State agencies were initially informed of the SM's Unusual Event and Alert declarations within the regulatory time limit through the communicator's use of the State's proceduralized message form and a dedicated communications link. However, the communicator initially did not follow avcilable gul dance and initla!!y contacted lowa officials after the Unusual Event declaratiori. The cominunicator soon corrected his error and made use of the available guidance when making this and subsequent initial notifications of Illinois and Wisconsin officials within the regulatory time limit. Correct use of the notification procedure and checklist was an inspection Followup Item (IFl 50-295/97029-01 and 50-304/97029-01).
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The Shift Assistant (SA) exhibited difficulty in preparing an initial notification message to the NRC Headquarters Operations Officer following the Unusual Event declaration. The SM provided valuable assistance in compos;ng the message form's event description.
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The Radweste Foreman dcmonstrated good teamwork by helping the SA respond to l
several questions from the simutated NRC Headquarters Operations Officer as the SA
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transmitted the Unusual Event report, such as correcting minor errors,
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The Radwaste Foreman later activated the Emergency Response Data System, which -
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would transmit computerized data to NRC Headquarters, within 20 minutes of the Alert declaration, well within the one hour requirement, The transfer of command and control from the SM to the TSC's Station Director (SD)
was completed in an orderly manner within one hour of the decision to activate the TSC.
The SM informed the Unit 1 crew of this transfar of lead responsibilities, The SM later informed CRS personnel when the SD declared a Site Area Emergency and when the SD transferred command and control of event response to the Corporate Manager of
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Emergency Operations (CMEO) located in the Oc ) orate Emergency Operations Fac;lity (CEOF-)in Downers Grove, Illinois, b.2 Technical Suonort Center (TSC)
Overall performance by the TSC's staff was effective. Participants were professional and maintained their focus on the emergency throughout the exercise.
TSC activation was rapid and well coordinated. As the first five or six emergency responders arrived at the facility, they Immediately signed in on the staffing status board, obtained their emergency procedures, and established communications with
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counterparts to obtain a current status of the omergency conditions and plant status, The transfer of command and control for emergency responsibility from the SM to the SD in the TSC was smooth and efficient, The transfer had little impact on staff in the facility; everyone was awara of the transfer and information into and out of the facility was uninterrupted.
The SD maintained effective command and control of the facility's staff and their activities during the entire emergency response. Frequent facility briefings were very structured and thorough. All staff personnel were involved in the briefings and provided appropriate information. Side conversations or phone discussions wore terminated for the briennge, which m!nimized any potential d!stractions. Occesional updates were appropriately used to provide the TSC staff with significant changes to the emergency conditions,
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The SD demonstrated appropr ate concern for plant personnel safety when an explosion was reported in the Turbine Building by requesting the area be searched for casualties, A request for search of potentially injured personnel was prioritized immediately after the explosion report.
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The Operations Director pro-actwely monitored the Emergency Action Levels (EAls)
and identified potential event paths which could escalate the emergency classification.
The SD correctly declared the Site Area Emergency in a timely manner following further degrades in plant conditions. In depth plant status discussions were conducted by the Technical Director, Operations Director, and the Maintenance Director and were summarized during facility staff briefings.
The Environs Director and other key TSC staff gave appropriate concem to simulated
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meteorological and radiological conditions when choosing appropriato evacuation routes for non emer00ncy workers. Frequent dose projections were run on the computers after the radiological release was reported and meteorological data was continually updated.
Status boards were promptly initiated and continuously updated. Entries were accurate and clearly legible from alllocations in the TSC. The computerized Significant Events Log was effectively used to track and disseminate information to the other emergency response facilities.
The transfer of command and control for emergency responsibility from the SD in the TSC to the Corporate Manager of Emergency Operbtlons in the Corporate Emergency Operations Facility (CEOF) was smooth and efficient. The CEOF takes overall responsibility for command and control of the utility response to an emergency until the Emergency Operaticns Facility is adequately staffed and ready to take over these responsibilities, b.3 DaciallonaLSupDDILCenter (OSC)
The overall perforrnance of OSC management and staff was competent. The OSC was fully staffed and operational, at the request of the Control Room, following the Unusual Event declaration. Staffing was in accordance with the onsite emergency plan and governing implementing procedure. The initial sign in process and access control worked well.
The OSC Manager demonstrated very effective command and ::ontrol of the facility.
Briefings were frequent and informative. He established clear prioritization to tasks as the scenario changed and informed the staff of changing priorities. A positive example was when Task 17 was assigned an " urgent" priority and, while preparing for team dispatch, a second " urgent * priority task was received in the OSC. The OSC Director immediately realized that the second " urgent * priority Tesk 19, was the stations' highest priority and redirected Task 1'T to Task 19. Internal OSC communications, as well as communications between OSC and TSC personnel, were effective.
No'so levels within the OSC were higher than ideal at times, and numerous discussions unrelakd to exercise events were noticed. However, the reduced attention on the part of the USC responders dlJ not impact the effectiveness of their response.
Status boards were consistently well maintained and effectively used to track personnei in each technical discipline who were available for assignment to emergency response
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teams. Provisions for reviewing radiation work permits, issuing dosimetry and establishing dose limits were effective. Simulated exposures received by response team members were effectively tracked. Respiratory certifications were tracked by a computerized tracking system.
The priority assigned to each response team by the TSC was clearly understocd by OSC ma,sagement and communicated to OSC personnel. Response team briefings were concise and included current information on relevant exercise radiological and plant conditions. Team leaders were designated and Radiation Protection Technicians (RPTs) were assigned to teams, to constantly monitor radiological exposures. Upon
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return to the facility, teams were adequately debriefed and asked to report any unexpected conditions encountered. Briefings and debriefings were documented according to procedures.
Radiation Protection practices were proactive in support of the OSC. Habitability surveys were continuously conducted from the activation of the OSC. A radiological controlled area was established when the potential of a radiological release became possible due to degrading plant conditions.
The inspectors observed selected emergency retponse teams dispatched from the OSC and noted that: (1) the briefings for the assigned tasks were thorough; (2) the expected radiation levels, stay times, and routes were determined prior to the teams' departure frrm the OSC; and (3) the teams exhibited teamwork. However, the Irispectors also noted that the communication between the response teams and the OSC was hampered by a licnited supply of radios and radio communication difficulties. Inplant teams compensated, per procedure, by the use of the in plant phone system. Licenseo personnel indicated that an evaluation of the plant radio system was planned.
Early in the exercise, the licensee could have pcid more attention to returning the *0" emergency diesel generator (EDG) to service. Specifically, in response to the loss of offsite power on Unit 2 and.the failure of the *0" EDG, an " urgent" priority emergency response team was sent to investigate. Prior to the team's departure, the team was granted permiscion to use the "2A" EDG output breaker, which was out-of service for this exercise, to replace the "0" EDG breaker if the breaker was the cause of the failure.
The team found that the *0" EDG breaker failed to closo due to damaged closing coil wiring, informed the OSC of the result of their troubleshooting activities, and recommended the replacement of the breaker. The OSC then redirected the team to another " urgent", but higher priority '.ask without acting on the team's recommendation.
Following the completion of the second task, the team returned to the OSC and was debriefed. The OSC did not initiate additional action to replace or repair the *0" EDG output breaker, as other tasks were viewed as of higher priority. Repair of this breaker would have been prudent and appropriate. The licensee determined replacing the breaker had been overtaken by ot' er activities.
The inspectors also noted that a t.PT directed an emergency response team cuiside the plant buildingt in order to avoid traversing a short distance through a 100 mrem /hr field.
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The RPT apparer Uy believed that this route would result in lower individual radiation
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dose. However, tre scenario included a release in progress, with the wind from the-
South. Building wao effects could have created localized unknown radiological
conditions. The tearn's electronic dosimetry would have alarmed if elevated radiation -
levels were encountered by the team after they exited the building. The inspectors concluded that this decision was questionable, since it re' *lted in valuable time being
lost with little potential dose saving
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b.4 Emergencv.Onerations Facilltv (EOF)
The near site EOF was activated following the Site Area Emergency declaration, by personnel from the licensee's corporate office and other nuclear stations who were
prestaged in the local area. EOF personnel performed their duties very effectively, Upon arrival, EOF personnel efficiently obtained needed procedures and other
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principal assistants.
i Following a teleconference with TSC and CEOF counterparts Eoc taff received a s
detailed initial briefing by senior EOF personnel and were advised of the MEO's
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Aftar another thorough discussion with TSC and CEOF counterparts and receiving
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assurance that all EOF staff were ready to assume their responsibilities, the MEO I
assumed command and control of the event response. EOF staff, as well as Illinois and Wisconsin senior officials responding from their response facilities, were promptly advised of this transfer of command and control.
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Status boards and periodic briefings by the MEO's principal staff were very effective in keeping all EOF staff informed of changing plant conditions, associated revisions to accident mitigation priorities, and EOF habitability. Functional group leaders effectively i
participated in ther ) briefings, including a public informatien officer. Inputs or questions from EOF staff were encouraged during briefings.
After receiving sufficient verifications of further degradation in Unit 1 conditions, the MEO quickly and correctly declared a General Emergency. Protective measures staff i
efficiently formulated an associated offsite Protective Action Recommendailon (PAR).
While the associated General Emergency message form was being communicated to the states' communicators within the regulatory time limit, the MEO contacted the states'
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decision makers to provide more detailed information on the bases of this emergency re-classification, the PAR, and to respcnd to any questions.
The MEO and his principal aides maintained frequent communications with TSC and CEOF counterparts, as well as with state officials. During these communications,
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Information was shared related to onsite and offsite protective measures recommended l
t and implemented, changing accident mitigation priorl3es, the release pathway, and l
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oMsite dose projecthns. The MEO ensured that state officials clearly understood the
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relative severities of the degrades to Un!t 1 and Unit 2. Questions posed by state
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l officials were promptly and correctly answered, based on the information available to the
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MEO.
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The EOF's protective measures and reactor safety staffs quickly recognized the initiation l
of the unmonitored and unfiltered release, and began associated actions to assess its i
consequences. Although the proceduralized PAR flow chart was briefly misread due to l
a nomenclature error during the PAR reassessment, the MEO was promptly advised of his staff's error. A procedurally correct, revised PAR was quickly transmitted to State
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officials along with the information on release initiation.
l Protective measures staff effectively directed the activities of the Zion Station's two offsite radiological monitoring teams and remained aware of the team members'
accumulated doses. The teams' survey results were communicated to both states by a j
dedicated communicator, who also shared dose projection information with state l
counterparts. State officials shared their monitoring teams' results with this l!censee
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communicator.
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t Upon learning that state officials had recommended that their radiological monitoring ledms take potassium lodida due to the unfiltered nature of the telease, the MEO made an acceptable, analogous decision for the Zion Station's offsite monitoring teams.
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radiation survey measurements made well within one mile North of the Owner Controlled Area. When dose projections based on these measurements indicated that the Protective Action Guides could be exceeded beyond 10 miles North of the Zion
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Station, the MEO and his senior protective measures staff briefed State decision makers
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on these projections and their bases. Wisconsin officials advised the licensee that the geographic subareas being evacuated a/ e result of the current PAR extended sufficiently beyond 10 miles from the stata t so that further evacuations were not considered necessary.
Protective measures staff were very thorough and effective in assessing the possibility of evacuating the near site EOF due to its proximity to the Zion Station, current and forecast wind conditions, internal and external radiological measurements for the EOF,
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and procedural guidance. Their assessments were brought to the attention of the MEO, t
who weighed the pros and cons of either evacuating the EOF, or not having a relief shift proceed to the near site EOF. The MEO made the prudent decisions that 16 EOF staff need not be evacuated and that a relief shift should proceed to the near site EOF, unless an unforseen change in wind conditions would occur.
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b.5 Scenario and Exercise Control j
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The inspectors made observations dering the exercise to assess the challenge and
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realism of the scenario and to evaluate the control of the exercise. The scenario was J
considered very challenging, involving simultaneous classifiable emergency events at both units, major electrical failures, a steam release and steam generator tube rupture.
The inspectors determined that the scenario was appropriate to test basic emergency
capabilities and demonstrate onsite and offsite exercise objec;ives.
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i Overall control of the exercise was adequate. No controller prompting or major exercise
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control problems were identified. However, the inspectors noted several problems with
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' the control of the scenario and the over simulation of activities:
On one occasion, a controllet allowed a response team to enter and stay in a
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steam envirynment without providing any simulation for approximately 3 minutes.
On several occasions, at the request of RPTs, controllerw provided dose rate
information without verifying that the RPTs were correctly utilizing the instruments to simulate obtaining the requested information or that the instruments were properly setup. An example of such oversimulation was
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Identified while accompanying the team sent for Task 21. While the RPT's survey meters were operational, the technician began to rely on the controllers input of radiation levels rather than taking actual readings On one occasion, a controller allowed a non-licensed operator to simulate
donning high voltage protective gear for breaker racking operations.
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On numerous occasions, controllers allowed personnel to simulate donning
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Licenses actions to determine and specify the correct level of exercise simulation was an Inspection Followup ltem (IFl 50 295/97029 02 and 50 304/97029-02).
b.6 Licensee Self Critlaues The inspectors attended the license's self critiques in the TSC, OSC, and EOF that occutted after the termination of the exercise. Exercise controllers solicited inputs from participants in addition to providing the participants with the controllers' initial assessments of participants' performances. The inspectors concluded that these initial self critiques were thorough and in very close agreement with the bulk of the inspectors'
observations.
During the initial self critique of EOF participants' performance, a lead controller
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indicated that a meeting with State officials was planned for early 1998 to discuss protective measures issues of mutual concern, including the topic of formulating PARS
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I The licensee's overall self assessment was in close agreement with the NRC evaluation
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team's conclusions.
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Qyerall Conclusions The exercise was a competent demonstration of the licensee's capabilities to implement its emergency plans and procedures. Event classifications were correct and timely.
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Offsite notifications and offsite protective action recommendations were also correct and timely, inplant activities were proper ly prioritized. Transfers of command and control
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were orderly ano timely.
The licensee's overall self assessment was considered effective.
V. Management Meetings X.1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the -
conclusion of the inspection on December 5,1997. The licensee acknowledged the findings presented.
The inspectors asked the licensee whether any materials examined during the inspection
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should be considered proprietary. No proprietary information was identified.
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PARTIAL LIST OF PERSONS CONTACTED Licenate J. Brons Site Vice President D. Bump, Restart Manager R. Goldiey, Regulatory Assurance Manager L. Holden, Nuclear Licensing R. Johnson, EP Tiainer E. Katzman, Radiation Protection Manager L. Lanes, EP Coordinator
T. Luke, Site Engineering Manager R. Plant, Corporate EP
L. Schmeling, Training Manager
R. Starkey, Station Manager -
D. Stobaugh, Corporate EP M. Vonk, Corporate EP R. Zyduck, Quality and Safety Assessment Manager NRC D. Calhoun, Resident inspector E. Cobey, Acting Senior Resident inspector
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1DNS J. Yesinowski, Resident Inspector INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises for Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors
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ITEMS OPENED DDDDad-l 295/97029-01 IFl Use of notification procedure and checklist.
295/97029-02 IFl Over simulation of exercise tasks.
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LIST OF ACMONYMS USED
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AOP.
Abnormal Operating Procedure
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CEOF Corporate Emergency Operations Facility
CFR Code of Federal Regulations CRS
- Control Room Simulator i
DPR Demonstration Power Reactor i
DRP Division of Reactor Projects DRS Division of Reactor Safety
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EAL Emergency Action Level EDG Emergency Dieset Generator ENS Emergency Notification System EOF Emergency Operations Facility EPIP Emergency Pian implementing Procedure ERO Emergency Response Organization
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IDNS lilinois Department of Nuclear Safety
IFl Inspect!on Followup Item s
~ IP inspection Procedure MEO Manager of Emergency Operations NRC Nuclear Regulatory Commission
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NRR Office of Nuclear Reactor Regulation OSC Operational Support Center PAR Protective Action Recommendation PDR NRC Putile Document Room
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RPT Radiation Protection Technician SA Shift Assistant SD Station Director SM Shift Manager SS Shift Supervisor STA Shift Technical Advisor TSC-Technical Support Center
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