IR 05000373/1990020
| ML20059E813 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 08/31/1990 |
| From: | Dan Barss, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20059E812 | List: |
| References | |
| 50-373-90-20, 50-374-90-21, NUDOCS 9009100341 | |
| Download: ML20059E813 (9) | |
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REGION III
Report Nos. 50-373/90020(DRSS);50-374/90021(DRSS) . g ' Docket Nos. 50-373; 50-374 License Nos. NPF-11, NPF-18 '
- Licenseet Commonwealth. Edison Company Opus West III--
1400 Opus Place , -Downers Grove. IL '60515 . , [FacilityName: 'LaSalle County Nuclear Generating Station, Un.its 1 and 2: 11.nspection At: LaSalle Site, Marseilles, 11'..nois , '. ' Inspection-Conducted: August 20,'22-24, '.990 . ' ' (J.). Q - . Inspector:,D. M. Barss, ' 8/31/fo , Date-
- Accompanying Intpector: H.'Simons d
UJe SJ N ~ Approved By:' W. Snell, Chief-B/ai//o - - Radiological Controls and Date _ Emergency. Preparedness Section , "\\J _' Inspection Suramary ff . Inspection'~on August'20, 22-24, 1990 (Reports No: 50-373/90020(DRSS); ' No '50-374/90021(DRSS)). - 'g 1 Areas Inspected:. Routine, announced inspection of the-LaSalle County: Nuclear Genereting Station including the following areas: follow-up of licensee' , ' . actions on previously identified items'(IP 92701); followup on actual Lemergency; plan activations (IP 92700); andLoperational status of the emergency.
+ preparedness program (IP 82701). This inspection involved 1two inspectors. - Re w * r One.non-' cited violation of NRC requirements was identified E". g the. lack of specialized training for emergency repair and damager - . core.
teams.. - An exercise weakness based on a. failure to declare an Unusel Event from the June 6,1990 exercise, was satisfactorily addressed.
-The .3nsee 'has a well maintained emergency preparedness program, which ' they continue to : improve through self evaluation ~ and making refinements as " in , necessa ry.-
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Persons Contacted G.J. Diederich, Station Manager ' W.R. Huntinton,' Technical Superintendent D. Hieggelke, Health Physics Services Supervisor , , -K. Klotz, Emergency Preparedness Coordinator T. A. Hammerich, Regulatory Assurance Supervisor J.C. Renwick, Production Superintendent
J. Houston, GSEP Trainer L. Holden, On-Site Program Administrator S.- Jerz,, Nuclear Quality Programs J. Roman, Illinois Department of Nuclear Safety All of the above listed individuals attended the NRC exit inter' view held ! on August 24, 1990.
o ~ The inspectors also contacted other Mcensee personnel during the course
of the inspection.
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Licensee-Action on Previously Identified Items-(IP 92701).
, (Closed) Open Item No. 373/90005-01: The licensee failed to assess in a:
timely manner that an onsite fire required classification and declaration as an Unusual Event in accordance with emergency action levels-(EALs)'. i The licensee has-revised procedure LOA-FP-01, " Fire Alarm Response," to '1 include an action step which directs operators-to~ refer to procedure LZP-1200-1, " Classification of GSEPLConditions," to ensure that EALs are considered in response to, fires.
~ l The licensee has also developed a special supplemental training module to be presented as part of the semi-annual training _for Control Room personnel.
- This special module reviews the exercise weakness. identified by.thezNRC and the correct. actions that should have been taken during the exercise.
The semi-annual: retraining also includes a review of changes made to . l procedure LOA-FP-Ol'. This training started on August 13,-1990 and-is
scheduled to be completed by: September 17, 1990.
During the course of. the inspection, the inspectors observed a Control Room crew during a regularly scheduled simulator training-session which .;
- included a scenario requiring GSEP cctivation.
No problems were noted < in the ability of the Control Room crew to identify conditions which -{ P-1 warranted classification in accordance with EALs as a GSEP activation, i Subsequent required notifications were simulated and would have been l 'made in a timely manner.
t9 - Based on the licensee actions discussed above and the acceptable g performance observed during the simulator training session, this item ' _is closed.
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l? s i L j;. 4 y (Closed)~0 pen item No. 373/90005-02: A procedural inconsistency was --identified between ED-5 and LZP-1330-70, concerning correction factors y' used-in offsite dose calculations, t I The licensee,has modified the C-Model computer program _ routines.'ED-5 ^ and ED-26ifor offsite dose calculations. Verification calculations were ' performed by the licensee and no errors were reported.
This item is closed.
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Emergency Plan Activations (IP 92700) At 0640 on February 6.1989, the licensee declared an Unusual Event (UE) due to a potentially contaminated.. injured man requiring transportation to an offsite medical facility.
It was later determined the individual was not contaminated. The event was terminated at 0815 the same da#, At_0230 on March 3,.1989, an UE was declared based on Emergency Action-Level-(EAL) 3.D, " Loss of all Power to Unit Auxiliary Transformer and the associated Statien Auxiliary Transformer with.the Unit not in v Cold. Shutdown or Refueling." This was a conservative declaration ' that was initiated at the discretion of the Station Director since all power had not been. lost to the unit auxiliary transformer and the associated station auxiliary transformer, only, offsite power had been lost. The event-was terminated at 1743 the same day.
At 2200 on September 30, 1989, the licensee declared an UE due to a potentially contaminated, injured man requiring transportation to an offsite medical facility.
It was later determined the' individual was not. contaminated but a piece of anti-contamination clothing could not be removed from under the individual until he was treated at an offsite-medicalifacility. The event was terminated at 2335 the same day.
At 1430 on October 7,-1989, the licensee declared an UE due to-a lpotentially' contaminated, injured man requiring transportation to an offsite medical facility.
It was later detennined the individual was not. contaminated but the anti-contamination clothing which the injured ,
- person was wearing did have fixed contamination. The event was terminated at 1535 the same day.
At 1240 on March 22, 1990,- the licensee declared an UE based on EAL 3.C when all offsite commercial phone communications capabilities were ' lost. The licensea made good use of alternate communication capabilities 'to complete required notifications in a timely manner.
The ewnt was ' terminated at 2150 the same day, The licensee's records for each of the above emergency plan activations n.
v were reviewed.
For each event an appropriate classification was made - and notifications to State officials and the NRC were accomplished within required time limits.
The-licensee conducted a GSEP event review for each GSEP activation.
This review inebded gathering copies of applicable documents such as
Shift Engineer's Logs, Nuclear Accident Reporting System (NARS) forms, !
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Xk <j n , p.: , Emergency Notification System (ENS) notification worksheets,- Deviation Reportsand.LicenseeEventReports(LER).. An evaluation was then'made , to: determine if the classification was appropriate, notification timely.
3, p .and'if' the GSEP and associated procedures were properly.implementnd.. Problems identified through these reviews were of a minor nature ma , ,- .have been corrected by the licensee. :This practice of self evaluai. ion- 'following real. activations has helped the licensee improve.their' ", . emergency planning program.
, " No violations' of deviatieas.were identified.in: the review of this program g area.
4.. Operational Status of the Emergency Preparedness Program (IP 82701) e a.
Emergency Plan and Implementing Procedures There have been no changes to the licensee's: generic Generating " ' Station Emergency Plan (GSEP) or the LaSalle Annex to the GSEP since the last routine inspection. Revision 7 to the generic GSEP has not yet been issued. When it is issuad, the GSEP LaSalle Annex will then be reviewed and revised as appropriate.
,' The GSEP LaSalle Annex has been reviewed annually as required by procedure.
Several emergency plan implementing procedures related to the 'I conduct of assembly, accountability and statioti evacuation have < been revised. This revision was part of a continuinc refinement of this program area to strengthen a p:reviously identified weakness.
The licensee.has taken steps to ensure that affected procedures were revised concurrently.
Personnel affected b c-have been informed of the changes as'necessary. y these changes - The licensee's records pertainingLto the transmittal. of procedure revisions to affected procedure holders.were; reviewed.
This. review indicated that revisions have been sent-as appropriate including copies to the.NRC within~30 days of the changes.
Current copies of the emergency plan and implementing procedures ' were found'to be maintained and readily available in the emergency response facilities and the Control Room.
No violations or deviations were-identified in the review of this program area.
b.
Emergency Facilities, Equipment, Instrumentation and Supplies An inspection tour was conducted through the Technical Support . Center (TSC), Operational' Support Center (OSC), and the Control Room (CR).
These facilities were found to be as described in the LaSalle Annex of the Generatina atation Emergency Plan (GSEP).
The TSC is a dedicated facility ano was found to be clean, orderly and ready for use. An abundant supply ~ of GSEP logs and message forms are maintained for use in the facilities.
Individual log
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a a i 1 folders-are maintained for various positions which contain ' - ". appropriate; forms and procedural checklists. A spot check ^of the > < t checklists 1 revealed that Revision 9, dated December 9, 1989,'of p Attachment A, Security Directors Checklist of Initial
Responsibilities" from procedure LZP-1170-1 was in the Security. Director's. log folder when Revision 10, dated N1y 18, :1990, should
have been. The correct revision was installed during the course of the inspection.- < o g ' Radiological survey ' meters stored in the TSC were feand to be' I - calibrated:and ready for use. A check source is also available to- [ verify' meter operability. Each meter was checked End found to be a > satisfactory.
- A copy. machine designated for.use-in the TSC'is kept in the hallway.
o adjacent.to the TSC to be accessible:for normal work activities.
This copy machine was found to be out of ink and not operable at_.the time of the inspection. By the end of the inspection a.new copy -
machine which had been previously ordered for the TSC was delivered ' and installed. > The TSC now has a copy machine dedicaced for use in , that. facility.
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In the CR telephones dedicated for emergency use were clearly-labeled and positioned to be readily accessible.
The NRC emergency P ' notification syr. tem (ENS) (red phone)~was tested from the CR and found to have an annoying echo on the plant's end of the phone.
although communications could still be understood. The echo . - a - problem was reported -to the NRC Headquarters Duty:0fficer and corrected before the close of.the inspection. Appropriate procedures and notification forms were also found to be readily accessible and sufficiently: stocked for use -in the CR.
_ ~ I Respirator equipment for use with a supplied air. system isskept stored in the CR. This equipment was inspected and found?to be-adequately maintained.
- Th'e OSC is' established when necessary in the Auxiliary Building,;
elevation 768, adjacentjto the Shift Engineer's office area. 4This , ~ area is used on a' daily: basis by operations personnel'and emergency supplies 'are stored in : lockers.in an adjacent. hallway. The inventory ! of these; emergency lockers.were checked and found.to be as described
by procedures. One dosimeter charger was found to be inoperable'and.
' -. a count rate meter was found to have a dead battery. Both'ofLthese
deficiencies were corrected by the licensee.
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Emergency comunications systems surveillance records for the
emergency response facilities were reviewed and found to be complete s and thoro' ugh.- These surveiHances are conducted monthly and include
- the Nuclear Accident Reporting System (NARS)' phones, GSEP radios, GSEP microwave phone system conna tions, NRC ENS and Health Physics
- t Network (HPN)' phones and other inplant phone system extensions . maintained for emergency use and not used in normal work activities.
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7 ,,, . t, , . [ W M h... ' ' i ,w g[4 w-l , , h9 .l , , 7"- . . ' 4The;11censee's inventory records'for emergency. supplies were reviewed %, and'found to'have been-completed as detailed in appropriate-procedures.
!" ' Thest inventories included supplies for first aid, environmental.
. Q@ .samp.ing, deconte71' nation '1cilities, TSC, OSC, post accident ~ ) , sdmpling and an ambulance kit.
L + - &, No violations or deviatic identified in the review of this ' o e + t.
program area.
However, the
- lowing items are recomended for
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improvement:. ,i Count rate meters stored in the OSC and TSC could be plugged in
.' to allow trickle' charging of the internal battery.
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. . ~ An emergency supply of ink for the copy: machine-could be added . a to the TSC supply : inventory.
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Organization and Management Control 7i .It was learnec' through. discussion with cognizant licensee personnelz.
that there.have been two changes made in th_e licensee's organizational . structure which'affected emergency planning.
. .) ' The GSEP Coordinator'c reporting chain to the plant manager:has .been shortened by the elimination of the Assistant Superintendent < 3^^ of Services pusition..The GSEP Coordinator now reports to. the Health Physics Services Supervisor who reports to the Technical
Superintendent who reports to the Station Manager.
l ' Chemistry'and Radiation. Protection has been= divided into two separate functions. This division has benefit _ted emergency plannirg by focusing more specialized training on each group.. For example, the e chemistry technicians now are responsible for operating the high ' radiation sample system (HRSS)'and' radiation protection technicians m", are assigned to environmental monitoring and sampling. This focusing,
offresponsibilities'hasLimproved performance in'both areas.
The licensee ~ has not yet revised the GSEP: Annex to reflect the
division of Chemistry and Radiation Protection.
This revision is planned to be made after Revisic.. 7 of the Corporate GSEP is issued.
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- No violations or deviations were identified in the review cf this
' L program erea.
, d- . Emergency Preparedness Training < The current GSEP onsite training program was-reviewed with a GSEP Training 1 Instructor and the GSEP Coordinator including a review of ' m the training n trix requirements, lesson plans, training records ' e , and recent improvements to the program.
j 'The inspector reviewed the matrix of training requirements and the lesson plans. They both were acceptable in scope and depth for the , Director positions. The initial training of emergency response a f ' + i e I('
y - - , y+ ' , W r $(y .+ , , n; ., Y ' ' personnel' consists of required reading of applicable emergency plan x implementing procedures (EPIPs), appropriate classroom training? modules, and an examination which-they are required to pass. Annual . F-retraining consists of required reading of revised procedures and ' i other applicable EPIPs.and a retest' covering the material in the initial training modules. The training records of thirty-eight Y randomly chosen individuals:were reviewed. Of.these individuals, one was.found to have been late in being retrained.
This person .was not removed from the call out list, procedure LZP-1320-1- > ' " Augmentation of Plant Staffing," Revision 35 dated July 26, 1990 when his training had expired on June 9, 1990. There was a conscience decision to leave hN on the call out list since the individual was scheduled for retraining. This individual was completely retrained on August 16, 1990 using the initial training ~ requirements.
.; $ .The training program is being improved by an-effort to standardize, _ 'I most of the GSEP training across-the six Commonwealth Edison stations.
'The trainers from each of the stations meet quarterly to discuss. the training programs.
' . J Training is also enhanced by including relevant findings originating.
from drill and exercise critiques in the annual retraining program.
" Records of the 1989 emergency preparedness drills were reviewed.
All 1989 health physics, medical, post-accident sampling and shift augmentation drill requirements were successfully met. There were-q a few minor findings associated with the drills and these problems
were corrected lin a timely manner. The 1989 assembly / accountability-drill held!during the annual GSEP exercise was unsuccessful. This wasicorrected by revising procedores and having another assembly / = accountabilitiy drill. This drill was delayed untii January 1990-d due to an outage. Drill records were complete and indicated: that ' critiques were' conducted and' performance was evaluated, j" ! Interviews were conducted with six individuals assigned GESP responsibilities by the current revision of procedure LZP-1320-1, , " Augmentation of Plant Staffing." One individual was not aware-he
was currently on the call list. Several individuals who could be assigned to repair and damage control. teams were unclear. of their _ responsibilities and the unique management structure which wt.ald '.< N exist during a GSEP activation.
The-location and purpose of the OSC was not understood by 'some of the individuals Interviewed.
T .The inspector reviewed Section 8.2, " Training" of the GSEP and tce LaSalle Station'GSEP Training Matrix for the licensee's training -[
t requirements for Repair and Damage Control teams.
The licensee had not identified any specialized training for this position beyond ={ ( that given to all' site personnel in Nuclear General Employee Trailing ' (NGET).
10 CFR Part 50, Appendix E, IV.F specifies that specialized ' ' training,should be provided to repair and damage control teams.
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..; y,v s.: . . n .a Z The licensee had alreadyLidentified this weakness in their training h, -as. part of' an overall. upgrade'in.their emergency preparedness j' ! training u.odules,' and had developed a draf t list of objectives to be used in a training module for all emergency taams.
'The omission from the training program of specific specialized training for-individuals assigned emergency. repair'and damage a . Y control team responsibilities would normally be considered a violation.
However, the violation is not beirg. cited because the criteria specified in wtion V.A. of:the' Enforcement Policy ~. 'I . ' g were' satisfied.
(0penitemNo. 50-373/90020-01) One'non-cited violation was identified in the review of this [ ' " % program area.
In addition, the following. item is recommended , q' for improvement: >' Management communications to personnel assigned to the call; out. list should be reviewed to ensure personnel are infonned: r before they are placed on the call out list.
e.
Independent Reviews / Audits ' Records were -reviewed of the Quality Assurance (QA) Department =. Jaudits and surveillances conducted in 1989 and 1990.- These included. - the annual audits which fulfill the requirements of 10 CFR 50.54(t).
, two corporate audits, a surveillance of the OSC during the 1989 < pre-exercise, aL surveillance of the'1990 -GSEP exercise and a'- surveillance of an October 1989. GSEP 0ff-Site Agency. meeting.
All' records were readily available and complete. The auditor's checklists for the annual audits was reviewed. This checklist had .been-revised for both audits and each year continued to, have more t scope and depth for a better evaluation..of the program. The audit
checklists were completely filled out and had informative.: supporting e " evidenc'e to back' up their evaluation of whether an item was ' acceptable or deficient. These audits fulfilled;all the requirements , of 10.CFR 50.54(t) including an evaluation of the adequacies of the i interface between State.and local governments. The; auditors checkod .( ' letters of. agreement, verified.that letters of invitation were
, issued to support organizations for discussion of emergency planning
3, . issues, and in one audit it was noted that emergency action levels-A were reviewed with the Sta' 2 at a meeting. The October 1989 l-surveillance in'particular observed the interfaces between the: " licensee: personnel and the off-site agencies fin attendance.
The- ' , , audits were also made available to the' State and local governments.
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Audit findings are followed up on by QA every month until the item .is closed. The closure is evaluated by the cognizant QA inspector and reviewed by QA management. The findings are then tracked quarterly the following year to prevent reoccurrences.
m No violations or deviations were identified in the review of this program area.
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Exit 1nterview LThe' inspectors met with licensee representatives' dent +.cd in-Paragraph 1,; i - on August 24,_'1990.
The inspectors reviewed the scope and findings of- % . the-inspection _and'indicGed the _ licensee continues to have' a well ._ "" -maintained emergency program.. The licensce wast infonned of the non-cited' violation identified in Section 4d of this report-in a telephone call on
- August-31, 1990, c.
The licensee indicated ti.?t the'inforination discussed was not of a - proprietary l nature.
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