IR 05000373/1999014
| ML20211P248 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 09/08/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211P227 | List: |
| References | |
| 50-373-99-14, 50-374-99-14, NUDOCS 9909130170 | |
| Download: ML20211P248 (12) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION lll Docket Nos:
50-373; 50-374 License Nos:
50-373/99014(DRS); 50-374/99014(DRS)
Licensee:
Commonwealth Edison Company (Comed)
Facility:
LaSalle Nuclear Generating Station, Units 1 and 2 Location:
2605 N. 21" Road Marseilles, IL. 51341-9756 Dates:
August 9 - 13,1999 Inspector:
Robert D. Jickling, Ernergency Preparedness Analyst Approved by:
Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety
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9909130170 990908 PDR ADOCK 05000373 (D PDR
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EXECUTIVE SUMMARY LaSalle Nuclear Generating Station, Units 1 and 2 NRC Inspection Report 50-373/99014(DRS); 50-374/99014(DRS)
This inspection reviewed the emergency preparedness (EP) program, an aspect of Plant Support. The inspector selectively evaluated the quality of the EP program, related audits and reviews, reviewed the effectiveness of management controls; verified the adequacy of emergency response facilities and equipment; reviewed a number of EP training and qualification activities; and followed up on previous inspection findings. This was an announced inspection conducted by one regional inspector.
Plant Supoort Licensee personnel performed proper classifications and timely notifications during one
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actual activation of the emergency plan. (Section P1)
Emergency response facilities, equipment, and supplies were well maintained and in a
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state of operational readiness. Demonstration of emergency response equipment verified that the equipment was operable and ready for use. (Section P2)
The EP Department's corrective action items were effectively tracked using both the old
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and the new item tracking systems. Items tracked had a wide range of categories and had been appropriately addressed by the EP staff. Emergency Plan Implementing Procedures were clear and were consistent with the emergency plan and NRC requirements. (Section P3)
The licensee maintained an effective EP training program. Personnel were qualified for
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their emergency response positions. Interviewed emergency response organization personnel successfully demonstrated a very good knowledge of their emergency roles and procedures. (Section PS)
Management support for the emergency preparedness program was strong as identified
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through interviews and identified upgrades to the program. The EP staff and management were professional and responsive. (Section P6)
The licensee's 1998 and 1999 EP Program audit and assessments of the emergency
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preparedness program were of good scope and depth and satisfied the requirements of 10 Code of Federal Regulations 50.54(t). (Section P7)
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P Report Details l
IV. Plant Suonort
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P1 Conduct of Emergency Preparedness Activities l
P1.1. Actual Emeroency Plan Activations a.
Insoection Scope (82701)
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The inspector reviewed records and documentation packages regarding plant response for emergency plan activations that occurred since the last routine emergency preparedness program inspection.
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Observations and Findinos.
An Unusual Event was declared at 3:58 p.m. (CDT) on October 5,1998, due to the transportation of a radiologically contaminated person to an off-site medical facility. The Unusual Event was appropriately declared using Emergency Plan implementing
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Procedure LZP-1200-1," Classification of Generating Stations Emergency Plan (GSEP)
Conditions," HU7, " Transportation of Radioactively Contaminated Person to an offsite Medical Facility." Offsite notification to the State of Illinois via the Nuclear Accident Reporting System (NARS) was made at 4:07 p.m. which met the 15 minute requirement.
The Emergency Notification System (ENS) call to the NRC was initiated at 4:42 p.m.
which met the one hour requirement. The event was terminated at 6:45 p.m. on October 5,1998, after the person was decontaminated and radioactive contaminated waste was packaged and retumed to the station. The NRC was notified of the termination via ENS at 7:10 p.m. An investigation by the licensee was conducted which identified that a diver in the unit two suppression pool lost consciousness. The diver was transported to the hospitalin a contaminated condition which resulted in the GSEP Unusual Event declaration.
In accordance with LZP-1540-1, " Review of Actual GSEP Events," the licensee's emergency preparedness (EP) staff conducted a detailed and thorough assessment of plant personnel's emergency response. Documents reviewed indicated that the event
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classification and related notifications of offsite authorities and the NRC were made properly and in a timely manner.
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Conclusions i
The inspector concluded that the licensee appropriately implemented the emergency plan in declaring the Unusual Event. The emergency classification was made correctly, and offsite notifications were timely. The evaluation package was detailed and provided a thorough assessment of the plant's response to the actual event.
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P2 Status of EP Facilities, Equipment, and Resources
- P2.1 Material Condition of Emeraency Response Facilities
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Insoection Scooe (82701)
The inspector evaluated the material condition of th4 control room, Technical Support -
Center (TSC), Operational Support Center (OSC), and the offsite field team GSEP van.
Field team monitoring kits and equipment were also inspected. The licensee E
demonstrated the operability of numerous pieces of emergency response equipment, L
including radiological survey instruments, dose assessment and plant data computer term!nals, a portable generator, and communications equipment. Records of periodic
' inventories and equipment tests were also reviewed.
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- Observations and Findinos The control room was in a good state of operational readiness. Current emergency plan implementing procedures were ready and available, and the emergency' notification system phone was verified operable. Procedure checklists, located in the Shift Manager's office, were available and current.
The TSC was maintained in a state of operational readiness. Computers and monitors in the TSC had been upgraded, and a common "login" was created for GSEP use which
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reduced the amount of time needed to access point history information. The sign-in board was clear and easily observed from most areas of the TSC facility. Radiological survey equipment _ stored in the facility were available and operable.
' The OSC was well maintained with sufficient supplies available to accommodate
. response personnel. Radiological survey equipment stored in the facility had current calibrations and.were operable. Status boards were in place for status updates, facility staffing, and response team tracking. A new process for " urgent" response teams had
. been initiated and used in recent drills. Team personnel were pre-selected from each of the station's departments and staged in the main area of the OSC. The licensee indicated that the pre-selected team process would ensure more timely briefing and dispatch of " urgent" response teams The GSEP van was in very good material condition. Supplies were available and in adequate quantities. Procedures reviewed by the inspector were current and available in the van. - Instruments and equipment were verified to be functional, and calibration dates were current. The van and portable generator were started to verify that they were also functional.
Records for the 33 prompt alert and notification sirens for 1998 and 1999 were reviewed by the inspector. Annual operability for 1998 was 98.9 percent, with 98.3 percent for the lowest month's average. The current 1999 annual operability average was 98.8 percent,
. ith 96.7 percent for the lowest month's average. Siren operability exceeded the annual w
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acceptability limit of greater than or equal to 90 percent.
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Conclusions Emergency response facilities, equipment and supplies were well maintained and in a state of operational readiness. Demonstration of selected emergency equipment verified that the equipment was available and operable. A new " urgent" team process in the OSC was implemented to provide a more timely response of " urgent" priority OSC teams. Siren operability records indicated the prompt alert and notification sirens had been well maintained.
P3 EP Procedures and Documentation a.
Inspection Scoce (82701)
The inspector reviewed a sample of Emergency Plan implementing Procedures (LZPs).
SpecBeally, Emergency Plan Implementing Procedures LZP-1110-1, " Station Director (Acting Station Director)," Revision 25, dated June 24,1999; LZP-1135-1, "GSEP Communications and Communicator implementing Procedure," Revision 10, dated May 5,1999; and LZP-1170-2," Assembly and Accountability of Personnel," Revision 8, dated November 12,1997, were reviewed by the inspector. Also, the corrective action and issue tracking system reports related to the EP Department were examined.
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Observations and Findinas Procedure LPZ-1110-1 clearly identified precautions which included directing radiation protection technicians to perform radiation surveys on backshifts or weekends when the Radiation Protection Supervisors were not onsite, stating that the control room shall be relieved of command and control as soon as possible after the declaration of an Alert or higher classification, and requiring the activation of the Emergency Response Data System within one hour of classifying an Alert or higher emergency. Minimum staffing i
was clearly defined for the TSC prior to transfer of command and control which included five staff members. Attachments were effectively included for implementing response guidance for each of the four emergency classifications, fires, hazardous materials, and command and control transfers.
Procedure LPZ-1135-1 identified appropriate guidance for station personnel providing offsite agency communications and for the GSEP Communicator and Recorder positions. An attachment provided additional off site notifications guidance to be used in the event normal communications were inoperable during an emergency.
Procedure LPZ-1170-2 delineated the methods for personnel assembly and accountability and could be used in the event of a GSEP emergency, fire, tornado, or as determined by the Shift Manager, Acting Station Director, or Station Director. The procedure clearly identified that a site assembly must be initiated when a Site Area Emergency or General Emergency was declared. The 30 minute requirement for GSEP l
assembly completion was identified as a limitation.
The inspector reviewed the corrective action and tracking system used by the EP Department to determine the range of issues identified and the effectiveness of corrective actions and trending. The corrective action program was currently in a transition period, switching from the Nuclear Tracking System to the Action Tracking System. Approximately 30 Nuclear Tracking System and Action Tracking Method items
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items,25 Nuclear Tracking System and 4 Action Tracking Method items had been closed. The items reviewed were clearly identified by number, date, category, and description, with responsible organization identified, assignment dates and due dates listed. These reports adequately documented and tracked the status of corrective actions related to a wide range of items identified by plant personnel, c.
Conclusions All EP Department's corrective action items were effectively tracked using both the old and the new item tracking systems. Items tracked had a wide range of categories and had been appropriately addressed by the EP staff. Emergency Plan Implementing Procedures were clear and were consistent with the emergency plan and NRC requirements.
P5 Staff Training and Qualification in EP a.
Inspection Scope (82701)
The inspector reviewed various aspects of the EP training program. The review included interviews with selected key emergency response organization personnel (a control room Acting Station Director and a TSC Station Director) and the review of drill and related critique records, attendance records, and the GSEP Cal: List. Records from the training tracking program were compared with the call out list to determine whether listed personnel were qualified. Respirator and self contained breathing apparatus (SCBA) qualifications of plant personnel and records of periodic inventories and equipment tests were also reviewed.
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Observations and Findinas Two key emergency response organization (ERO) personnel demonstrated a good i
knowledge of procedures and emergency responsibilities. During the interviews, personnel were consistent in their comments that the EP staff were professional and responsive regarding their responsibilities and duties.
The training attendance forms and other records were compared with the GSEP Call List to verify that personnel on the call out list were qualified. All ERO personnel reviewed were currently qualified for their emergency response positions. Training files contained appropriate documentation, including test results and attendance forms.
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Review of respirator and SCBA qualification documentation provided the following information:
RespiratorI SCBA > Qualifications DEPARTMENT NUMBER oF TRAINING / MEDICAL RESPIRATOR sCBA QUALIFIED INDIVIDUALS OUALIFIED OUALIFIED Radiation Protection
48/42
37 Operations 131 90/116
106 Instrument Maintenance
47/36
nr Electrical Maintenance
59/48
nr Mechanical Maintenance
48/79
nr Chernistry
12/11
7 Welders
13/10
nr Note: Departments did not include office support, trainers, and some supervisors.
nr: Not required by the licensee.
NRC Information Notice 98-20, " Problems with Emergency Preparedness Respiratory
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Protection Programs," was issued June 3,1998. This information notice alerted licensees to multiple generic weaknesses in respiratory protection programs supporting emergency preparedness. Respiratory protection qualifications included three parts:
respiratory training, medical testing, and a mask fit. The numbers above represented the current respiratory qualifications by department. Discussion indicated that licensee personnel were aware of the information notice and had evaluated its information.
The inspector reviewed records for the semi-annual augmentation tests. Five tests had been conducted since the last routine NRC inspection. One test was identified as unsuccessful due to two TSC communications personnel responding at greater than 25 percent beyond the 60 minute goal. The two communications personnel were not identified as minimum staff personnel. A successful re-test was conducted less than five weeks later. A new Community Alert Notification (CAN) system had been initiated in February of 1999 to upgrade the augmentation call out process, c.
Conclusions The licensee maintained an effective EP training program. Training, drills, and exercises were properly critiqued. Interviewed ERO personnel were knowledgeable of their emergency roles, and personnel listed on the ERO call out list were currently qualified for their emergency response positions. The semi-annual augmentation tests had been appropriately conducted on a periodic basis.
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' P6 EP Organization and Administration a.
~ Insoection Scooe (82701)'
The inspector conducted discussions with the EP staff regarding the current
organization and any changes to the program and personnel.-
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- Observations and Findinas No'significant changes occurred in the EP organization since the last routine inspection in January 1998. The Emergency Planning Coordinator reported to the Radiation Protection Manager who reported to the Station Manager. The Emergency Planning Trainer reported to the Emergency Planning Coordinator. Emergency preparedness department staffing had remained constant, with the exception of the EP instructor who had been in place for approximately one year. Some station management changes had
required additional initial ERO position training in the last year. Approximately 30
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percent of the current ERO management personnel had been in their emergency positions for less than 12 months.
' Discussions with the EP staff identified a number of enhancements that had been completed. In addition to the new CAN system for ERO call out, another upgrade was the completion of the change to the Comed UNIX integrated station computer system in May 1999.. Also, Severe Accident Management (SAM) has been implemented by the i
licensee, and SAM personnel would be located in the TSC for emergency response.
The licensee indicated that these enhancements would further improve the performance of the EP program.
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Conclusions Discussions with the EP staff and si_te personnelindicated strong management support
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had been provided to the program. Enhancements to the program and the EP staff's professional responsive approach maintained and improved the program performance and training.
P7 Quality Assurance in EP Activities
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P7.1 Audits a'.
Inspection Scooe (82701)
The inspector reviewed Nuclear Generation Group Audit Report Comed-98-03, Emergency Preparedness / Radiological Environmental Monitoring Program (REMP)/
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Offsite Dose Calculation Manual (ODCM)," dated May 15,1998; the LaSalle Station Nuclear Oversight Assessment Report NOA-01-99-034, " Emergency Preparedness
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- Report NOA-12-99-PSO4, " Emergency Preparedness Assessment," dated May 26, 1999.
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Observations and Findinas Integrated audit Comed-98-03 (EP/REMP/ODCM) was conducted by three individuals during March 30 through April 10,1998, for LaSalle. The audit reviewed drills and exercises, interfaces with State and local govemments, facility and equipment readiness, corrective action commitments, GSEP, procedures, capabilities, training, j
qualifications, and organizational changes. The audit concluded that the station had an acceptable program and that overall performance improved. The emergency plan was wellimplemented at the station, and Comed was prepared to respond to an actual emergency, should one occur. Two findings were generated during this audit which included the following:
I Procedure LZP 1510-01, Revision 5, did not contain written instructions to
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accomplish confirmation of biennial support agency agreements and offers of
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annual training.
Minor administrative deficiencies were found during a review of 245 procedures
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in the TSC.
These items had been appropriately tracked and resolved. The audit also contained an evaluation of the adequacy of interfaces with State and local governments, which is required by 10 Code of Federal Regulations (CFR) 50.54(t). The evaluation of adequacy of interface of State and counties had been accomplished by documentation review, telephone survey, and face-to-face discussions.
Emergency Preparedness Program assessment report NOA-01-99-034 was conducted by two individuals during April 5 through 15,1999. The assessment verified the effective implementation of the EP Program. The assessment found that the EP Program has been adequately implemented. Nuclear Oversight's assessment concluded that the GSEP organization was capable of controlling and supporting an emergency event. Nuclear Oversight issued one finding:
Only three of four Environs Field Directors were currently facemask qualified.
- This issue was corrected during the assessment.
The audit also contained an evaluation of the adequacy of interface with LaSalle County.
Dresden Station Emergency Preparedness Assessment NOA-12-99-PSO4 included an evaluation of the adequacy of interfaces with Grundy County and the State of Illinois.
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These evaluations of the adequacy of interfaces with the State and local agencies are required by 10 Code of Federal Regulations (CFR) 50.54(t). The evaluation of adequacy of interface of State and counties had been accomplished by interviews and
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concluded that there was a good working relationship between the agencies and the station.
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Conclusions The licensee's 1998 and 1999 emergency preparedness program audits and assessments satisfied the requirements of 10 CFR 50.54(t). Corrective actions resulting from the audits were properly tracked and completed within reasonable times.
Evaluation of adequacy of interfaces with State and local governments for the audits were adequate.
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P8 Miscellaneous EP lasues P8.1 (Closed) Insoection Followuo item No. 50-373/98003-01(DRS): 50-374/98003-01(DRS):
Problems with the audibility of the assembly siren in the Service Building were identified by the licensee. Corrective actions included modification of the public address system to include a tone generator to duplicate the GSEP siren for the Service Building.
Successful tests and drills had been conducted. This item is closed.
P8.2 (Closed) Insoection Followuo item No. 50-373/98008-01(DRS): 50-374/98008-01(DRS):
During the 1998 EP exercise it was identified that the initial NRC notification was
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delayed. Corrective actions included a training package emphasizing that the Emergency Notification System notification are to be made immediately after State and local notifications. This issue was also discussed in table top drills conducted after the 1998 exercise. Additionally, this issue had been included in simulator training for operations personnel. This item is closed.
P8.3 (Closed) Insoection Followuo item No. 50-373/98008-02(DRS): 50-374/98008-02(DRS):
During the 1998 EP exercise, an Exercise Weakness was identified concerning the ability to consistently dispatch " urgent" priority teams from the OSC in a timely manner.
This issue has been included in all table top drills, and a training package had also been issued. This item is closed.
P8.4 (Closed) Inspection Followuo item No. 50-373/98008(DRS): 50-374/98008-03(DRS):
During the 1998 EP exercise, an item was opened due to the failure to verify SCBA qualifications of an OSC team. Corrective actions included issuance of a training package, a procedure change to add respirator qualification checks on the briefing form, and the issue was discussed in annual training as a lesson learned. This item is closed.
X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the i
conclusion of the inspection on August 13,1999. The licensee acknowledged the findings
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presented. The licensee did not identify any items discussed as proprietary.
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PARTIAL LIST OF PERSONS CONTACTED Licensee S, Adler, Regulatory Assurance S. Barrett, Maintenance Manager J. Benjamin, Site Vice President C. Beny, Chief of Staff B. Blaine, Radiation Protection Operations Supervisor N. Carpenter, Training D. Farr, Operatons Manager -
R. Flahive, Corrective Actions Program V. Gengler, Security Supervisor T. Gierich, Work Control Manager
'J. Henry, Shift Manager D. Hiezelke, Nuclear Oversight P. Holland, Regulatory Assurance A. Howard, Emergency Planning Coordinator C. Howland, Radiation Protection Manager J. Kodrick, Maintenance R. Krohn, Emergency Planning Trainer
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M. Lohmann, Engineering Administration Manager J. Meister, Station Manager P. Nottingham, Radiation Protection -
P. Quealy, Radiation Protection Support Supervisor J. Richardson, Human Resources Supervisor B. Riffer, Nuclear Oversight Manager D. Rhoades, Work Control F. Spangenberg, Regulatory Assurance Manager P. Stachniak, Nuclear Oversight Assessment Manager D. Stobaugh, Corporate Emergency Preparedness R. Varju, Chemistry.
IDNS J. Yesinowski, Nuclear Safety Engineer NRC J. Hansen, Acting Senior Resident inspector
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INSPECTION PROCEDURES USED IP 82701:
Operational Status Of The Emergency Preparedness Program
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= ITEMS OPENED, CLOSED, AND DISCUSSED
,Ooened None
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50-373; 374/98003-02 IFl Audibility of the Service Building assembly siren.
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50-373; 374/98008-01
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. Delayed NRC emergency notification during the
'1998 EP exercise. (Section P8.2)
'50-373; 374/98008-02 IFl.
Problems with timely dispatch of some " Urgent"
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l OSC respor,se it,atis during the 1998 EP exercise.
(Sections P21 and P8.* )
d 50 373; 374/98008-03 ~
IFl Failure to ver'fy the status of SCBA qualifications for an OSC response team. (Section P8.4)
Discussed
.None LIST OF ACRONYMS USED CAN Community Alert Notification
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CFR Code of Federal Regulations -
CDT.
. Central Daylight Time
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Comed Commonwealth Edison
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DRS Division of Reactor Safety-ENS Emergency Notification System :
- EP Emergency Preparedness ERF Emergency Response Facilities ERO
- Emergency Response Organization GSEP Generating Stations Emergency Fian
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LZP LaSalle Emergency Plan implementing Procedures NARS
. Nuclear Accident Reporting System
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ODCM.
Offsite Dose. Calculation Manual OSC-
. Operational Support Center REMP
^ Radiological Environs Monitoring Program l
, Severe Accident Management SCBA Self Contained Breathing Apparatus TSC Technical Support Center
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UNIX ~
- Integrated Station Computer System i
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