IR 05000454/1986030

Insp Repts 50-454/86-30 & 50-455/86-26 on 860929-1003.No Violation Noted.Major Areas Inspected:Emergency Preparedness Program,Including Licensee Actions on Previously Identified Items & Emergency Detection & Classification

ML20197A973
Person / Time
Site:	Byron
Issue date:	10/21/1986
From:	Allen T, Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20197A809	List: IR 05000454/1986030 ML20197A805
References
50-454-86-30, 50-455-86-26, NUDOCS 8610270434
Download: ML20197A973 (9)

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U.S. NUCLEAR REGULATORY COMMISSION l

REGION III

Reports No. 50-454/86030(DRSS); 50-455/86026(DRSS)

Docket Nos. 50-454; 50-455 Licenses No. NPF-37; CPPR-131 Licensee: Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690 Facility Name: Byron Nuclear Generating Station, Units 1 and 2 Inspection At: Byron Site, Byron, IL Inspection Conducted: September 29 through October 3, 1986 Inspectors: T.ANe to/u/sc, Team Leader Date LJ. S~#

J.Pattersonh io/u/a Date M. Smith Approved By:

(JE SM William Snell, Chief ich,/u Emergency Preparedness Date Section Inspection Summary

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Inspection on September 29 through October 3, 1986 (Reports No. 50-454/86030(DRSS);

j No. 50-455/86026(DR55))

l Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program: licensee actions on previously identified

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items; emergency plan activations; emergency detection and classification; protective action decisionmaking; notification and communications; changes to the emergency preparedness program; shift staffing and augmentation knowledge

. andperformanceofduties(training);publicinformationprogram; licensee audits; and maintenance of emergency preparednes Results: No violations of NRC requirements were identified during this inspection.

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DETAILS 1. Persons Contacted Commonwealth Edison Company

• R. Querio, Station Manager

• R. Pleniewicz, Production Superintendent

• R. Ward, Services Superintendent

• T. Joyce, Assistant Superintendent, Technical Services

• G. Schwartz, Assistant Superintendent, Maintenance

• W. Burkamper, Quality Assurance Supervisor, Operations

• R. Flahive, Rad Chem Supervisor

• Whitemore, GSEP Coordinator

• J. Pausche, Regulatory Group Leader T. Tulon, Operating Engineer F. Hornbeak, Technical Staff Supervisor T. Schuster, Assistant Technical Staff Supervisor R. Franklin, Shift Engineer T. Gierich, Shift En ineer D. Sulouff, Shift En ineer A. Javorik, Station ontrol Room Engineer (SCRE)

W. Kouba, SCRE S. Swan, SCRE W. McNeil, Lead Rad Chem Foreman S. Fletcher, Rad Chem Foreman D. Hermann, Rad Chem Foreman R. Munson, Rad Chem Foreman S. Sober, Health Physics Group Leader D. Drawbaugh, Support Services Instructor Non-Commonwealth Edison Personnel K. Dorsey, Nurse Manager, Rockferd Memorial Hospital M. Lewis, Assistant Chief, Byron Fire Protection Dis * Indicates those who attended the October 3, 1986 exit intervie . Licensee Actions on Previously Identified Items (Closed) Open Item Nos. 454/85034-01 and 455/85034-01: Develop and implement procedural guidance to ensure that emergency supplies and kits are inventoried af ter use and that missing"or expended items are replaced in a timely manner. Procedure BZP 500-4, Inventories of Emergency Supplies and Equipment," had been revised to require inventories quarterly and after each use, and the prompt replacement of any missing item. The inspector verified that inventories had been accomplished after kit use and quarterly and that missing items were promptly replaced. This item is close r

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(Closed) Open Item Nos. 454/86013-01 and 455/86011-01: The NRC was not notified within one hour after the Site Area Emergency in the annual exercise was declared and was not notified of key emergency events during the exercise. Procedure BZP 100-T1, " Station Director Checklist," and '

BZP 310-1, " Initial Notifications and GSEP Responses," have been revised to clarify the Station Director's responsibilities for notifying the NR The revision also referred the Director to BAP 1250-T4, " Event Notification Worksheet," for guidance on the information to be transmitted. In addition, the licensee indicated that future exercise ground rules and objectives would be written to clarify exercise notification expectation The inspectors determined that the licensee had notified the NRC within one hour of emergency plan activations during 1986 and had informed the NRC of appropriate activities occurring during the activations. This item is close . Emergency Plan Activations The inspectors reviewed documents related to the five emergency plan activations which occurred between September 1, 1985, and September 1, 1986. The documents reviewed included: Licensee Event Reports (LERs);

Shift Engineer's Logs; Nuclear Accident Reporting System (NARS) forms; licensee Event Notification Worksheets; and NRC Headquarters Duty Officer records. The inspectors determined that the licensee had completed the required notifications to the NRC and responsible State and local government agencies within the required time periods. Followup notifications were completed within adequate time periods after significant event changes and terminations. The five Unusual Event (UE) declarations were appropriate, but unnecessarily early in one case. The UE of September 16, 1985, was declared about 1.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after entering a Technical Specification which allowed 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to correct the problem. (The problem was corrected within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />). The licensee recognized later that the UE declaration was early and has made the declaration at more appropriate times in similar situations occurring since September 1985. The inspectors reviewed other LERs and did not find any plant conditions which warranted emergency plan activation ^

Based on the above findings,'this portion of the licensee's program was acceptabl . Emergency Detection and ClassYfication (82201)

The inspectors reviewed portions of the Generating Stations Emergency Plan (GSEP), Byron Annex to the GSEP, and Byron Station Emergency Plan Implementing Procedures (EPIPs). The GSEP and EPIPs contained the same Emergency Action Levels (EALs), which had 31 initiating conditions and the required four levels of event classification. Typographical errors identified in EPIP EALs during the previous inspection had been correcte The inspectors conducted walkthroughs with a team of one Shift Engineer (SE) and one Station Control Room Engineer (SCRE) and individually with two other SEs and one other SCRE. As Acting Station Director (50), the SE had responsibility for emergency classifications and for making the

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required offsite notifications and protective action recommendations until relieved by the SD. The SCRE was third in line of succession to SD and had responsibilities for assisting the SE in diagnosing and evaluating abnormal conditions. Personnel were able to demonstrate adequate familiarity with the GSEP, EPIPs, EALs, and notification equipment and forms during the walkthroughs. These walkthroughs presented conditions requiring all four levels of classificatio The SEs and SCREs correctly classified the events presented and demonstrated the ability to function as a team. All five demonstrated an adequate knowledge of their responsibilities and it was clear that they understood that, as Acting SD, the SE had the ultimate responsibility for declaring an emergenc Based on the above findings, this portion of the licensee's program was acceptabl . Protective Action Decisionmaking (82202)

As Acting SD, the SE had the undelegatable responsibility and authority to issue offsite protective action recommendations until relieved by the S The SEs and SCREs interviewed during the walkthroughs described in Section 4 of this report knew the requirement to issue an offsite protective action recommendation within 15 minutes following any General Emergency declaration. They demonstrated the capability to make correct onsite protective action decisions and to formulate offsite recommendation The Acting SDs utilized meteorology data for determining the proper protective actio The inspector reviewed the GSEP, Byron Annex, and appropriate EPIPs and determined that procedures for formulating offsite protective action recommendations were consistent with current regulatory guidance. The inspector noted that the protective action decisionmaking flowchart was more legible and that previous incorrect references had been removed from the guidance table in Procedure BZP 300-A2, " Recommended Protective Actions."

Based on the above findings, this portion of the licensee's program was acceptabl . Notification and Communications (82203)

The Byron Station provisions for accomplishing initial notification to licensee personnel and offsite governmental support organizations have been described in Section 6 of the GSEP and Byron Annex. Specific, adequate procedures for notifications and communications, and for maintaining and testing communication systems were in the EPIPs. For notification of a GSEP activation at the Byron Station, the dedicated NARS and ENS have been the primary communication link to State and County emergency organizations and the NRC. Should the NARS or ENS become inoperative, backup commercial telephone numbers for all appropriate offsite agencies were listed in the EPIPs and GSEP telephone directories.

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The inspectors reviewed reports of' monthly, quarterly, and annual communi-cation system tests and drills conducted during the period of September 1985 through September 1986. The tests and drills had been conducted in accordance with regulatory requirements and the GSEP and EPIP commitment The equipment checks appeared to be thorough and included facsimile and computer terminal modems. All tests were adequately documented and the reports indicated that corrective action was taken in a timely manne The inspector found adequate supplies of NARS forms and Event Notification Worksheets in the Control Room and Technical Support Center. As discussed in Section 3 of this report, the inspectors verified that notifications and communications of actual GSEP events were adequate and in accordance with regulation Based on the above findings, this portion of the licensee's program was acceptabl . Changes to the Emergency Preparedness Program (82204)

The NRC staff indicated its approval of Revision 2 to the Byron Annex in a letter to the licensee dated May 13, 1986. Revision 2 was based on Revision 5 to the GSEP and included improvements suggested in the previous inspection report. The changes included: the Station Director (SD) will notify State and County officials of any emergency recommendations that are issued; the Byron Station is entirely responsible for conducting the semiannual off-hours augmentation drill; and the SD is to assure that there is an annual review of the Emergency Action Levels with appropriate offsite official .The inspector examined the licensee's provisions for preparing, internal reviewing, and distributing new and revised BZP series Emergency Plan Implementing Procedures. These provisions were unchanged from the previous inspection and were considered adequate. The inspector determined that the established preparation, review, and distribution procedures had been followed for several recently revised BZP procedure The revisions checked had been distributed to licensee personnel within one week after being approved and to the NRC within 30 days after approva Manual holders were required to document the receipt and correct filling of revised procedure Based on the above 'indings, this portion of the licensee's program was acceptabl . Shift Staffing and Augmentation (82205)

i The minimum shift staff provided by the licensee's procedure, for augmentation of onsite staff BZP 300-A-5, was reviewed and found to have

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met the goals of Table B-1 of NUREG-0654, Revision 1. Provisions included adequate guidance on the staff needed to declare specific emergency response facilities operational. The licensee's call tree procedure and prioritized call list, BZP 600-A-1, identified at least three persons for i each key onsite emergency organization position. The inspector identified

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inconsistencies between shift staff numbers listed in BZP 300-A-5 and l

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Figure 4.2-3 of the GSEP. For example, the BZP listed a minimum staff of nine for an Alert while a minimum number of 11 was listed in the GSE The inspector selected three Call Supervisors from those listed in BZP 600 A-1 and called them at home. These supervisors had their call tree list available and seemed knowledgeable of their shift augmentation responsibilities. Records of the augmentation drills conducted in August 1985 and April 1986 were reviewed and indicated that the drills were conducted in accordance with appropriate BZP procedures and that adequate augmentation was accomplishe Based on the above findings, this portion of the licensee's program was acceptable; however, the following item should be considered for improvement:

• The inconsistency between niinimum staff numbers in Byron Procedure BZP 300-A-5 and the GSEP should be eliminated or explained in the BZ Knowledge and Performance of Duties (Training) (82206)

' The inspectors reviewed the Station's emergency preparedness (EP)

training program for licensed and non-licensed personnel who had key roles in the onsite emergency organization. The licensee's Production Training Center had overall responsibility for ensuring that all licensee, contractor, and other personnel granted unescorted access to the Station received annual training of general aspects of the GSEP and Byron Annex. The' Station Training Department has administered that training and additional annual training to persons assigned specific positions in the onsite emergency organization. The annual EP training requirements for Station personnel were specified in procedure BTP 300-T2, " Byron Station EPIP Training Matrix." About a dozen training records for persons assigned to various Station Group director positions were checked and each record was complete and up to date according to Procedure BTP 300-T Three new lesson plans related to specific GSEP subjects had been added to the previous 18 plans. Inspection of the new lesson plans (communicators, OSC Director, ODCS-A) determined that the plans were adequate in scope and applicable to EP. Procedure revisions relevant to the emergency plan and NRC inspection reports on EP are routed by the GSEP Coordinator to persons assigned key positions in the emergency organizatio In addition to the SE/SCRE walkthroughs previously described in this report, the inspectors conducted walkthroughs or interviews with three Technical Directors, two Rad Chem Directors, three OSC Health Physics Supervisors, and three teams of two Rad Chem Technicians. All persons interviewed demonstrated an adequate understanding of their emergency response duties. The directors and supervisors knew their responsibilities, could use appropriate procedures, and understood their authority and interfaces with other emergency response positions. They demonstrated an adequate knowledge of installed instrumentation that could be utilized to

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help assess emergency condition The technicians knew the equipment required for offsite monitoring , where the equipment could be located, what to do if the equipment failed, and described acceptable radiological survey and sample routine Based on the above findings, this portion of the licensee's program was acceptabl . Public Information Program (82209)

The inspector reviewed the Byron 1986, Emergency Information publication and determined that it described appropriate emergency planning informatio The publication also provided points of contact for the public to acquire additional information from the licensee, the. State, and local government organizations. The public information program and offsite coordination program were managed by the licensee's public information and emergency planning staffs located in the Chicago Corporate office. The inspector determined that the regulatory requirements for public information were adequately me Based on the above findings, this portion of the licensee's program was acceptabl . Licensee Audits (82210)

The inspector reviewed Quality Assurance (QA) Department records of independent audits and surveillances of.the Station's emergency preparedness programs which were conducted since September 1, 198 The reports of onsite audit QAA 06-86-26 and offsite audit 06-86-II were determined to adequately document those audits and to be adequate in scope and depth of questions regarding the regulatory requirements of 10 CFR 50.54(t). Reference documents from which the audits were developed included regulatory guides, 10 CFR Part 50, the GSEP and Byron Annex, NRC repcrts of previous inspections of the Station's emergency preparedness program, and the emergency plan implementing procedures. Negative items identified by the audit were categorized as findings, open items, observations, or comments, which are comparable to the NRC's categories of violation, open item, improvement item, and comment, respectivel One open item related to emergency supply provisions was identified in AuditQAA 06-86-26. The QA program for followup on open items appeared to be adequate for assuring that corrective action is reported to the QA Department within 30 days anc that the Department conducts a followup within 90 days to evaluate the effectiveness of action take Eleven records of QA surveillances of medical, communications, augmentation drills, and inventories of emergency equipment, conducted between September 1, 1985, and September 1, 1986, were reviewed by the inspector. The review determined that QA surveillances applicable to l emergency preparedness were of appropriate scope and variety and that they were adequately documente I

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s The licensee had made audit and surveillance results addressing the Station's interface with offsite emergency support organization available to appropriate State and local government organizations. The availability of these audit portions and how to request copies was addressed at the Annual Offsite Agency Meeting held on September 26, 198 The GSEP Coordinator was required to evaluate the adequacy of records generated by the. Station during GSEP events and the timeliness of all offsite notifications. The inspectors determined that the GSEP Coordinator had performed this task in a satisfactory manne Based on the.above findings, this portion of the licensee's program was acceptabl . Maintaining Emergency Preparedness The inspector determined that the licensee's Letters of Agreement with local emergency support organizations had all been reissued in 198 The inspector contacted management level representatives of the Byron Fire Protection District and Rockford Memorial Hospital. -The persons contacted expressed no dissatisfaction or problems with emergency preparedness training that had been provided by the licensee and were adequately aware of their organization's roles and the support to be provided by Station personnel in the event of an emergency at the Byron-Station. The inspector determined that representatives of the Fire Protection District had participated to some degree in some of the-Station's fire drills and Station fire brigade personnel received some training-at'the Fire District's training facilit The inspectors examined records of the September 26,~1985, offsite agency meeting. The records indicated that appropriate State and local officials had been invited and attended the meeting. The meeting agenda included discussions of the GSEP, the Station's Fire Protection and Security Plans, emergency action levels, the licensee's quality assurance program, and a question and answer sessio The. licensee had conducted or was scheduled to conduct the annual emergency preparedness drills required by regulations and specified i in the GSEP and Byron Annex. The drills completed had been critiqued i by drill participants and controllers and were adequately documente Areas requiring improvement were addressed and tracked by the GSE Coordinato An inspector examined records of emergency equipment and supply- kit

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inventories performed since October 1, 1985, and determined that all the i

inventories specified in BZP 500-4, " Inventories of Emergency Supplies and Equipment," had been completed on schedul Comparisons of inventory I records with drill records indicated that inventories were conducted in a L timely manner after a kit was used in a drill and, with one minor ex'eption, c kit inventories were maintained at fully stocked quantities.

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The July 9,1986, inventory of the OSC emergency kit (BZP 500-T7) listed 18 of the required 20 silver zeolite cartridges as being on hand and no apparent corrective action was taken at that time.

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The inspector determined that neither the procedure (BZP 500-4) nor the

~ inventory checklist (BZP 500-Ts) specified whether the number of items found in a kit had to be recorded. Only one inventory checklist did not have any numbers recorded, but it had checkmarks indicating that the inventory count was correct. However, a "c" in the same column would-indicate that the inventory had to be corrected. On several checklists it was difficult to determine if the recorded symbol was a checkmark indicating correct inventory or the letter "c" indicating corrective actio It was also noted that the environmental monitoring checklist, BZP 500-T8, did not require periodic replacement of self reading dosimeter The inspector observed the quarterly inventory of the environmental monitoring supplies, support hospital supplies, and Emergency Operations Facility (EOF) supplies. These inventories were conducted by technicians who used the applicable checklists and carefully checked and counted the items. The technicians found out of date sets of film badges and self-reading dosimeters in the hospital supplies. These out of date dosimetry devices were found packaged together and behind the dosimetry-devices authorized for current use. Similarly, one out of date self-reading dosimeter was found during the inventory-at the E0F. The licensee must improve inventory or equipment accountability procedures to ensure that out of calibration or expired equipment is not left in emergency-kits. This is an Open Item (454/86030-01 and 455/86026-01).

In addition to the open item, the following items should be considered for improvement:

• Inventory procedures should clarify whether or not the number of each item found is to be recorded or not and should use more easily distinguishable marks for indicating correct and incorrect inventor * Inventory checklist consistency should be improved by using the similar headings, footnotes, and action ,

1 Exit Interview The inspectors met with licensee representatives identified in Section 1 on October 3, 1986, to discuss the preliminary inspection findings. The licensee agreed to consider the items discussed and stated that none of the material discussed was proprietary in natur . . __ _

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