IR 05000454/1990005
| ML20033E194 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 02/21/1990 |
| From: | Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20033E193 | List: |
| References | |
| 50-454-90-05, 50-454-90-5, 50-455-90-04, 50-455-90-4, NUDOCS 9003090323 | |
| Download: ML20033E194 (8) | |
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U.S. NUCLEAR REGULATORY COMMISSION l
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REGION III
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Reports No. 50-454/90005(DRSS); 50-455/90004(DRSS)
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Docket Nos. 50-454; 50-455 Licenses No. NPF-37; NPF-66 Licensee:
Commonwealth Edison Company Post Office Box 767
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Chicago, IL.60690
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Facility Name:
Byron Nuclear Generating Station, Units 1 and 2
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Inspection At:
Byron Site, Byron, Illinois Inspection Conducted:
January 30 through February 2, 1990
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I Inspector:
Patterson F
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Accompanying Personnel:
D. Barss Approved By:
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William Snell, Chief Date
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Radiological Controls and
Emergency Preparedness Section
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Inspection Summary:
i Inspection on January 30 through February 2,1990 (Reports No. 50-454/90005(DRSS);
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No. 50-455/90004(DR55)
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Areas Inspected:
Routine announced inspection of the following areas of the
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I Byron Station Emergency Preparedness (EP) program:
action on previously
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l identified items (IP 92701); emergency plan activations, operational status'of the program (IP 82701), emergency plan and implementing procedures, emergency
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facilities and equipment, tra ning, organization and management, and
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independent audits.
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.Resul ts:
No violations or deviations were identified during the inspection.
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The EP program continues to function well.
The Training Department has
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defined its goals, interactions with corporate EP, and listed the specific
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responsibilities of each training group as related to EP training.
A new administrative procedure has improved coordination in the training department i
as related to EP.
Other factors of the program are being implemented to exceed GSEP requirements.
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DETAILS
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1.
Persons Contacted
- R. Pleniewicz, Station Manager i
- R. Ward, Technical Superintendent
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- G. Schwartz, Production Superintendent
- J. Kudalis, Services Director
- T. Schuster, Nuclear Licensing Administrator
- S. Barrett, Radiation Protection Supervisor
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- A. Chernick, Training Supervisor
- G. Rundlett, General Instructor, Training
- R. Carson, Onsite GSEP Programs Administrator, Corporate
- S. Sober, GSEP Coordinator i
- D. Bump, Nuclear Quality Programs
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- C. Rahn, Office Supervisor
- J. Capp, Assistant GSEP Coordinator
- E. Zittle, Regulatory Assurance Staff r
- D. Swartz, Byron Project Engineer
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T. Oracki, Lead Instructor, Support Services D. Winchester, Quality Assurance Superintendent K. Orris, Engineering Assistant, Regulatory Assurance
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- Denotes those licensee representatives who attended the NRC exit
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interview on February 2, 1990.
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The inspectors also contacted other licensee personnel during the
inspection.
2.
Li,censee Actions on Previously Identified Items (92701)
a.
(Closed) Open Item Nos. 454/88018-01; 455/88016-01.
The Station Director's Communication position has been proceduralized (BZP-100-T13, Revision 0) and training provided.
Since these actions were taken, a new position of Assistant Station Director
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has been established; and it will be formalized when Revision 7 to the GSEP is issued.
This item is closed.
b.
(Closed) Open Item Nos. 454/88018-02; 455/88016-02.
This item
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encompassed the Training Department, Corporate Emergency Planning Byron Administration Department, and the GSEP coordinator.
Through discussions with cognizant Training Department Instructors, the inspectors determined that the entities involved are now better coordinated.
Responsibilities are delineated in a new procedure titled Emergency Planning Administration.
BAP 600-8, Revision 0.
Revised lesson plans are scheduled to be issued by approximately May 1, 1990.
This item is closed.
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l c.
(Closed) Open Item Nos. 454/88023-01; 455/88023-01.
An observation from the 1988 annual exercise was that there was insufficient
communications from the OSC and TSC to support the Radiation /
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i Chemistry Technician (RCT) in the bomb search event, also indicating
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1ack of planning by the OSC for entry into a high radiation area.
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These problems did not occur in the 1989 exercise, which indicated
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better preparation and training.
This item is closed.
i d.
(0 pen) Open Item Nos. 454/89018-01; 455/89020-01.
This item
resulted from some inadequacies in following environmental sampling
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l procedures by the environmental sampling team in the 1989 exercise.
l Drills and training sessions have addressed these inadequacies to a great extent.
However, until environmental sampling for air, water, soil, and vegetation is adequately demonstrated in the 1990
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annual exercise, this item remains open.
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l 3.
Emergency Plan Activations (IP 92700)
l A review of license and NRC records indicated that there were four
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emergency plan activations since September 23, 1988, until the date of
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the inspection.
Two of these were fire related, one a grass fire and the
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other a small fire in a pump motor.
The two other events were plant operations related.
Each event was correctly classified, notifications made within time requirements, and updates of conditions were made to the
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NRC and the State, where applicable.
The GSEP compilation and evaluation
of records associated with plan activations were thorough and complete.
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Based on the above findings, this portion of the licensee's program was acceptable.
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4.
Operational Status of the Emeroency Preparedness Program (82701)
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Emeroency Plan and Implementino Procedures
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To assure that changes in the GSEP for Byron Station and changes in
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the emergency plan implementing procedures (EPIPs)'are submitted to
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the NRC within 30 days of such changes, the inspector selected at random some issue dates of procedures.
The Document Control representative stated that return receipts signed by Region III and listing the date sent out were only kept for three months.
Beyond the three month period the computer printouts only list the date l
thattherevisionwasIssued.
From this scoping review, it was not readily apparent that the licensee had a method to assure that these i
procedures were sent to and received by the NRC within 30 days after
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l being issued.
It was determined that, from NRC Region III receiving
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records, these procedures had been distributed within 30 days after
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L being issued, as required.
The licensee should develop some method to assure that EPIP changes e
are sent to the NRC within 30 days after they are issued.
This is
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required by 10 CFR 50.54(q) and Appendix E,Section V.
To assure
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that this issue would be addressed, the GSEP Coordinator entered an
item on the licensee's Action Item Record requesting action prior J
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to the exit interview.
There was some difficulty in verifying that the two year EPIP review was being conducted as required by the GSEP, Section 8.5.
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administrative representative from the corporate office was
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contacted and this person gave instructions to Byron representatives
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on how to develop this information from their computer generated data.
The end product produced was exactly what was needed.
Prior
to that, the representatives from Regulatory Assurance and Document r
Control were not aware of any method to verify that these two year reviews were being conducted as required by the GSEP.
Better
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communication and coordination on information required for GSEP
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should bt initiated through the GSEP Coordinator.
Based on the above findings, this portion of the licensee's program was acceptable; however, the following item is recommended for improvement:
Improved dialogue and coordination is recommended between the
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GSEP Coordinator, Document Control, and Regulatory Assurance to ensure the requirements of Section 8.5 of the GSEP, titled
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" Distribution, Review and Updating of the GSEP" and corresponding EPIPs are being met, b.
Emergency Facilities, Equipment, Instrumentation, and Supplies
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Records of supply inventories and facility and equipment surveillances were reviewed and found to have been completed in a timely manner in accordance with established procedures.
Deficiencies identified through inventory checks and surveillances
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l were quickly resolved to ensure that emergency response facilities l
l were adequately maintained in a state of readiness.
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l It was confirmed by the inspector that the frequent replacement of
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many items in first aid kits and selected items in the personnel decontamination area, 401 level of Auxiliary Building, was
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i necessary.
However, the consumption rate seems considerably higher l
when compared to actual events requiring use.
However, through monthly inventory checks these items were maintained in adequate
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supply.
t A tour of Emergency Response Facilities was conducted with the following observations noted for each facility.
The Technical Support Center (TSC) was clean, neat and
adequately set up for immediate use in an emergency situation.
TSC equipment and supplies were readily available for use and
in good order with one exception.
The TSC copy machine was f
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temporarily being used in another location and was nof
immediately available for use.
l Copies of plans and procedures were available and up to date in
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the TSC.
However, three copies of Figure BYA 6-2, dated May 1986, Revision 2, Byron Station Evacuation Time Estimates, j
were found under glass cover on the TSC tables. The current i
version is Revision 3 dated February 1987.
These outdated
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figures will be replaced with the current revisions.
j An electronic status board (a computer terminal) has been added
to the TSC to facilitate rapid and accurate transmissio.n of i
information and data from the TSC to the Emergency Operation f
Facility.
Also a direct phone line between the security directors and the Security Alarm Station (SAS) has been
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l added.
This additional phone line should enhance the
communications capability between the security director and
SAS, particularly when personnel accountability is performed.
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In the Control Room (CR) current copies of Emergency Plans and.
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procedures were available and stored in a designated, marked
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location for quick access.
Forms for notification and
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appropriate documentation were readily available.
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Emergency Communication Equipment (Telephones) were neatly
arranged and clearly labeled for easy identification.
One survey instrument in the CR emergency equipment locker
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was found to be out of calibration according to attached t
calibrations sticker.
A check of calibration records indicated the survey instrument was within calibration frequency and had only been mislabeled.
The equipment storage area for the OSC was neatly maintained
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and easily accessible.
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In two locations, the Radiation Protection Officer Emergency
Medical Kit and the Personnel Decontamination Area, bottles of
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Saline solution were found which were past their expiration date,(December 1989).
Also, two bottles of eye wash were found with elapsed expiration dates.
In other areas reviewed, it was determined that Byron Nuclear Station has recently obtained a van which has been equipped and dedicated for use in support of GSEP activities.
An area has also been designated in the assembly areas where personnel in protective clothing can assemble and be accounted for while maintaining segregation from
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personnel in street clothing.
Based on the above findings, this portion of the licensee's program
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was acceptable, t
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c.
Organization and Management Control The current reporting line for the GSEP Coordinator continues, as in prior years, to the Health Physics Supervisor, then to the Technical Superintendent, and on to the Station Manager.
From information j
received this reporting order does not impede actions or important
decisions related to EP.
Some of the Licensee's other plants have i
the GSEP coordinator reporting directly to the Technical Superintendent.
The person serving as GSEP Coordinator was appointed to that position in August 1989.
A part time Assistant GSEP Coordinator was i
appointed in September 1989.
The GSEP van was purchased since the
prior inspection.
This purchase can also be viewed as a management
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commitment, both Corporate and Station, to improve the capability
and technical competence of the environmental monitoring teams and
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the field monitoring in general.
Based on the above findings, this portion of the licenset's program
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was acceptable, i
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Training
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To address the coordination problems identified in Open Item.
Nos. 454/88018-02; 455/88016-02 (see Section 2) the licensee issued
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Procedure No. BAP 600-8, which specifies the function of the station
EP group, their relationship with corporate EP, the station Training
Department Responsibilities, and the coordinating responsibilities of the station EP group.
Another element of the Training Departments
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function is the submittal of documentation of EP training which is l
consistent with Procedure BTP 300-6, which is a training guide with numerical designations for EP training courses.
The following EP drills were conducted and successfully met the
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requirements of the GSEP including critiques:
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i 2 - Shift Augmentation Drills
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2 - Health Physics Drills (one using the High Radiation Sampling
System (HRSS))
1 - Environmental Drill 1 - Medical Drill
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1 - Communications Drill l
1 - Site Assembly and Accountability
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In both of the Shift Augmentation Drills the position of Environs
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Director was difficult to staff in the recommended time frame.
To improve response times, pager numbers for GSEP call out personnel were added to appropriate phone lists and call supervisors were retrained to use pager numbers as necessary.
This should help in lessening the response time for the Environs Director as well.
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Approved lesson plans were available.
Those reviewed were considered to be satisfactory.
These lesson plans have been developed and updated.
Final approval of the revised lesson plans
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is scheduled to be completed by May 1, 1990.
The approved EP
Training Matrix is also included as an attachment to this l
procedure.
This attachment includes all the required training,
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including drills and applicable procedures for each emergency
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response position with the exception of training for Control Room
Personnel.
Their EP training is provided twice a year. The proposed lesson plan for Control Room personnel includes some EP
related information, especially for Emergency Action Levels (EAls).
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Interviews were conducted with seven individuals holding the following emergency response positions:
one Technical Director, one
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Environmental Director, two OSC Supervisors, and three Rad / Pro
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technicians.
All demonstrated very good capabilities and
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competencies in knowing their emergency response functions.
Knowledge of and familiarity with implementing procedures could be
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improved for the'OSC and Technician level responders.
Also, training records for 14 individuals, whose names were selected randomly, were reviewed to assure that the training was current and complete.
No discrepancies were identified in the training records.
Based on the above findings, this portion of the licensee's program '
was acceptable, e.
Independent Reviews / Audits Quality Assurance (QA) Department records of audits and surveillance were readily available and addressed key aspects of the EP program as identified by the inspector.
Two QA audits and nine surveillances each year were conducted since the last inspection of
September 1988.
The earlier audit included activities since
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May 1988 through June 1989.
The second audit identified as a Corrective Actions Audit was concutted in January 1990 and included many plant related areas besides EP.
One item identified in the January 1990 audit was followup on an NRC Information Notice which stressed the importance of maintaining confidentiality for the exercise scenario developers.
This was a good example of QA addressing NRC current issues that relate to EP.
Other areas of review in the June 1989 audit included the adequacy of interface of State and local governmental agencies with the licensee, the Illinois Plan for Radiation Accidents shift augmentationcapability,andLettersofAgreementwlthoffsite.
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support agencies.
Surveillances included most GSEP required drills and attendance at a meeting of offsite agencies with station and corporate level personnel, whose agenda included a review of current EALS applicable to the Byron Station.
The QA program as administered, where applicable to-the EP program,
appeared well disciplined in content and thorough.
It demonstrated J
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a good follow-up mechanism to track items which needed improving,
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revising or elimination.
Many more surveillances were conducted
on a yearly basis than the two required.
A monthly informal meeting
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with the GSEP Coordinator helps keep the QA group informed of EP
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areas needing QA attention.
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Based on the above findings, this portion of the licensee's program
was acceptable.
5.
Exit Interview The inspectors met on February 2,1990, with those licensee representatives identified in Section 1 of this report.
The scope and
preliminary inspection findings were summarized.
No violations were identified.
The EP program as presently administered appears to be functioning well.
Better defined training goals, including defining the responsibilities of corporate training, station training and the station's EP group should make for a more effective and better structured program.
Improved communications between the GSEP Coordinator's office and administrative support groups as Document Control and Regulatory Assurance, will clarify how these two support groups can better assist'
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the GSEP coordinator in meeting certain GSEP requirements.
The part-time
assistant to the GSEP Coordinator should be quite useful, if properly
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directed, to implement the station EP program.
The licensee was asked if any of the information discussed during the
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exit interview was proprietary.
The licensee responded that none of the information was proprietary.
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