IR 05000454/1998002

Insp Repts 50-454/98-02 & 50-455/98-02 on 980105-09.No Violations Noted.Major Areas Inspected:Review of Emergency Preparedness Program & Aspect of Plant Support

ML20198T395
Person / Time
Site:	Byron
Issue date:	01/21/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20198T388	List: IR 05000454/1998002 ML20198T383
References
50-454-98-02, 50-454-98-2, 50-455-98-02, 50-455-98-2, NUDOCS 9801270048
Download: ML20198T395 (11)

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U.S. NUCLEAR REGULATORY COMMISSION  !

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REGION lll l

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Docket Nos: 50-454;50-455 -

License Nos: NPF 37; NPF-66 [

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Report Nos: 50-454/98002(DRS); 50-455/98002(DRS)  :

Licensee: Commonwealth Edison Company (Comed)

I Facility: Byron Generating Station, Units 1 and 2 Location: 4450 N. German Church Road Byron,IL 61010

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Dates: January 5 9,1998 r

Inspectors: James Foster, Senior Emergency Preparedness Analyst Don Funk Emergency Preparedness Analyst Approved by: James R. Creed, Chief Plant Support Branch 1 Division of Reactor Safety

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t EXECUTIVE SUMMARY f

Byron Generating Station NRC Inspection Reports 50-454/98002; 50-455/98002  !

This inspection reviewed the Emergency Preparedness (EP) program, an aspect of Plant .

Support. This report evaluated the quality of EP program related audits and reviews, reviewed l'

the effectiveness of management controls, verified the adequacy of emergency response facilities and equipmentireviewed EP training and qualification activities, and included follow up i

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on previous inspection findings. This was an announced inspection conducted by two regional inspectors, j Overall, the EP program had been maintained in an effective state of operational readines Emergoney response facilities, equipment, and supplies had been well maintaine .

Management support to the program was strong and interviewed key emergency response personnel demonstrated competent knowledge of responsibilities and emergency procedure ;

+ Overall, the emergency response facilities, equipment, and supplies were very well [

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maintained. All emergency equipment requested to be demonstrated was verified operable. The prompt alert and notification system sirens were well maintaine (Section P2.1)  ;

• The Emergency Plan implementing Procedures reviewed were clear and easy to use, ,

Documentation reviewed was complete. Problems had been properly entered into the Problem Identification Form system when considered to exceed the threshold for entrance to the system. Corrective actions on several PlFs remained to be fully determined. The EP staff had proactively analyzed the impact a major steam generator project would have on the site EP program. The Public information Brochure had recently been distributed. (Section P3)

. Overall, EP training was effective. Interviewed key emergency response personnel ,

demonstrated competent knowledge of responsibilities and emergency procedure Training records indicated that the program for tracking emergency responder i qualifications was effective. Training modules were properly updated with one minor J exception. An effective program for defining and tracking respirator qualifications for emergency responders had been proactively developed (Section PS)

+ Both the annual audit and Peer Review recommended that the EP trainer should report to the EP Coordinator as a means of strengthening the program through increased communication and cooperation, (Section P6)

. The licensee's 1997 EP audits and surveillances, and 1997 EP Program Sel Assessment Report were effective and satisfied the requirements of 10 CFR 50.54(t).

The audit and program self assessment were of good scope and depth. Identified issues were appropriately tracked and resolved. Corporate efforts in assessing the overall program added value (Section P7)

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Reoort Detan IV. Plant Support P2 Status of EP Facilities, Equipment, and Resources P Material Condition of Emergency Resoonse Facilities (ERFs) Insoection Scone (82701)

The inspectors evaluated the material condition of the control room, Technical Support Center (TSC) Operational Support Center (OSC), and Emergency Operations Facility (EOF). The OSC activation cart was inspected. Both field monitoring team vans and associated equipment (field monitoring kits) were also inspected. The licensee demonstrated the operability of several pieces of emergency response equipment, including radiological survey instruments, dose assessment and plant data computers, portable generators, and communications equlpment. Records of periodic inventories and equipment tests were also reviewe b, Observations and Findings The control room was well maintained and had current EP procedures available. The emergency notification system phone was verified operabl The OSC, TSC, and EOF were well maintained. One observed enhancement was the addition of a work space and procedures to support a Severe Management Team in the TSC A severe accident management status board had also been developed. A colo coded Station Director " quick reference" had been developed to provide reference to applicable procedures and placed at the Station Director's desk. An electrical distribution diagram had been added to facilitate analysis of grid problem Telephones, computer terminals, and other equipment were tested and found operabl Current procedures were available in the facilities. The licensee provided demonstrations of portable electric generators, dose assessment computers, and plant data computer A computer had been added to enhance the OSC by allowing access to the Generating Station Emergency Plan (GSEP) section of programs. This computer was found to have an improper password. This problem was viewed as very minor and was immediately correcte Prompt alert and notification siren operability report for 1996 - 1997 was reviewed by the inspectors. Annual siren operability for 1997 was 98.3 percent with 96,9 percent reported for the lowest month's average. The operability report automatically highlights siren operability percentages of less than 95% for management attention.1997 siren operability for Byron consistently exceeded the Federal Emergency Management

Agency acceptability standard of 90 percen L

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l The inspectors reviewed the semiannual augmentation drill records. Three drills had i been conducted since the last routine NRC inspection and were reported as successful, .

The inspectors noticed that the drills conducted during 19931996 had been conducted at approximately the same time frame and month, providing some predictabilit i j Variation from this pattom was noted in the 1996 and 1997 drill .

<' Conclusions  !

Overall, the facilities, equipment, and supplies were very well maintained. All

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emergency equipment requested to be demonstrated was found operable, The prompt alert and notification system strens were well maintaine ,

P3 EP Procedures and Documentation insoection Scoos (82701)

The inspectors reviewed a selection of licensee emergency plan implementing procedures (EPIPs) and emergency plan sections. Recent memoranda issued by the EP staff were reviewed and discussed. Problem identification Forms assigned to the -

Emergency Preparedness Group were reviewed. Also, the Public Information Brochure was reviewe Observations and Findinos One of the emergency implementing procedures reviewed by the inspectors was BZP-300-01, " Protective Action Recommendations *, Revision 1, dated December 23,1997.

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The procedure mirrors the corporate procedure, and was well detal!ed. Definitions were properly provided for the terms " release occurring", * potential release", "unmonitored release *, and * release duration." It was noted that the flow chart associated with the t procedure (BZP-300-A2) refers the reader to figure 6.3-2, which is a portion of the corporate procedure but not the site procedure. This erroneous reference had no impact, since the figure was for sector determination, which is performed utilizing site maps and charts, Discussion indicated that the reference would be corrected, in the near future, by a procedure change, The inspectors r6 viewed CEPIP 310101, " Environmental Sample Collection Procedures", revision 12, dated December 4,1997. The procedure was concise and technically adequate. The snow sampling portion of the procedure,in section 8.g. called upon the user to record sampling location and other details in the ' comments" section of the attached sampling form The attached sampling form lacked a " comments" 4

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section, but did contain adequate space to enter the desired information, it was indicated that the procedure would be clarified to more accurately sp6cify the recording guidance, Discussion indicated that the "OSC benchmarking" process was complete. This process

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standardized procedures and documentation utilized in OSCs at each Comed site, facilitating sharing of OSC personnel from site to site,

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l The plant was in the final stages of replacing the steam generators in Unit 1. Discussion and a review of documentation indicated that the EP staff had reviewed and planned for the impact this evolution would have on the site EP program. This was considered a proactive initiative on the part of the EP staff. As a followup to the last evaluated exercise, the licensee had evaluated use of the core damage assessment methodology contained in NRC Response Technical Manual 96, and concluded that it was useable, with modifications to account for a faster heatup rate when conditions exist for a zirconium-water reaction, per Westinghouse Owners Group calculations. The analysis

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also noted that this procedure was to be utilized for determination of core damage, not core damage quantificatio A search of the PlF system and discussion with the EP Coordinator identified ten Byron station PlFs related to emergency planning. Several of these PlFs were either closed or in the process of being closed; review of these PIFs indicated that corrective actions were acceptable. An example of this was PIF B1997-01637 related to high temperatures in the TSC during the summer due to the failure of an air conditioning chiller uni Several PIFs were appropriately open and a selective review was performed. PlF B1997 01464 pertained to the two exercise weaknesses related to event classification and use of the Acting Station Director checklist identified during the 1997 evaluated exercise, PIFs B1997 01190 and B1997 01233 both pertained to difficulties in hearing either assembly alarms or plant pages in certain areas of the plant. Related PlF B1997-0394 documented continuing problems with audibility of plant alarms. Discussion indicated that a * trending" PlF would be utilized to consolidate problems related to plant alarm audibility and track the resulting evaluation and subsequent corrective action Evaluation of these problems was in progress, with corrective actions in progress or not fully determined. Corrective actions in progress or proposed appeared appropriat Review of the PlF documentation indicated that these problems had been properly identified as meeting the threshold for entering into the PlF syste Discussion and a review of documentation indicated that a corporate PlF (C1997 00067)

had been generated relative to a perceived negative trend in initial event classifications during evaluated exercises at several Comed sites. A possible cause of the trend was identified nn an Apparent Cause Evaluation form as the methodology utilized for simulator training, in that event classifications and notifications were being done after the fact during training, absent the time pressure to classify an event present in an exercise or real event. Further monitoring of this item, and determination of adequacy of corrective actions was planned. This PIF appeared to be an appropriate use of the corporate PlF system to identify, track, and resolve a problem affecting multiple station The inspectors reviewed the Byron Emergency Information Public Information Brochur The brochure had recently been distributed, and contained a printed note on the cover page noting additional emergency radio station frequencie ._

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• .  ? Conclusioni The EPIPs reviewed were clear and easy to use. Documentation reviewed was  ;

complete. Problems had been properly entered into the PIF system when considered to exceed the threshold for entrance to the system. Corrective actions on several PIFs remained to be fully determined. The EP staff had proactively analyzed the impact a

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major steam generator project would have on the site EP program. The Public Information Brochure had recently been distributed.

< P5 Staff Training and Qualification in EP l

' insoection Scone (82701)

The inspectors reviewed various aspects of the licensee's training program. The  ;

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reviews included interviews with selected key emergency response organization (ERO)

personnel including a TSC Chemistry Director and a TSC Technical Director, review of training modules, computerized qualification records, and the Emergency Call List. The

, inspectors also observed training conducted for new license candidates. The status of the respirator qualification program was reviewe ' Ohnenallons and Findinas The inspectors compared the training module matrix, prioritized calllisting for staff (BZP ,

600 A1) with current computer printouts for emergency response personnel verifying that personnellisted were qualified. All ERO personnel reviewed were currently qualified for their emergency response positions. The EP trainer also maintained a computerized qualification listing for response personnel who were not a part of the call listing. These listings included personnel assigned to Operations, Rad Protection, Chemistry, and Maintenance. Records indicated that drills and training were formally critique Interviews with two key emergency response personnel indicated appropriate knowledge of procedures and eme,gency responsibHities. Each individual was able to describe the response process in detall, and describe both their response functions and the applicable procedures they would utiliz Discussion Indicated that there had been additional involvement by the EP coordinators in operator simulator training. This additionalinvolvement was reported to have shown en improvement in operator classification and notification performanc Several training modules were selected and read; no problems were identified. A review of training module revision dates indicated that training modules, with one exception, had been reviewed and revised in 1996 and 1997, Training module S 25, 'ODCS Specialist", was found to have a revi:,lon date of December 21,1994. The training module was also out of date in that it did not provide training on MESOREM96, which is the dose calculation program currently utilized, Discussion and a review of records indicated that corporate personnel had provided training for Offsite Dose Calculation

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System (ODCS) personnel, utilizing a corporate training module which appropriately addressed MESOREM96. Therefore, the failure to update the training module had no

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impact on current training quality. Corporate EP personnelindicated that the corporate module would be transmitted to the site for transformation into a site training modul Updating of training module S 25 was an Inspection Follo' i up Item (IFI) 50-454/455/98002 01).

The inspectors discussed the status of the respirator qualification program and reviewed qualification summary documentation. The EP staff had been assigned a Nuclear Tracking System tracking item (454 512 97 RESPROG-01) to " evaluate and determine the adequate number of respirator qualified personnel needed to support OSC emergency teams staffing for required disciplines.* Disciplines to be evaluated included mechanical, electrical and instrument maintenance, rad protection, chemistry, and operations. The total number of affected individuals in each discipline had been identified, and the percentage of those qualified,in each group. Of those not qualified,it had been determined which individuals required only a mask fit to be qualified. The total affected population had been determined to be 289 individuals, with 200 of these qualified as of January 9,1998. The NRC is currently developing a position on respirator qualification for emergency teams, but this has not been finalized. The above actions appeared to be a proactive effort to develop a comprehensive program even without regulatory guidance, Conclusions Overall, EP training was offective. Competent knowledge of emergency responsibilities and procedures was demonstrated by key ERO personnel. Interviewed key emergency response personnel demonstrated their knowledge of responsibilities and emergency procedures. Training records indicated that the program for tracking emergency responder qualifications was effective. Training modules were properly updated with one exception. The training module which had not been updated had not been utilized; training had been provided by corporate personnel using a current module. An effective program for defining and tracking respirator qualifications for emergency responders had been proactively develope P6 EP Organization and Administration No significant changes have been made to the EP organization since the last inspectio The Emergency Preparedness Coordinator continued to report to the Health Physics Supervisor, and the EP trainer reported to the Operations Training Group. Both the annual audit and Peer Review recommended that this organization be modified to have the EP trainer report to the EP Coordinator as a means of strengthening the program through increased communication and cooperation. The inspectors discussed with the Health Physics Supervisor the possible change of the organl7ation as recommended, and were advised that management was very receptive to the proposed reorganization, and would likely make this change in the very near futur .

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P7 Quality Assurance in EP Activities a, lagection Scope (82701)

The inspectors reviewed the Byron Site Quality Verification (SOV) Audit of Emergency Preparedness, QAA 06 97-06, dated May 12,1997. The audit objective evidence was reviewed and discussed with the lead auditor. Also reviewed were surveillance reports related to emergency preparedness, the 1997 Emergency Preparedness Program Sel Assessment (" peer review *) report, dated July 25,1997, conducted during April 1418, 1997 by corporate and Braidwood EP personnel. In addition, corporate documerits, the Corporate EP program Self assessment Summary, Corporate Emergency Preparedness Self Assc'sment, and Summary Analysis of 1997 Comed GSEP Drill and Exercise Performance, were reviewe Observations and Findings The SQV audit was very well detailed; objective evidence and surveillance reports supported the audit findings. While the primary focus of the audit report was the 1997 ovaluated exercise, other audit requirements were also well addressed. The audit resulted in two level ll corrective action requests related to exercise weaknesses identified during the 1997 ovaluated exercise. The audit report and discussion with the lead auditor indicated that the overallimplementation of the EP program had been effectively maintained. The audit identified that the interface with the state and local governments have been effective, which satisfied the requirements of 10 CFR 50.54(t).

A single lead auditor had performed the annual audit at all six Comed Stations, which had provided the auditor a basis for ranking the effectiveness of the station's EP program The EP Program Self Assessment (" Peer Review") was conducted during July 23 25, 1997, utilizing NRC inspection procedure 82701 as the base document for the revie This review concluded that the Byron EP program had been maintained at a "high level."

The report noted improvements in the program initiated during 1997, and that the

" physical appearance of the facilities has improved, training documents are current, and several programmatic enhancements are in place." The report noted that there did not appear to be a process for providing additional training and retesting individuals who did not achieve the requisite score on EP training module tests. Discussion with the EP trainer indicated that this problem had been corrected by providing for additional training and a retest. The report advocated revision to the site EP organization, to have the EP trainor report to the EP coordinator, as was the practice at all other sites. The * Peer Review" has proven to be a useful tool in identifying and obtaining corrective action on EP program issues at this site and others, Discussion and document review indicated that the EP staff held periodic meetings wiih the Site Vice President to discuss the status of both the overall EP program and items resulting from previous audits and Peer Reviews. This indicated strong upper management attention to the EP progra _. -- . - - - - _ - . - -- - - _ - . - _ - . -- - .

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The inspectors discussed audit and Peer Review findings and actions taken for the identified issues. Licensee evaluation of these items, documentation, tracking,  :

corrective actions (where completed), and closure were effective and appropriate. Good practices were also identified in the reviewed reports such as the EP training exam bank maintained in conjunction with the Breldwood sit Corporate documents indicated that a Corporate Eniergency Preparedness Self Assessment had been performed during October 1417,1997, by personnel from the '

Quad Cities, Byron, and Braidwood sites, utilizing the same methodology as a site Peer  ;

Review. The assessment was well detailed and comprehensive. Draft documents  :

Indicated that a summary of the various Peer Reviews conducted during 1997 was in l progress, as well as a summary analysis of exercises, per-exercises and drills conducted at all Comed sites during 1997. The inspectors concluded that these <

documents were very worthwhile in assessing the overall emergency preparedness  !

program, ConCJunions The licensee's 1997 EP audits and surveillances, and 1997 EP Program Sel Assessment Report were effective and satisfied the requirements of 10 CFR 50.54(t).

The audit end program self assessment were of good scope and depth. Identified issues were appropriately tracked and reviewed for resolution. Corporate efforts in assessing the overall program were added valu P8 Miscellaneous EP lasues

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P (Ooen) Insoection Followuo item No. 50-454/97006 01: 50-455/97006-01: During the 1997 emergency exercise the Shift Engineer classified early exercise conditions as an Unusual Event when conditions met the guidelines for an Alert. Corrective actionc taken included counseling the individual, discussion of the issue during training, and modified simulator training methodologies. Corrective actions for this problem appeared adequate. This item will remain open pending appropriate demonstration of classification of emergency events during an exercise or dril P8.2 (Ocen) Insoection Followuo itegi No. 50-454/97006-02: 50-455/97006 02: During the 1996 emergency exercise the Shift Engineer failed to utilize the Acting Station Director

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checklist. Corrective actions included counseling the individual, discussion of the issue

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during training. This item will remain open pending appropriate demonstration of Acting Station Director checklist utilization during an exercise or dril ,

V. Management Meeting X1 Exit Meeting Summary The inspector presented the inspection results to licensee management at the conclusion of the onsite inspection on January 9,1998. The licensee acknowledged the findings presente The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie _- __ __ _ _ _ _ , _ . - . _ _ . _ _ _ - _

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PARTIAL LIST OF PERSONS CONTACTED pcensee J. Bauer, Health Physics Supervisor D. Brindle, Regulatory Assurance Supervisor R. Colgiazlor, NRC Coordinator D. Drawbaugh, Emergency Preparedness Coordinator T. Glerich, Operations Manager K. Graesser, tsyron Site Vice President K. Kofron, Byron Station Manager .

S. Merrel, Emergency Preparedness Trainer T. Oracki, Auditor  :

S. Pettiger, Operations Training Supervisor T. Schuster, Manager of Quality A Safety Assessment D. Stobaugh, Corporate Emergency Preparedness Supervisor M. Vonk, Corporate Emergency Preparedness Director NBC

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N. Hilton, Resident inspector IDMS

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C. Thompson, Resident Engineer INSPECTION PROCEDURES USED IP 82701 Operational Status of the Emergency Preparedness Program ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-454;455/98002-01 IFl Updating training module S 25,"ODCS Specialist'.

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None.

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50-454;455/97006-01 IFl Failure to classify to the highest applicable EA ;455/97006-02 IFl Failure to utilize the Acting Station Director l procedure and checklis _ , _ . _

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l LIST OF ACRONYMS USED CFR Code of Federal Reguistions DRP Division of Reactor Projects  !

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DRS Division of Reector Safety EAL Emergency Action Level l EOF Emergency Operations Facility *

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EP Emergency Preparedness

- i EPIP Emergency implementing Procedures

ERF Ernergency Response Facilities .

i ERO Emergency Response Organization GSEP Generating Stations Emergency Plan t

IDNS lilinois Department of Nuclear Safety IFl Inspection Followup item i NPF Nuclear Power Facility NRC Nuclear Regulatory Commission NRR Nuclear Reactor Regulation ODCS Offsite Dose Calculation System  !

OSC Operations Support Center FOR Public Document Room PlF Problem Identification Form .

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RPT Radiation Protection Technician SRI- Senbr Resident inspector SOV Site Quality Verification (now Quality & Safety Assessment)  ;

TSC Technical Support Center i

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