IR 05000456/1986021

Preoperational Emergency Preparedness Insp Repts 50-456/86-21 & 50-457/86-19 on 860529-0613.No Noncompliance or Deviations Noted.Major Areas Inspected:Administration of Emergency Preparedness Program

ML20212A427
Person / Time
Site:	Braidwood
Issue date:	07/22/1986
From:	Allen T, Foster J, Meck R, Ploski T, Shafer W, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212A423	List: IR 05000456/1986021 IR 05000457/1986019
References
50-456-86-21, 50-457-86-19, NUDOCS 8607280180
Download: ML20212A427 (76)

Text

{{#Wiki_filter:__ U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-456/86021(DRSS); 50-457/86019(DRSS) Docket Nos. 50-456; 50-457 Permits No. CPPR-132; CPPR-133 Applicant: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Braidwood Station, Units 1 and 2 Inspection At: Braidwood Site, Braidwood, IL CECO Corporate Offices, Chicago, IL Inspection Conducted: May 29 through June 13, 1986

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Inspection Summary Inspection on May 29, through June 13, 1986 (Reports No. 50-456/86021(DRSS); 50-457/86019(DR55)) Areas Inspected: Special announced pre-operational appraisal of the state of onsite emergency preparedness at the Braidwood Station involving the following areas: Administration of the Emergency Preparedness Program; Emergency Organization; Training and Retraining; Emergency Facilities and Equipment; ,

' Emergency Plan and Implementing Procedures; and Coordination with Offsite i

Groups; and Drills, Exercises and Walkthroughs. The appraisal involved five NRC inspectors and four consultant Results: No items of noncompliance or deviations were identified; however, 38 Open Items were identified, most of which must be completed prior to Fuel Loa ;

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g DETAILS . 1.0 ADMINISTRATION OF THE EMERGENCY PREPAREDNESS PROGRAM i 1.1 Responsibility Assigned i The Assistant Vice-President and General Manager, Nuclear Stations, has been assigned overall responsibility for implementation of the Generating Stations Emergency Plan (GSEP). This individual reported to the Vice-President, . . Nuclear Operations. The Assistant Vice-President, Nuclear Services has been assigned responsibility for development and updating of the GSEP and station-specific annexes, for maintaining the operational readiness of offsite ., Emergency Response Facilities (ERFs), for periodic training of offsite

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emergency organization personnel, and for providing guidance to the stations regarding the readiness of onsite ERFs and the onsite emergency response organization. The Supervisor of Emergency Planning reported to the Vice-President, Nuclear Stations through the Technical Services Manager. The Supervisor, who was assisted by a staff of about 30 persons, (Health Physics, lead and staff. level onsite and offsite emergency planners, and clerical , support personnel) had day-to-day responsibility for managing the applicant's emergency preparedness progra . At the Braidwood Station, the Services Superintendent had been delegated the

! responsibility for implementing and administering the Station's GSEP progra Day-to-day responsibility for the program had been delegated to the Station's GSEP Coordinator, who reported to the Services Superintendent through the Rad / Chem Supervisor and Assistant Superintendent - Technical Service Although the Station's GSEP Coordinator administratively reported to the Station's Services Superintendent and functionally reported to the corporate Supervisor of Emergency Planning, it was evident from the coordinator's i

position description that that position was primarily a Station, rather than a , corporate positio The Station's GSEP Coordinator estimated that over 90 percent of her time was

spent in performing duties identified in her position description, which included conducting and/or auditing some specialized GSEP training for onsite

, emergency organization personne The coordinator also served as the point of

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. contact for corporate personnel and contractors responsible for the meteorological and radiological environmental monitoring program Based on the above findings, this portion of the applicant's program is acceptabl . 2 Authority
; The generic GSEP and station specific annexes were both approved by the Assistant Vice-President and General Manager, Nuclear Stations. The station's i annex and Emergency Plan Implementing Procedures (EPIPs) were approved by the

Station Manager. Personnel assigned duties in the onsite and/or offsite

emergency organizations have been given the authority to perform these duties

' as stated in the GSEP, Braidwood Annex, and relevant EPIPs. Administrative

controls were being implemented such that personnel will not be assigned emergency response duties prior to their completing all relevant training !

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requirement Based on discussions with the GSEP Coordinator, she has been given sufficient authority and support from Station management to perform assigned task Based on the above findings, this portion of the applicant's program is acceptabl . 3 Coordination The Station's GSEP Coordinator was responsible for coordinating station GSEP activities with the various departments and served as the principal onsite source of expertise on the GSEP and emergency preparedness regulations and guidanc The GSEP Coordinator was also the Station's liaison with the corporate emergency planning staff, and with local governmental and private emergency

support organizations on an as needed basis. The corporate emergency planning t staff was primarily responsible for interfacing with the Illinois Emergency Services and Disaster Agency (IESDA) and Illinois Department of Nuclear Safety (IDNS).

Interfaces between the GSEP Coordinator and corporate emergency planning staff have largely been confined to such special activities as the annual exercise, emergency preparedness drills administered by corporate staff, and some offsite support organization training activitie Coordination between station and corporate emergency planning staffs on day-to-day matters and the pre-implementation review of corporate generated procedures, such as ED and EG series that were also used at the stations, has been relatively infrequen In contrast, the GSEP Coordinators from the applicant's operating nuclear stations and the Braidwood Station have participated in periodic counterpart meetings, have served as exercise controllers at each others' annual exercises, and have routinely shared and discussed work experiences, including the findings of NRC Inspections and Institute for Nuclear Power Operations (INP0) visits. The GSEP Coordinator was a member of the Station's onsite review committee for all onsite emergency preparedness matters, as well as for the review of proposed revisions to the generic GSEP and the Braidwood Anne The GSEP Coordinator and corporate emergency planning staff indicated that there had been some discussions regarding a "GSEP Surveillance Program" that was an organizational goal intended to improve standardization of coordinators' activities at the various nuclear stations and to increase their involvement in monitoring activities related to their stations' GSEP programs. However, discussions had not yet progressed to the stage that the program had been formally documente Also, based on discussions with corporate emergency planning staff and the coordinators at Braidwood and several of the applicant's operating nuclear stations, there was an increasing trend to assign additional duties to GSEP Coordinators which might or might not have any relevance to the stations' emergency preparedness program Based on the above findings, this portion of the applicant's program was acceptable; however, the following items should be considered for improvement:

* The GSEP Surveillance Program should be developed and formally documente .  . _ . _ _ . . _ _ _

• Additional duties assigned to GSEP Coordinators should be relevant to the stations' emergency preparedness programs and should not be of an extent to prevent the Coordinators from adequately performing their principal duties.

• There should be increased interaction between corporate emergency planning staff and the GSEP Coordinators on routine matters affecting the stations' programs, including pre-implementation review of corporate-generated procedures that are also used at the stations.

1.4 Selection and Qualifications The Supervisor of Emergency Planning was appointed by the Assistant Vice-President and General Manager, Nuclear Stations, and was qualified to perform assigned emergency planning functions. He was responsible for the appointment and training of his staff. Training of emergency planners has been performed as a matter of practice. Actual training received has been subject to the availability of appropriate courses and the individuals who would benefit from such training.

While the GSEP Coordinator's position description addressed educational requirements, it did not address training requirements or a frequency for providing training opportunities. However, it was apparent that repeated training opportunities had been made available. The Station's GSEP Coordinator had already completed some emergency planning training offered at Harvard University; an introductory course in power plant operations conducted by INP0; and a two-week course on Pressurized Water Reactor systems that included Control Room simulator as well as classroom work. Although the GSEP Coordinator's position description addressed knowledge of pertinent regulations, the position description indicated that no level of knowledge of relevant regulations or guidance was a job qualification requirement.

Based on the above findings, this portion of the applicant's program was acceptable; however, the following item should be considered for improvement:

• The GSEP Coordinator's position description should include a minimum frequency for professional training opportunitie Job qualification requirements should include some knowledge of current, relevant regulatory requirements and guidance.

2.0 EMERGENCY ORGANIZATION 2.1 Onsite Emergency Organization The inspectors determined that an onsite emergency organization, referred to as the Station Group, was being established as described in Revision 5/5A of the GSEP and in relevant Braidwood Station Emergency Plan Implementing Procedures (BwZP series), with the exception that station management soon planned to formalize an additional Station Group position to be called the Station Director's Communicator. The Station Group's organizational structure is provided in Figure 1 of this repor Section 4 of the GSEP and BwZP 100 series procedures described the duties and responsibilities of each director position in the Station Group. The GSEP and relevant Bw2P series procedures

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also described the emergency duties and responsibilities of the Shift Engineer (SE), who will be on shift 24 hours per day and would become the initial Station Director (SD) upon the declaration of any emergency. The GSEP and the Station's implementing procedures described the line of succession to the SE as follows: Shift Foreman (SF); Station Control Room Engineer (SCRE), which

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is the applicant's terminology for the Shift Technical Advisor (STA) position; and the senior Nuclear Station Operator (NS0) on-shift. Selection criteria for members of the onsite emergency organization were based on the similarities to their normal duties and the standards developed by the Institute for Nuclear Power Operations (INP0).

With the exception of the Station Director's Communicator position, persons who have been assigned as members of the onsite emergency organization were identified as such in Revision 0 to BwZP 600-1, Prioritized Call Listing for Staff Augmentatio The applicant planned to update this procedure quarterl The applicant was also implementing administrative controls to ensure that station personnel will be familiar with the GSEP and relevant BwZPs prior to assignment to a position in the onsite emergency organization. These controls were contained in NSD Directive NSDD-505, Revision 1, and in Revision 0 to BwZP 500-9, Assignment of Station Personnel to GSEP Positions. However, based on discussions with the Station's GSEP Coordinator and a review of BwZP 600-1, the inspectors determined that the requirements of NSDD-S05 and BwZP 500-9 had not yet been fully implemented at the Braidwood Station, as evidenced by the unavailability of associated completed GSEP Assignment and GSEP Proficiency Forms. Persons assigned to the following positions in Revision 0 to BwZP 600-1 had completed required GSEP training: all Station Group Directors; all Call List Supervisors; communicators / recorders (except Station Director's Communicators); Radiation Chemistry Technicians (RCTs); Mechanical, Electrical, and Instrumentation Maintenance Foremen; Radwaste Coordinators; Nuclear, Electrical, and Mechanical Engineers; Radwaste Coordinators; and Computer Equipment Engineers. The inspector noted that while various supervisors' signatures were reqilired on BwZP 500-9's GSEP Assignment and GSEP Proficiency Forms, the person being assigned to a GSEP position was not required to sign either form as documentation of an awareness of and agreement to accept the GSEP position. Also, while at least three persons had been identified for many positions listed in Revision 0 to BwZP 600-1, only two persons were identified for the following key positions: Rad / Chem Director, Onsite Environs Director, Security Director, Administrative Director, and Stores Director. Three fully trained persons must be available for each of these positions to better ensure the capability to fill these positions for prolonged periods, in the event of someone's illness, incapacitating injury, reassignment, unexpected employment termination, or other reasons for . unavailability. The station's GSEP Coordinator indicated that a goal had been to identify at least three persons for all positions in the onsite emergency organization, and that additional, fully trained persons would be identified in future revisions to BwZP 600-1, as would persons already identified for the Station Director's Communicator positio Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, there must be at least three persons identified for all onsite emergency organization positions. (456/86021-01; 457/86019-01)

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

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 * The procedural requirements of BwZP 500-9 should be completed prior to Fuel Load, i

* The GSEP Assignment Form and/or GSEP Proficiency Forms, as contained in i BwZP 500-9, should include provisions for the signature of.the individual i being assigned a position in the onsite emergency organizatio i

2.2 Augmentation of the Emergency Organization 2.2.1 Onsite Emergency Organization

i Upon declaring an emergency, the initial SD would, as indicated in the GSEP and BwZP 600-1A3, initiate personnel augmentation by contacting'the Station' t

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Duty Officer by telephone or pager system. Per Standing Order 50-ST-0029, the Station Duty Officer was identified as being the on-call Duty Operating . Enginee The Station's augmentation scheme was contained in BwZP 600-1A1, 1A2, and 1A3 for situations classified as a Transportation Accident or any of

the four emergency classes (Unusual Event, Alert, Site Area Emergency, and i . General Emergency). If implemented in accordance with procedural guidance, the applicant's provisions for augmenting on-shift staff would meet the goals of Table B-1 of NUREG 0654, Revision In accordance with the GSEP and

Braidwood Annex, the Station was entirely responsible for conducting semi-annual, off-hours augmentation drills to demonstrate the capability to i augment on-shift personnel in a timely manner. However, the applicant has not:

yet conducted an off-hours augmentation. drill for its onsite emergency

~ organizatio t The GSEP Coordinator was responsible for updating the call list information in

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BwZP 600-1 on a quarterly basis. Appropriate persons identified on the call l listings were prioritized by their estimated travel. times to the Station, which were also provided in the listings. To better ensure that onsite i emergency organization personnel actually assume their responsibilities in a

;  timely manner after arriving at the Technical Support Center (TSC), the GSEP and BwZP 400-1 described a minimum TSC staff that could perform the essential       "
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activities associated with that facility pending the arrivals of additional

staff.

An apparent inconsistency was noted regarding the duties of the Shift Foreman in the event of an onsite fire or another type of GSEP event. BwZP series

procedures designated the Shift Foreman from the unaffected unit to report to i the OSC during an Alert or higher emergency class to assume the duties of the i OSC Director. However, other Braidwood procedures assigned a Shift Foreman to

] the position of the Fire Brigade Captain. In the event a Shift Foreman was not available for OSC Director duties, the onshift Rad / Chem Foreman would assume > l the position of OSC Director, which would leave his assigned emergency position

of OSC Supervisor vacant. These procedures and assignments assumed two Shift

' Foremen were on. shift at all times. However, Technical Specifications and Braidwood Administrative Procedures required only one shift Foreman. If only

;  one Shift Foreman was on duty and a fire existed and/or manning of the OSC was

necessary, it appeared that all required positions would not be filled.

t Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program: I

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Prior to Fuel Load, the applicant must conduct a successful, off-hours

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i "- - augmentation drill of the onsite emergency organization. (456/86021-02;  ; 457/86019-02) , t 'e Prior to' Fuel Load, the applicant must reevaluate the Shift Foreman's multiple emergency assignments to ensure manning requirements are met during fires and/or other GSEP events which may warrant OSC activiation.

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   (456/86021-03; 457/86019-03)    )

2.2.2 Offsite Emergency Organization

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The applicant's provisions for augmenting the Braidwood and other nuclear

Stations' onsite emergency organizations with an offsite organization have been described in Revision 5/5A of the GSEP and in the GSEP Telephone Directory.

For the Braidwood Station, the offsite emergency organization would be based e at the Emergency Operations Facility / Joint Public Information Center (E0F/JPIC),

" _ located near Mazon, Illinois and/or at the Corporate Command Center (CCC),

e located in downtown Chicago, Illinois. The GSEP stated that the size of the offsite emergency organization would vary depending upon the nature and extent of the emergency situation. During a Transportation Accident or incidents

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classifiable as Unusual Events or Alerts, the CCC may be activated. The CCC

;  Director would activate personnel, identified for those positions shown in

- Figure 2,_that.are deemed appropriate for the situation. For any Site Area or General Emergency, the entire offsite emergency organization depicted in Figure 3 would be activated. The GSEP, and CCC and EOF implementing i procedures contained position descriptions and guidance for fulfilling the responsibilities for each offsite emergency organization position, respectivel Although there were no selection criteria established, the Assistant Vice-President and General Manager, Nuclear Stations were responsible for selecting persons for the offsite emergency organization, based on their normal work assignments and standards developed by INP0. Offsite emergency organization personnel were drawn from the applicant's corporate staffs and from the onsite

:  emergency organizations of all the applicant's nuclear generating stations.

$ _ The applicant's corporate emergency planning staff indicated that Revision 6 ,

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to the GSEP, scheduled for submittal to the NRC in the Summer of 1986, would include significant changes to the offsite emergency organization. Among these changes would be the deletion of some positions, such as Medical Director, , Legal Consultant, and Accounting Director. Such positions were no longer

;  considered as necessary for the offsite emergency organization, as the emergency i  duties of persons providing medical, legal, and accounting services to the GSEP

, organization were perceived to be essentially unchanged from their normal duties.

3 However, the applicant also planned, following any NRC approval of Revision 6, i to delete all GSEP training requirements for those persons whose positions had i been deleted from the offsite emergency organization.

- The GSEP Telephone Directory, which has been updated on a quarterly basis by corporate emergency planning staff, contained listings of personnel, normal work locations, and telephone number information for adequate numbers of persons for each position in the offsite emergency organization. Although only two persons were identified for the Medical Director position, one of

these physicians has been on call 24 hours per day. Three Legal Consultants

were identified. Typically, however, six to fifteen persons were identified

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for each emergency organization positio The telephone directory included a scheme for prioritizing persons listed for each position, based on the estimated travel times to the E0Fs associated with each of the applicant's nuclear generating stations, except for persons who would respond to the E0F for an emergency at the Braidwood Station. The directory also included contact information regarding Federal, State, and local government emergency support organizations, and for private emergency support organizations associated with each generating station, including Braidwood Statio , To better ensure that offsite emergency organization personnel actually assume their responsibilities in a timely manner after arriving at the CCC or E0F, the applicant's GSEP, and CCC and E0F implementing procedures described the minimum staffs needed within each of these facilities. These essential activities included assumption of command and control of the overall emergency response effor Since July 1985 the applicant has demonstrated the capability to effectively augment the ensite emerge icy organization with the offsite organization during unannounced, utility-only exercises for the LaSalle, Zion, and Byron Stations (Inspection Reports Nos. 372/85011 and 374/85011; 295/86001 and 304/86001; and 454/86013 and 455/86011, respectively). Only one or two members of the

. corporate emergency planning staff had prior knowledge of the exact dates and start times of these exercises. Others in the applicant's emergency organization knew the months. scheduled for these exercises. These unannounced activations of the offsite emergency organizations all took place during normal working hour Based on the above information, the following deficiency must be corrected to achieve an acceptable program:
* Prior to Fuel Load, the GSEP Telephone Directory must be revised to include a priority notification scheme for members of the offsite emergency ogranization who would report to the Mazon E0F following an appropriate emergency declaration at the Braidwood Statio (456/86021-04; 457/86019-04)

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

* Applicant personnel whose positions may be d C eted from the offsite emergency organization in future GSEP r?6isie s should continue to receive annual overview training on 'Jn* 14EF ' o they better understand the emergency response organization d n J,.rr they may still have to

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* The applicant should conduct periodic, off-hours augmentation drills of its offsite emergency organization personnel who would respond to the CCC or to a station's E0 _ , __ _ .

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3.0 TRAINING AND RETRAINING 3.1 Program Establishment i The applicant has a formally documented emergency plan training / retraining program in Section 8.2 of the generic GSEP. Training Procedures BwTP 600-1 to 37 specifically related the stations' emergency training program to Section of the GSE The applicant's Production Training Center (PTC) has developed and provided to the Braidwood Station a GSEP training program matrix and associated lesson plans. The Braidwood Training Department has used the materials provided by the PTC for reference in the development of its own station-specific lesson plans and GSEP training requirements. However, the PTC materials were not being used directly for GSEP training. Thus, this portion of the inspection concentrated on the materials the Braidwood Training Department was actually using for GSEP training.

- Instructors for the GSEP training program were selected by criteria set forth in the CECO Instructor Certification Program NSDD-T04, which detailed instructor qualification requirements for all CECO nuclear stations. However, the GSEP instructor selection / qualification instruction for Braidwood Station have not yet been approved. This instruction was still in draft form, dated January 198 The applicant's GSEP required initial and annual training of all assigned emergency response personnel. All Station personnel have received concise, generic overview training on the GSEP. Site specific portions of the GSEP training program and corresponding Emergency Plan Implementing Procedures (EPIPs) were conducted for those personnel assigned to director and supervisory positions in the onsite emergency organization. Assignment of personnel to the GSEP organization was addressed in the GSEP and procedure BwZP 500-9, with additional selection criteria provided in Nuclear Station Directive (NSDD-S05), Rev. 1. Personnel qualified to assume duties in the emergency organization were also listed in the GSEP Telephone Directory, which has been updated each quarter. The current directory was dated March 21, 1986, which met the quarterly requiremen Lesson plans have been developed for personnel assigned to management positions of the GSEP organization (e.g., Station Director (SD), Acting Station i Director, Technical Director, Operations Support Director (OSC) etc...) by the Station Training Department. .Each lesson plan was cross-referenced to a matrix detailing which EPIPs were relevant for that director. However, this cross-reference matrix was an informal document maintained by the training department. Written testing on the directors' training was being implemented at the time of this appraisa A review of the Braidwood GSEP lesson plans was conducte All appeared to cover the information and knowledge requirements necessary for the directors to perform their assigned duties. Each lesson plan clearly stated the performance objectives of the lesson. Provisions were in place to record each trainee's attendance; the date training was conducted; the title of the lesson; and the instructor. These records were maintained as hard copy records and

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_ __ were also logged in the site's training computer files. Training included a discussion of procedures applicable to the duties expected of the trainee and a general description of the GSEP organization. Communications training has also been conducted. Emergency detection, classification, and protective action decision-making were detailed in the lesson plans for the SD and Acting SD The SEs, SF, and SCREs were scheduled to receive the same training on SD responsibilities. Hands-on walkthrough/talkthrough training has be en conducted for some of the GSEP training areas (e.g., fire brigade, environs groups, Station Directors). The Braidwood GSEP Training staff planned (resulting from trainee feedback) to conduct additional on-station training as part of the annual GSEP training. Lesson plan G1-EP-XL-19, Station Group Support Personnel Training Module, wrongly stated that 75 REM whole body and no thyroid dose limit were the limits on emergency worker exposures allowable for stopping a release. A change was in progress to correct this lesson plan error.

At the time of the appraisal, major procedure or training requirement changes which occurred between annual training sessions were informally noted by instructors. The instructors received change notices from Central Files and then determined if trainirig was required. A required reading program was being established to provide formal updated training to GSEP personnel on changes to emergency equipment or procedures which could occur between annual training sessions.

All employees who will be authorized for unescorted access to Protected Areas of the plant were receiving initial training (NGET, Nuclear-General Employee Training) in appropriate aspects of the Braidwood plan and EPIPs as related to the generic GSEP. This training course was required on an annual basis and was developed in accordance with requirements set forth in NGET program developed by Production Training. A new BwTP titled " Station Emergency Plan Training" was in draft and a part of the onsite Review Committee process.

This new procedure will require annual emergency pl'an training / retraining for all CECO and contract employee Failure to acquire the training, or failure of the associated examination would result in the employee's loss of security badge. NGET training included classroom lectures, walk-throughs, and hands on demonstration. However, no formal training method or procedure was established to train non-licensee emergency augmentation personnel.

Fire brigade training has been established and implemented. The initial training consisted of 40 hours of both classroom and hands-on training (actual firefighting in the onsite fire training complex). Followup classes and training will be conducted each quarter. Training records were current and complete. The fire brigade teams were comprised of licensee personnel selected from the Equipment Attendants and Equipment Operators. The fire brigade leader would be an on-shift Shift Foreman.

Department supervisnrs will be responsible for assuring that employee training qualifications are maintained. A Training Coordinator was designated for each department and will be responsible for scheduling training and retraining of personnel with the Training Departmen . - _-__ _

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 . Based on the above findings,-the following deficiency must be corrected to achieve'an acceptable program:

Prior to Fuel Load, the applicant must complete the following tasks:

i- * Formally implement and complete the GSEP testing program for Station Group directors;. ,

 * Establish and implement a required reading program for all members of the-i onsite emergency organization;
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 * Establish a training method for non-licensee emergency augmentation personnel;

* Establish and implement the Braidwood GSEP instructor selection /

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qualification program; and ! i * Establish and implement the BwTP " Station Emergency Plan Training" progra (456/86021-05; 457/86019-05) i In addition, the following items should be considered for iiiprovement:

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 * The position-specific lesson plan /EPIP cross-reference matrix should be formalize *. The emergency worker dose limits for stopping a release, as stated in the Station Support Personnel lesson plan, should be correcte * The information in the Control Room Operations Personnel lesson plan

regarding use of the NARS code should be corrected.

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 * The EPIP/GSEP director matrix should be incorporated in a formal training
:   requirement.

3.2 Program Implementation A-review of the Braidwood training records for personnel assigned to the emergency organization was conducted. The records were in good order and up to date. The records were maintained by the Braidwood Training Department both in hard copy and in a computer system (SYFA). The records included the name of the course, the course number, the date of the class, the name and signature of the trainee, the course length, and the instructor's name. Use , of the computer system allowed for quick record searches to insure all required training for assigned personnel had been completed.

' Acting Station Director training has not been completed. Fifteen of 29 persons assigned still needed to complete training. Eleven were scheduled for ! training on June 16, 1986, as part of the operator license class. This class

was in progress during this inspection. The training date(s) for the other j four persons had not been set.

Other areas where training was incomplete were

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! * One assigned Technical Director had not completed training;

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* Seven of 11 Rad / Chem Foremen. assigned as OSC Supervisors had not completed training;
* Fourteen of 29 assigned RCTs have not completed Red Cross Multimedia training; and
* The Operations Director training was incomplete for the assembly / evacuation modul Discussions with the applicant's personnel assigned to the onsite emergency organization indicated that the training was actually conducted as recorde Walkthroughs with Control Room (CR) personnel indicated all had been through the required GSEP training program. However, seven of ten indicated the GSEP training program was inadequate for their needs. The need mentioned most often was to have some integrated training requiring the CR team to react simultaneously to both off normal reactor plant conditions and activation of the GSEP. Instead, these areas had been treated as separate training event As indicated in Section 7.0 of this report, the walkthroughs demonstrated that the operators did have difficulty handling both plant and GSEP procedures simultaneousl Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program:
* Prior to Fuel Load, the applicant must complete all initial GSEP training requirements for all members of the onsite emergency organizatio (456/86021-06; 457/86019-06)
* Prior to Fuel Load, the applicant must create within the GSEP Training Program an integrated training section that provides CR personnel an opportunity to simultaneously practice both Reactor Plant Procedures for off normal events and the GSEP Procedure (456/86021-07; 457/86019-07)

4.0 EMERGENCY FACILITIES AND EQUIPMENT Emergency Facilities 4. Assessment Facilities 4.1. Control Room ' The Control Room was located in the 451 foot level of the Auxiliary Building, as described in the Braidwood Annex. Both units will be controlled from a shared, common Control Room. The Shift Engineer's (SE) office was adjacent to

' the Control Room. No special GSEP kits or lockers will be maintained in the Control Roo Evaluation of the Control Room as an assessment facility was conducted from the aspect of the operators being able to perform emergency detection, classification, notification, and protective action recommendation activitie The following GSEP equipment was installed and operational: the NARS phone system; the GSEP radio base station (licensed); a dedicated line to the SPS0; dedicated lines to the Technical Support Center (TSC) and Operational Support Center (OSC); and several commercial telephone lines as backups to the NARS and Emergency Notification System (ENS) to the NR . . .- - . . - . - . - .- - ..

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The following equipment was only partially installed, or installed but not operational: ENS phone (phone not installed); Offsite Dose Computer System (0DCS) A-model (see Section 5.4.2); Unit l's Safety Parameter Display System (SPDS); the public address (Gai-Tronics) system (see Section 4.2.3); digital and analog readouts from the onsite meteorological monitoring system (see Section 4.2.1.4); the Radiation Monitoring System (RM-11) (see Section 4.2.1.2); readouts from the Fire Detection System (see Section 5.4.2.4); Control Room Emergency Ventilation System; Control Room Access Control System; and readouts from the Seismic Monitor System (see Section 5.4.2.3).

Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the Control Room must be complete Specifically, the following items must be installed and operational: the ODCS A-model; Unit 1 SPDS; the RM-11 system; readouts from the Fire Detection System; the Emergency Ventilation System; digital and analog readouts of onsite meteorological measurements; the access control system; and readouts from the Seismic Monitoring System (456/86021-08; 457/86019-08).

4.1.1.2 Technical Support Center (TSC) The Technical Support Center (TSC) was located on the 435 foot level at the north end of the Turbine Building, and was as described in the GSEP and the Implementing Procedures (BwZPs). The primary entrance was from the Turbine Building deck via a card-reader controlled door, an air lock, and a second door into an entry foyer. Two portal monitors were located in the foyer for use as necessary during an emergency. The portal monitors were not yet operational. The foyer will also be used as a security guard station for access control and accountability. Off this foyer were a Health Physics work space, a conference / supply room, a small room with a shower for decontamination, and a HVAC room. Another door opened to a lighted stairwell which led to the TSC entry door on the 435 foot level. The stairwell was equipped with chloride battery pack emergency lights at the top and bottom of the stairwell. A second entry way to the TSC was located at the northwest corner of the TSC at the 435 foot level. The applicant stated that there were no plans to station a security guard at this door or to use it as a contamination check point. Using the stairwell and exit onto the Turbine Building floor at the 451 foot level, the Control Room could be reached in about two minutes. However, the physical separation of the two areas would preclude any face-to-face interaction between TSC and Control Room personne The main TSC area on the 435 foot level included a large, well-lighted room sufficient for at least 25 persons. This area would be the principal work space for the Station Director, his supporting directors, technical aids, and administrative and clerical personnel. Peripheral to the main room were a number of smaller rooms: a computer and communications equipment room; an electrical equipment room; a State agency office with a NARS line and an outside commercial line; an office services room with a copy machine and, to be installed later, a microfiche reader / printer; an NRC office with one outside commercial line and a second telephone with two lines reserved for HPN use; a small conference room or office with one outside commercial line; a ,

.- - - - - - - - _ , -- - __ , _ .- __ .- - _ _ _ - _ _ - . - .

storage room; men and women's lavatories; and a large lunch and meeting room with an adjoining kitchen. The main work space, the computer room, the office services room, and the electrical equipment room were provided with fixed emergency lighting.

The TSC was equipped with color-coded, labeled, operational, dedicated telephone lines to the Control Room; Operations Support Center (OSC); and Emergency Operations Facility (E0F); Corporate Command Center (CCC); the NARS line to the Illinois Department of Nuclear Safety (IDNS), the Illinois Emergency Services and Disaster Agency (IESDA), the CECO System Power Supply Office, three local county IESDA offices, and two county sheriff's offices.

The Health Physics Network (HPN) telephone lines were installed and operational (they were, in actuality, commercial lines reserved for HPN use). The Emergency Notification System (ENS) had not been installed. Multiple extension telephones were available at each director's desk. The Environs Director's desk was also equipped with an operational GSEP radio for communicating with field monitoring teams. A dedicated, operable Party Line system provided three party line circuits: one for Health Physics, one for environmental, and one for technical support use. Several wall mounted telephone units were available, with one dedicated to telecopier use. A plant public address system (GAI-TRONICS) was installed but not operational.

Emergency power for all TSC telephone equipment was provided from the security diesel generator.

The TSC was designed to have the same radiation shielding capability as the Control Room. The TSC HVAC system had provisions for particulate (HEPA) and charcoal filters, which will be installed incident to a construction test ite The main TSC work area was provided with an area radiation monito A continuous air monitor (CAM), which will monitor radioactivity at the HVAC exhaust, was installed but not operational. The TSC HVAC system was designed to operate on a 90% recirculation /10% make-up air mix. In the event of a chlorine alarm the system would automatically shift to full recirculation. In the event of an airborne radiation alarm operator action would be required in the HVAC room (at the TSC 451 foot level) to shift to the filter mode. This would retain the air flow mix at 90% recirculation, but would dampen the make-up flow through the HEPA and charcoal filters. There was no procedure available directing an operator to perform this action.

Criteria for evacuation of the TSC was provided in BwZP 400-1, step F.5.

However, the criteria cited was..."When 10 CFR 20 limits are likely to be exceeded." In contrast, criteria for OSC evacuation were provided in Bw2P 400-2 as numerical in dose / dose rates values. Neither BwZP 400-1 nor 400-2 was referenced in BwZP 100-8, the Rad / Chem Director Implementing Procedure.

Four display monitors, two for each unit, were installed for the Safety Parameter Display System (SPDS). The system for Unit 1 was in preoperational testing. The system for Unit 2 was not completed. Computer terminals, display screens, and printers had been installed for the applicant's Offsite Dose Calculation System (00CS). The system was operational, and a demonstration was observed. One computational program, the A-model, was not available, but the applicant had committed to having that Model operational prior to Fuel Load. A more detailed discussion of ODCS software is contained in Section 5. In addition to the computer terminals, display screens and printer dedicated to 0DCS, an identical arrangement was available near the Station Director's i

     {

desk in the TS Like the ODCS, it was composed of a RAMTEK colorgraphic ! terminal and screen for displaying up to four plant parameters at one ' time, a black and white WYSE terminal and screen capable of monochromatic single parameter trend display (numeric), and an associated printer. However, the associated Point History / Point Trend software was not yet installed and operational, as indicated in Section 5.4.2. Also available in the TSC was an alarm typer to print out Control Room alarms. A word processor was located in the offices services room.

A twelve hour clock was located on the wall behind the Station Director Communicator's desk. The applicant stated that log times / event times had, in previous drills, been handled in both 12 and 24 hour time notation, and that a firm decision as to which would ultimately be used had not been made.

Each Director was provided with a binder containing copies of relevant emergency plan implementing procedures (BwZPs), telephone numbers and message forms, plus a second binder with relevant blank log sheets. Additionally, each Director's desk was provided with in-out baskets, general office supplies, and other items of specific relevance to a particular director. It was noted during an interview with a Maintenance Director that bound computer hard copies of spare / repair parts availability and cross reference listings were available and in use at appropriate persons' normal work stations.

However, copies of these were not located in the TSC. The Environs Director's workspace was also provided with the Braidwood Volume (VII) of the Illinois Plan for Radiological Accidents, and the Environs Director's Emerger.cy Procedures, which included procedures for manual and computer-assisted offsite dose calculations.

Clerks from Central Files maintained current controlled copies of the following types of procedures in the TSC: general operating (BwGP); abnormal operating (Bw0A); event-specific sub procedures; emergency contingency actions (BwCA); functional restoration (BwFRST); administrative (BwAP); radiation protection (BwRP); annunciator response (BwAR); system operating (Bw0P); chemical control (BwCP); stores (BwWP); and emergency operating (BwEP/ES).

Current copies of the GSEP, the Emergency Implement Procedures (Bw2P), and the final Safety Analysis Report (FSAR) were also maintained in the TSC. The station's Technical Specifications had not been approved; however, a copy of the draft proposed Technical Specifications was available in the TSC. No copy of the EOF or CCC implementing procedures was available as reference material in the TSC.

The applicant stated that in lieu of full-size P and ID drawings, the office services space would be provided a full set of microfiche aperture cards and a reader / printer. While aperture cards were on file and were being maintained; however, the reader / printer had not yet been installed. The applicant also stated that, although no composite system flow diagrams were yet available, they were being procure .-. . . - .___ .-. . .

The TSC contained a number of wall mounted and/or portable plant status boards for display of the following types of information: plant status; emergency classification; containment status; principal events; a TSC staffing / sign-in board; and current staffing at the CCC and the E0F. An additional board was available for trending key plant system parameters. Three easels with flip charts were availabl The TSC was equipped with 10 and 50 mile radius Emergency Planning Zone (EPZ) topographic maps, an onsite sampling / monitoring point map and a 10 mile EPZ sampling / monitoring point map. Both sampling / monitoring maps had sectors indicated by letters (A through R); the other two maps used 16 compass points for sector identificatio The applicant stated that aerial photo maps were being procured.

' Adequate copies of the Nuclear Accident Reporting System (NARS) form, Plant Status forms, GSEP Log forms, Environmental Assessment Log forms, GSEP Message forms, and radiological status forms were available in the TS The seating arrangement of the various directors facilitated their interaction with the Station Director and with each other. They were also able to easily view most of the various status boards and the SPDS monitors. It was observed that the Plant Status Board contained a large amount of displayed information, relative to the size of the boar This necessitated small lettering and a crowded appearanc Should this prove to be a problem, consideration should be given to expanding this board to two boards, or replacing it with a larger boar Applicant actions to meet the requirements of Supplement 1 to NUREG 0737 were described in a letter, dated April 14, 1983, from Mr. Cordell Reed, CECO, to Mr. H. R. Denton, USNR Schedules for completing these requirements were developed in accordance with Generic Letter 82-33 issued to all licensees / applicants by the USNRC's Office of Nuclear Reactor Regulatio Final determination of the adequacy of the applicant's permanent TSC to meet Supplement 1 requirements will be done during a subsequent appraisal which will be conducted after completion of the above action Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the TSC must be complete Specifically, the following items must be installed and operational:

Entry foyer portal monitors and decontamination facilities; Microfiche printer / reader; emergency ventilation system and associated HEPA and charcoal filters and Continuous Airborne Monitor; both SPDS displays for Unit 1; a procedure for operation of the ventilation system, including operator action in the event of a CAM alarm; Point / History / Point Trend Computer software; and a copy of the approved Technical Specifications. (456/86021-09; 457/86019-09) In addition, the following items should be considered for improvement:

* The applicant should provide for a security / access control point and/or a radiological check point at the 431 foot level access doors to the TS __ -- - -- . . - -  -. . -. -. -. -.

.     .-. . . . - . .
 *' Step F.5 of BwZP 400-1 should be revised to specify numerical criteria for evacuation of the TS * BwZP 400-1 and 400-2 should be referenced in BwZP 100-8, the Rad / Chem Director Implementing Procedur * The time notation (12 or 24 hour clock) to be used during TSC-activation should be standardized and an appropriate wall-mounted clock should be installed.

i_

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 * Copies of spare / repair parts availability and cross reference listings should be available in the TSC for use by the Maintenance and Stores

, Directors.

l * A reference copy of CCC and EOF implementing procedures should be in the TS * Composite system flow diagrams should be available in the TSC.

'

 * The 10 and 50 mile radius EPZ topographic maps should also have A through R sector designation .1.1.3 .0perational Support Center i

The Operational Support Center (OSC) was located as described in the Braidwood Annex and in BwZP 400-2, as Meeting Room B on elevation 451 of the Service Building. Personnel who would report to the OSC included, but were not

L necessarily limited to, operating personnel not assigned to the Control Room, o Radwaste personnel, Rad / Chem Technicians (RCTs) and maintenance personne In i

addition, BwZP 400-2 was being revised to add an appendix which would provide > a more detailed listing of personnel who would report to the OSC in the event of an emergenc The OSC had an adjustable room partition which could be

;

opened to provide additional space. It had been demonstrated during the , November 1085 exercise that adequate space was available to accommodate assigned personnel. Status boards, emergency equipment and supplies, log ,' books and data sheets were in place. Color coded dedicated telephones with  ! direct lines to the Control Room and TSC were provided and were operable in the OSC. Additional telephones, a public address system and handi-talkie radios were available as backup communications. Battery powered emergency lights with an approximate two hour useful life were located above doors A and . B of the OSC, and should provide sufficient lighting for a safe exit of the OSC

in the event of a total power outage.

' Since the OSC did not offer personnel protection from direct radiation and airborne contamination, the Shift Engineer's office on elevation 451 of the Auxiliary Building was designated as the backup OSC. Per procedure BwZP 400-2, personnel would evacuate the primary OSC in the events of dose rates of l 100 mrem /hr or more, and/or personnel received whole body doses of 1.0 rem or greater, or " airborne concentrations that required respiratory equipment."

. Based on the above findings, this portion of the applicant's program is acceptable; however, the following item should be considered for improvement: i 18

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• The applicant should provide an airborne concentration number in BwZP 400-2 as a part of the conditions to determine when OSC personnel shall be evacuated to a backup location.

4.1.1.4 Emergency Operations Facility (EOF) The Emergency Operations Facility (EOF) location was as described in the GSEP and BZPs. It was near Mazon, Illinois, approximately 10 miles WNW of the Braidwood Station. Since it is beyond 10 miles from the Station, the E0F is exempt from habitability requirements. When EOF activation would be ordered, a multi person security team would be dispatched to the E0F, as directed by one of the following individuals: Corporate Nuclear Duty Officer; TSC Security Director; or the Corporate Security Officer.

The EOF was comprised of a number of rooms, the largest being the Recovery Center which served as the principal workspace for the applicant's EOF personnel and representatives from NRC and other offsite agencies. Next to this room was the Recovery Manager's conference room, which contained a device for activating the facility's microwave communications system.

The applicant indicated that another room will serve as a low-level counting facility for samples received from offsite monitoring teams. However, the logistics for analysis of samples from field monitoring was undefined.

Section 7.3.7 of the Braidwood Annex, entitled " Facilities and Equipment for Offsite Environmental Monitoring," stated that the Braidwood Station maintained a supply of emergency equipment and supplies for offsite monitoring and sampling as delineated by Figure 7.7-1 of the generic GSEP. The inspectors could not locate Figure 7.7-1 in Revision 5/5A to the generic GSEP. The plan did not describe the E0F's counting facility or its location. Furthermore, GSEP Environs Group procedure EG-13 (EPIP: NST-E0F-LAB-7) did not describe where the samples should be delivered. Procedure EG-14, "Radioanalysis of Environmental Samples at the EOF," has not been written. No roster of persons qualified to analyze the sample has been developed. No training program was in place to prepare personnel to conduct analysis of field samples at the E0F.

Health Physics supplies, as could be used by field survey teams, were stored in a cabinet in the JPIC portion of the building. An office services area contained various equipment, including a copy machine, microfiche sets of P& ids, and a microfiche reader for generating large-scale copies of these P& ids. Space was available for at least nine NRC and one FEMA representatives.

An NRC office was equipped with an HPN and several commercial telephones, some of which would become functional upon Level I communications activation. With the exception of the HPN and those instruments made functional by Level I or II activation, all other telephone instruments checked were operational. An Environs group radio for communicating with field survey teams could also serve as a backup communications link with the Control Room, TSC, and CCC.

A public address system was installed and operable in the E0F. The E0F also had desk space for security personnel, men and women's lavatories and locker rooms with showers, janitorial space, a lunch room with kitchen facilities, and several small rooms for miscellaneous use . - - - - . - --,-mm-rf--- - e ---

  - w,---------m - - ,

The E0F had the fixed maps and status boards similar to those in the TSC, plus a number of portable status boards which could be wall mounted as needed. In addition, the portion of the Recovery Center reserved for State representatives had a map depicting predetermined traffic control point The facility also contained one or more copies of the following documents: GSEP; FSAR; Illinois State Plan for Radiological Accidents, including both the State and Braidwood site specific volumes; CCC/E0F Procedures; INP0 Resources Manual; Environmental Director Procedures; Offsite Dose Calculation Manual; BZPs; and various categories of station procedures for Braidwood, LaSalle, and Dresden Stations. A copy of the approved Braidwood Technical Specifications was not yet available in the E0F. Each director's desk had blank message forms and other office supplies. Additional copies of the various E0F forms were available from the office services staf There were two separate lines by which the E0F received electrical power from the applicant's grid. The Recovery Center was also equipped with a battery powered emergency ligh CECO actions to meet the requirements of Supplement 1 to NUREG 0737 were described in a letter dated April 14, 1983, from Mr. Cordell Reed, CECO, to Mr. H. R. Denton, NR Schedules for completing these requirements were developed in accordance with Generic Letter 82-33 issued to all licensees by the NRC's Office of Nuclear Reactor Regulation. Final determination of the adequacy of the applicant's EOF to meet Supplement 1 requirements will be done during a subsequent appraisal which will be conducted after completion of the above actions in accordance with the schedule issued as a confirmatory order by the NR l Based on the above findings, the following deficiency must be corrected to achieve an acceptable program: Prior to exceeding 5% rated power, the EOF must be complete Specifically, the following must be completed:

*  Handling, logistics and analysis of field monitoring samples at the EOF must be proceduralized and consistent with the emergency plan;
*  A roster of trained individuals must be developed for the logistics and analysis of field monitoring samples at the E0F; and
*  A copy of the approved Braidwood Technical Specifications must be available in the EOF. (456/86021-10; 457/86019-10)

4.1. Corporate Command Center (CCC) The CCC was located on the twelfth floor of the Edison Building in downtown Chicago, Illinois. Twenty-four hour access to the CCC was available to authorized personnel. The CCC was comprised of several work areas: a dedicated room utilized by the CCC Director and some key staff; nearby work space normally occupied by the corporate Emergency Planning Section; and work space adjacent to the dedicated CCC room.

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The dedicated room contained the following operable communications equipment: a dedicated line (yellow phone) linking the CCC to any nuclear station's Control Room, TSC, and E0F; a microwave channel (gray phone) also linking these facilities; a dedicated Nuclear Accident Reporting System (NARS) line to the Illinois Department of Nuclear Safety (IDNS), Illinois Emergency Services and Disaster Agency (IESDA), and the applicant's System Power Supply Officer (SPS0); a separate line to the SP50; a separate line to the IDNS; additional telephones allowing party line communications between health physics, technical support, and environmental staffs in the CCC, TSC, and E0F; a GSEP radio, primarily for communications with field monitoring teams, but which can also link the CCC with a station's Control Room, TSC, and E0F; and several telephones having internal and/or commercial extensions. To facilitate communications to all work areas available to CCC staff, a public address system had been installed, with a microphone located near the CCC Director's work station.

The dedicated room also contained a computer terminal and printer for use by dose assessment staff. Another terminal for generating displays of key plant parameters, as available using the applicant's Point History and Point Trend software, was located in a corner of the CCC room. However, a reference manual of computer point identifiers for the Braidwood Station was not yet available in the CCC so that Braidwood Station data could be accessed. The room also contained 10 and 50-mile EPZ maps for the applicant's nuclear generating stations and a variety of moveable, wall-mounted status boards for displaying relevant information by appropriate topics. The room was also equipped with several battery powered emergency lights.

Reference materials found in the CCC work space included: the GSEP and Station Annexes; ED- and EG- series procedure manuals; CCC and EOF implementing procedures; EPIPs, Techical Specifications, and FSARs for all the applicant's nuclear generating stations; State and County emergency plans for each nuclear station; the NRC Region III emergency plan; the Offsite Dose Calculation Manual (0DCM); INP0 Resources Manuals; and reduced scale drawings of plant layouts, piping and instrument diagrams (P& ids), and electrical system diagrams for all stations except Braidwood. The available copy of the Braidwood Stations' Technical Specifications was the preliminary version.

Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

• The CCC must be provided with the following items prior to exceeding 5%

power: a copy of the approved Braid 4ood Station Technical Specifications; a reference manual of computer point identifiers for the Point Trend and Point History programs relevant to the Braidwood Station; and copies of apprcpriate Braidwood Station layout, P& ids and electrical systems diagram (456/86021-11; 457/86019-11) 4.1.1.6 Pest Accident Primary Coolant Sampling and Analysis At the time of inspection, the applicant was installing a Sentry High Radiation Sampling System (HRSS) for each uni Sample, analysis, and control panels were located at the 401-foot elevation in the auxiliary building. A waste drain tank and pumps were installed at the 383-foot elevation. The HRSS was located such that it should be accessible under accident condition . _ _ _ _ _ _ _ _- __ ___

.- -   _  -  -  _ _ . - _ _ - -

l The Braidwood Annex (Revision 1) to the GSEP described the measures to be implemented to prevent excessive exposures to HRSS operators. These measures included lead shielding in the liquid sampling panel and the chemical analysis panel; concrete shielding above, below and around the sides of the panels; and a cart equipped with a shielded cask for transporting the radioactive sampl The Annex also indicated that sample collection and analysis could be performed within 3 hour Based on the above findings, the following deficiency msut be corrected to achieve an acceptable program: a e Prior to Fuel Load, the applicant must satisfactorily demonstrate the use of the HRSS for primary coolant sampling under simulated accident conditions. (456/86021-12; 457/86019-12) ] 4.1.1. 7 Containment Air Sampling and Analysis The air sampling system was a t,ubsystem of the HRS This subsystem was being installed at the 364 foot elevation of the auxiliary building in proximity to i the containmen The Containment Air Sampling Panel (CASP) was located such that it should be accessible under accident conditions. The Braidwood Annex to the GSEP indicated that excescive exposure to the sampling system operator would be limited by lead shielding in the sampling panel and concrete shielding above, below, and around the sides of the panel. The Annex also indicated that sample collection and analysis could be performed with 3 hours.

Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must satisfactorily demonstrate the use of the CASP for sampling under simulated accident condition (456/86021-13; 457/86019-13)

4.1.1.8 Post-Accident Gas, Particulate, and Radioiodine Effluent Sampling and Analysis , The applicant plans to install two (one per stack) General Atomics Wide-Range ' Gas Monitors (WRGM) for monitoring and sampling stack effluents, as described in the Braidwood Annex. This annex also described the General Atomic Company detectors that the applicant planned to install in the four main steamlines (two detectors per steamline). The annex stated that a shielded sampling rack will be provided for the collection of the auxiliary building's vent stack particulate and radiciodine samples. The WRGMs would be located such that they should be accessible under accident condition The particulate / effluent sampling and analysis equipment installation, operability and conformance to NRC requirements were already being monitored

on an ongoing basis by the Region's facilities Radiation Protection Sectio Based on the above findings, this portion of the applicant's program is acceptable.

i

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4.1.1.9 Offsite Laboratories The applicant maintained a contract with a firm to provide analyses of environmental samples, as described in the GSEP. At a minimum, these activities included maintenance of the fixed offsite air sample stations and the analysis of environmental thermoluminescent dosimeters (TLDs). During an emergency situation, these activities would be directed by either the Environmental / Emergency Coordinator or the Environs Director, as specified in the GSE For relatively hot samples, as well as low level samples, the applicant could also analyze samples at the Quad Cities, Dresden, Zion, LaSalle, and Byron Nuclear Stations. Calibration of analysis equipment was routinely conducted by the respective stations as part of their routine calibration program. In addition, the applicant was installing counting facilities capable of analyzing environ-mental samples at the Mazon E0F. This equipment consisted primarily of an intrinsic germanium detector and a sodium iodide (Nal) detector for gamma isotopic analyses. The status of laboratory facilites at the E0F has already been addressed in Section 4.1. Based on the above findings, this portion of the applicant's program is acceptabl . Protective Facilities 4.1.2.1 Assembly / Reassembly Areas An inspection of the onsite assembly areas, which were specified in BwZP 300-5 and 300-6, was conducted. These areas were: (1) Machine Shop; (2) Unit 1 and Unit 2 Turbine Building Trackways; (3) Technical Support Center (TSC); (4) Operational Support Center (OSC); (5) Control Room; and, (6) Security Gatehouse. The areas were found to be as described in the Braidwood Anne The Machine Shop was intended primarily for non-essential station and contractor personnel, other than construction workers who would assemble in one of the Turbine Building trackway area Inspection of the three assembly areas for non-essential personnel revealed that there were no emergency route markings posted, nor were there any signs posted in the Service Building to indicate the routes to the assembly area The GSEP Coordinator stated that signs and route markings have been ordered, with a target in place date of August 2, 198 Normal lighting and ventilation in the Turbine Building trackway and Machine Shop assembly areas were considered adequate. However, there was no emergency lighting provided or planned for those areas. There were no plans to preposition portable radiation monitoring equipment in those areas; instead, it was stated that Rad / Chem Technicians (RCTs) would take necessary monitoring equipment to those areas after an assembly was announce For accountability purposes, ten card readers were installed in the Unit 1 Turbine Building Trackway area, but the readers were not yet operationa The applicant stated that ten additional card reader units were to be installed in the Unit 2 trackway area and four card reader units were to be installed in the Machine Shop area. The applicant stated that signs would be located around the Machine Shop indicating assembly sub-areas by department. This would facilitate accountability in the event the card readers were inoperabl ._ _ ._ _ _ _ . __ _ _ _ . _ __

_ Shielding of the gatehouse assembly area and the machine shop and trackway areas was only that afforded by the building structures themselves. There were no plans to locate supplies such as respiratory protection, protective clothing and portable lighting in the trackway areas, nor in the machine shop area (other than that equipment already available in the machine shop for other use). Communications equipment planned for all assembly areas would be adequate (security guard radios, Gai-Tronics, and plant emergency telephones), once Gai-Tronics is operabl Three off-site reassembly areas were specified in the Braidwood Annex. These areas were the LaSalle County Nuclear Generating Station, the Dresden Nuclear Generating Station, and the Joliet Generating Station. The emergency routes proposed for each of these reassembly areas were shown on Figure 6-4 of the Braidwood Annex. This figure indicated a common exit from the plant in a northerly direction for approximately three miles, at which point the routes branche The initial three mile northerly leg could pose a plume exposure problem, especially since a common wind direction was southerly. Discussions with security personnel indicated that other routes were available and would be considered on a case by case basi Based on the above findings the following deficiencies must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must complete installation of:  route designations delineating directions to onsite assembly areas; emergency lighting for each of the three assembly areas intended for nonessential personnel; and card readers in the onsite assembly areas. (456/86021-14; 457/86019-14)

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

* The applicant should evaluate the availability of emergency supplies (such as respiratory equipment, protective clothing, portable lighting)

which might be needed by non-essential personnel in onsite assembly area * The applicant should identify one or more additional plant exit routes that begin in directions other than to the north. All site evacuation routes should be depicted in the Braidwood Annex and also in implementing procedures BwZP 100-8, BwZP 300-5, and BwZP 300-6.

4.1. Medical Treatment and Decontaminaticn Facilities The onsite medical treatment and decontamination facilities were under construction as adjacent rooms on the 426 foot level of the auxiliary building near the Station's radiation protection area. No medical, decontamination, or communication equipment was installed in these facilities. According to the Station Health Physist, contamination monitoring equipment would be used from nearby radiation protection instrumentation supplies. The facilities appeared to be accessible to a stretcher carried by two individual Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

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    - - - _ . - - . - - - .-. . . _ . - -

    -. - . . . ..

,

 * Prior to Fuel Load, the medical treatment and decontamination facilities located on the 426 foot level of the auxiliary building must be completed, including installation of associated medical, decontamination, and communications equipmen (456/86021-15; 457/86019-15)

4.1.3 Expanded Support Facilities The inspectors discussed provisions for expanded support with applicant personnel and inspected facilities to be utilized. The applicant would augment the Braidwood Station's emergency organization with emergency response

'

personnel from the Quad-Cities, Dresden, LaSalle, Zion, or Byron Nuclear Stations and from the corporate offices. Space had been allocated in the Mazon E0F for contractor personnel (i.e. , Westinghouse and Sargent & Lundy).

Space for at least five NRC personnel was provided at the TSC, as was space for FEMA and at least nine NRC representatives at the Mazon E0F. Operable communications equipment was available to support these personnel. Additional resources such as trailers could be provided through the Corporate Command Center's Manpower and Logistics Director. Additional communications i capabilities could be provided through the Communications Director. EOF facilitieswerejudgedadequateforexpandedsupportofarecoveryeffort following an acciden Based on the above findings, this portion of the applicant's program is acceptabl .1.4 Emergency News Center The designated Emergency News Center (ENC) was located in a storage / workshop area at one end of the applicant's E0F building located near Mazon. This location has been utilized as the E0F/ ENC for the applicants' southern division nuclear stations (LaSalle, Dresden, and Braidwood Stations). However, this ENC was only marginally acceptable in terms of size, ventilation, and number of

;  electrical outlets. Security provisions existed for segregating the ENC from the EO The ENC was a medium sized room equipped with folding chairs, tables, podium,
) overhead projector, status boards, and some telephones, which become operational when EOF level 1 communications have been activated. The ENC also contained 10 and 50 mile EPZ maps, plus composite flow diagrams of the primary and secondary i

systems. The applicant would use EOF administrative staff and copying equipment

,

to type and reproduce press releases for distribution within the EN ; The applicant was taking action to upgrade the ENC facilit Funds have been budgeted and conceptual drawings have been develope Planned accommodations

!  for a miximum capacity of 125 media representatives will include: improved
*

ventilation, telephone system, copying and administrative capabilities, i facilities for video cameras, and upgraded security provisions. Construction was scheduled to begin June 1987 and be completed by the end of 1987.

l The applicant stated that there had been preliminary internal discussions regarding the need for an alternate ENC for additional media representatives who are not able to concentrate only at the Mazon facilit ;

__ _ __ ___ _ _ _ _ _ _ _ _ _ _ _ _ _ -_ _ - __ _ _ _ . _ _

Based on the above findings, this portion of the applicants' program was acceptable; however, the following item should be considered for improvement:

* The applicant should continue evaluating the need for an alternate ENC to the Mazon facility and should coordinate this planning effort with appropriate State agencie .2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Survey Instruments The inspector examined the emergency kits and emergency equipment lockers maintained at the Braidwood Station. These kits and lockers were located or scheduled to be located in the Guardhouse, TSC, OSC, and the Sulfuric Acid Pump House in accordance with BwZP 500 series procedures. The ambulance kit was not located in the Guardhouse as indicated by the procedure, but was temporarily stored in the GSEP Coordinator's office on the third floor of the Service Building. The ambulance kit was scheduled to be placed in the Guardhouse following implementation of additional security measure , Additional first aid kits and stretchers were planned to be positioned at a later date, but prior to Fuel Loa The location of environs kits in the Sulfuric Acid Pump House was not identified in BwZP 500-3. The GSEP Van and

, Environs Team kit equipment located at the Mazon EOF was routinely inventoried i by EOF Emergency Planning (EP) personnel, who indicated that a copy of the

quarterly inventory had been forwarded to the Braidwood GSEP Coordinator.

i Instrument calibration and equipment replacement services have been provided by ! Dresden personnel. The St. Joseph Medical Center emergency kit was also ! maintained by Dresden personnel; however, not all appropriate Braidwood personnel were fully aware of the hospital emergency kit's contents and its exact location within the hospita The Braidwood Station kits and lockers were either sealed with breakaway seals or were locked. Keys were maintained by Rad / Chem personnel. Contents of the emergency kits were checked against the inventory check sheets and found to be complete. Survey instruments were operable, instruments calibrations were current and instrument check sources were included in the kits. Instruments provided were appropriate for emergency monitoring with adequate measuring capabilities, ranges and sensitivitie Adequate numbers of dosimeters, TLDs and extremity devices were available. P;'ocedure EG-18 provided a method to be used to make a quick estimate of an iodine release from field team measurements for iodine concentrations of at least 1.0 E-7 uCi/c Particulate activities in air of 1.0 E-9 uCi/cc Cs-137 equivalent could be measured. Portable Ion Chamber instruments with Beta / Gamma distinguishing capability were contained in the offsite kit Procedural provisions required that the contents of the emergency kits were to be inspected, inventoried and operationally checked quarterly, after each use, or when a seal was discovered broken. Incperable instruments found during

inspections were to be promptly replaced. The OSC and Environs offsite

emergency kits contained sufficient numbers of instruments / supplies to equip the members of teams projected to be needed during an emergency.

,

__ _ _ . __ _ _ . _ ., _ ._ _ _ _. _ _ . . _ _ _ . , _ __ _

Inplant capability for detecting airborne iodine in the presence of noble gases was accomplished by Process Radiation Monitoring Constant Air Monitors which provided ambient air monitoring for detecting airborne particulate radiation, iodine, and noble gases in selected station areas. This monitoring system was not completely tested, calibrated and operational at the time of the inspection, as discussed further in Section 4.2.1.2.

Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

• Prior to Fuel Load, the ambulance emergency kit must be positioned in the guardhouse, as stated in BwZP500- All first aid kits and stretchers must also be positioned in predesignated inplant locations prior to Fuel Loa (456/86021-16; 457/86019-16)

In addition the following items should be considered for improvement:

• Dresden Station personnel responsible for the St. Joseph Medical Center's emergency kit should routinely provide the Braidwood Station with copies of records of kit inventories and instrument checks, and should provide information on the kit's exact storage location.

• Mazon E0F personnel responsible for the GSEP van and its contents should routinely provide the Braidwood Station with copies of inventory records for the van's equipment.

• Procedure BwZP 500-3 should indicate the storage location of the environs kits used by field teams.

4.2.1.2 Area and Process Radiation Monitors The area and process radiation monitoring systems were reviewed to determine if they were capable of providing the information required to implement the GSE The station was designed with a comprehensive system of area and process monitors, as described in FSAR Sections 11.5, " Process and Effluent Radiological Monitoring and Sampling Systems," and 12.3.4, " Area Radiation and Airborne Radioactivity Monitoring Instrumentation." These systems were designed to have operating characteristics consistent with postulated accident conditions.

Sensors will be hermetically sealed and have the appropriate ranges to monitor the pertinent accident conditions described in Table BWA 5-1, "Braidwood Emergency Action Levels." Instrument calibrations would be performed at the frequency prescribed in the Technical Specifications.

The systems, provided by General Atomics, have their primary alarm and readout in the Control Room via a RM-11 computer display and console. Safety-related circuits also have redundant readouts on the RM-23 back panel in the Control Room (panel number IPM10J). All monitoring systems reviewed were on vital power supplies, except the station blowdown monitor ORE-PR010, which was a process monitor providing an alarm onl .

The station design utilized five " loops" of monitoring devices, polled by the RM-11 system. At the time of this appraisal, none of the loops were completed and calibrated. Applicant personnel indicated their goal for systems completion and calibration was September 30, 1986. The completion, testing, and calibration of area and process radiation monitors was an item which must be completed prior to Fuel Load. This item was already being tracked by the Region's Facilities Radiation Protection Sectio Based on the above findings, this portion of the applicant's program is acceptabl .2.1.3 Non-Radiation Process Monitors The non-radiation process monitors described in the applicant's plan and procedures as being relied upon for emergency detection, classification and assessment were incorporated in existing instrumentation located in the Main Control Room. The process monitors inspected included: feedwater flow; containment pressure and temperature; core thermocouples; pressurizer level and pressure; steam generator wide range level; subcooling; vessel level and reactor coolant system pressure. The process monitor readouts listed above and located in the Main Control Room and were readily observable. The instrumentation provided was sufficient to determine appropriate EAL No analog or digital readout for containment humidity was present on the control panels, and a review of computer points indicated that it was not a calculated point. Control room personnel indicated that they did not have approved curves for calculating containment humidity from t containmentfancoolerinlet/outletdgybulbtemperatures(geavailable F) and inlet / outlet dew point temperatures ( F). A curve labeled "For Information Only" was available in the Control Room in the " Curve Book." The Curve Book binder was labeled as a controlled copy. However, most pages were marked "For Information Only." Walkthroughs with some Control Room personnel demonstrated that they could effectively use the curve provided to determine containment humidit Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must provide an approved means of determining containment humidity such that an emergency condition would be classifiable per the humidity criteria in EAL Condition No. 2 (456/86021-17; 457/86019-17)

4.2.1.4 Meteorological Monitoring Program The applicant's meteorological monitoring tower was located approximately 1880 feet northeast of the containment buildings. The system, which has been in operation since 1973, was equipped to monitor the basic parameters necessary for offsite dose assessment, as well as additional meteorological information. The tower was equipped to measure: ambient temperature at 30 feet; differential temperature between 30 and 199 feet; dew point tempera-ture at 30 and 199 feet; wind speed and direction at 34 and 203 feet; and 28 _ . _ _ - _ _

     .

precipitation at ground level. In addition, the horizontal wind direction standard deviation (sigma-theta) was computed and available for stability classification if needed. The meteorological instrumentation complied with the specifications of Regulatory Guide 1.97.

The inspector accompanied a technician from the applicant's contractor during a weekly inspection and servicing of the monitoring system. The technician was responsible for conducting a visual inspection of tower-mounted equipment, replacing analog strip charts located in a temperature controlled shack, serving the chart recorders, and verifying the operability of the system's microprocessor and the shelter's temperature control system. The results of these checks have been documented on a weekly visitation form. During this visit, all monitoring system equipment appeared to be functioning properly.

Monitoring system calibrations have been performed bimonthly and have been documented.

The applicant's contractor has had primary responsibility for ensuring adequate data recovery rates and data quality. In addition to periodic monitoring site visits and system calibrations, the contractor's staff forecasters have been remotely interrogating the monitoring system twice per day, seven days per week.

In addition, a project meteorologist has interrogated the system on weekdays.

Analog strip chart data have been examined upon receipt at the contractor's office. Corresponding digital data were screened by a validation program which flags suspect and missing data. Should any of these checks result in a decision to visit the monitoring station, such action can be initiated without the applicant's prior approval. A member of the applicant's corporate staff has also been remotely interrogating the monitoring system at a frequency dependent on that person's availability. The applicant has also used a " pol-val" program to identify missing or suspect data. The results have been brought to the contractor's attention.

The applicant does not have a backup meteorological tower installed at the Braidwood Station. Instead, the applicant would use other measurement levels or derived parameters to serve as backups should a needed parameter be unavailable. Wind sensors have been equipped with heater elements to reduce the threat of sensor freeze-up during winter conditions, while the meteorological tower has been grounded for protection against lightning damage. Signal condi-tioning equipment has also been protected against surges caused by lightning.

Should an event of significant magnitude occur to severely damage the monitoring system, the applicant has maintained contracts to have a temporary tower erected and instrumented within 72 hours, weather conditions permitting. Forecasts of meteorological parameters utilized in dose assessment would be available at any time from the contractor maintaining the monitoring system. The GSEP Coordinator, who was also an Environs Director, indicated that a earlier study had shown that meteorological data from the applicant's Dresden Station could be representative of meteorological conditions at the Braidwood Station. However, this information was not included in any ED-series procedure or in the Station's lesson plan for Environs Directors.

As indicated in Section 4.1.1.1, the inspector determined that no digital or analog readouts of meteorological parameters were yet available in the Control Roo Digital data utilized in dose assessment would be available via the applicant's A-Model program, which was not scheduled to be available in the

_

     .

_ _ _ _

      ,

. Control Room until September 1986. The A-Model program will contain only basic ' meteorological data checks and would print a warning message if a parameter value would exceed its sensor's performance limits or if a value would remain unchanged beyond a specified time period. Strip chart recorders for all the

measured meteorological parameters were installed in a panel near the Control Room's center desk. However, these recorders were not scheduled to be operable and calibrated until sometime in July 1986. The inspector verified that analog wind speed would be in units of miles per hour, while dose assessment software ' required units of meters per second. Also, the parameter measurement levels listed on placards by each recorder contained some inaccuracies. While the measurement levels listed on these placards were appropriate for the Byron Station's meteorological monitoring system, the measurement levels at the Braidwood Station were sometimes different.

l Applicant actions to meet the requirements of Supplement 1 to NUREG 0737 have

: been submitted to the NRC. Schedules for completing these requirements have been developed in accordance with Generic Letter 82-33 issued to all licensees

'

and applicants by the NRC's Office of Nuclear Reactor Regulation. Final deter-mination of the adequacy of the station's meteorological monitoring program will be done during a subsequent appraisal to be conducted after completion of the required actions in accordance with the schedule issued as a confirmatory letter by the NR Based on the above findings, the following items should be considered for

,

improvment:

* The applicant should ensure that appropriate ED-series procedures and Environs Director training materials address which nuclear stations'

meteorological data may serve as representative backup data for characterizing another station's meteorological conditions.

l * Placards associated with analog strip chart recorders located in the - Control Room should list the meteorological measurement levels for ! Braidwood, rather than the Byron Statio * Analog wind speed data available in the Control Room should be in the unit of measure utilized in dose assessment software and manual backup calculation procedure .2.1.5 Seismic Monitoring System

Braidwood Emergency Action Level (EAL) Procedure BwZP 200-1A1, Condition 3,

" Earthquake," provided for emergency classification as follows: Unusual

- Event-Seismic equipment activated (at level 0.02g); Alert-At level greater than operating basis earthquake (0.05g); Site Emergency-At level greater than safe shutdown (0.21g). The seismic design classifications for plant construction, components, and instrumentation have been described in the Byron /Braidwood FSA Onsite seismic monitoring equipment, as described in the Braidwood Annex, will consist of a central recording time history accelerograph unit with strip chart recorder, indicator lights, and play back system. The lights will indicate when the system is triggered and whether the operating bases or safe shut down

!

  - --.-. . - - - - __ . . ..-

_ _ __ _ - . maximum accelerations are exceede An acceleration of 0.02g will activate the seismic switch which turns on the monitor and will indicate an alarm condition on the Control Room annunciator panel. The Seismic Monitoring Panel will be located in the Auxiliary Equipment Room adjacent to the Control Room. The monitor panel has not been completed, as was indicated in Section 4.1.1.1 of this repor An internal letter, Byron Station (Byron-85-0947), dated July 8, 1985, has requested a change to the Seismic Monitoring System measurement range due to occurrences of system alarms with no actual indication of a Seismic Event.

4 The onsite (Byron) review was completed and the letter was a request for offsite (corporate) review. This change would apply to Braidwood if implemented. A Technical Specification change will be require i Based on the above findings, this portion of the applicant's program is acceptabl .2.2 Protective Clothing

. Storage locations for protective clothing for emergency use were still being evaluated, per discussion with the Station Health Physicist. He stated that
'

one location would probably be on 426 foot level of the auxiliary building near the radiation protection are Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Storage locations for protective clothing for emergency use must be determined, and the clothing must be in place prior to Fuel Loa (456/86021-18; 457/86019-18)

i 4.2.3 Emergency Communication Equipment

! The inspector discussed the status of the Station's assembly / evacuation / fire alarms, radiation alarms, and the public address (Gai-Tronics) system with cognizant construction and start-up engineers, plant Health Physics and opera-tional analysis staff. Neither the assembly / evacuation / fire alarm equipment nor the radiation alarm equipment was completely installed at the time of the appraisal. In accordance with IE Balletin 79-18, the applicant has done some work on identifying high noise areas where visual alarms would be used in lieu of audible alarms to alert personnel. The applicant's representatives indicated that system testing of the audible and visual assembly / evacuation / fire alarm equipment was scheduled to begin in early August 1986. At the time of

inspection, the applicant had no plans to provide visual alarms for radiation alarm equipment in high noise areas. The applicant stated that the Gai-Tronics ' system was operable in some plant areas, such as portions of the auxiliary building and fuel handling building, and that the entire system would be , operational by Fuel Loa , The installation and operational status of primary and backup emergency communications equipment, and the associated power supplies for this equipment, j has been described for each onsite and offsite emergency response facility in I

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. - - - - - - . - - - - - - - - - - - - - - - - --- . - - -. -

_ . . ._ Subsections 4.1.1.1 through 4.1.1.5 of this Inspection Report. The installation and operational status of the Prompt Notification (siren) System for the 10 mile EPZ is described in Subsection 6.2.2 of this repor Per IE Bulletin 79-18, the applicant must identify ano provide for adequate assembly evacuation, fire and high radiation alarms in high noise area Installation and operability of the intended visual alarms may be deferred until the end of the first refueling outage, provided that adequate interim measures will be in place by Fuel Load for alerting personnel in high noise areas to take appropriate protective actions in the event of such alarm As indicated in Sections 4.1.1.1 and 4.1.1.2, the Emergency Notification System (ENS) equipment was not yet completely installed and operable in the Control Room and the TSC. The inspectors understood that the applicant had not yet performed the actions indicated in IE Bulletin 80-15, which addressed the possible inoperability of the ENS in the event of a loss of offsite powe Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the following must be installed and operational:

the public address system and the assembly / evacuation / fire alarm (456/86021-19; 457/86019-19)

* In accordance with IE Bulletin 79-18 and prior to Fuel Load, the applicant must develop and be ready to implement adequate interim measures for alerting personnel in high noise areas of a fire, assembly, evacuation, or local high radiation alarm. By the end of the first refueling outage, the applicant must have operable visual alarms to alert personnel in all identified high noise areas of such alarm (456/86021-20; 457/86019-20)
* Following installation of the ENS equipment in the Control Room and TSC, the applicant must complete the actions specified in IE Bulletin 80-1 (456/86021-21; 457/86019-21)

4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies The applicant was maintaining routine maintenance equipment and supplies at the Braidwood site. A complete listing of all supplies, parts and equipment was available, including initial stocking levels, high-low quantity levels, common applicability listings, and cross-references to parts common at other Commonwealth Edison nuclear facilitie A specific listing of projected needs for onsite damage control had not been developed. However, a review using a sample list developed by the inspector was conducted, and the parts / equipment on the list were, with some exceptions, found to be available from onsite maintenance equipment and supplies. Extra equipment, if required, would be available from the nearby Dresden or LaSalle Stations or from the Byron Station, which was a replicate facility to Braidwood with a likely very high degree of common parts. Notable among items not available were fire suits, steam suits, " band-it" kits, and damage control tool

bags or tool roll [

.  .- - __ - _ -- --. .

Based on the above findings, this portion of the applicant's program is acceptable. However, the following items should be considered for improvement:

* The applicant should develop a listing of damage control equipment, parts and supplies which may typically be needed for rapid and/or temporary repairs. The list could include quantities available at various storage locations in the plan * The applicant should acquire or assemble several <famage control tool kits or tool rolls. The contents should be determined by experience and judgement to include those items which might be needed by a team dispatched from the OSC. Such pre-assembled / pre positioned kits should be readily available to OSC staf .2.5 Reserve Emeroency Supplies and Equipment The ins'p'Ector reviewed and examined the applicant's reserve emergency supplies and equipment. The Braidwood Nuclear Generating Station had an inventory of supplies and equipment, including: protective clothing, radiation detection survey instruments, respirator protective equipment, first aid supplies and dosimetry. The supplies and equipment, except for survey instruments, were controlled by a computer system which tracked minimum and maximum onsite supplies and provided lead time so that sufficient quantities of supplies and equipment were readily available. Adequate quantities of emergency reserve supplies were maintained at specified minimum stock level onsite. In addition, Braidwood could obtain supplies including compatible radiation detection instrumentation, communications and transportation equipment from any of the applicant's other nuclear facilitie Based on the above findings, this portion of the applicant's program is acceptabl .2.6 Transportation There were no Station vehicles dedicated for offsite monitoring team use during an emergency. According to the Station Health Physicist, the Station's Rad / Chem Department vehicle and the CECO GSEP van should be available for offsite survey team The GSEP van was maintained at the Mazon E0F, which was about a one-half hour drive from the Braidwood Station. The inspector determined that there were no procedures indicating how the GSEP van would be dispatched from the E0F to the Braidwood Station during normal or off-hours. There were no procedures indicating which station vehicles would be made available for offsite survey team use should the GSEP van and/or Rad / Chem vehicle be unavailabl Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:
* Prior to exceeding five percent power, procedural provisions must be established for ensuring that the GSEP van can be dispatched from the Mazon E0F during normal and off-hours. Also, procedural guidance must be established for ensuring that suitable station vehicles would be

> identified for offsite survey team use should the GSEP van and/or Rad / Chem Department vehicle not be availabl (456/86021-22; 457/86019-22)

. __ _ _ _ _ _ _ - - _ _ _
  . _- - - - _ -

 . .0 EMERGENCY IMPLEMENTING PROCEDURES 5.1 General Content and Format The inspectors reviewed the GSEP implementing procedures (BwZP), and found that

, .all were properly arranged in the format prescribed for BwZPs by Braidwood Administrative Procedure BwAP 1300-2A1, " Standard Formats (for procedures)." It was noted that the standard format only required for BwZPs, a title, purpose, and references sections, with a prerequisites, precautions, limitations and actions, and a main body (the proce Sre itself), being optional. In actuality, BwZP procedures contained: (1) Ti+ - (2) Purpose; (3) References; (4) Prerequisites; (5) Precautions; s) Limitations and Actions; (7) Procedure (main body); and, in some cases, (8) Appendice The BwZP procedures covered all the subjects / topics listed in the GSEP and were generally grouped by function, as was the case for EPIPs for the applicant's operating nuclear stations. Each grouping (100, 200, 300, 380, 400, 500, and , 600) had its own index of procedures within that group. However, there was no

'

composite index to cover all Bw2Ps in the BwZP binders. This made the procedures more cumbersome to find, which was reflected in some of the walkthroughs. A full procedure index should be placed at the front of the BwZP binder to ease locating applicable procedures. Also, the individual group indices were not validated with a date and some sort of control stamp, to better indicate when a new procedure or revision had been promulgate As a general comment, the overall organization and sequencing of the procedures did not seem to follow a consistent pattern, and that, coupled with the lack of an overall composite index, make the BwZP procedures somewhat user-unfriendl Where applicable, the procedures clearly specified the individual or organizational element responsible for performing the tasks covered by that procedure. However, Figure 6.3-1, of BwZP 380-4, " Recommended Protective i Actions - General Emergency," contained several problems. Because of the large amount of printed material on a relatively small sheet, the words were very difficult to read. Additionally, the reproduction was not of good quality, which compounded the proble Each procedure did, where appropriate, provide prerequisites, precautions, and limitations to be observed. These were placed before the body of the procedure. Action steps were clearly displayed in a step-by-step sequential fashion, with several minor exceptions. For example, in BwZP 300-1, Step E.1, the direction regarding use of Code 20 or Code 38 would be more appropriate as a procedural ste With some exceptions, which are noted herein, the Emergency Action Levels (EALs) and Protective Action Guidelines (PAGs) were clearly specified, along with the emergency actions and/or protective action recommendations to be implemented. The following observations were made regarding the EALs provided in Appendix A to BwZP 200-1:

* Conditions 1, 4, and 5 mandated a Site Emergency when equipment was degraded by aircraft crash, missiles, explosion or fire beyond an LC0 requiring shutdown or exceeding a Technical Specification safety limi Condition 14 mandated an ALERT for the same conditions, except that the

_ _ _ _ _. - _ __ .._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

      . _ _ . _ _ _ _

      ..

o possible causes were not specified. This appeared to be inconsisten Additionally, Condition 27 lacked a footnote indicating that unmonitored releases can be estimated from field measurements (per guidance of NUREG 0654). Both of these items have already been identified in Supplemental Safety Evaluation Report, Docket Nos. STN 50-456, STN 50-45 * Condition 2, Alert, stated that Control Room evacuation was warranted when 10 CFR 20 limits are expected to be exceeded. NUREG 0654 guidance stated: "When 10 CFR 20 exposure limits are expected to be exceeded and control is established from local control stations within 15 minutes."

• The General Emergency EAL for Condition 16, Loss of Fission Product ,

Barriers was formatted such that the user would have to also refer to the ' indicator listed for the Site Emergency EAL for Condition 16 in order to make a classificatio >

* Condition 24 apparantly did not address the possibility of a primary to secondary leak and a subsequent unisolable steam leak outside containmen Condition 24 addressed Reactor Coolant System leaks or LOCAs only in terms of containment parameters, and also failed to consider an unisolable steam leak outside containment as a loss of a fission product barrier when it occurs in conjunction with a primary / secondary LOC * Condition 21, Unusual Event, refered to a drop in feedwater temperature of at least 60 F. The corresponding Byron Nuclear Station EAL refers to a decrease of at least 40 F. It was not determined which value was correct, but both should probably be the sam In general, references were provided both under standard section "B", and within the body of a procedures in the applicable step. However, there were exceptions as well as instances where references were cited in section "B" and never used in the body of the procedure, and vice versa. It was also noted that some of the reference documents listed were not available in the TS Many of the procedures were accompanied by attached sign off lists, checklists, and data sheets. However, many of the checklists were too general to be of much use, when, in fact, they could have provided lists of options and other items to assist a person in carrying out his responsibilitie Conversely, there was no detailed check off for use in conjunction with BwZP 380-1, for approving emergency worker exposure limits for vital equipment protection or life saving tasks. Such a check off could include briefing items (dose rate in area, expected stay time, expected dose, current lifetime does of volunteer, ways to minimize dose, possible physiological effects, use of potassium iodide, plus a signature by the volunteer and approval by the person authorizin Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:
* Prior to Fuel Load, the applicant must replace existing Figure 6.3-1 of

, BwZP 380-4 with a legible copy of this figure. (456/86021-23; j 457/86019-23)

* Prior to Fuel Load, the following inconsistences and discrepancies in the

! EALs must be corrected:

l I _

 . . - .   - - - -_ . . _ . - - - . .  . -

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,

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  (1) The wording of the Alert EAL for Condition 2 must be revised to

, include the words "and control is established from local control . stations within 15 minutes."

(2) The wording of the General Emergency EAL for Condition 16 must be revised to repeat the wording currently for Site Emergency, as well as the existing words under General Emergency, in order that the l- General Emergency EAL will stand alon ;- i

(3) The applicant must re-evaluate EAL Condition 24 in light of *

. primary to secondary LOCA and an accompanying unisolable steam leak 4 , outside containment, which equates to two fission product barriers i breached. The review should be directed at whether the use of L existing EALs will result in a correct classificatio , , (4) The applicant must resolve the apparant disparity in feedwater F temperatures between the Braidwood EAL Condition 21 For an Unusual l Event and the corresponding Byron EA In addition, the following items should be considered for improvement:

"

* The applicant should develop a consolidated index for all BwZPs, to be

  - placed at the front of the BwZP binder. The pa0es of the index should
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be dated. The index should be updated whenever procedure revisions occu t

!  * As BwZP procedures are revised, attention should be given to assuring that
,

all pertinent references are cited in the body of the procedures at the

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applicable step (s), and that only cited references are included in the list of references. Additionally, all references cited in procedures used in }: _ the Control Room, TSC, OSC, EOF, or CCC, should be available in those facilitie * The applicant should develop a detailed check-off list for use in 4 conjunctionwithBwZP380-1forbriefingandapprovingvolunteersto !- exceed normal 10 CFR 20 dose limits in emergency situations to protect j vital equipment or to save live .2 Emergency, Alarm and Abnormal Occurrence Procedures , i The inspector reviewed the applicant's Emergency Procedures (BwEP/ES), i Contingency Actions Procedures (BwCA), Abnormal Procedures (Bw0A), and Functional

Restoration / Status Trees (BwFRST). With one exception, all applicable had, above i procedures, prior to the first procedural step or included as the first proce-1 dural step, a note to direct the user's attention to the requirement to inform I the Station Director to evaluate whether a condition exists which requires GSEP i-

' initiation per BwZP 200-1. The one exception noted was 1Bw0A-ELEC 5. The applicant stated that Rev. 51 of that procedure was in the approval chain and ! should correct that omission.

Limiting Condition for Operation Action Reports (LC0AR) were reviewed. In 1 each applicable LC0AR the first step under " ACTION" directed the user

"IF

conditions exist which require GSEP initiation Then notify the Station GTEP

36 !, ,

           *
*w-wr y www -+vm mp~e w-,-------vw mm+--mtmg ev -+,>w,-- e nm ,a ,-,nm ' w
     -

w-n , , wnne e , een* ,e -wn -p ew ww -,s, -e we ovv- m-~

Director for further evaluation." This statement contained two disparitie First, if a condition exists which requires GSEP initiation, then it should be initiated, not evaluated. Second, the title " Station GSEP Director" does not exist. Reference for GSEP evaluation, if necessary, should be to the Station Directo Based on the above findings, this portion of the applicant's program was acceptable; however, the following items should be considered for improvement:

* The next revision to 18w0A-ELEC 5, " Local Emergency Control of Safe Shutdown Equipment," should include the step referencing GSEP evaluation per BwZP 200- * In next revisions to applicable LC0ARs, the wording of the statement contained as ACTION Step 1 in the LC0ARs should be revised to state the correct title of " Station Director," rat.5er than the incorrect " Station GSEP Director." The wording should also le revised to indicate that the Station Director would initiate, rather than evaluate, GSEP response activitie .3 Implementing Instructions Separate BwZP procedures existed for the Sta*; ion Director, the Acting Station and each Station Group Director. These procedures specified each Director,s responsibilities and the management level within the GSEP to which Director he reports. Instances of shortcomings in these procedures regarding appropriate references are addressed in Section 5.1 of this report. There were procedures available covering each of the topic / subjects listed in the GSEP.

Functional responsibilities assigned to the Station Director were clearly stated. Those responsibilities which are not delegable were addressed in BwZP 100-1, D.1.(a) and (b). However, absent from this list were: (1) the responsibility for requesting federal assistance; (2) the responsibility for authorizing emergency radiation exposures in order to protect vital equipment or to save life. It was noted that this second item, while not currently covered by GSEP Revision 5/5A and thus, also not by the Implementing Procedures, had been addressed in Revision 6 to the GSEP, which was in onsite/offsite review during this inspectio The Shift Engineer (SE), as the initial or Acting Station Director, had authority for declaring an emergency classification, making notifications, and recommending protective actions to state authorities if appropriate (BwZP 100-1 and 100-12). He had the authority to activate the GSEP Station Group as needed, using BWZP 600-1. Although BwZP 100-12, " Acting Station Director Implementing Procedure," delineated the Control Room responsibilitics of the Shift Engineer in his capacity as Acting Station Director, there was no check off list provided with this procedure outlining those actions for which he is responsible. Included would be such things as event classification, appropriate notifications, on-hours and off-hours augmentation, filling out of the NARS form, guidance on which tasks available personnel should perform, and in what order, and the sounding of the assembly / evacuation siren for a Site or General Emergenc The list should not contain any extraneous information that is not needed by the Acting Station Director to carry out his responsibilitie _ - - -

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GSEP responses to the various emergency classifications (Unusual Event, Alert, SiteEmergency,GeneralEmergency)werep'rovidedasappendicestoBwZP300-1,

" Initial Notification and GSEP Respons Emergency classifications were made based on readily available, observable information, using BwZP 200-1 and its Appendix A, Braidwood Emergency Action Levels, which was a table of EALs versus emergency classification The 500 series of BwZPs adequately addressed quarterly inventories of TSC/0SC equipment and supplies, as well as battery and meter checks / calibrations, and communications checks. Logs and records maintained by the GSEP Coordinator properly documented those action As noted previously, neither the GSEP nor the implementing procedures vested responsibility in a single designated individual to approve emergency radiation exposures of 25 and 75 REM (whole body) for vital equipment protection and life saving, respectively. Revision 6 to the GSEP, now in internal review, was intended to correct this omission. When that occurs, BwZP 100-1, along with any other relevant procedures, 100-12 and 380-1, should be revised to reflect the problem, that had oeen identified in the Safety Evaluation Report, Docket Nos. STN 50-456, STN 50-45 There was no procedural step in any of the BwZP procedures requiring a plant public address announcement of the classification of an emergency. Such c step should be included in the Station Director and Acting Station Director implementing procedures. There was no check off list provided to assist the Station Director in relieving the Acting Station Director, nor for assisting him in the turnover /information exchange with the E0F Recovery Manager and/or the CCC Director. Similar check-off lists would be beneficial to the various Station Group Directors when they turnover to their relief In a number of locations in the procedures where notification of NRC was j addressed the wording did not reflect the current wording of 10 CFR 50.72(a)(3),

which states, "The licensee shall notify the NRC immediately after notification ' l of the appropriate state or local agencies, and not later than one hour after the time the licensee declares one of the emergency classes."

Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must include the responsibility for requesting federal assistance, and the responsibility for authorizing emergency worker radiation exposures for vital equipment protection and saving of life, to the list of non-delegable responsibilities of the Acting Station Director and Station Director in the appropriate Bw2P (456/86021-25; 457/86019-25)
* Prior to Fuel Load, the applicant must revise those BwZPs where reference to NRC notifications occurs to correctly reflect the current wording of 10 CFR 50.72(a)(3). (456/86021-26; 457/86019-26)

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

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1

 * The applicant should include procedural steps, where appropriate, in the Station Director and Acting Station Director implementing procedures to

! provide for a plant public address announcement after the declaration of an emergenc ,

 * The applicant should. develop check off lists for. use by the Acting Station     :

Director (Shift Engineer) in turning over to the Station Director, and for 1 the Station Director in turnover or information exchange with the EOF Recovery Manager or the CCC Director. Similar check-off lists should be developed to facilitate shift relief for the various Station Group i Director l

 * The applicant should develop an Acting Station Director check off list as an Appendix to BwZP 100-12, to summarize those items for which he is 1   responsibl .4 Implementing Procedures 5.4.1 Notifications
,

The applicant has established procedures for the notification of Federal, State and local agencies that would be involved in the protection of the general public in the event of an emergency plan activation at the Braidwood Statio The Shift Engineer (SE), who is on duty 24 hours, was charged with the respon-sibility and authority to classify emergency conditions should they occu Procedures BwZP 100-1 and 300-1 directed the SE to promptly notify the State of Illinois of any emergency classification. A Nuclear Accident Reporting System (NARS) form would be completed and approved by the Station Director (SD).

Information on the NARS form included: the emergency classification,

;

radioactivity release potential, the affected sectors and protective action *

recommendations, if required. Initial State and local notifications would be l made via a dedicated phone system (NARS) to the Illinois Department of Nuclear l Safety (IDNS) and to the Illinois Emergency Services and Disaster Agency (IESDA)

, utilizing the NARS form format. The State would then notify the appropriate local government' agencies. In the case where a General Emergency (GE) was the . initiating event, a different NARS dial code would be used to notify both the a' State and local governments simultaneousl A system for verifying the NARS notification was included in the procedures. The above procedures also ensured ' the NRC would be notified via the ENS phone system after notification of State

!  . officials, but not later than one hour of the classificatio Appropriate i  procedures included commercial telephone numbers in the event that the NARS and/or ENS dedicated lines would become unusable. Notifications to the State i  of Indiana, which is partially located within the 50 mile EPZ, would be performed by the State of Illinoi ,

The BwZPs included a call tree system to augment the onsite emergency organization and to activate corporate support. Telephone numbers for local services and contractor or private agency support were provided. Provisions existed to update these emergency call lists quarterl i i l' 39

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,_,,r, ._ . . - - ,_  ._c.____.____ . _ . _ _ , , , _ . . _ , , . . _ _ _ - _ _ _ - , , ,_.__..._-...,__,_.,-__.,_.___.,_..-...___ . . . _ . -

Section 6.1 of GSEP Revision 5/5A, dated July 1985, was reviewed. Included in this section was a detailed procedure for hourly followup messages to State and local authorities. Details of the followup messages' contents were specified, and included most of the information contained in Criterion 4 Planning Standard E, of NUREG 0654, Rev. 1. Per BwZP 100-3, the Station's Technical Director was assigned the responsibility for preparation of the followup notification check-lis The notification must be approved by the SD prior to transmittal.

Corporate procedures indicated that followup notifications from the Corporate Command Center (CCC) would be prepared by the Intelligence Director and approved by the CCC Director. In the E0F, followup notifications would be prepared by the Advisory Support Director and approved by the Recovery Manager.

Based on the above findings, this portion of the applicant's program is acceptable.

5.4.2 Assessment Actions A review was conducted of the applicant's facilities, equipment and procedures related to accident assessment. There was no single procedure which comprehensively addressed accident assessmen Procedures BwZP 100-1 through 100-12 described the Station Group directors' emergency organization positions, duties, and the emergency facilities from which they would operate. Procedures BwZP 300-1A1 through Bw2P 300-1A5 spelled out specific actions to be taken for each emergency class. Definitive guidelines for event classification were presented in BwZP 200-1A1, "Braidwood Emergency Action Levels." These procedures were supplemented with required relevant training for the emergency responders.

In the event of a radiological emergency, the overall direction of plant assessment actions initially would be the responsibility of the Shift Engineer, as described in Bw2P 100-12. The emergency organization will be augmented as described in the GSEP and appropriate BwZPs. The Initial Station Director responsibility would be transferred, along with command authority, to the Station Director located in the TSC. The activation of the Corporate Command Center would place the Environmental Director in charge of dose assessment and development of offsite Protective Action Recommendations (PARS). Expanded activation of the E0F will place the Environmental Emergency Coordinator as the lead individual responsible for dose assessment. The final authorities in the CCC and E0F were the CCC Director and Recovery Manager, respectively. The general responsibilities, as passed from one emergency manager to the next, included: determining operational and radiological conditions; assessing trends; and taking actions as specified in the GSEP and implementing procedures. These actions included making decisions to classify the emergency condition, initiating corrective in plant actions, and making appropriate offsite protective action recommendations. However, the initial assessment leading to an emergency classification would be made by the on-duty Shift Engineer.

Assessment actions would be initiated by following the procedures pertaining to the emergency classification declared. Trend analysis of key plant parameters would be accomplished through the use of status boards, computerized displays, supplemented by charts and graphs as needed. Plant status information was not yet available through computer based data acquisition and display systems. The applicant planned that a Point History / Point Trend Computerized plant parameter records system similar to those employed at its other nuclear power plants would be installed by Fuel Load to assist in accident assessmen In general, the BwZP procedures were not ordered in the sequence that they would be use For example, a logical progression would start with event identification and classification, and proceed to initial notifications, call outs, activation of facilities, et Instead, individual Station Group director procedures preceded the EAL procedur However, the Braidwood BwZPs were organized in a manner consistent with the EPIPs of the applicant's five other nuclear stations. Not all BwZP procedure steps were adequately cross referenced so that the user would be guided to the next appropriate action For example, Step 6 of BwZP 300-1A3 instructed the Station Director to activate the onsite TSC and OSC but did not refer him to BwZP 400-1 and BwZP 400-1, the appropriate facility procedures. Similar difficulties were encountered with the contents of the Environmental Director's Procedure The description of the accident assessment staffs and their mobilization were not adequately prescribed in the station procedures (e.g. the staffing of the environs team in the TSC, and the team's functional interactions with other groups). The mechanics for the transfer of responsibilities to the CCC or the E0F for accident assessment and PARS were not proceduralized, other than it was expected that transfer of these responsibilities would coincide with the transfer of overall command and control from one facility to another. The inspectors found no proceduralized methods for dose assessment in the Control Roo BwZP 200-1 specified EALs to be used by assessment personnel in decision making activitie Other BwZP 200 series procedures identified priority systems and sources of information for making assessments of core damage. Comparable procedures for assessing an unmonitored release of fuel handling accident were not in place. While no priority system was indicated for making dose assessment calculations, a computerized "C Model" menu was available for the Environs Directo A computerized, "A Model" was expected to be operational in the Control Room in September 1986. The system will provide dose assessment information and Protective Action Recommendations (PARS) based on direct sensing of plant parameters. However, the system will not provide dose assessments on PARS from unmonitored releases, (e.g. rupture of a waste gas tank). No manual - calculational procedures were contemplated to back-up the computerized A model once it was installed. Instead, Control Room personnel were instructed to use default offsite protective action recommendations derived from BwZP 380- Specifically, Step E.3. of procedure BwZP 380-4, Revision 4, stated:

" Control Room personnel (Acting Station Director) are not required to perform offsite dose calculations or estimations. Control Room personnel should use default recommendations (PARS) provided in this procedure (BwZP 380-4) until offsite dose calculations are provided by the Technical Support Center (TSC), Corporate Command Center (CCC) or Emergency Operations Facility (E0F) staff."

Procedure BwZP 380-4, "GSEP Protective Action Guidelines," provided the guidance for PAR Appendices to the procedure included full-scale reproductions of generic GSEP Table 6.3-1, " Recommended Protective Actions for Actual or Imminent Gaseous Release Conditions," and Figure 6.3-1, " Recommended Protective Actions - General Emergency." Both the Table and the Figure were to be used as decision making aids, as stated on the figure. GSEP Table 6.3-1 listed PARS relevant to each emergency classification and the projected doses in zonal areas of 0-2

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miles, 2-5 miles and 5-10 miles respectively from the station. However, use of this table would not enable an Acting Station Director to develop a PAR for an unmonitored release. For example, Figure 6.3-1 was a PAR flow chart which only applied to General Emergencie The figure provided a rapid method to arrive at PARS based on actual or imminent radioactive releases where knowledge of containment radiation levels and integrity, and reactor vessel level was available.

The primary dose assessment methodology was the computer assisted Offsite Dose Calculation System (0DCS) C-Model. The operation of the C-Model was described in the GSEP Environmental Director Emergency Plan Implementing Procedure (ED series) ED-25. Procedures, ED-3 through ED-22, and ED-24, 30, and 31 were the detailed manual procedures of the Environmental Director. They encompassed all environmental sampling activities and advice to the Emergency Environmental Director (or the equivalent) on hazardous materials, including radioactivity affecting plant personnel and the public.

Walkthroughs of dose assessment calculations problems were performed by the two people who were identified in procedure BwZP 600-1A3, Call List B, to be Onsite Environs Directors in the TSC. It was noted that the procedure for running the ODCS, ED-25, was incomplete in that it did not display the password or includg all the detailed steps for obtaining printed outputs (e.g. include all the " CAPS LOCK" steps). The Environs Directors were able to perform both computerized and manual dose assessments from plant data and from field monitoring results. They understood their roles and emergency functions adequately. However, it was apparent to the inspectors that the C-Model Software has several potential human factors weaknesses which could increase the risk for humaa error under the stress of accident conditions.

Input to the C-Model that were from instrument readings were not always in thesameunitsofmeasurgasthginstrumentoutpu Some units inconsistently used were: mrem and R, F and C; and mph and m/sec. Conversion of units should be internal to the program, rather than being done manually using an available conversion factors table in the ED procedures binder. There should be better consistency between the program's units for output and the applications of those outputs (e.g. for determining PARS in conjunction with Figure and Table 6.3-1). The step requiring comparison of C-Model output with Table 6.3-1 or Figure 6.3-1 is an avoidable risk of human error. Figure 6.3-1 and/or Table 6.3-1 could be inccrporated into the program so that PARS could be part of the computer output.

C-Model default parameter values were not indicated and/or automatically input if they were needed to run the program (e.g. default meteorological data).

Output which used default input parameters was not so labeled. The dose assess-ment model of the C-Model was a straight-line Gaussian with no capability of plotting plume dispersion. No documentation of the theory and assumptions incorporated into the model was available for reference in the TSC.

Based on the above findings, the following deficiency must be corrected to achieve an acceptable progra _ ___

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• Prior to exceeding five percent power, the applicant must ensure that Control Room procedures yielding offsite PARS are in place and appropriate personnel are trained on the procedures so that all radiological accidents including unmonitored releases and/or the unavailability of specific instrumentation (e.g. containment radiation levels) are covere (456/86021-27; 457/86019-27)

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

• The applicant should review the BwZPs to ensure that appropriate procedure steps specify referenced procedures.

• The applicant should develop procedural guidance to describe accident assessment staffs and their inter relationships.

• The applicant should include, in appropriate ED series procedures, the necessary computer passwords and instructions on when computer commands must be capitalize Otherwise, such software restrictions should be eliminated.

• The applicant should ensure that instrument readings used as inputs to dose assessment calculations have the same measurement units as those required by the dose assessment software.

• The applicant should computerize offsite PAR guidance in the C Model.

• Dose assessment printouts should include " flags" to indicate when any default input value was utilized.

5.4.2.1 Offsite and Onsite (Out-of-Plant) Radiological Surveys Offsite and out-of plant onsite radiological surveys would be conducted by the applicant using procedures in the Environs Group (EG) series. The applicant had made provisions for the activation of two field monitoring teams, designated Black and Gold, and had dedicated emergency equipment for their use. The team (s) would be appointed by the Rad / Chem Director or the Environs Director. Their equipment was stored in the Sulfuric Acid Pump House located south of the Security Guardhouse. Included in each emergency kit was a copy of the EG series procedures and the Environmental Monitoring Book. The equipment was being inventoried quarterly to assure its availability for use during an emergency.

Sampling points, both onsite and offsite, were clearly designated on field team maps included in EG- These points would be referenced when reporting and recording data. The remaining EG series procedures dealt with survey techniques; protective equipment and personnel dosimetry use; KI use by emergency workers; radio usage; meteorological data interpretation; environmental sample collection; personnel decontamination; high specific activity samples required; hospital support; airborne iodine-131 measurement using the HP-210 pancake probe; and GSEP Van and E0F Environs team field kit equipment. Adoitional guidance for establishing, directing, surveying and protective measures to be taken were included in the BwZP 100 and 380 series procedures. Specific survey techniques were included in BwRP 1740-1, which was the procedure used as a basis for training RCTs. BwRP 1740-1 and EG-3 procedures addressed the need for acquiring both open and closed window reading _ -- . _ . _ - . . . . .-. ._ -

Field teams would log sample data to include dates, times, locations, names of surveyors, instruments used, flow rate data and sample count tim Environmental sample labels were included in the field team kits. Collection methods were specifie Data would he transmitted to the TSC, OSC or EOF by radio or telephon Samples collected onsite would be taken to the Station counting room. Offsite samples would be taken either to the Braidwood or other nuclear Station or to the E0 Field team samples would be transported to the radioanalytical lab by run-ners, as per direction of the Environmental Director or Environmental / Emergency Coordinato Based on the above findings, this portion of the applicant's program is acceptabl .4.2.2 Inplant Radiological Surveys There were no specific emergency inplant radiological survey procedures. Normal station Radiation Protection procedures were used. These procedures included: BwRP 1250-1, " Exposure Rate Surveys"; BwRP 1480-1, " Contamination Surveys"; BwRP 1360-1, " Air Sampling of Suspected and Known Airborne Radioactivity Areas"; and other BwRP procedures as required. BwRP 1740-1, " Radiation Protective Practices During Accident Condition", provided special guidelines to Rad / Chem Technicians (RCTs) involved during radiological emergencies. BwRP 1740-1 covered specific equipment to be used, communication, recording of radiological survey results and reporting the results to the appropriate personne BwZP 380-1,

" Emergency Dose Limits and Radiological Controls for Rescue and Recovery Opera-tions, provided exposure guidance during emergencies. BwRP 1210-2, " External

, Dose Records," provided control of external exposure. BwRP 1310 covered j Respiratory Protection, and BwRP 1410, Protective Clothin Inplant equipment needed for emergency survey and protective use was stored in the OSC and TS Inventories anc maintenance of this equipment were addressed in BwZP procedure The Rad / Chem Foreman in the OSC would instruct RCTs to log results of samples and inplant survey information and update and maintain a current Radiation Status Board. Radiological information would be logged on standard survey sheets. These sheets contained spaces for date, time, location, name of surveyor, instrument used, serial number and time on and off and flow rate where appropriate. Inplant samples collected by RCTs were normally counted 4 and analyzed in the normal station counting room. If there were counting room background radiation problems, a backup counting area was identified to be located at the 401 foot level in the Turbine Building. This equipment was temporarily being stored on the third floor of the Service Building. Samples would be uniquely labeled for later identification. Communications systems available for use by inplant emergency teams included plant telephones, Gai/Tronics, and portable radios. Radiation protection guidance was included in BwRP 1740-1. These procedures which addressed inplant radiological surveys appeared to be written from the viewpoint of the persons responsible for performing inplant radiological survey ,_ _ _ . _ ._ -

~ Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must position the analytical counting equipment at its designated location on the 401 foot level of the Turbine Building to serve as a backup counting room. Appropriate personnel must have completed training on the use of the facility's equipmen (456/86021-28; 457/86019-28)

5.4. Seismic Monitoring System Analysis (SMS) Procedure 1 Bw0S 3.3.3.1.a-1, Rev. 51, detailed the monthly surveillance required on the SM It included a verification of power supply, alarms functioning, proper operation of the tape recorder system, and reset of the clock, etc. Procedure BwAR 0-38-E5, Rev. 0, detailed the operator response for an annunciator board alarm and included in the immediate actions steps to verify the alarm, check for operating basis earthquake, check for safe shut down earthquake, and notify the Shift Engineer for GSEP evaluation. Subsequent actions were to contact technical staff for evaluation and data retrieval, monitor and evaluate the plant, and to refer to the Technical Specification for Limiting Condition of Operation applicabilit Procedure BwAR 0-38-E6, Rev. 0, detailed operator action in the event of seismic equipment failure, annunciator board alarm, and included an immediate verifica-tion of battery switchover to insure equipment is energized by the batter Equipment operation would last about 1/2 hour on the internal battery. However, operators have not received hands-on training of the seismic monitoring syste Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must complete operator hands-on training on the seismic monitoring system. (456/86021-29; 457/86019-29)

5.4.2.4 Fire Assessment and Classification Emergency Action Level (EAL) Procedure BwZP 200-1A1 included, as Condition 5,

" Fires: (on going as described by observation or alarm, and verified by the fire brigade). Fires occurring at the station would be classified as an Unusual Event, Alert or as a Site Emergency, depending on their severity, duration, if offsite assistance is required, and/or the effects of the fire on vital equipment for plant operations as described in the Technical Specification The procedure adequately addressed EAL classifications for a fire emergency at the Braidwood Statio The fire monitoring panels were located in the Control Room and in the Auxiliary Equipment Room adjacent to the Control Room. During this inspection, the fire monitoring system was only partially installed and not fully operational, as was indicated in Section 4.1.1.1 of this repor Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

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* Prior to Fuel Load, the applicant must complete operator hands-on training on the fire monitoring system. (456/86021-30; 457/86019-30)

5.4.2.5 Primary Coolant Sample Analysis Procedure BwCP 713-5 gave radiological precautions for post accident sample preparation and analysis. BwCP 723-2 provided dilution criteria for post accident isotopic analysis. Procedures BwCP 713-1, 713-2, and 713-3 covered on-line analysis of pH, conductivity, dissolved oxygen, chloride ano dissolved hydrogen at the chemical analysis panel of the HRSS. Procedure BwCP 713-4 pertained to the analysis of boron as will procedure BwCP 713-6. Procedures AAIS-CCP-0002, 0003, 0004, and 0021 covered radioactivity analyses for noble gas, particulates, iodine, and liquid coolant samples, respectivel Procedures BwCP 713-1, 713-2, and 713-3 were reviewed, but not functionally evaluated because the chemical analysis panel of the HRSS was not operational at the time of this inspectio Procedures BwCP 713-5, 723-2, and 713-4 had been written, but were not approved. BwCP 713-6 had not been written at the time of this inspection. The status of procedures relating to the analysis of primary coolant samples was being monitored on an ongoing basis by the Region's Facilities Radiation Protection Sectio Based on the above findings, this portion of the applicant's program is acceptabl .4.2.6 Post Accident Containment Air Sample Analysis Procedure BwCP 713-5 provided radiological precautions for post accident sample analysis. This procedure was discussed in Section 5.4.2.5. No procedure covering the sample preparation of iodine samples that require a purge of noble gases had been written at the time of the inspection. Procedures AAIS-CCP-0002, ' l 0003, and 0004 covered radioactive isotopic analyses for noble gas, particulates, i and iodine, respectively. These procedures were also addressed in Section 5.4.2.5. Due to the status of equipment installation, it was not possible to determine whether samples could be analyzed in less than two hour The status of procedures relating to the analysis of post accident containment air samples was being monitored on an ongoing basis by the Region's Facilities Radiation Protection Sectio Based on the above findings, this portion of the applicant's program is acceptabl .4. Post Accident Stack Effluent Sample Analysis Procedure BwCP 713-5 provided radiological precautions for post accident sample analysis. This procedure was discussed in Section 5.4.2.5. No procedure covering the sample preparation of iodine samples that require a purge of noble gases had been written at the time of inspection. Procedures AAIS-CCP-0002, 0003, 0004, and 0034 covered isotopic analysis for particulates, iodine, and stack effluents, respectively. All of these procedures have been complete _

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The status of procedures relating to post accident stack effluent sample analysis was being monitored on an ongoing basis by the Region's Facilities Radiation Protection Sectio Based on the above findings, this portion of the applicant's program is acceptabl . Protective Actions 5.4. Evacuation of Owner Controlled Areas Personnel evacuation was called for by BwZP 100-1A4 and 1A5 (Site Emergency Checklist and General Emergency Checklist), and by BwZP 300-5 (Security Director and Operations Director) and 300-6 (Assembly and Evacuation of Personnel) in the event of any Site Emergency or General Emergency declaration, or if it was determined that radiological or other hazards are such that evacuation is prudent. However, none of the aforementioned procedures included a caution that evacuation of nonessential onsite personnel should be delayed if such action could expose evacuees to greater risks than having them shelter in place. The decision to evacuate would be made by the Acting Station Director or Station Director, after consulting with specified Station Group directors, if they were available. Evacuation of specific areas or buildings may be ordered under conditions such as described in BwZP 300-6. The Acting Station Director or the Station Director would direct the evacuation by having the NSO sound the evacuation alarm for a two minute period. It was stated that a pager or public address announcement will accompany the siren. However, no procedural step directed this announcement, either as to content or sequenc On hearing the assembly / evacuation siren personnel would be required to report to one of six assembly areas identified in the Braidwood Annex and designated in Sw2P 300-5A2 (Assembly Areas) and BwZP 300-6 (Assembly and Evacuation of . Personnel). Personnel would be notified of their assigned assembly area during ! NGET training; additionally, it was stated that by August 1986, signs will be posted in the Service Building and construction spaces indicating which assembly areas to use. At the time of the inspection neither the signs nor the floor route markings (arrows) were installed, nor was there a formal implementing procedure specifying who should go where. A draft handout entitled "Braidwood Site Accountability Guidelines" was reviewed and found to contain such guidanc The applicant stated that all onsite personnel, and particularly those contractor personnel who work outside the protected area will be provided with hardcopy instructions (possibly the "Braidwood Site Accountability Guidelines") along with their pay envelopes at some time prior to Fuel Lea A Security Post Instruction provided for a mobile patrol to use the mobile public address system to verbally direct all personnel to their designated assembly areas. This would be done during one complete patrol of the perimeter following the ordering of the assembly and would serve to alert personnel, particularly those outside the protected area but inside the owner controlled area, that an assembly had been ordered. This same instruction directed roving building patrols enroute to the assembly areas to direct any

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personnel encountered to report to their designated assembly area Accountability was included in BwZP 300-5 (Assembly and Evacuation of Personnel-Security Director) and was addressed in BwZP 300-6 (Assembly and Evacuation of personnel-operations Director). Neither of these procedures made reference to specific personnel monitoring / decontamination procedures; however, Rad / Chem staff involvement was indicated in both procedure The Nuclear General Employee Training (NGET) required initial and periodic assembly / evacuation training for all unescorted personnel in the protected area. However, as is common for plants at this stage of completion, the tones of the assembly / evacuation signals were unfamiliar to a majority of personnel who were asked by the inspector describe the assembly / evacuation siren's soun Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Prior to Fuel Load, the applicant must revise appropriate Bw2Ps to include guidance regarding hazards which may exist and may warrant continued sheltering of nonessential onsite personnel in lieu of their evacuation following completion of assembly / accountability activities. (456/86021-31; 457/86019-31)

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

* The applicant should incorporate into appropriate implementing procedures directions on sounding the assembly / evacuation siren and making an announcement on the plant paging system. A prescripted message should be provided in the procedure for use when making this announcemen * The applicant should insert references to pertinent personnel monitoring / decontamination procedures as appropriate within the existing assembly / accountability / evacuation procedure '

* The applicant should periodically test the assembly / evacuation siren in order to familiarize onsite personnel with its soun '
* The applicant would distribute the "Braidwood Site Accountability Guidelines" to all onsite applicant, contractor, and construction personnel prior to Fuel Load. Distribution records should be maintained so that the completeness of the distribution can be verifie .4. Personnel Accountability Procedures BwZP 300-5 and BwZP 300-6, " Assembly and Evacuation of Personnel" (300-5 keyed to the Security Director responsibilities and 300-6 keyed to the Operations Director responsibilities), described the applicant's provisions for the assembly / accountability of onsite personnel. Personnel accountability was also addressed in the GSEP, the Braidwood Annex, and in a Braidwood Security Post Instructio The Security Director was responsible for ensuring that a full accounting was completed within 30 minutes following declaration of any Site Emergency or General Emergency, or when personnel assembly / accountability had been directed

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for any other reason. Accountability will be performed by the security force using the security computer system and the card readers installed, or to be installed, at the various assembly areas. If the security computer were inoperative, manual accountability would be accomplished through the various work group supervisors at the assembly areas. For permanent plant personnel and specified contractors, BwZP 300-5A1, " Assembly Checklist - Personnel Accountability," would be used to document those accounted and unaccounted for.

Tne Security Director will receive a compilation of accountability reports from all assembly areas, the gatehouse, and.the Control Room (CR), TSC, and OS The assembly area and gatehouse reports will be sent via the Security Shift Supervisor; the CR, TSC, and OSC reports will be sent via the Operations Director and the Rad / Chem Director. However, the applicant has not yet conducted an assembly / accountability drill involving a total number of applicant, contractor, and construction personnel as may be available onsite during an initial refueling outage for Unit 1.

BwZP 300-5, prescribed the use of security patrols to assist in locating missing and/or potentially injured personnel. Braidwood Security Post Instruction 09 stated that a search team will consist of a security officer and a RCT. However, there was no single procedure which addressed all aspects of the conduct of an onsite search and rescue operation, including such things as team leadership and composition, team briefing, debriefing, communications, and systematic search routes and methods. Discussions with applicant personnel indicated their understanding of a need to maintain accountability once established. However, the method for accomplishing this seemed limited to relying on standard " carding in and carding out" practices. There was no procedure which assigned responsibility for the maintenance of accountability once it had been established.

Based on the above findings the following deficiencies must be corrected to achieve an acceptable program:

• Prior to Fuel Load, the applicant must conduct a successful onsite assembly and accountability drill involving a total number of applicant, contractor, and construction personnel as may be expected onsite during a refueling outage. (456/86021-32; 457/86019-32)
• Prior to Fuel Load, the applicant must develop procedural guidance to address the means of maintaining accountability once it has been established. (456/85021-33; 457/86019-33)

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

• A separate Search and Rescue procedure should be prepared, which addresses all aspects of the conduct of an onsite search and rescue operation, including: team leadership and composition, team briefing, debriefing, communications, and systematic search routes and methods.

5.4. Personnel Monitoring and Decontamination The inspector reviewed the following procedures: BwZP 100-8, Rad / Chem Director Implementing Procedure; BwZP 300-5 and 300-6, Assembly and Evacuation of Personnel; BwZP 380-3, Rad / Chem Response to Personnel Injuries; BwZP 380-3A1, Patient Radiation and Medical Status Record; BwRP 1340-1, Personnel Monitoring 49 _ - _ _

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for Internal Radioactive Contamination; BwRP 1400-T1, Personnel External Contamination Recor Primary emphasis was on Plan and procedural provisions for personnel monitoring and decontamination at the offsite reassembly areas.

Various Station Radiation Protection Procedures (BwRP) described the processes for monitoring individuals when exiting restricted areas, or other areas known or suspected to be contaminated. Relevant BwZPs included appropriate steps to insure that personnel monitoring and decontamination procedures were in effect, if needed, at both onsite and offsite assembly / reassembly areas. However, neither BwZP 300-5, Bw2P 300-6, nor BwRP 1470-1 provided a reference to GSEP Environs Group Procedure EG-10, the corporate-developed procedure for offsite applicant personnel and vehicle decontamination at relocation centers. The applicant stated that none of the procedures or monitoring / decontamination materials were kept at the Joliet Generating Station, but that those procedures and materials would be carried to the Joliet Station by RCTs from the Dresden Station. However, no listing of procedures or other materials which Braidwood personnel may desire at Joliet Station had been provided to Dresden Station personnel, nor did Braidwood Station have a listing of Dresden Station requirements in the event Braidwood was supporting Dresden evacuees at Joliet Station.

BwZp 300-11, " Emergency Treatment of Injured Personnel"; BwZP 380-3, " Rad / Chem Response to Personnel Injuries"; and BwRP 1470-1, " Routine Personal Decontamina-tion," all addressed actions pertinent to contaminated personnel, Doth injured and non-injured. BwZP 380-3A1, " Patient Radiation and Medical Status Record Log," would be prepared by the RCT who accompanied a injured / contaminated person to the hospital. This form (BwZP 380-3A1) did not contain provisions for recording the survey instrument used (model, serial number), and the instrument probe and conversion factor used, nor did it require the name and/or signature of the RCT who performed the survey and decontamination. Also, instructions did not exist in BwZP 380-3 for routing the completed BwZP 380-3Al to the Station Health Physicist or to the Rad / Chem Director.

BwRP 1470-1 required preparation of and provided instructions for completion and submission of from BwRP 1400-T1, " Personnel External Contamination Record," for each personal and/or clothing contamination event, a contamination event being implied therein as sufficient counts above background in a low background area to require decontamination. This form included the name of the individual surveyed, clothing, skin and nasal contamination found, survey results after decontamination, the decon method used, and the survey instrument number.

However, there was no place on the form to record both the survey instrument model number and serial number, nor was there a place to record instrument probe and conversion factor used. The form did provide for indication for Health Physics follow-up and any other follow-up required or recommended. BwRP 1470-1 provided decontamination procedures and methods for various levels of contamina-tion. However, the applicant stated that no special procedure was provided for skin contaminated with radiodine.

The contamination levels which require decontamination were implied, rather than specified, in BwRP 1470-1, " Routine Personnel Decontamination." These levels were confirmed by the applicant to be..."any counts above background" (in a low background area). BwRP 1480-1, " Contamination Surveys," did specify in Section F.4.b that a direct reading of greater than 5000 dpm/100cm2 (beta / gamma) required decontamination. However, this procedure was not referenced in BwRP 1470-1, nor in any of the applicable BwZP procedure Although no procedural reference was found regarding forwarding of collected personnel radiological contamination would be provided to the RCTs in the OSC, who would then handle the data in the normal fashio Based on the above findings, this portion of the applicant's program is acceptable. However, the following items should be considered for improvement:

* Procedure EG-10 should be referenced in BwZP 300-5, BwZP 300-6, and BwRP

, 1470- * The applicant should provide a listing to Dresden Station personnel of all procedures, publications, and other materials desired to be taken to the Joliet Station by Dresden Station personnel, in the event that Joliet Station is selected as a reassembly area for Braidwood Station evacuee * Form BwZP 380-3Al should be revised to provide for recording the model and serial number of the survey instrument used, the instrument probe and conversion factor used, and the name and/or signature of the RCT performing the survey /decontamiantion. Instructions should be provided on the form, or in procedure BwZP 380-3, for forwarding the completed from to the Station Health Physicist or to the Rad / Chem Director.

<

* Form 1400-T1, Personnel External Contamination Record, should be revised to provide for recording both the survey instrument model and serial number and the instrument probe and conversion factor use * Procedures BwRP 1470-1 and BwZP 380-3 should be revised to reference numerical values for contamination levels that require decontamination, as stated in BwRP 1480- * The requirements for handling and processing personnel contamination data collected during emergencies should be proceduralize .4. Onsite First Aid and Rescue The inspectors reviewed the applicant's procedures related to onsite first aid and rescue. In general, the procedures assigned responsibilities, defined methods for receiving, handling and transporting injured persons who might also be contaminated, and provided criteria for determining treatment priority and using offsite treatment facilitie Procedures BwZP 100-2 and 100-8 assigned responsibilities to the Operations Director and Rad / Chem Director for organizing and dispatching aid and rescue teams, but did not provide guidance on team composition. Such guidance on team composition was eventually located in a Security Post Instruction, which indicated that the multiperson teams would be composed of at least one person trained in first aid and radiation survey techniques, namely a RCT and a security office Procedure BwZP 380-3, " Rad / Chem Response to Personnel Injuries," provided instructions for the issue, collection, and recording of emergency team dosimetry device However, the instructions did not require that pocket dosimeters (PDs) either be zerced or the initial reading recorded before issue

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to emergency response personne An unknown initial reading on a PD could invalidate its use for exposure control, as discussed in Section 7. The inspectors also found that BwZP 380-1, " Emergency Personnel Dose Limits and Radiological Controls for Rescue and Recovery Operations," did not alert personnel to the possible need for extremity exposure or multiple whole body exposure monitoring for first aid and rescue teams. Team operations could easily occur under radiation exposure conditions for which additional exposure monitoring should be used, if practicable, for exposure monitoring accurac Also, it was noted that the BwRP procedure volume index incorrectly listed the 1800 series as Medical Program procedures, when the proper series was the TLD Program procedure Approximately half of the 29 RCTs and 21 Shift Foremen and Shift Engineers have been trained in the Station's American Red Cross approved multimedia first aid and life support certification cours Training and certification of the remaining personnel was scheduled to be completed by about August 1986, < per discussions with the training instructor Ambulance services were covered in procedures and arranged for with the

, Braidwood Fire Department, which had a mutual aid agreement with several

other local ambulance service Based on the above findings, this portion of the applicant's program was acceptable; however, the following items should be considered for improvement:

*  The applicant should add information on first aid and rescue team composition to procedures BwZP 100-2 and 100- *  The applicant should include a precautionary statement in BwZP 380-1 to consider the needs for extremity exposure monitoring and multiple whole body exposure monitoring for search and rescue team member *  The applicant should add instructions to BwZP 380-3 to require that pocket dosimeters either be zeroed or the initial reading recorded prior to issue to emergency response personne *  The BwRP procedure volume index should be corrected regarding the Medical and TLD program procedure set . Repair and Corrective Action Repair and corrective actions were not addressed in a specific implementing procedur The Maintenance Director, located in the TSC, would direct the total onsite maintenance program to include repair and corrective action operations, as approved by the Station Director. His responsibilities were outlined in procedure BwZP 100-4, " Maintenance Director Implementing Procedure,"

and BwZP 400-1, "TSC Implementing Procedure." Teams would be dispatched from the OSC as stated in BwZP 100-10, "0SC Director Implementing Procedure," with the makeup of each team determined by the OSC Director based on the assigned task to be performed. BwZP 100-8, " Rad / Chem Director Implementation Procedure" addressed relevant duties which included: plant area radiation monitor reading evaluations; hazardous material surveys; protective clothing; respiratory

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protection; access control within the plant; and, when requested, to provide this information to the OSC Director and maintenance personnel for planning repair team entry to the plant. The Rad / Chem Director would refer to the BwRP series procedures for appropriate information concerning radiation protection practice On activation of the TSC and OSC, assigned personnel would report to these facilities to accomplish emergency functions which included repair and correc-tive actions. All Station Group Directors except the OSC Director would report to the TSC. The Shift Engineer as acting Station Director, would designate an OSC Directo BwZP 400-2, " Operation Support Center Implementation Procedure," identified personnel who would report to the OSC; however, a more detailed listing of OSC personnel was being prepared as a Appendix A to this procedur There was no procedure in the BwZP series which specifically addressed safety considerations for repair or corrective action activitie BwZP 100-10A1 addressed OSC Director duties which generally indicated that the OSC Director would organize inplant teams, with the assistance of the Rad / Chem Supervisor, to support maintenance efforts. The OSC Director duties did not include ' detailed guidance concerning content of team briefings and debriefings, such as: briefing the teams on emergency status of the plant; radiological conditions to be expected, based on current area radiation monitor data and recent inplant surveys; exposure limits; stay time; required protective and emergency equipment; routes to follow to reach the repair scene to maintain minimum exposure to team personnel; personnel hazards which could be encountered, such as fire, steam, smoke or wreckage; and appropriate team debriefings to determine team finding Based on the above findings, this portion of the applicant's program is acceptable; however, the following item should be considered for improvement:

* The OSC Director duties listed in BwZP 100-10A1, should include additional guidance on the content of team briefings and debriefings for repair and corrective action activitie . Reco/ery The Corporate Command Center (CCC) Director, Station Director, or the Recovery Manager had the authority to downgrade the emergency classification and declare a Recovery Mode of operations. Procedures BwZP 300-1A6 (Revision 1), "GSEP Response to Recovery"; BwZP 300-2 (Revision 0), " Actions for Downgrading an Emergency Classification, Recovery, Reentry, and Emergency Termination";

BwZP 300-2A1 (Revision 0) Appendix A, " Guidelines for Downgrading an Emergency"; BwZP 300-A2 (Revision 0) Appendix B, " Guidelines for Recovering"; BwZP 300-2A3 (Revision 0), " Guidelines for Reentry"; and BwZP 300-2A4 (Revision 0),

" Guidelines for Termination," contained guidance consistent with the GSEP for recommending reduction in emergency classifications, declaring recovery, or terminating the emergency condition. Procedural guidance addressed evaluation of stabilized plant conditions, evaluation of Emergency Action Levels, and consultation with NRC, State, Applicant, and NSSS vendor representative Notifications of those organizations would be made upon initiation of a Recovery mod Overall management of the recovery organization would be done by a Recovery Manage All Station Group directors would report through the Station Director, who would report to the Recovery Manage . . _ . -__ _ _ - . _ . . _ . .- -. .. --. - . - - _ _ _ .- ._ .-

    :

Based on the above findings, this portion of the applicant's program is acceptable.

5. Public Information The inspector reviewed the Information Director procedure (CCC-4) and Emergency News Center (ENC) procedures (E0F-4, E0F-27, E0F-28, EOF-29, E0F-30), which related to the dissemination of information to the public and the media. These procedures specified the responsibilities of the Information Director, ENC Director, Spokesman, Newswriter, Information Liaison and Briefing Coordinator.

The responsibilities included collecting, verifying and disseminating information on emergency situations to the public via news media; issuing approved press releases; coordination of information with other involved Public Information Officers (PIO); providing three Spokespersons (Corporate, Technical, and Health Physics) at the ENC; and responding to information requests from the news media.

The procedures did not identify the media organizations involved in news dissemination, nor did they identify how the media would be contacted if an emergency occurred. Provisions for coordinating internal dissemination of information about an emergency situation to the applicant's own employees were not identified; provisions for information coordination among PI0s of various organizations prior to ENC activation were not identified; and provisions for rumor control were not found in the procedures.

Corporate public information personnel indicated that a formalized corporate procedure entitled " Communication Services Plan" was being develope This document will formalize rumor control provisions, tredia identification, coordination of PIO information prior to activation of ENC, and provide for information dissemination within the company.

The applicant was nearing completion of specific corrective action to upgrade the capabilities of its Technical Spokespersons. A procedure designated three spokespersons selected according to their positions in the corporate structure.

The corporate spokesman was selected from personnel qualified to answer questions regarding utility respcnsibilitie The technical spokesman was selected from corporate personnel with nuclear engineering expertise. The Health Physics spokesman was selected from corporate personnel with Health Physics expertise.

Media confrontation training had been developed to train and prepare these spokesmen to respond to public media inquiries. The training had been completed by all selected personnel. Three of 24 selected spokesmen successfully participated in the LaSalle Station exercise held April 8, 1986.

Based on the above findings, the following action must be completed to achieve an acceptable program:

• Prior to exceeding five percent power, the applicant must complete development of and any associated training on the " Communication Services Plan." (456/86021-34; 457/86019-34)

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5.5 Supplemental Procedures 5. Inventory. Operational Check, and Calibration of Emeroency Equipment, Facilities and Supplies Inventory lists, inventory schedules, maintenance responsibilities, and associated records relevant to emergency equipment, facilities, and supplies were located in the applicant's BwZP 500 series procedures. The GSEP Coordinator was responsible for monthly communication system check The Rad / Chem Foremen were responsible for most other equipment, facilities and supplies which were checked at least quarterly. Procedures also required inventories and checks whenever equipment was used from a kit and whenever a kit closure sealing device was found broken. A formal inventory and review was provided by BwZP Inventory Checklists, which were item specific and which included appropriate equipment operation and calibration checks. Checklists were required to be signed by the person conducting the inventory or check and to be routed to the GSEP Coordina-to Except as noted below, the GSEP Coordinator was responsible for the final review of each checklist and assurance that any deficiency was corrected.

BwZP 500-3, " Environs Sampling Supplies," did not state where the kit was stored or assign responsibility for assuring that kit inventory deficiencies were corrected. BwZP 500-8A1, " Ambulance Kit Inventory Checklist," did not include a spare dosimeter charger battery. The applicant initiated action during this appraisal to correct both BwZPs as described.

Based on the above findings, this portion of the applicant's program is acceptable.

5. Drills and Exercises The applicant's provisions for drills and exercises were contained in Section 8.3 of the GSEP, Subsection 8.1 of the Braidwood Annex, and in implementing procedure BwZP 500-1. The Division Vice-President and General Manager, Nuclear Stations was ultimately responsible for ensuring that required drills and exercises are scheduled and conducted. However, the Station was entirely responsible for performing monthly NARS operability tests and for conducting periodic fire drills and off-hours augmentation drills. The Station , was also responsible for supplying needed equipment, facilities, and personnel for all drills and exercises. Exercise and drill scenarios were generally prepared by corporate staff. Exercises were coordinated with appropriate Federal and State Agencies. However, Station personnel, who would not be among those demonstrating their capabilities in a given drill or exercise, would assist corporate staff in related scenario development, control, and/or observation tasks on an as needed basis.

Upon receipt of an operating license, the applicant will be committed to conduct an annual exercise, plus annual environmental monitoring, assembly / accountability, and medical emergency drill Health Physics and unannounced off-shift augmen-tation drills will be conducted semi-annuall Communications from the Control Room, TSC, and E0F to the NRC Operations Center and Region III Office will be l tested monthly. The operability of the NARS phone will also be tested monthly.

Fire Drills will be conducted in accordance with Technical Specifications  ! requirement ) 55 l l l _ _ . - _ _- _ _ , _ , _ . _ _ - _ _ . _ _ . _ , _ -

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A critique will be held upon completion of any GSEP drill or exercise. An evaluation will then be submitted to the person responsible for the drill or i exercis The Action Initiation Request was a formal administrative mechanism utilized to track appropriate drill and exercise recommendations. The GSEP l Coordinator has also been utilizing a personal tracking system for some critique items. Unless otherwise required by Technical Specifications, drill records will be retained for a period of two years, while exercise records will be retained for five years.

i Based on the above findings, this portion of the applicant's program is acceptabl . Review, Revisions, and Distribution of Emergency Plan and Procedures . The inspectors reviewed the applicant's system for ensuring that proper reviews, updates, and revisions will be accomplished to maintain the GSEP

}  and its implementing procedures. Provisions for distribution of controlled j  copies of these documents were also reviewe BwAP 1300-4 (Periodic Review of Permanent Procedures) required a formal i  biannual review of all implementing procedures in accordance with GSEP
!  Section 8.5 BwAP 1205-3 (On-site Review Functions) also required review of the GSEP and implementing procedures. The applicant's procedures for
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developing and issuing new or revised permanent procedures were outlined in BwAP 1300-2. This guidance provided for writer preparation, supervisory review, Onsite Review Committee (OSRC) review, cognizant personnel review, i cross reference identification, and Plant Manager authorizatio BwZP series procedures originals and revisions have originated with the GSEP Coordinator, who then forwarded the documents via the Rad / Chem Supervisor to the Station Procedures Coordinator. The Station Procedures Coordinator would select the membership of the On-site Review Committee (OSRC) for each procedure to be reviewed. Those selected must be knowledgeable personnel, selected from the qualification list provided in 8wAP 1205-1Ts (Selection and Authority of 3 OSRC). Committee membership must be approved by the Technical Staff Supervisor to assure the minimum representation requirements as specified in BwAP 1205-2T2.

The disciplines were defined in BwAP 1205-1T1. The Technical Staff Supervisor

,  also would approve or add any additional disciplinary representation he deemed  ,
!  appropriate and indicate " ROUTE" (generally done for subsequent revisions other
,  than major) or " Schedule Formal OSR" (originals and major ravisions).

! " Route" reviews were being tracked by the Station Procedures Coordinator who i ensured that all committee members review, comment, or sign the procedure for approval. Formal OSRs included a period for each member to review the material, 4 followed by one or more formal meetings. The procedure writer, who would attend i a OSRC meeting, would incorporate any approved committee comments and then return the procedures to the Station Procedure Coordinator, who would obtain the OSRC ,

!

member signatures and forward the procedure to the Plant Manager for approval.

, - The GSEP Coordinator initiated routine procedure and annex reviews by use of an l automated " tickler" system, initiated by data input forms (follow-up forms), i which result in a reminder to the GSEP Coordinator of the upcoming review

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i requiremen The GSEP Coordinator, in liaison with the Rad / Chem Department, will then effect needed changes. Proposed changes will then be forwarded to the , Plant Manager for approva ; Distribution of BwZPs was proceduralized in BwAP 1300-5 " Station Procedures Distribution." BwAP 1300-5T1 was a " Procedures Distribution List" and l prescribed' distribution of BwZPs to required onsite and off-site personnel.

i

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The Station Group's and General station telephone lists were issued as BwZP 600-Al and A3 respectively. These lists will be updated quarterly, as required by the GSEP, by means of.the same automated scheduling system as used

 - for GSEP and other procedures. Procedures BwZP 600-1, 600-2, and 600-3 required quarterly procedure and/or appendices reviews. However, the designated responsible individual was not identified. The GSEP Coordinator presently performed the reviews. A cross check of telephone lists in the GSEP Telephone Directory and the aforementioned BwZPs revealed only two inconsistencie i  Based on the above findings, this portion of the applicant's program is acceptabl However, the following item should be conside' red for improvement:

 *  The applicant should identify, in procedures requiring periodic
'

review / update, the title of the person responsible for performing the review / update.

) 5.5.4 Audit

] The inspector reviewed the method by which audits of the emergency preparedness < program were conducted to satisfy the requirements of 10 CFR 50.54(t). These audits were performed by the corporate Quality Assurance (QA) organization, based , onsite or offsite, which had no emergency response or emergency planning role The applicant had no unique procedure established for auditing GSEP, and the

following sequence of events would be adhered to in conducting all audits:

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l The Station based QA staff would prepare an annual audit schedule which

;   included a description of referenced requirements which were included in l   each audi , The proposed audit schedule would then be submitted to the Corporate QA      :

! Director of Operations who reviewed the schedule, added additional audit i references as appropriate, based on his review of potential generic j problems identified at other sites. The approved audit schedule would

. then be returned to the Station.

l Prior to the audit, the Lead Auditor would prepare an audit checklist j using the references in the audit schedule and the GSEP audit matrix (QAM-3, Enclosure 7). This checklist would contain the specific questions to be reviewed during the audi '

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 - . The completed audit checklist would be submitted to the Corporate QA Director of Operations for review and approval to ensure that questions were appropriate for the referenced requirements and that potential generic problems vould be examined during the audit. The approved checklist would be sent back to the Station. The audit would be conducted and an exit meeting would be held at the conclusion of the audit. The audit report would identify the subject, scope, references utilized, period of the audit, and a summary of findings, open items, and observations. The report would also contain a general description regarding the overall assessment of the area audited. The audit report, along with all backup documentation and the completed checklist, would then be submitted to the Corporate QA Director, who would review the package to ensure that findings were supported and that no areas of review had been omitted. After Corporate QA approval, the report would be submitted to the audited group. Findings would be tracked by the QA organization to ensure that acceptable corrective actions had been proposed and implemented by the audited group. If corrective actions implemented were acceptable, the item or finding would be closed and corrective action implementation would then be examined periodically for one year. If the corrective action proposed was not acceptable, or if corrective actions were not submitted to QA by the audited group within sixty days, the audit finding and the history of its resolution would be submitted to the Executive Vice-President for resolution.

The acceptability of proposed corrective actions would initially be made by the Lead Auditor; however, final determination would be made by the Corporate QA Director for Operations.

The above sequence describes the generic conduct of audits by QA personnel based at the Station. In addition, an annual audit of the station's emergency preparedness program will be conducted by the corporate QA organization utilizing QA personnel from the corporate offices or from other generating stations. An annual audit will also be conducted by the QA organization of the corporate GSEP activities.

The GSEP audit matrix (QAM-3, Enclosure 7) referenced above contained a comprehensive listing of the requirements which must be examined in each annual audit and the corresponding portions of the GSEP which implement these requirements. This procedure provided reference to all emergency planning requirements and their location in the GSEP, Station Annex, or 10 CFR sections, yet was flexible enough to allow the auditor to use professional judgement in preparing audit question _ . _ _ ___ _ _ __ . _ _ _ .

In addition to audits, the QA organization performed surveillances of various emergency preparedness activities, such as the conduct of drills and exercises.

In these cases, the performance of personnel and adequacy of procedures would be evaluated separately from the applicant's drill / exercise observation program.

The inspector reviewed dccumentation related to the following audits and surveillances of the Braidwood Station's emergency preparedness program including actions on audit findings, and found them to be acceptable: Audit 20-84-13; Audit 20-85-16; Surveillance 20-85-119; Surveillance 20-85-132; and Surveillance 20-85-140 In accordance with 10 CFR 50.54(t) requirements, the applicant has established a mechanism for making the portion of the annual audit related to state / local interface available to offsite authoritie The inspector reviewed documenta-tion which verified that an annual offsite support agency meeting had been held on September 15, 1985, and that the agenda included the identification of a person who could provide relevant audit results to offsite support organizations upon request.

Based on the above findings, this portion of the applicant's program is acceptable.

6.0 COORDINATION WITH 0FFSITE GROUPS 6.1 Offsite Agencies The inspectors met with a representative of the Illinois Emergency Services and Disaster Agency (IESDA). In addition to Section 4.8 of the generic GSEP, the roles of State agencies were delineated in the Illinois Plan for Radiological Accidents (IPRA). The development of these offsite plans was coordinated by the applicant and State official ~ Subjects developed and agreed upon include: protective action recommendation criteria; notification procedures; emergency classifications; coordination of offsite exercises; training of offsite officials; and anticipated emergency responses based on the emergency classification. State agencies have a copy of the applicant's GSEP. The applicant had sufficient copies of IPRA. Tne review of the emergency actions to be taken for each emergency class and associated recommendations was included in the applicant's training program for offsite support agencies which has been conducted annually.

An inspector interviewed shariff's department representatives from Grundy, Kankakee, and Will Counties. Communications capabilities between the Station and the respective Sheriff's offices included radio, NARS, and commercial telephone lines. A copy of the GSEP has been provided to these Sheriff's Offices. Sheriffs' personnel have attended training offered by the applicant.

The Will County Sheriff's Department also served as the offsite security support group. The IPRA also provided a description of the County ESDA Coordinators' responsibilities, including the responsibility for activating the prompt notification system. However, the prompt notification system for Braidwood Station has not been installed, nor has training been performed, as discussed in Section 6.2.2 of this report. The Sheriffs' personnel were aware and expressed an understanding of their responsibilities and procedures in response to an

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emergency at the Braidwood Statio Their understanding was consistent with the expectations of both parties as expressed in the letter of agreement and the applicant's procedures. Sheriffs' personnel were knowledgeable and supportive with respect to providing emergency assistance to the applicant.

The primary medical treatment facility for radioactivity contaminated injuries was located in Joliet, Illinois, approximately a forty minute drive from the Braidwood facility. The inspectors interviewed the Head Nurse and Coordinating Physician. St. Joseph Medical Center has agreed to provide medical care to injured personnel from the Braidwood facility who are overexposed or may be injured and contaminated with radioactive material. The hospital was equipped with facilities and supplies to handle and give medical treatment to radio-actively contaminated injured personnel. Radio contact was available between the Braidwood Fire and Rescue Squad's ambulances and the hospital. Emergency Room staff were trained by Radiation Management Corporation (RMC) personnel, who were under contract to the applicant. To date, this training has included participation in two emergency drills, as well as reviewing and discussing videotapes of various emergency drills. Procedures developed by RMC were available in the Emergency Room. These procedures described mobilization activities, treatment techniques, decontamination methods, bioassay sample collections, and the methods to return the facility to its pre-emergency status.

The applicant was responsible for providing basic radiation equipment for personnel protection and basic decontamination supplies. Hospital facilities were currently adequate for the treatment of a small number of injury cases.

Hospital personnel were satisfied with the coordination efforts of the applicant with respect to training, communications, notifications, equipment supplied, and routine planning information exchange.

The Braidwood Fire and Rescue organization provided firefighting response and ambulance services to the Braidwood Station. The inspectors interviewed the Fire Chief, toured the facilities, and examined their firefighting equipment.

The district's staff consists of 29 personnel, of which 28 are volunteers. At least 3 personnel are on shift at all times, and the dispatch center is manned 24 hours per da Mutual aid agreements with surrounding organizations have been developed to provide additional firefighting personnel and equipment to the Braidwood site. In addition, arrangements have been made by the Station to provide dosimetry to the responding offsite firefighting personnel.

Training of district personnel was conducted during the appraisal. This training included the handling of potentially contaminated patients and site access procedures. The Braidwood Fire and Rescue Squad received training from the Station's Fire Brigade staff, and these two groups have apparently developed a good working relationship. Fire District personnel have worked with the Braidwcod Station Fire Marshall in the development of the fire preplans. A copy of currently approved preplan was maintained at the District fire station. The Fire and Rescue Squad has a copy of the IPRA and Braidwood Annex to the GSE .

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An inspector reviewed the applicant's onsite files and records concerning letters of agreement. The letters will be renewed every two years, as was described in the plan. During this inspection, agreements were in effect or in the process of renewal for the seven local fire departments, the local hospital, the three counties in the ten mile EPZ, and the appropriate state police district.

Overall, the representatives from each agency were professional and enthusiastic with respect to their roles in the Braidwood Station's emergency preparedness program. The applicant has been making frequent contact with the appropriate responders and a spirit of professional cooperation was evident. Satisfaction was uniformly reported with respect to the frequency and nature of the training received. All representatives interviewed were well versed on their emergency roles, and appropriate protective actions associated with the various emergency classifications.

Based on the above findings, this portion of the applicant's program is acceptable.

6.2 General Public 6.2.1 Emergency Information Brochures Emergency information brochures have been developed by the applicant and reviewed, and coordinated with appropriate State and local governmental agencies.

Distribution was accomplished by mailing to all utility customers and permanent residences, and through bulk distribution to motels, businesses, park, restaurants, and such places where the transient adult population could obtain a copy. A verification log was maintained of the locations and dates of these bulk deliveries, and mailings which were all completed in October 1985. Once the applicant is required to follow its emergency plan, the pamphlet will be updated and distributed on an annual basis. The applicant has planned to distribute the next issue of the Braidwood Emergency Information Brochure in the Spring of 1987, to coincide with the distribution schedules of brochures associated with its operating nuclear generating stations.

The public information brochure has been evaluated as acequate by FEM However, it remained subject to revision based on the yet-to-be issued decisions of the ASLB regarding an offsite emergency planning contention. The applicant antici-pated that any ASLB decision requiring changes to the text of the Braidwood brochure could be made in time so that the Spring 1987 issue of the brochure would include any required changes. The pamphlet was in a form that is easy to read, and included a prepaid postcard, which contained the individuals mailing label and check blocks indicating the individuals special needs. This postcard was pre-addressed to Illinois ESDA authorities for their processing and use during any evacuation situation. The pamphlets also contained information on what to do if sirens are activated, information on radiation, action to take if shelter or evacuation are ordered, the means of public notification (EBS, sirens), information on the emergency plan and where further information may be obtaine An emergency sign placement program is being attempted by the applicant and upon program completion for the Braidwood EPZ they will place emergency signs in recreational areas located near all other site The applicant will direct a request for emergency information signs through Illinois ESDA IESDA would request permission through the Department of Conservation, Division of Public Lands, who would notify the specific parks in the EPZ. The signs will be financed by the applicant, produced by IESDA and Department of Conservation and erected by park personnel. The applicant indicated they would attempt to place signs in recreational areas around Braidwood by June 198 Based on the above findings, the following deficiency must be corrected to achieve an acceptable program:

* Unless otherwise directed by the ASLB, the next edition of the Braidwood Public Information Brochure must be distributed by April 30, 198 (456/86021-35; 457/86019-35)

6.2.2 Prompt Notification (Siren) Systeai This system will consist of about 68 warning sirens, 23 of which will have public address (PA) capability. These 23 sirens will be located in or near all but three of the recreation areas within the 10-mile EPZ. Siren activation equipment will be located in the Sheriff's Department offices in each of the three counties in the EPZ. Local officials will be able to activate some or all of the sirens within their geographic areas of responsibility. At the time of this appraisal, all but about six of the sirens had been installed. Roughly 40 percent of the sirens were already fully operational, as they were also part of the siren network for the applicant's Dresden Station. A siren system design study was scheduled for submittal to FEMA in July 1986. The applicant's goal was to have the Braidwood Station's siren system fully operational by September 30, 1986, including completion of system activation training by all i offsite officials charged with this responsibilit A formal demonstration of system activation and operation was scheduled to take place in early December 1986 to satisfy a FEMA requiremen Sirens having PA capability will be powered by batteries that will be continually recharged by AC power. The system's mechanical sirens will have only an AC power supply. The applicant's contractor will provide periodic preventive maintenance on each siren and round-the-clock emergency repair service as needed. Local officials will have the capability to deactivate malfunctioning sirens and to authorize emargency repairs by the applicant's contractor without prior approval from the applicant. The applicant also indicated that there were plans to upgrade the Braidwood Station's siren system so that certain siren components could be functionally checked by remote interrogation from a yet to be determined location. Beginning sometime in 1987, the Station's siren system will be tested on a monthly basi Based on the above findings, the following action must be taken to achieve an ' adequate program: i ! 62

i I

.. - . . _ _ . _ . _ . . . _ . __ ..-

.  . _ _ _

___ _ _ . _ ~-_ _ _ __ . a

             , '

F ! * Prior to exceeding five percent power, the prompt notification system for i the Braidwood Station'.s 10-mile EPZ must be fully operational, including completion of training by all persons responsible for system activation.

l (456/86021-36; 457/86019-36) 6.3 Media Briefings i  !

               '

! . The inspector reviewed CECO's current news media orientation program relevant to coordination and dissemination of accurate information to news media organizations. A reporters guide, titled " Nuclear Power and Braidwood" has been prepared and addresses.the following subjects: operating cycle of a PWR,

     -
          .

radiation, emergency planning, training and a glossary of common technical term A radiological orientation training program is offered to radio /TV/ press personnel prior to each annual exercise required by 10 CFR 50, Appendix E. The program agenda included an introduction to the emergency plan, daily plant operations vs, incident response operations, emergency action levels, information about radiation, E0F organization, media points of contact, media space allocation and a discussion of the Illinois Plan for Radiological Accidents by ' personnel from the State of Illinois. These annual media orientation programs are conducted at the Emergency News Center located at the Mazon E0 A review of attendance records revealed only'two representatives from the many local . media organizations invited actually attended the November 1985 sessio Interviews with corporate public information personnel revealed that small media attendance had become a problem for all the applicant's plant sites. Efforts are underway to upgrade the entire orientation program in order to. encourage attendance. Improvements may include collaboration between the Production Training Center and corporate Public Information personnel to effect a more efficient program of information dissemination to the news media. This updated program would likely be conducted three times a year: a program relevant to Braidwood, Dresden, and LaSalle at the Mazon EOF; a program relevant to Byron t i and Quad Cities at either the Dixon or Morrison EOF; and a program relevant to ! Zion at the Zion EOF.

l Based on the above findings, this portion of the applicants program is acceptabl However, the licensees progress toward its commitments to improve its orientation program improvement will be tracke . - 7. 0 Drills, Exercises, and Walkthroughs

I 7.1 Drills and Exercises ! The applicant had conducted medical, health physics, communications, and

environs team drills during 1986 in accordance with Section 8.3 of the GSEP I and BwZP 500- However, as indicated earlier in this report, an off-hours

shift augmentation drill and the initial assembly / accountability drill had not

! yet taken place. These two drills must be successfully conducted prior to ! Fuel Load. The applicant conducted an emergency preparedness exercise in , November 1985. Prior to the exercise, scenario development was coordinated , among the NRC, FEMA, the applicant, and various State and local governmental agencies. These meetings allowed each agency to participate and comment in

               '

the development of the scenario for the exercise.

' 63  ;

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     ._. _ .-_ _ _ ~ - _ _ _--- - . _ _. __ _ _ . _ .

, The applicant's GSEP Coordinator has been informally tracking relatively minor drill-identified improvement items. Items involving procedure revisions or Major drill identified improvement items would be tracked using the Station's [ Action Initiation Request progra , Based on the above findings, this portion of the applicant's program is

acceptabl . Medical-Drill

 >The inspectors observed a medical response drill from the time of ambulance arrival at the Station gate until the patients were evacuated. The drill was conducted by the Radiation Management Corporation (RMC) with coordination by

- the applicant's corporate staff and the GSEP Coordinator. Two persons were simulated as being injured and contaminated with radioactivity, one of whom had probable life threatening injuries. The inspectors also attended the drill critique, which was lead by the GSEP Coordinator and included RMC's

. evaluation of drill performance. The drill critique covered most of the j  important emergency response and control problems evident during the dril '

These included: failure to expeditiously remove the seriously injured person; . delay in departure of the ambulance with the seriously injured person; . inconsistent contamination control practices; and disorganization of efforts ! ' due to no one person taking charge of on-scene event The inspectors believed ' that some of the above findings were presented at the drill critique too casually, especially the seriousness of not expeditiously getting the patient

- with life threatening conditions to a medical facility. Transport of a seriously injured patient should not be delayed for detailed control of low levels of contamination nor held up for a fellow worker with non-life

threatening injuries.

)l In addition, the inspectors noted that self-reading pocket dosimeters (PDs) issued to the ambulance personnel would have been of little value for exposure . ' control. The PDs were not zeroed before issue nor were initial readings recorded (or such actions simulated). All of the PDs checked by the inspector had initial readings of greater than 3/4 full scale.

] I A medical response drill was not required prior to Fuel Load. Accordingly, the above findings, which should be considered for improvement or included in future medical response training, were discussed with the GSEP Coordinato .2 Walkthroughs ' 7. Control Room Walkthroughs . Walkthroughs were conducted with five sets of two persons in the Control Room (CR). It was unknown at the time if all of these personnel will be those actually assigned to CR shifts for plant operations. In addition to the training instructor, the following personnel were provided for CR walkthroughs: two Shift Engineers (SE), five Shift Foremen (SF), and two Shift Control Room

. Engineers (SCRE). Scheduling difficulties were due primarily to eleven CR shift

' personnel being actively involved in pre-license training. The ten personnel interviewed were organized into five shifts consisting of one actual SE or acting SE, and one actual SCRE or acting SCR i f . ' ___ -__ .-- . _ . _ __, _ _ _ _ . _ _ _ . , _ _ _ _ _ . , . _ _ _ _ _ _ . - . _ _ _ _ _ _ _ _

--   -._ .- .

The walkthroughs consisted of general questions relating to the Braidwood GSEP program and a scenario of off normal reactor plant events that escalated from Unusual Event (UE) to General Emergency (GE). Plant operating, abnormal, and emergency procedures as well as BwZP procedures were reviewed to insure the scenario was site specific. All walkthroughs were conducted in the CR with all documents, procedures, and materials normally in the CR available for interviewee use during all portions of the walkthrough. Two procedures, Bw0A Pri 1 and 4, contained statements which referred the user to another procedure, but did not specify the procedure number. Instead, the Bw0A procedures indicated that the procedure numbers would be inserted (LATER). All procedures must adequately direct the user when referencing other procedure During the general questioning, there was a lack of complete understanding regarding which GSEP facilities are to be activated at which emergency classifications. With some prompting most teams were able to correctly answer this question. However, one team continued to incorrectly state that the TSC and OSC would only be activated after a Site Emergency (SE) was declared. Four teams could not adequately determine the length of time required to evacuate three offsite sectors out to five miles. Although all tried to find a procedure to make the estimate, some simply stated they had never heard of an evacuation time estimate and had no idea where to look for such information. None of the teams could perform a dose projection and all stated they had not received train-ing in dose projection methods. A computer capable of automatically performing dose projections was scheduled for operation in the CR in September 1986, as indicated ir. Sections 4.1.1.1 and 5.4.2 of this report. When given a main stack release rate and asked to classify per the EAls and determine appropriate Protective Action Recommendations (PAR), three teams needed prompting; one team misclassified; one team incorrectly converted miles / hour meteorological readouts on a CR panel to meters /sec required in EAL 27 (clearly demonstrating the need to use observable plant parameters for EAL classifications). Additional training is required in this are During the scenario portion of the walkthroughs, all participants were able to adequately detect off normal plant conditions. All demonstrated good knowledge of the use of the Nuclear Accident Report System (NARS) form; however, one team incorrectly provided the station telephone number to the inspector, playing the role of a call recipient, thereby compromising the call validation schem It was noted that this team had correctly described the validation scheme during the general question portion of the interview. All teams correctly simulated initial notifications to the NRC in a timely manner; however, none were knowledgeable about the I&E Notice (IN 85-78) regarding the NRC information needs during an emergency. One team failed to initiate a shutdown to hot standby condition as required by Technical Specifications until prompted. Two teams failed to classify an Unusual Event when conditions required a plant shutdown. One team failed to provide the correct PAR for the , given plant conditions (due to the poor quality of the PAR tlow diagram in ' BwZP 380-4).

Based on the above findings, the following deficiencies must be corrected to achieve an acceptable program: Prior to Fuel Load, the applicant must complete additional emergency preparedness training for all SEs, SF, and SCREs, with emphasis on the following:

.-- . - - _ - __ . ._ - -. . .-

I

* Identification of CR shift personnel and completion of integrated training for each CR shift requiring the concurrent use of Reactor Plant Procedures and EPIPs;
* Understanding which emergency response facilities must be activated for each emergency class;
* Understanding of offsite evacuation time estimate data in protective action decisionmaking;
* Familiarity with the guidance provided in NRC Infomation Notice IN 85-78;
-and
* Ability of'all persons who could become Acting SD to correctly classify
' emergencie (456/86021-37; 457/86019-37)

7. Walkthroughs With Other Emergency Response Personnel-In addition to the walkthroughs with Control Room aersonnel described in Section 7.2.1, the inspectors conducted walkthrougls with a number of persons

<

assigned to the onsite and offsite emergency organizations. The purposes of these walkthroughs were to assess the adequacy of the emergency preparedness training efforts, and to assess the interviewees' (nowledge and understanding of the applicant's overall emergency preparedness prpgram and their specific emergency response duties. Interviewees were alloSed to refer to relevant procedures as they deemed appropriate. In general, station personnel inter-y viewed had not participated in the November 1985 exercis The following types and numbers of emergency orgardlation personnel were interviewed: two Station Directors; two Operations Directors; two Technical Directors; two Maintenance Directors; two Rad / Chem Directors; two Environs Directors; one Stores Director; one Administrative Director; one Security Director; five Call Supervisors; nine Communicators / Recorders; three Mechanical Maintenance Foremen; two Electrical Maintenance Foremen; three Instrument Maintenance Foremen; two Radwaste Coordinators; four Chemists; twelve RCTs; one Medical Director; one Accounting Director; one Legal Counsel; one Communications Director; and three Emergency News Center Spokesperson With the following exceptions, the aforementioned individuals demonstrated an adequate knowledge of the applicant's emergency preparedness program and their own emergency response roles. Of the Station Group directors interviewed, three were weak in their understandings of the emergency plan in general, while two others' knowledge was marginally adequate. One individual was judged marginally acceptable in his understanding of his. specific emergency responsibilities. Several of the Call Supervisors indicated that they did not have their portions of the Station's emergency call-out lists readily available at their residences. All five did, however, demonstrate an adequate understanding of how the call system worke Based on the above findings, the following deficiency must be corrected to achieve an acceptable program: !

i

r

* Prior to Fuel Load, the applicant must complete remedial training on general and position-specific aspects of the Station's emergency preparedness program for the following types of Station Group directors:

Station, Operations, Technical, and Maintenance Directors. (456/86021-38; 457/86019-38) In addition, the following item should be considered for improvement:

* The applicant should implement additional administrative measures to ensure that Call Supervisors keep their current call-out lists readily available when offsit .0 Persons Contacted 8.1 CECO Personnel E. Fitzpatrick, Station Manager
*C. Schroeder, Services Superintendent
*L. Davis, Assistant Superintendent, Technical Services
*D. Paquette, Assistant Superintendent, Maintenance
*C. Tomashek, Project Startup Superintendent
*P. Barnes, Regulatory Assurance Supervisor
*F. Willaford, Security Administrator
*N. Coan, Office Supervisor
*P. Parks, Regulatory Assurance Staff
*L. Literski, GSEP Coordinator
*R. Kyrouac, Station Quality Assurance Supervisor
*A. Scott, GSEP Training Instructor
*L. Butterfield, Nuclear Services Technical Manager
*J. Golden, Nuclear Services Technical, Emergency Planning Supervisor
*W. Brenner, Emergency Planning Supervisor
*F. Krowzack, Emergency Planning Supervisor P. Cretens, Assistant Superintendent, Startup R. Lemke, Technical Staff Supervisor R. Legner, Senior Operating Engineer R. Ungeran, Operating Engineer T. Bobic, Master Electrician J. Huffman, Master Mechanic R. Benn, Assistant Security Administrator G. Nelson, Assistant Technical Staff Supervisor T. Meyer, Station Fire Marshall R. Milne, Construction Engineer G. Hausman, Senior Startup Engineer R. Aker, Rad / Cham Supervisor J. Purazzo, Construction Engineer W. Scott, Project Startup Engineer M. Trusheim, Technical Staff T. Keith, Station Health Physicist D. Akerman, Training Instructor R. Fay, Support Group Instructor J. Receveur, Shift Engineer C. Melone, Systems Engineer

r j l I D. Rupert, Welding Engineer R. Jenkins, Electrical Group Leader M. Boyle, Mechanical Maintenance Foreman l M. Andrews, Station Chemist H. Pontious, General Engineer W. McGee, Training Supervisor N. Kauffman, Training Group Leader G. Schiebrel, Project Group Training Instructor R. Ryan, Support Group Instructor D. Overbeck, Maintenance Group Training Instructor J. Andrasco, Mechanical Maintenance Foreman J. Lundberg, Mechanical Maintenance Foreman J. Matthews, Technical Staff ' J. Gosnell, Thermal Group Leader J. Galligan, Operations Staff W. McCue, Shift Engineer J. Bowee, Shift Engineer D. Higinbotham, Shift Foreman S. Jensen, Shift Foreman K. Eckert, Shift Foreman L. McCoy, Shift Foreman J. Chojmicki, Shift Foreman D. Cooper, Station Control Room Engineer J. Nalewajka, Station Control Room Engineer N. Sanborn, Station Control Room Engineer (Instructor) L. Rhoden, Fire Brigade Training Instructor D. Graves, Staff Assistant H. Edwards, Assistant Storekeeper P. Harvey, Rad / Chem Supervisor J. Anspaugh, Health Physicist B. Lloyd, Chemist R. McGaw, Rad / Chem Technician l T. Benoit, Rad / Chem Technician T. Vanderwort, Quality Assurance Inspector > A. Scaccia, Offsite Emergency Planner C. Ross, Chemist J. Bates,-Chemist ,' D. Nguyen, Startup Engineer E. Waloszin, Operations Analyst D. Shamlin, Health Physics Foreman

.

T. O'Brien, Technical. Staff

' J. Jasmosz, Licensing Group Leader

K. Skinner, Health Physics Foreman P. Harvey, Health Physics Foreman ' T. Kirman, Electrical Maintenance Foreman

T. Forrest, Electrical Maintenance Foreman R. Himes, Instrument Maintenance Foreman l J. Allen, Instrument Maintenance Foreman j

' P. Stanczak, Instrument Maintenance Foreman ' J. Petro, Radwaste Coordinator ! l

i 68

e I l J. Testa, Radwaste Coordinator A. Graham, Rad / Chem Technician M. Meyerhoff, Rad / Chem Technician J. Price, Rad / Chem Technician l D. Southcomb, Rad / Chem Technician  ! L. Branchaw, Rad / Chem Technician D. Gron, Rad / Chem Technician C. Shelton, Rad / Chem Technician D. Hudson, Rad / Chem Technician M. Sweeney, Rad / Chem Technician M. Erbeck, Rad / Chem Technician R. Owen, Technical Staff M. Smith, Technical Staff T. Blackmon, Emergency Planning Supervisor J. Barr, Emergency Planning Supervisor L. Duchek, Emergency Planning Supervisor T. Greene, Emergency Planner T. Markwalter, Emergency Planner B. Saunders, Nuclear Security Administrator R. Moore, GSEP Training Specialist R. Dwyer, Public Information Officer R. Halley, Senior Staff Physician G. Myrick, Health Physicist H. Dellay, Legal Counsel M. DePanzio, Environmental Group Leader M. LePage, Facilities Specialist D. Denealy, Environmental Health Physicist J. Harl.ow, Supervising Financial Coordinator R. Hajdk, Communications Engineer T. Kovak, Radiation Protection Director R. Pavlik, Radiation Protection Assessment Coordinator

* Indicates those persons who attended the June 13, 1986 exit intervie .2 Non-CECO Personnel J. Fairow, Emergency Preparedness Supervisor, ESDA C. Leach, Lt., Grundy County Sheriff's Department J. Lutz, Grundy County ESDA J. Olson, Grundy County Under Sheriff C. Grygiel, Fire Chief, Braidwood, Illinois D. Gould, Will County ESDA G. Luchowski, Will Ccunty Sheriff's Department M. Field, Sgt. , Kankakee County Sheriff's Department R. Meentz, Kankakee County ESDA J. Brown, Head Nurse, St. Joseph's Medical Center R. Tarizzo, M.D., Coordinating Physician L. Kemper, Meteorologist, Murray and Trettal K. Toelle, Meteorologist, Murray and Trettal

e 9.0 Exit Interview

On June 13, 1986, the inspectors, the Chief of the Emergency Preparedness Section and the Chief of the Emergency Preparedness and Radiological Protection Branch met with those applicant representatives denoted in Section 8.1 to present the preliminary findings of the appraisal team. The applicant understood that written responses would be due for all open and improvement items documented in this Inspection Report, and indicated that none of the information discussed at the meeting was proprietary in natur I

70

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:l 1-

STATION DIRECTOR

         (Plant Operations Manager)

! I I I I OPERATIONS TECHNICA MAINTENANCE STORES DIRECTOR DIRECTOR DIRECTOR DIRECTOR I I I I STAFF STAFF STAFF STAFF l SHIFT ENGINEER l

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OSC ADMINISTNATIVE SECURITY RAD - CHEM ONSITE

DIRECTOR DIRECTOR DIRECTOR DIRECTOR

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*osc Director reports to operations support canter FIGURE I GSEP STATION GROUP ORGANIZATION
             . _ _ _ - - _ _ - -

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j j CORPORATE COMMAND l CENTER DIRECTOR i

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4 SYSTEM POWER i OlSPATCHERS j LEGAL ! CONSULTANT MEDICAL i OIRECTOR

) ) I I I I , ENGINEERING INTELLIGENCE ENVIRONMENTAL MANPOWER AND DIRECTOR DIRECTOR DIRECTOR LOGISTICS DIRECTOR l' I

I I I I i HEALTH PHYSICS INFORMATION ACCOUNTING COMMUNICATIONS

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OIRECTOR DIRECTOR DIRECTOR DIRECTOR

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l Recovery Manager Staff r-- - - - - - , Advisory Emergency Technical Waste System i i Station Administration / Scheduling Environmental / Design and Support News Center Support Rod. Control i I Logistics Planning Emergency Const. Support Director Director Manager Manager Director Manager , l l Manager Coordinator Manager

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p-- l STATION l Staff Staff i Staff L GROUP J Staff Staff Staff I Staff ! l l l

l Health Physics Training l _ _ ,_ Environs ; l Director Director Director

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l Staff Access Control l _ ! y I Director l g _ Waste System l l l Director Communications ' l I l _ Director l EOF l Stan t_____,

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l CCC l r------------, I I I l Corporate Command Center l Environmental Director i Director l l ggggy ENVIRONMENTAL L _ _ _ _ _ _; _ _ _ _ _ _ _sl CENTR

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FULL RESPONSE OFFSITE GSEP ORGANIZATION Division -  ! Staff l Director i L____________________; }}