IR 05000456/1988027

Insp Repts 50-456/88-27 & 50-457/88-27 on 881017-22.No Violations,Deficiencies or Deviations Noted.Major Areas Inspected:Followup on Actual Emergency Preparedness Program & Previously Identified Items

ML20206E338
Person / Time
Site:	Braidwood
Issue date:	11/08/1988
From:	Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206E327	List: IR 05000456/1988027 ML20206E322
References
50-456-88-27, 50-457-88-27, NUDOCS 8811180049
Download: ML20206E338 (12)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-456/88027(OR$$); 50-457/88027(DR$5) .

Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77 Licensee: Commonwealth Edison Company Post Box Box 767 Chicago, IL 60690 Facility Name: Braidwo;d Nuclear Generating Station, Units 1 and 2

, Inspection At: Braidwood Station, Bracevtile, Illinois Inspection Conducted: October 17-21, 1988 Int- .'.or:

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Approved Cy: liiam Snell, Chief //

Emergency Preparedness Section Date/ /

Inspection Summary Inspection on October 17-21, 1988 (Reports No. 50-456/88027(DRSS);

No.50457/86577[0k_lS1]

Xreas Inspectedi Routine unanr.ounced inspection of the following areas of the Braidwood Station's emergency preparedness program: followup on previously-identified items (IP 92701); followup on actual earergency plan activations (IP 92700); and operational status of the emergency preparedness program (IP 82701 and IP 82206). The inspection involved one NRC inspecto Results: No violations, deficiencies or deviations were identified during this inspection.The program continues to have strong management support (Section 2, 4c, and 4d).The onsite emergency organizatien has good procedures and an innovative training program that goes beyond the program described in the Emergency Plan (dections 4a and 4d). Facilities and equipment have been improved in several areas (Sectinn 4b).

Self-identification of problems has generally been good, with thorough corrective actions (Section 2, 4d, and 4e). With one exception, the licensee's Emergency Plan activations have been timely. All offsite notifications have been timely and adequately detailed following these emergency declaration Recurds generated following these declarations, and self-evaluations of these records have been well done (Section 3).  ;

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W o Open Items were identified with respect to the onsite training progran [

f.iection 4d). Both relate to problems which the licensee had recently ;

identified but had not yet completed corrective action. Both were largely due to the recent redefinition of "annual training" and a recent change in ;

emergency preparedness tiaining instructors. These Open Items are isolated i

instances and are not indicative of an overall decline in the training !

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DETAILS Persons Contacted M. Kofron, Produt.tton Superintendent

• 0. O' brine, Services Surerintendent

• R. Legner, Assistant Superintendent. Technical Services

• 5. Rot;, Ass'istant Security Administrator

• R. Ake , Rad Chen Suoervisur

• L. Literski, GSEP Coordinator

• L. Huston, Acting Training Supervisor

• M. Egner, G5EP Training Instructor

• R. Carson, Corporate Emergency Planning Supervisor

• J. Bowman, Corporate Emsrgency Planntrg Staff

• H. Pont'ous, Operations Staff

• E. Carroll, Rgulatory Assurance Staff M. Harper, Quality Assurance Inspector F. W111aford, Security Administrator l R. Harty, Instruccot, Radiation Management Consultants, In *The above personnel attended the October 21, 1988 exit intervie . Licensee Action on Previously Identified Item (!P 92701)

[Open)OpenItemNo. 50-456/88021-01: Ouring the August 1988 exercise, accountaotitty of all onsite personnel was not completed in a timely m6iner when required. The steciated evacuation of nonessential onsite pertonnel was not ordered in a timely manner following completion of accountabt11t The licensee's proposed corrective actions included: tdentification and correctiJn of the problems which resulted in the untimely accounting of onsite personnel; a remedial 1988 assembly /accountaattity drill; and review of procedural guidance on evacuating nonessential porsonnel. The Itcensee identified a number of factors which together resulted in the untimely acccunting of all onsite personnel during the exercise. Practice assembly detits have been conducted and criticued on Octob6r 8 and 20, 1938 to evaluate the effectiveness of proposed corrective action On October 8th, the Itcensee successfully accounted for approximately 130 onsite personnel within 30 minutes. Tha licenses conservatively decided that aeditional refinements to the provisions for accounting for onstte personnel needed to be evaluated usta: a typical number of persons that would be enstte during a normal workday. The inspector was in the Technical Supply Center (TSC) to observe the October 20th assembly drill and critique. Quality Assurance (QA) staff also evaluated this det11. Over 820 of the 829 persons cnstte at the beginning of the drill were successfully accounted for within approximately 20 minutes of the start of the dril The overall coordination and communication among Control I

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Room, TSC, and Security Force staffs was much improved over that observed i during the August 1988 exercise. However, due to seve.al conflicting i reports received late in the dd it, at least one person had not been adequately accounted for when tne drill was _ terminated 44 minutes af ter it began, The licensee correctly conclud M that the Octeber ',0th drill was unsuccessful, Proposed corre:tive ac. ions included correcting a !

computer printer problem. Interviewing participants wito had made confiteting accountability re;: orts to TSC staff, and interviewing those l few persons who had been reported as located or as unoccounted for at ;

various tirres late in the drill, The Itcensee planned to conouct a [

third practice assembly drill prior to requesting t..it NRC staff evaluate (

another assembly drill later this year, l The licensee has 911minated *,he only inconsistency in procedural guidance regarding the evacuation of nonessential onsite personnel, T>is item remains open penc'ing NRC evaluation of a successful 1963 l assembly / accountability dril [ Emergency plan Activatier.s (!p 92700)

L Licensee and NRC records of actual emergency plan activations for the I period G.tober 1, 1987 through October 16, 1988 were reviewed. These (

records included: summaries generated by NRC Duty Officers: Licensee l Event Reports (LERs); Control Room logs; initial notifiuton message !

forms to Sta?v and NRC officials that were prepared by onsite personnel; l followup messago forms prepared by onsite personnel; records generatad by l iechnical Support Center (TSC) staff during an Alert declaration; and l l

evaluations of licensee records for each event that were performed by the t l

GSEP Coordinator, j During this time period, the licensee declared six Unusual Events !

and one Alert. All these situations were correctly classified, hwever, l l as indicated in Inspection Reports No. 50-456/88019(ORP) and i l

50-457/88019(ORP), the June 7,19S8 Unusual Event was not declared in >

a timely mener upon commencing reactor shutdown. The NRC was not '

informed of th) commencement of reactor shutdown in a timely manner, Severity Level IV Notices of Violation were issued fo* the untimely emergency declaration and late notification of rete .hutdown on f June 7, 19SS, By letter dated August 22, 3988, the licensee indic6ted !

that all corrective actions worid be completed by the end of 198 (

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With the enception of the June 7th occurene, all emergency declarations I were made in a timely manne Records generated by onsite personnel (

following every declaration were well-detailed to facilitate later l reconstruction of their ehergency response activ)Me Initial }

notifications of State and NRC officials were completed within the !

regulctory time limits following each declaration. The licensee has

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continued the worthwhile practice of requiring on-shift personnel to complete a version of t,he hRC's Event Notification Worksheet before l i

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t communicating with NRC Duty ofsicer The GSEP Coordinator's evaluattor* i of records associated with actual emergency plan acth4tions were thorough, including documentation of any identified problems and r associated corrective action *

An Alert was cortectly declared on July 2,108 The bulk of the TSC I staff were in position within about 80 minuus of this dec'.. . io However, the facility was not declared fully operational fo. scout '

ancther hour. The Generating Stations Emergency Plan (GSEP) lists  :

specific positions which must be filled for a fully operational TSC, i including the Rad Chem Director position. A Rad Chen Director did not .

arrive in the TSC until apprcximately 135 minutes af ter the Alert declaration. Although TSC staff provided support i 3 Centrol Room's '

Acting Station tirector prior to tho Rad Cham Direc ** rival, the TSC's Station Director did r.ot declare the fac*itty M serational i untti the Rad Chem Cirector had arrived and had be d. The GSEP Coordinator has proposed a plan revision te corporats n. . gency Pinnnirg !

staff which would allow greater flexibility when considsrug a TLL to I be fully operational. The proposed change to the 1989 revision to the i generic GSEP is that the TSC could be considered fully operational once f sufficient qualified staff are present to fulfill emergency classification, i protective action decisionmaking, and offsite agency notification responsibilitie Based on the above findings, this portion of the licensee's program was !

acceptabl :

4. OperationalStatusoftheEmergencyPreparednessprogram(IP82701} f Emergency Plan and Implementing Procedures f i

By letter dated Auguit 31,19R8, NPC Region III staff approved ,

Revtsion 6B to the Generattnq Stations Emergency Plan (GSEP) common i I to all six of the licensee's nuclear station This revision was '

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dated Marc * 1988, but was first submitted for NRC s< view in early .

l August 19B The Station's Emergency Preparedness (EP) program was !

l in the latter stages of being adjusted following the epproval and I l implementation of Revision 68. As indicated in Section 4d o' this !

l report, the primary impact of Revision 6B on the Station's EP }

program was a change to the definition of "annual training" for ;

members of the onsite emergency organizatio i On October 20, 1988, NRC staff received proposed revisions to the Emergency Action Levels (EALs) for the Braidwood and Byron Nuclear Generating Stations. The proposad EALs are part of a significant i upgrade intended to standardize the format and technical bases, where ,

possible, of the EALs utilized at this licensee's Pressurized Water l

Reactor (PVR) and Boiling Water Reactor (EWR) sites. The proposed ;

EALs had undergone onsite and ef fsite sect.nical review prior to i submittal. The licensee indicated that these Eats would not be l procedura11 zed until any sign'ficiant NRC concerns have been I resolve l 5 1

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NRC Region III staff have rewiewed all new and revised Braidwood Station Emergency Plan Implementing Procedures (EPIPs) following receipt. One procedural inconsistency regarding provisions for evacuating nonessential onsite personnel became apparent during the 1988 exercise, as inaicated in Section 2 of this repor No other EPIP inconsistencies with commitments made in the GSEP and Braidwood Annex to the GSEP have been identified by NRC staff. The licensee was conducting the required biennial review of the EPIFs versus the GSEP and Braidwood Annex at .he time of this inspectio Based on the above findings, this portion of the licensee's program was acceptabla, Emergency Response Facilities (ERFs), Equipment, and Supplies The onsite ERFs were toured and were as described in the Braidwood Annex to the GSEP and relevant EPIPs. Several equipment improvements were evident during a tour of the TSC. A new printer, i linked to the security computer, had been installed and wat operable during the October 20th assembly drill. An improved weather information status board was available. Four additional telephones had been installed in the main TSC workspace for use by NRC Site Team representatives. The telephones were located at the

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workstations utilized by the licensee's counterparts to these NRC

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representative Each telephone had a separate plant extension and could also be utilized for offsite calls, l Review of completed checklists for the period January through l September or October 1988 indicated that the GSEP Coordinator l and/or assistants had completed all procedurally required periodic communications equipment checks, first aid supplies inventories, and inventories of Health Physics and office supplies reserved for use

by emergency responders. Lccations addressed in these checklists l included

the Control Room, onsite ERFs, gatehouse, the onsite l decontamination /first aid room, and the Station's screen houses.

I Inventory checklists specified minimum quantities of items and l

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required verification of the supplies' locations and completenes Appropriate checklists addressed periodic replacement of perishable items, verificatica of the current calibration of survey instruments and air samplers, and functional tests of battery powered equipmen Inventory procedures included provisions for conducting inventories after use of the supplies or following discovery of an unsealed supply container, in addition to the periodic inventory requiremen Records reviewed indicated that all problems identified during inventories and communications equipment checks had been corrected in a timely manne Based on discussions with cognizant personnel, over 100 large first aid kits had been ordered and were expected to be delivered later in 1988. The First Aid Subcommittee of the Station's Safety Committee had not yet decided how many of these kits would be deployed at which onsite locations, or which department would be

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'. . i assigned *esponsibility for the periodic inventory of these kit .At present, there were 25 GSEP First Aid Kits, six First Responder Field Packs, and several dozen stretchers with blankets deployed ct predesignated locations within the Owner Controlled Are ;

Based on the above findings, this portion cf the licensee's '

program was acceptabl Organization and Management Control The EP program has received good support from Station management, as -

evidenced by the number of 1988 table top sessions and drills in excess of GSEP commitments and by the efforts being made to increase a replacement training instructor's.overall knowledge of the licensee's program. The GSEP Coordinator reported to the Station Manager through the Rad Chem Supervisor, the Assistant Services ,

Superintendent, and the Services Superintendent. However, it was apparent that this formal reporting chain was not necessary in order :

to bring EP concerns to the Station Manager's attentio The Station's EP program has been managed by a full-time GSEP Coordinator who has held this position since prior to Unit 1 licensing. The coordinator had previously been a member of the licensee's corporate EP staff. A member of the Station's Training ;

Department staff has been available about 30 percent of the time to- '

function as the GSEP Training Instructor. The previous and current certified instructors were responsible for conducting the bulk of the classroom training sessions for the onsite Emergency Response Organization (ERO) and for maintaining individuals' EP training records. As a "subject matter expert," per internal guidelines, the GSEP Coordinator can conduct EP training session < without being a certified instructor. During 1988, the coordinator has conducted a number of training sessions for field survey team members as part of the annual Radiation Chemistry Technician (RCT) requalification progra The Coordinator also developed three Control Room drills and six TSC tabletop sessions to enhance the annual EP training of ERO members who would function at these lecation A replacement GSEP Training Instructor was appointed in nid-September 1988 following the transfer of the individual who had held that position for several years. The new instructor observed ;

the annual exercise prior to his appointment, was a controller at i the September 1988 Zion Station exerc4se, and was scheduled to be a controller at the December 1988 Byron Station exercise. He has l attended GSEP Training Instructor and GSEP Coordinator counterpart i meeting Such staff development activities wert included in the

"Station Emergency Planning Qualification Program" for any new GSEP Training Instructor or GSEP Coordinator. This prngram was  :

proceduralized in early October 1988, and was based on a program i implemented in 1988 at the licensee's Quad Cities Statio _.- t

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The formal and informal corrective action tracking systems in place during the previous inspection remained in use during 1988. The formal tracking systems used by Quality Assurance and Regulatory Assurance staffs, plus the informal system used by the GSEP Coordinator, together encompassed onetime and periodic action item Letters of agreement with all offsite support organizations for the

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Braidwood Station were updated in mid-1988. All letters of agreement were updated biennially in accordance alth the GSEP. The Station's staff was responsible for updating agreements with local support organizations, while corporate staff were responsible for updating agreements with private and governmental organizations which would provido emergency support for any of th:s licensee's nuclear station Adequate numbers of personnel have been identified for specific lead and support positions in the onsite ERO, with no instances of the same persons being identified for more than one positio Administrative systems were in use to ensure that ERO members and

+ heir supervisors were informed of the formers' ERO membershi .

The callout procedure for the onsite ERO has been updated on a quarterly basis by the GSEP Coordinato The Corporate Technical Services Department conducted an indepth assessment of the Station's EP program in the Summer of 1988. A number of improvement items were identified. No major program problems were identified. The GSEP Coordinator c'escribed the corrective actions that had been completed on appropriate improvement item Corporate EP staff have begun issuing quarterly performance assessment reports for the licensee's six nuclear station The summary report for the period June through August 1988 was reviewed. The report listeo recent and upcoming EP events at each station. Performance assessments for each Station's EP program were made for the following categories: drills; exercises; traininy; independent evaluations (performed by NRC, QA, or INPO); station effluents; and an overall ratin Ratings of items under each category were presented in a color-coded scheme consisting of green, white, yellow, and red. Supplemental comments and supporting data for various ratings were provided in the quarterly report. However, ;

the formulas used to compute the ratings were not availabl '

Progress made by corporate EP staff on current projects was also summarized in the quarterly report. Copies of the quarterly report had been routed to all Station Managers; GSEP Coordinators and their immediate supervisors; GSEP Instructors and their supervisors; the corporate Technical Assessment and Nuclear Licensing staffs; and corporate EP staff. Such a wide distribution should lead to a better overall awareness of recent onsite and corporate EP activities, plus some insight as to how the quality of performing onsite tarks has been perceived by corporate managemen _ - _ _ _ _ -__ __ _

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Based on the above findings, this portion of the licensee's program '

was acceptable,

' Training (Also 82006)

The required annual EP training program for individual members of the onsite ERO consisted of classroom sessions and required readings of Emergency Plan Implementing Procedures (EPIPs) and sections of i the GSEP considered to be relevant to specific ERO positions. A certified instructor from the Station's Training Department was responsible for conducting the balk of the classroom sessions, issuing required reading assignments, administering examinations on position-specific training materials, and for maintaining individuals'

EP training records. The GSEP Coordinator has conducted eight training sessions for field survey teams as part of the  ;

RCT annual requalification progra ;

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The Coordinator also developed and conducted three Control Room s tabletop drills and six TSC tabletop drills or problem sching  !

sessions. These creative drills exceeded the annual training commitments described in the GSEP and were adequately documente The Control Room and TSC tabletops typically included emergency classification, offsite notification, and protective action decisionmaking tasks for a given scenario. The TSC sessions usually involved position-specific questions posed to individual key staff and to the entire group of director Responses to these questions i would then be discussed by the attendecs. The GSEP Coordinator was preparing a proposal to Station management for monthly tabletop and problem-solving sessions during 1989. Supervisory personnel assigned to the Operational Support Center (OSC) would also be included in the 1989 progra The biennial review of the Station's EPIPs versus the GSEP was in progress, in accordance with a GSEP commitmen The EP Training lastructor was involved with comparing the current lesson plans, which had been approved during 1986, versus subsequently issued EPIPs. This task was expected to be completed by January 198 An additional benefit of his reviewing :11 the lesson pla.;s versus new and revised EPIPs was that the recently appointe1 Training Instructor's familiarity with both sets of docuaents would increase more rapidl The position of Chemistry Specialist had been proceduralized in January 1988 and successfully demonstrated during the August 1988 exercise. Persons assigned to this position had received a classroom training session on the GSEP which was required for all members of the onsite ERO and had participated in the TSC tabletops and problem-solving sessions. While the need for a position-specific lesson plan had been self-identified, the lesson plan had not yet been developed. The required reading assignment matrix contained in procedure BwTP 600-37, Revision 1, addressed all onsite ERO positions with the exception of the Chemistry Specialist. The l 9 l

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licensee must fully inco porate the Chemi,vy Specialist position into the Station's annual EF trairing ' program of classrooni train'fg and required reading at signments. Tnia is Open Item  !

No. 50-456/88027-0 '

As indicated in Section 4a of this report, one change in the ,

recently approved Revision 6B uf the GSEP was the redefinition of

"annual" EP training. "he revised Eu training definition was analogous to that used for granting unescorted accass' privilege Members of the licensee's ERO must row complete an.iutl tre.ining requirements by the end of the calendar quarter corresponding to the quarter in which training was completed in the previoW year. lne GSEP Training Instructor had determinesi that ten iadividuals listed in the fourth quarter revision of Procedure Bw2P 600-2A3,

"Prioritized Call 1.isting," had not succer.sfully. completed all position-specific training requirements prior to October 1, 198 One individual was being transferred from the Station on October 21, 1988. Seven of the remaining nine persons were already scheduled to i

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complete their annual training requirements by the end of October 1988. The other two persons had been temporarily assigned to duties away from the Braidwood Station and would not be available onsite until sometime in November 1988. At the October 21, 1988

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exit interview, the licensee committed that the seven persons '

available onsite in October would complete all training requirements by November 1, 1988, while the two persons returning in November would complete all EP training requirements by December 1, 198 This commitment will be tracked as Open Item No. 50-456/88027-0 The following onsite EP drills were scheduled for later in 1988: ,

annual assembly drill; annual medial drill; semiannual, off-hours augmentation drill; and semiannual, inplant Health Physics dril t

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The annual environmental monitoring delli had been conducted in mid-Octobe This drill's critique report was not yet availabl Records indicated that all other required EP drills had been successfully conducted, critiqued, and adequately documented during 1988. The internal critique report for the August 1988 exercise was not yet available for revie Annual training for local ambulance services on dealing with contaminated, injured onsite persons was scheduled for late October 1988. The annual offsite support organization meeting to discuss the Station's EP program, includir.g EALs used to classify abnormal plant conditions, was scheduled to take place in December 198 The inspector observed the morning portion of a training session for RCTs on responding to onsite medical emergencies. The session was conducted 'oy a reprosentative of Radiation Management Consultants, Incorporated. These sessions were being conducted on every Wednesday in October as part of the annual RCT requalification program. The morning lecture primarily dealt with various triage and other emergency first aid concerns. The instructor discussed a

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number of case studies based on his years of experience as a I paramedic. The afternoon portion of the day's training was to be a review of the videotape of the 1987 medical drill. All RCTs were to attend the training on one Wednesday during October. The instructor was very responsive to questions and encouraged attendees to provide feedback on the training, or to express any other concerns regarding onsite medical response capabilities, by completing critique sheet Based on the above findings, with the exception of the two Open Items, this portion of the licensee's program was acceptabl Independent Reviews / Audit '

Quality Assurance (QA) Department records of 1988 audits and surveillances of the Stction's EP program were reviewed. All  ;

records were complete and readily available, except for the

, surveillance of the assembly drill conducted during this inspection. The 1988 audits satisfied the requirements i of 10 CFR 50.54(t). Records indicated that timely and adequate

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corrective actions had b.>en taken on identified problem l i

The annual audit program consisted of an "onsite audit" performed by QA staff based at the Braidwood Station and an "offsite audit" performed by QA staff from other locations. The onsite audit focused on the Station's EP program, while the EP program was one of

many topics addressed in the offsite audit. The format of the l checklist used in the offsite audit had changed since the 1987 l 1 offsite audit. The 1988 checklist consisted of approximately 75 single or multi part questions, grouped in eight topic areas,

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from which the auditor chose a sample of about 20 items to evaluat '

t QA Department guidelines required semiannual surveillances of the EP i program. Onsite QA staff had conducted six program surveillances through October 21, 1988. Surveillance topics included the annual  ;

exercise, several EP drills, a monthly communications equipment <

test, and verification of quarterly inventories at several onsite ,

, locations. The nature of the questions and findings of the onsito j

QA staff's audits end surveillances indicated that the auditors .

possessed a good understanding of the Station's EP progra i

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Based on the above findings, this portion of the licensee's program L i was acceptabl l i Exit Interview r On October 21, 1988, the insputor met with those licensee .

I representatives identified in Section 1 to present the preliminary l

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inspection findings. The licensee indicated that none of the matters ,

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discussed were proprietary. The licensee committed that seven persons,  ;

1 who had not completed all 1988 EP training requirements before October 1,

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1988, would do so by October 31st. The licensee also committed that two other members of the onsite emergency organization, who were offsite until sometime in November 1988, would complete all 1988 EP training requirements by December 1, 198 ,

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