IR 05000456/1989029
| ML19351A624 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 12/06/1989 |
| From: | Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML19351A623 | List: |
| References | |
| 50-456-89-29, 50-457-89-29, NUDOCS 8912200018 | |
| Download: ML19351A624 (7) | |
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'U.S. NUCLEAR REGULATORY COMMISSION-
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REGION.III
' Reports'No. 50-456/89029(DRSS); 50-457/89028(DRSS)
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Docket Nos. 50-456; 50-457 Licenses No. NPF-72; NPF-77
. Licensee:
Commonwealth Edison Company'
Post Office Box 767.
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Chicago, IL.60690
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Facility Name:
Braidwood Nuclear Generating Station, Units ~1 and 2 iInspection at:- Braidwood Station, Braceville, Illinois Inspection conducted:
November'13-17, 1989
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Inspectors:
. P. Patterson Date
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LO.C. M
. Approved by: William Snell, Chief it A /2>
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Radiological Controls and Emergency Date i
' Preparedness Section
. Inspection Summary:
Inspection on November 13-17, 1989, (Reports No. 50-456/8029(DRSS);
No. 50-457/89028(DRSSJ)
Areas Inspected:
Routine announced inspection of the following areas of the Emergency Preparedness Program:
activation of the emergency plan (IP92700);
emergency plan and implementing procedures; organization and management; emergency. facilities and equipment; training; and independent audits (IP82701).
The inspection involved one NRC inspector.
Results:
No violations, deficiencies,.or deviations were identified during this inspection. The emergency preparedness program has good organization and is particularly strong in training, both formal and informal, including drills and " tabletop" exercise practices.
The audit program is thorough and does include several surveillances as part of its program.
A quarterly performance-assessment by the Corporate emergency preparedness staff also has been added as part of an overall review function, both onsite and offsite.
The program
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under'the direct guidance of the Generating Stations Emergency Plan (GSEP)
Coordinator continues as a high quality effort.
8912200018 891208 PDR. ADOCK 0S000456 O
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DETAILS (
~ 1-Persons Contacted
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"D. O'Brien, Technical Superintendent
- B. Mc Cue, Operating Engineer
- D. Ambler, Health Physics Supervisor
- A. Haeger, Operating Staff
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- E. Carroll, Regulatory Assurance Staff
- P. Holland, Regulatory Assurance Staff o
- L. Literski,. GSEP Coordinator
- M. Egner, GSEP Trainer, Training Department
- R. Cozzi, Quality Assurance / Nuclear Safety Oversight
- L. Kim,- Quality Assurance Inspector
- L. Raney, Onsite Nuclear Safety 7-L L. Weber, Shift Engineer
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R. Mertogul, Station Control Room Engineer
- These licensee representatives listed above attended the November 17, 1989, exit interview.
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s 2.
Emergency Plan Activations (IP92700)
During this inspection period there were nine declared emergency events which were so identified by the licensee.
The first one, during-October 1988, a notification of an Unusual Event (NUE) has already been addressed by the NRC Resident Inspectors.
This event resulted in the initiation of an Emergency Action Level (EAL) change, additional emphasis as a training related concern, and a guidance letter from corporate management-in January, 1989.
The EAL change was needed_because Control Room personnel considered the condition as a power reduction and not as a reactor shutdown.
EAL-3a, under System Malfunctions, now states that an unusual event declaration is required at the commencement of a technical specification required reactor shutdown.
There were seven other NUE's declared since October 1988.
In addition, one Alert was declared on February 23, 1989.
This event was correctly classified using EAL-3a, System Malfunctions, which is applicable if equipment is degraded such that only one system or means is available for achieving and maintaining a cold shutdown condition except during controlled, planned evolutions.
Since the entire time from the Alert declaration until the termination of the emergency was only 28 minutes, shift augmentation was not initiated.
This event and all the NUE's except for the one on October 1988, were properly
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administered using the correct EAL; and offsite notifications were made within the required times.
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3.
Operational Status of the Emergency Preparedness (EP) Program (IP82791)
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Emergency Plan and Implementing Procedures The next revision of the Generating Station's Emergency Plan (GSEP)
which applies generically to all six of the licensee's nuclear stations is scheduled for January,1990.
Station Emergency Plan l-
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Implementing' Procedures:(EPIP's) were reviewed in 1988 and'are scheduled to be reviewed in 1990.
This two year review period is specified in the'GSEP, Section 8.1.3, which includes this 'and other J'
onsite emergency response facilities (ERF's) confirmed that current.
responsibilities for the Station Manager.
A-spot check of the revisions of GSEP and relevant-EPIP's were'available.
The ERF's observed included the Control Room.
From interviews and a review of plans and certain procedures, the inspector concluded that there were
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no.new substantive changes present in the current GSEP or Braidwood j
EPIP's that were not reviewed previously.
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Based'on the above findings, this portion of the licensee's program -
was acceptable.
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Emergency Response Facilities, Equipment, and Supplies The Control Room (CR), Technical Support-Center (TSC), and Operational Support Center (OSC) were reviewed as to their adequacy as ERF's.
There were no changes identified-in emergency response i
related equipment and facilities as described in the previous
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inspection of October, 1988. The TSC and CR were considered to
be operationally ready.
The exception was the OSC, which has to
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mount status boards and install certain communications equipment
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to become operational from its location in the Service Building.
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The inspector-interviewed-the Shift Engineer (SE) briefly in the i
CR.
The SE identified the EAL change in the Braidwood EPIP's which
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resulted from the emergency declared event of October-31, 1988.
The Emergency' Telephone Directory in Series 600 of the EPIP's was j
' determined to be current as identified in the CR procedures manual.
The CR's radiation monitoring capabilities through instrumentation, f
annunciators, and computer display terminals were reviewed with
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the assistance of the Shift Control Room Engineer.
The various
alarm level points were identified on the terminal display and l
the significance of the various colored lights were also explained.
l These radiation monitors included area radiation monitors, process radiation monitors, containment air monitors, and wide range gas monitors.
The wide range gas monitors represented the last measuring point before a release would go through the stack.
There is one j
main stack leaving the auxiliary building for each of the two
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Braidwood units.
The sum of the output of the two stacks as measured by the wide range gas monitor represents the total release.
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entire monitoring system and its visible components were very state-of-the-art in visibility; and, if monitored by qualified CR j
personnel, should be able to identify increased radiation levels j
and pinpoint any release point in the system without undue delay.
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Two emergency kits were selected for inventory, one in the TSC and one in the OSC.
Specific key emergency equipment was examined, and radiation monitoring instruments were checked for operability.
4" The equipment selected was found to be satisfactory, and the radiation monitoring equipment was operable on all scale increments.
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Inventory frequency for all emergency equipment kits was reviewed
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by: record checks and found to be satisfactory.
Approximately 25-additional large first aid kits are now in place.
These plus the-present 25 first aid kits have helped eliminate the problem of personnel breaking the seal on the emergency kits to get certain-first aid items from them.
These approximately 50 large-first aid kits are unsealed and are in locations more likely to be used for job related minor accidents.
i Based on the above findings, this portion of the licensee's program was acceptable.
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Organization and Management Control There have been-no changes in the EP organization at Braidwood since the previous inspection.
The reporting chain for the GSEP Coordinator appears to be rather tedious as-it moves upward from the Radiation / Chemistry Supervisor to Services Director and then to' Station Manager.
A more direct reporting path to the Station Manager would be more desirable.
However, from observations and assurances from station managers, the present arrangement seems to function satisfactorily.
The GSEP Coordinator does have direct access, unofficially, to the Station Manager if the situation demands it.
The current GSEP Trainer is continuing to be'more involved in the various aspects of the EP program and has held that position-for a year.
A. cooperative relationship between the GSEP training
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representative and the GSEP Coordinator is important and should be maintained.
The annual training / indoctrination meeting with offsite support agencies was held on October 12, 1989.
Besides corporate representatives, several station management personnel and the GSEP Coordinator were present.
Letters of Agreement with offsite support. agencies, police, fire protection, hospital and ambulance services, etc., are not due for renewal until next year.
There were no new additions for support services that would require a Letter of Agreement.
One newer orgenizational facet relates to quarterly performance assessment reports by the Corporate EP Staff.
These were initiated in-mid-summer 1988.
The quality of these assessments could be considered as being related to management control.
These assessments may help improve the EP program at Braidwood.
There are monthly input reports that make up the quarterly assessment reports.
At the time of this inspection, neither the monthly input reports or the quarterly assessment reports were being provided to any of the GSEP Coordinators.
If these reports were made available to the site GSEP Coordinators, they could be aware of what items could be addressed to improve the EP program.
In conclusion, there were no substantive changes in the organization and management control from the previous inspection in October, 1988.
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Based on the above. findings, this portion'of the licensee's program-a'
was^ acceptable.
However, the following item should be considered for.
improvement.
The quarterly performance assessment reports and monthly input
reports issued by the Corporate EP should be made available to all'the licensee's GSEP Coordinators.
This distribution could be beneficial to all concerned.
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Training-Through a review of documentation and discussion with the GSEP Coordinator, it was confirmed that the following drills were conducted satisfactorily within the required time spans and satisfactory critiques were held where applicable.
1. -Communication Drills 2.
Health Physics Drills - Semi-annually 3.
Environmental Drill - Annual 4.
Shift Augmentation Drills 5.
Assembly and Accountability Drills 6.
Medical Drill Four individuals with the following emergency response titles were interviewed:
One Rad / Chem Supervisor, one Chemistry Specialist,
'and two Radiation Protection Technicians (RPT).
The RPT's were interviewed as Environs Team members.
All four individuals demonstrated good' emergency response knowledge and skills for the specific position they were assigned. The Chemistry Specialist is a new emergency response position.
The specific knowledge needed for this position should be helpful to the Rad / Chem Director in an emergency condition.
The GSEP Trainer was interviewed.
He adequately described iiis duties 'and later demonstrated the capability to retrieve training records both manually and by computer display terminal.
A few lesson
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plans were reviewed and found to be satisfactory.
The lesson plan for the position of Chemistry Specialist cutlined the areas where the Chemistry Specialist could contribute skills to the emergency response in the TSC.
These areas included direction over the chemical sampling by the technicians, analysis of data from the Post Accident i
Sampling System, overseeing demineralizer activities, main steam
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blowdown column for analysis of spent resins and other chemically related plant systems.
This position should bring a better balance between the radiation and health physics aspects and the chemical analysis of various plant systems when the plant is in an emergency L
mode.
Monthly training sessions have been initiated recently by the GSEP Coordinator. They include any new topics of EP interest including procedure changes and any recent EAL changes.
These are informal sessions and usually directed at TSC responders only.
These sessions
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are.in' addition to required GSEP training sessions.
So far, these A
sessions have been well-received by the participants and appear to help maintain enthusiasm for the EP program and its ramifications by these timely. updates on EP related activities.
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To get some assurance that those individuals with emergency response (ER) functions were trained annually on all required courses, 31 names were selected from a list of designated emergency responders.
All 31 had been trained annually on the' approved courses for that ER position.
Retrievability for..these training records was well demonstrated.by.the GSEP Trainer.
Based on the above findings, this portion of the licensee's program-was acceptable.
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Independent Reviews / Audits Independent audits were conducted in 1989 by the Quality Assurance (QA) Department using staff based at Braidwood.
The main portion of this QA audit was done in June, 1989, and resulted in one s'
finding.
This finding, as evaluated by the inspector, was
. considered administrative and minor in importance.
In addition, several surveillances were conducted'at the site in 1989 by the QA Department.
Offsite audits related to the EP program were conducted in September, 1989, by an offsite QA group.
One of their conclusions was that Braidwood was interfacing satisfactorily with State, county,.and other local governmental agancies such as police and fire departments, hospital, and ambulance services.
However, QA determined that the GSEP training matrix guidance issued by Corporate EP staff did not address training requirements for the onsite Fire Brigade and the First Aid and Rescue Team.
Follow-up on this lack of including guidance in the training matrix for these two emergency response groups consistea of. including this item in a QA Corporate EP audit done on October 24, 1989.
Corporate EP hes agreed to discuss the issue at the next-GSEP trainers meeting scheduled for November 28, 1989.
At that time, discussion and prompt resolution has been promised.
At the Exit Interview, the Inspector asked the licensee to inform him as soon as resolution of this QA finding is made.
This item would have been more serious except for the fact that Braidwood is currently providing the training as required for the Fire Brigade and First Aid and Rescue Teams.
The Corporate discrepancy is between the generic GSEP requirements and the Corporate issued training matrix guidance, EPGR-TR-0201, Revision 0, Emergency Preparedness Training Administrative and Course Management Information.
In conclusion, satisfactory independent audits are being conducted annually.
Findings, suggestions for improvement, and other audit conclusions are being acted upon and corrections made where applicable.
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Based on the above findings, this portion of the licensee's program was' acceptable.
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' Exit Interview On November 17, 1989, the inspector met with those licensee representatives identified in Section-1 of this report.
The scope and preliminary findings of the inspection were ~ summarized.
No violations were identified.
I Overall, the EP program at Braidwood continues to be well organized j
and effective. One small sample of the above_ average caliber of the j
EP training was identified in the responses demonstrated by the four individuals selected for walkthrough/ interviews.
All exemplified a high degree of competence.and a very positive attitude relating to their emergency response functions.
Other facets of the program appear to be well implemented and are examples of continued vigilance by the GSEP Coordinator.
The licensee indicated that none of the information discussed was proprietary in nature.
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