IR 05000456/1996020

Insp Repts 50-456/96-20 & 50-457/96-20 on 961210-13.No Violations Noted.Major Areas Inspected:Plant Support & Evaluation of Performance During Plant Biennial Exercise of Emergency Plan

ML20147B706
Person / Time
Site:	Braidwood
Issue date:	01/28/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20147B702	List: IR 05000456/1996020 ML20147B698
References
50-456-96-20, 50-457-96-20, NUDOCS 9702030137
Download: ML20147B706 (12)

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U.S. NUCLEAR REGULATORY COMMISSION l

• REGION ll1

. l 1 l l Docket Nos: 50-456; 50-457

Licenses No: NPF-72; NPF-77

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Reports No

50-456/96020(DRS); 50-457/96020(DRS)

Licensee: Commonwealth Edison (Comed)

Facility: Braidwood Nuclear Plant, Units 1 and 2 l

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Location: RR #1, Box 79 Braceville, IL 60407 Dates: December 10-13,1996 Inspectors: R. Jickling, Lead Emergency Preparedness Analyst J. Foster, Sr. Emergency Preparedness Analyst T. Ploski, Sr. Emergency Response Coordinator L. Cohen, Sr. Emergency Preparedness Specialist F. Kantor, Sr. Emergency Preparedness Specialist R. Glinski, Radiation Specialist R. Winter, Reactor Engineer Approved by: James R. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

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9702030137 970128 PDR ADOCK 05000456 O PDR

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EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 & 2 NRC Inspection Reports 50-456/96020; 50-457/96020 l This announced inspection included evaluation of performance during the plant biennial exercise of the emergency plan and review of previous open item Plant Sucoort Overall performance during the 1996 emergency preparedness exercise was very goo The exercise was a successful demonstration of the licensee's capabilities to implement its emergency plans and procedures. The facilities were staffed and activated promptly, classifications of the simulated events were timely and accurate, and offsite notifications were completed within 15 minute *

Overall performance by the Control Room Simulator crew was very good. The crew was focused and effective throughout the exercise. Excellent communi-cations were maintained with other facilities and personnelin the plant. (Section P4b.1)

• The Technical Support Center staff's performance was excellent. Good command and control was demonstrated by the Station Director including detailed facility briefings. Emergency action levels were proactively reviewed to determine conditions which could lead to esc alating the emergency classification. (Section P4b. 2)

• Overall Operational Support Center staff was very good. Facility briefings were frequent and thorough and included plant status, specific tasks, and radiological and safety issues. Command and control was effectively maintained by the facility director as indicated by the staff's organization and efficient performance of their duties. (Section P4b.3) l l

• Field Monitoring Team performance was good. Teams were proactively dispatched prior to any plant radiological release and effectively tracked the radiological plume after the release started. (Section P4b.4)

Overal!, the Corporate Emergency Operations Facility performance was goo Command and control was properly transferred to the facility which then effectively fulfilled its role as an interim facility. The staff closely monitored plant conditions t to determine which conditions, would have to occur to escalate the emergency l classification. (Section P4b.5)

• Overall performance of the Mazon Emergency Operations Facility staff was goo The Manager of Emergency Operations maintained very good communications with

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other facilities. Facility managers kept their staffs well advised of evcnt response, major changes in plant conditions, and resulting decisions. (Section P4b.6)

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Reoort Details ,

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^3 EP Procedures and Documentation

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Review of Exercise Obiectives and Scenario (82302)

The inspectors reviewed the 1996 exercise's objectives and scenario and determined that they were acceptable. The scenario provided an appropriate framework to support demonstration of the licensee's capabilities to implement its emergency plan. The scenario included a large radiological release and numerous equipment failures. Exercise realism was enhanced by use of a mock NRC Site Team comprised of emergency preparedness coordinators from other utilitie P4 Staff Knowledge and Performance in Emergency Preparedness Insoection Scone (82301)

The licensee conducted a partial State participation, full county participation, biennial exercise on December 11,1996. The exercise was conducted to test major portions of the onsite and offsite emergency response capabilities. The licensee activated its emergency response organization and emergency response facilitie l The inspectors evaluated licensee performance in the following emergency response l facilities: )

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• Control Room Simulator (CRS) l

• Technical Support Center (TSC) )

• Operational Support Center (OSC) l

• Commonwealth Edison Field Monitoring Team vehicles

• Corporate Emergency Operations Facility (CEOF) ,

• Mazon Emergency Operations Facility (EOF)

l The inspectors assessed licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recomrnendations, command and control, communications, and the overall implementation of the emergency plan. In addition, the inspectors i attended the post-exercise critiques in each of the faci;ities to evaluate the I licensee's self assessment of the exercis Ememency Resoonse Facility Observations and Findinas b.1. Control Room Simulator (CRS)

The operating crew was effective and focussed on responding to the emergency conditions throughout the exercise. Excellent communications were maintained between other response facilities in the plant. Repeat backs, acknowledgements,

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and "this is a drill" were observed for all outside communications over telephone lines and radio j The CRS briefings were very good as indicated by the Unit Supervisor when he summarized plant conditions, provided control room direction, and answered questions in a concise, effective manne Good teamwork was observed in the facility including verification that the TSC was '

aware they had the responsibility to transmit the Alert declaration NRC notification after the transfer of command and control from the CRS was complete b.2 Technical Suocort Center (TSC)

Activation of the facility was efficient and rapid. The TSC assumed command and control approximately 25 minutes after the Alert was declared and transferred l command and control to the CEOF 38 minutes late I An excellent initial briefing provided plant status, including the dropped control rod, and the condition of the injured individual. The Station Director also discussed the

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i tasks assumed by the staff, demonstrating good command and control.

l The Station Director, Operations Director, and Technical Director worked well as a team. They reviewed plant status and ditermined that a Site Area Emergency (SAE) should be declared when a steam leak was reporte Emergency Action Levels (EALs) were reviewed, and " trigger points" which could lead to higher emergency classifications were identified. The Station Director also l

i provided information to the CEOF during discussions for escalating to a General Emergericy (GE) classificatio The TSC's control of and communication with the Field Monitoring Teams (FMTs)

were excellent. The FMTs were directed to take potassium iodide (KI) when large

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concentrations of radiciodine were identified in the radiological release. The teams effectively tracked the plume and identified its centerline and boundaries. Also, the

teams conducted open and closed window survey readings to determine whether i

the radioactive plume was a ground level or elevated releas Status boards were well maintained throughout the exercise. A determination was made of which reactor parameters should be trended (based on plant conditions).

The " Priority of Work" status board was well utilized to track OSC team assignments and priorities. Priorities were classified as urgent, high, medium, and low and the definitions were displayed adjacent to the boar A two-man mock NRC team was present in the TSC as well as an actual 'ONS player. There was also a mock NRC site team consisting of three additional :

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persons in the EOF. These " mock" teams were actual emergency preparedness coordinators from other utilities and effectively provided additional realism and challenge to the exercis .

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The initial message for the Alert classification directed designated TSC and OSC personnel to report to their respective facilities. There was no initial plant public address announcement declaring the Alert nor any reason for the emergency classification. In a real event, the Control Room would be called by personnel trying to obtain information. The large number of calls could preclude internal and external communication Dose projections were conducted periodically. It was noted that the release duration used for the calculations was initially one hour and then changed to the elapsed release time. Dose projection personnel did not obtain a release duration estimate from the operations group. Using the current release elapsed time would ( not provide a total dose projection and could be under-conservative.

. At the end of the exercise, an adequate discussion of Recovery Phase issues was conducted; however, use of the recovery procedure was not observed. Participants appropriately understood that certain equipment should not be repaired until a root cause evaluation of failure could be performe b.3 Onerations Sunoort Center The inspectors observed that the OSC area, equipment, and personnel were well organized. The large OSC area allowed the staff to establish separate work areas for the various functions and no congestion was noted. The staff quickly setup the equipment and activation of the OSC was efficient. However, the system used to identify and log in OSC staff was initially slow due to the large number of personnel arriving and the process for filling out and arranging the tags on the status boar The OSC Director (OSCD) frequently conducted detailed briefings. The briefings were occasionally given following the TSC briefings, at which time the OSCD would address specific issues that pertained to OSC activities. The briefings included plant status, specific OSC tasks in progress, current radiological conditions, and radiation protection and safety concerns. The inspectors noted that operators'

radios often competed with the briefings to the extent that OSC supervisors could not be heard clearly over the noise of the radios. The additional noise in the facility was a distraction but did not appear to adversely affect the function of the OS Command and control was effective as personnel were organized and cognizant of their duties. The inspectors noted that the OSCD became directly involved in some detailed activities, such as team briefings and communications with inplant team This direct involvement was not delegated to the various technical supervisors which would have allowed the OSCD to concentrate on facility coordination and directio Access control was effectively implemented by limiting entry to only one door. The inspectors observed that a second door was properly posted and no attempts were made to enter the OSC by the second entry. The OSC habitability was appropriately monitored by radiation protection (RP) staff. A step off pad was established at the entrance to the room and a radiation protection technician (RDT)

was positioned to monitor returning teams. The inspectors observed several teams

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returning to the OSC and noted that team members conducted proper contamination surveys at the step off pad.

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. The inspectors observed timely team formation and dispatch. The OSC staffing status board clearly communicated available staff. Team briefings were effectively l conducted by the OSCD and various OSC supervisors. These briefings addressed I

the specific task, low dose routes, and expected radiclogical conditions. When l applicable, the briefings also covered safety concerns such as radiation dose / dose rate hold points, respirato;/ p stection, contamination control, and potential fire

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hazards. The briefing information was recorded on briefing forms which were l reviewed and signed by OSC supervisory staff.

l The inspectors accompanied turbine floor and auxiliary feedwater pump inplant emergency response teams. The inplant team RPTs exercised effective controls for external radiation and contamination hazards. The teams properly demonstrated response to simulated radiological conditions in responding to the appropriate plant location with the appropriate protective equipment and using suitable time needed to complete their tasks. However, the inspectors noted that after the initial supply of electronic dosimeters (EDs) was exhausted, the OSC staff did not obtain more EDs, but were instead instructed by controllers to simulate use of EDs for subsequent response team Field Monitorina Teams The field monitoring teams were proactively dispatched prior to a radiological release from the plant. The two teams were appropriately briefed, conducted practical equipment checks, and dispatched without any observed problem Radio communications to and from the teams were clear and directions were clearly understood for actions and surveys to be performed. The teams appropriately tracked the radiological plume, locating the plume edges and the centerlin Coroorale Emeraency Ooerations Facility The CEOF consisted of several dedicated rooms in the licensee's corporate offices in Downers Grove. The CEOF organization included nuclear station as well as corporate personnel. The CEOF staff and several station personnel, were prestaged in a nearby conference room prior to activation of the facility. Therefore, the licensee's capability to staff the CEOF with.in the specified goal of 60 minutes was not demonstrated during this exercise. Following the declaration of the Alert the CEOF staff activated the facility and prepared to assume command and control in an orderly and efficient manner utilizing the appropriate corporate emergency plan implementing procedures (CEPIPs).

The CEOF organization is composed of a smaller number of response personnel than the licensee's EOF organization. The CEOF organization consists of 13 staff positions of whien eight have been identified to achieve minimum staffing. The Corporate Manager of Emergency Operations (CMEO) discussed the plant status l with the Commonwealth Edison Nuclear Duty Officer, who was present in the CEOF, and the Station Director (SD) in the TSC. At 10:01 a.m., the CMEO

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E determined, through discussions with his key staff managers, that minimum staff was in place in the CEOF in accordance with CEPIP-2200-0 The transfer of command and control authority from the Braidwood TSC to the CEOF was conducted appropriately. Following the declaration of the SAE command and control of the response to the emergency was transferred to the CEOF. Some minor confusion was corrected regarding which facility had the lead for issuing the 11:00 a.m. State Agency Update Checklist (SAUC). When it became known that the CEOF had assumed the 11:00 a.m. SAUC responsibility, the update was issued at the scheduled time. The CEOF staff offectively compensated for the loss of one of the protective measures staff due to illness. When the emergency response organization was unable to locate a replacement, r; member of the CEOF . staff essentially fu! filled two of the communicator positions. Thus, the CEOF functioned with a staff of 12 personnel for the exercise.

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The CMEO effectively directed his staff and maintained communications with the SD and Manager of Emergency Operations (MEO) in the Mazon Emergency Operations Facility (EOF). He also communicated periodically with the State of Illinois Radiological Emergency Assessment Center (REAC) commander and kept him informed of plant conditions and events which could have possible offsite consequences. The flow of information within the CEOF was adequate. Rather than conduct periodic meetings with his staff managers, the CMEO would go to the other rooms in the facility to obtain information from his staff. At times this resulted in the CMEO not being immediately available to respond to incoming telephone calls and potentially could have hindered the flow of information between the CEOF staff managers. Communications with the other emergency response l facilities was good, l l

The CEOF maintained command and control during the escalation of the event to a i GE. The staff closely monitored plant conditions and utilized the EAL procedures to anticipate conditions necessary to meet the criteria for a GE. Also, the CMEO kept the Illinois REAC commander informed of the situation and the possibility of escalating to a G Dose assessment activities were satisfactorily performed in the CEOF. The CEOF protective measures staff developed dose projections based on plant release and field measurement data utilizing the computer code MESOREM96. The protective measures staff utilized plant conditions and dose projections to develop the protective action recommendations (PAR) for the GE which were required in Nuclear Accident Reporting System (NARS) message number four. The Protective Measures Director misread the protective actions flowchart and recommended to the State to evacuate the 2 to 5 mile zone only in the affected downwind sectors, rather than the entire radius of all sectors in the 2 to 5 mile zone per the flowchar The licensee recognized and corrected the PAR with the next NARs message. The impact on the protective ac1ons implemented by the State were not significant since the State's evacuation sub-areas ultimately encompassed the area in questio The protective measures staff communicated frequently with their counterparts in the TSC and EOF and also compared results with the State radiological staff which

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j uses the same dose computer model. Field monitoring data were obtained by monitoring radio communications with the field teams which were controlled by the TSC and EOF. The Protective Measures Director (PMD) played a key role in the development of the decision to issue potassium iodide to the licensee's emergency worker Command and control was transferred from the CEOF to the EOF at 11:55 a.m., at i

which point the CEOF assumed a suppcrting role. Thus the CEOF was in control of the emergency response for a total of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes. Prior to termination

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of the exercise, the CMEO and key facility managers, at the request of the exercise l controllers, initiated preliminary recovery and reentry planning discussions. The l

i activity generally followed the steps outlined in the recovery and termination procedure, CEPlP 2011-01.

1 Mazon Emeraencv Ooerations Faqil,i,1y l 1

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The Security Specialist maintained an informative status board of significant events i and major decisions that were relevant to the security force as well as incoming l EOF staff. Some of the information on the status board included event classification times, transfers of command and control, and onsite protective actions.

During the EOF activation process, senior EOF respoMers kept their staffs well advised of efforts to assume command and control on the event response, major changes in plant conditions and resulting decision The Manager of Emergency Operations (MEO) and his key aides obtained detailed initial briefings from TSC and CEOF counterparts. The MEO and Assistant MEO (AMEO) demonstrated good concern for public health and safety by recommending to the Corporate MEO (CMEO) to make a General Emergency declaration, based on the extent of degraded plant conditions. They also recommended the CMEO discuss the decision with the State's decision make Transfer of command and contr. from the CEOF to the EOF was completed in an orderly manner and was clearly communicated to EOF staff and the TSC's Station Director (SD). Due to problems in establishing communications with the station's offsite radiological survey teams, TSC staff appropriately retained control of those teams until these problems were resolve The MEO maintained very good communications with TSC and CEOF counterparts and remained wellinformed of onsite priorities, changes in plant conditions, the i status of ongoing corrective actions, and onsite protective action Status boards and briefings by the MEO's key aides were used to keep EOF staff l

informed of those matters. Occasionally, status boards projected on the facility ( wall were difficult to read because of small print or poor copying onto transparency I

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j The MEO approved several appropriate revisions to the initial PAR Very good

! offorts were made to discuss these revisions and their bases with the State's

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decision maker before these PAR revisions were transmitted. The MEO and AMEO maintained awareness of State protective actions implemented and made good use of an Emergency Planning Zone map that illustrated sectors and evacuation subarea A scenario break message was issued at 2 PM to instruct participants to develop Recovery action plans for the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. After giving each response facility's key staff time to develop their action plans, the MEO led a good discussion involving key EOF, CEOF and TSC staffs to consolidate these sufficiently detailed plan b.7 Scenario and Exercise Control The inspectors made observations during the exercise to assess the challenge and realism of the scenario and to evaluate the control of the exercis The inspectors determined that the scenario was appropriate to test emergency capabilities and demonstrate onsite exercise objectives. Control of the exercise was good and no problems were identified, b.8 Licensee Self-Critiaue The inspectors observed and evaluated the licensee's post-exercise facility critiques immediately following the exercise. Participants and controllers participated in the discussions and completed formal critique form The facility critiques were open and quite self critical with participants and controllers providing comprehensive comments that were captured for later evaluation and disposition. While the player's comments were not very extensive in the CEOF, the controllers identified signifi: ant observations made by the inspectors and made several constructive comments to improve facility performance, primarily in the area of internal staff briefings, Overall Exercise Conclusions The licensee's overall performance was very good. The facilities were staffed and activated in a prompt manner. Good direction and control were observed at all of the facilities. The emergency classifications of simulated events were timely and accurate and offsite notifications were completed within 15 minutes. Personnel held many excellent discussions during the exercise within and between the facilitie P8 Miscellaneous EP lssues (Closed) Inspection Followup item (456/94003-01(DRSS); 457/94003-01(DRSS)):

During the 1994 exercise, the control room failed to properly implement the emergency operations procedures. During this exercise, emergency operations procedures were appropriately demonstrated. Also, Braidwood Standards were initiated which emphasized procedure adherence, a debrief guide was implemented which emphasized procedure adherence and was discussed at every debrief, and 9 <

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! completion of emergency operations procedure cycle training which reenforced :

l procedure adherence. This item is closed.

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(Closed) Exercise Weakness / Inspection Followup item (456/94003-02(DRSS);

457/94003-02(DRSS)): During the 1994 exercise, poor contamination control and the failure to properly evaluate radiological cond! ions and assign appropriate l protective equipment was identified. During this exercise, contamination contro!

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and radiological condition evaluations were well done. Also, discussions regarding this issue and use of protective clothing and respiratory protection were provided to RPTs in cycle training. During table top training, discussions were conducted with OSC responders regarding contamination control techniques. This item is close (Closed) Inspection Followup Item (456/94003-03(DRSS); 457/94003-03(DRSS)):

During the 1994 exercise, contamination control was not properly conducted at the OSC. During this exercise, contamination control was appropriately demonstrated at the OSC. Also, the licenses limited access to the OSC to only one entry and assigned a RPT to attend the step off pad at the entry to the facility to ensure proper survey techniques were performed. Annual EP training included a discussion of these corrective actions. Implementation of the 1996 OSC Benchmarking program included placing step off pads at the OSC entry only when necessary to avoid desensitizing workers to radiological conditions. This item is close (Closed) Inspection Followup Item (456/94003-04(DRSS); 457/94003-04(DRSS)):

During the 1994 exercise, the TSC and EOF failed to inform the CEOF of the status of key decisions in a timely manner. During this exercise, excellent communications were demonstrated between these facilities. Also, the licensee discussed proper communications with TSC, EOF, and CEOF personnel during training. A speaker phone had been added to the Station Director's desk in the TSC to broadcast facility briefings to the CEOF and EOF. This item is close V. Manaaement Meetinas X1 Exit Meetina Summarv i

The inspectors presented the inspection results to members of licensee l

management at the conclusion of the inspection on December 13,1996. The I licensee acknowledged the findings presented. No proprietary information was l identifie'd . l l

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PARTIAL LIST OF PERSONS CONTACTED Licensee H. G. Stanley, Site Vice President T. Tulon, Station Manager B. Wegner, Operations Manager A. Harger, Health Physics and Chemistry Supervisor M. Vonk, Emergency Preparedness Director K. Appel, Emergency Preparedness Coordinator M. Ray, Emergency Preparedness Trainer T. Burns, Sr. Scenario Developer R. Krohn, Corporate Emergency Preparedness R. Plant, Corporate Emergency Preparedness J. Barr, Site Quality Verification Auditor M. Cassidy, NRC Coordinator

lilinois Deoartment of Nuclear Services T. Esper, Resident Inspector

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NRC C. Phillips, Senior Resident inspector e

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INSPECTION PROCEDURES USED IP 82301 Evaluation of Exercises for Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors ITEMS CLOSED C10_ Sad 50 456;457/94003-01 IFl Failure to properly implement the emergency operating procedures in the control roo :457/94003-02 IFl Exercise Weakness for the lack of protective equipment and poor contamination control in the OS ;457/94003-03 IFl Failure to properly conduct radiological contamination control at the OS :457/94003-04 IFl CEOF failed to inform the TSC or EOF in a timely manner of key emergency response decision _ - . . - -. . ~ - - _ _. - - .. - .-.-. - .- - - . - . . - . - _ , ,

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LIST OF ACRONYMS USED 1

AMEO Assistant Manager of Emergency Operations ,

CEOF Corporate Emergency Operations Facility I CEPIPs Corporate Emergency P!an implementing Procedures l l CFR Code of Federal Regulations ,

! CMEO Corporate Manager of Emergency Operations 1 l DRP Division of Reactor Projects

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l DRS Division of Reactor Safety EDs Electronic Dosimetry EAL Emergency Action Level ENS Emergency Notification System i EOF Emergency Operations Facility  !

EP Emergency Preparedness FMTs Field Monitoring Teams GE General Emergency ,

GSEP Generating Stations Emergency Plan l IDNS Illinois Department of Nuclear Services l IFl Inspection Followup Item IP Inspection Procedure K! Potassium lodide MEO Manager of Emergency Operations MESOREM Utility Dose Assessment Computer Code NARS Nuclear Accident Reporting System NRC Nuclear Regulatory Commission OSC Operational Support Center OSCD Operational Support Center Director  ;

PAR Protective Action Recommendation  :

PDR Public Document Room l PMD Protective Measures Director  !

REAC lllinois Radiological Emergency Assessment Center RP Radiation Protection I RPT Radiation Protection Technician SAE Site Area Emergency i SAUC State Agency Update Checklist l TSC Technical Support Center l UE Unusual Event l I

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