IR 05000456/1998007

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Insp Repts 50-456/98-07 & 50-457/98-07 on 980519-22.No Violations Noted.Major Areas Inspected:Licensee Performance During Plant Biennial Exercise of Emergency Plan
ML20249B682
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 06/18/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20249B678 List:
References
50-456-98-07, 50-456-98-7, 50-457-98-07, 50-457-98-7, NUDOCS 9806240048
Download: ML20249B682 (12)


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REGIONlli p

l-i Dockot Nos:

'50-456; 50-457.

License Nos:

NPF-72; NPF-77 Report Nos:

50-456/98007(DRS); 50-457/98007(DRS)-

Licensee:

Commonwealth Edison Company Facility:

Braidwood Generating Station, Units 1 and 2 location:

RR #1, Box 84

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Braceville,IL 60407 Inspection Dates:

May 19 - 22,1998 Inspectors:

R. Jickling, Emergency Preparedness Analyst J. Foster, Senior Emergency Preparedness Analyst D. Nissen, Radiation Specialist J. O'Brien, Emergency Preparedness Specialist T. Ploski, Senior Emergency Preparedness Analyst Approved by:

J. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

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EXECUTIVE SUMMARY

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Braidwood Nuclear Generating Station, Units 1 and 2 l

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NRC Inspection Reports 50-456/98007; 50-457/98007 This inspection consisted of evaluation of the licensee's performance during the plant's biennial exercise of the Emergency Plan. It was conducted by regional emergency preparedness

- inspectors and an emergency preparedness specialist from NRC headquarters. No violations

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of NRC requirements were identified.

Plant Sucoort

. Overall performance during the 1998 Emergency Preparedness exercise demonstrated

that emergency plan implementation generally met regulatory requirements; (Section P4.1.c)

Overall, emergency response performance in the Control Room Simulator was

technically proficient and professional. An Alert was declared in a timely manner.

Offsite agencies were notified within the required times. (Section P4.1.c)

The Technical Support Center staff's responses were effective for scenario conditions.

  • The emergency reclassification and related offsite notifications were timely. Priorities were properly established and revised as plant conditions changed. (Section P4.1.c)

Overall performance of Operations Support Center management and staff was

appropriate. Priorities were clearly communicated to the staff. Facility and response team briefings were competent. (Section P4.1.c)

A technician was observed to unnecessarily post a high radiation area. (Section P4.1.c)

OSC staffing was slow due to some plant personnel not hearing an announcement to

staff the OSC. (Section P4.1.c)

i Overall performance of the Corporate Emergency Operations Facility (CEOF) personnel

was effective. CEOF staff provided support to counterparts in other facilities and communications with onsite and offsite responders were timely and comprehensive.

(Section P4.1.c)

Personnel performance of Emergency Operations Facility staff was appropriate.

  • Personnel quickly prepared to perform their duties. Adequate Protective Action Recommendations were determined in an efficient manner. The facility was rapidly activated and the transfer of emergency management and control was effective. Offsite notifications were made in a timely manner. (Section P4.1.c)

Self-critiques following termination of the exercise were critical and included inputs from

exercise participants as well as controllers. (Section P4.1.c)

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Report Details IV. Plant Support P3-Emergency Preparedness Procedures and Documentation.

.. P3.1 Review of Exercise Obiectives and Scenario (82302)

The inspectore reviewed the 1998 exercise objectives and scenario and determined that -

they acceptably exercised major elements of the licensee's onsite emergency plan. The scenario provided a challenging framework to support demonstration of the licensee's capabilities to implement its emergency plan. The scenario included a radiological release and several equipment failures.

P4

' Staff Knowledge and Performance in Emergency Preparedness

- P4.1 1998 Evaluated Biennial Emeroencv Preparedness Exercise a.

Insoection Scone (82301)

On May 20,1998,'the' licensee conducted a biennial exercise involving full participation by the State of Illinois and the counties of Grundy, Kankakee, and Will. This exercise was conducted to test major portions of the licensee's onsite and offsite emergency response capabilities. Onsite and offsite emergency response organizations and

- emergency response facilities were activated.

The inspectors evaluated performance in the following emergency response facilities:

o Control Room Simulator (CRS)

e Technical Support Center (TSC)

Operations Support Center (OSC)

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Corporate Emergency Operations Facility (CEOF)

Emergency Operations Facility (EOF)

e The inspectors assessed the licensee's recognition of abnormal plant conditions,

. classification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command and control, the transfer of emergency responsibilities between facilities, communications, and the overall implementation of the emergency plan.- In addition, the inspectors attended the post-exercise critiques in each of the above facilities, except the CRS, to evaluate the licensee's initial self-assessment of exercise performance.

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Emergencv Resoonse Facility Observations and Findings b.1

.Catrol Room Simulator (CRS)

The CRS crew professionally and effectively responded to abnormal plant conditions.

The Shift Manager recognized degraded plant conditions as warranting an Alert declaration, assumed the emergency duties of the Acting Station Director, and made this emergency declaration in a timely manner. Initial notifications were made to the State and local authorities within 15 minutes and NRC within 30 minutes of the emergency declaration, meeting and exceeding the respective notification timeliness requirements.

The inspectors observed good communications between the CRS crew and staff in other emergency response facilities (ERFs). Repeat back communications and acknowledgments were used extensively by CRS personnel.

The Acting Station Director's command and control of the CRS crew was competent.

His briefings were informative and appropriately timed so as not to adversely impact prompt responses to changing plant conditions. Changing plant conditions and related emergency response actions were included in the briefings. The Acting Station Director remained well aware of changing plant conditions and resulting responses.

The transfer of command and control from the Acting Station Director to the TSC's Station Director was smooth and well coordinated. No errors or omissions were noted during the transfer of command of the licensee's response to the Station Director.

b.2 Technical Succort Center (TSC)

Overall performance by TSC personnel was effective. The TSC was rapidly and efficiently staffed following the Alert declaration. Procedurally defined minimum staffing was achieved within 19 minutes of the Alert declaration. The Station Director accepted command and control of accident response within a timely 31 minutes of the Alert declaration.

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The Emergency Response Data System (ERDS) was activated within 35 minutes of the Alert declaration, which was well within the required 60 minutes. An infrequent evolution occurred during the exercise related to ERDS data transmission, which involved a quarterly operability surveillance by NRC Headquarters staff that included an automatic re-connection sequence verification. The Station's capability to transmit actual ERDS data was determined to be acceptable.

- The initial briefing conducted by the Station Director defined plant status and provided appropriate guidance to the TSC staff on current priorities. Subsequent, periodic briefings, which were performed by passing a remote microphone among key responders, were informative, concise, and kept TSC personnel properly apprised of i

current status, priorities, and current issues. On several occasions, TSC personnel made brief announcements regarding late-breaking events or significant changes in f

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plant conditions. Directors used position-specific checklists to better ensure that important information was included in the briefings. A noteworthy example was a clarification that the instrument air system was functional, and that only the equipment associated with the steam dump system was affected by an instrument air line leak.

Status boards were detailed and were well maintained throughout the exercise. The

" Priority of Work" status board, displayed inplant response team tasks, dispatch priority, plant priority, and team status, was well maintained. The board writer constructively displayed additionalinformation which included the time when the OSC was notified of each task, team dispatch, expected task completion time, and when teams were placed on hold.

TSC habitability was monitored using an installed area radiation monitoring system.

Frequent surveys were also conducted by a Radiation Protection Technician (RPT).

Additional emphasis was evident regarding other personnel exposure concerns.

Examples included verification that the spent fuel pool area was safe for personnel access, early initiation of inplant radiation surveys, and evacuation of nonessential personnel from the auxiliary building. An evacuation route for nonessential personnel was later selected to avoid a potential radioactive release path.

An Emergency Action Level (EAL) chart was actively reviewed during TSC activation to ensure that the current event classification was correct. Possible further equipment degrades, which could lead to higher emergency classifications, were proactively noted on this chart and were discussed among the staff.

Priorities were appropriately established for the TSC staff and inplant teams, and were adjusted as plant conditions changed. Priorities were rapidly communicated to the CRS and OSC. TSC staff was observed to frequently use ' repeat backs" and acknowledgments in their communications to avoid possible miscommunications.

Notifications to offsite agencies and the NRC were made in a timely manner and were appropriately detailed. Communicators competently tracked notification times and the times required for follow up notifications to State officials.

Colored overlays were used on a 10-mile Emergency Planning Zone (EPZ) map. The overlays represented the protective actions for the public by geographic subareas, ordered by the State officials. The overlays enhanced the clarity of the licensee's recommendations made to the offsite agencies.

Two Severe Accident Management Guideline (SAMG) evaluators also reported to the TSC. As SAMG usage was not an objective foi this exercise, these evaluators returned to other duties after they performed a review of the simulated plant conditions and compared their assessment to SAMG guidance.

The Station Director smoothly transferred command and control of emergency response to a Corporate Emergency Operations Facility (CEOF) counterpart in accordance with the Emergency Plan following a Site Area Emergency (SAE) declaration. TSC staff

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retained control of environmental monitoring teams until near site EOF staff were ready to assume this responsibility.

b3 Operational Suocort Center (OSC)

l The overall performance of OSC management and staff was appropriate. The OSC Director demonstrated effective command and control of the facility. Briefings were

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l frequent and informative. Teams were quickly assembled and dispatched from the OSC. Teams' radiological exposures were properly monitored by the escorting RPTs.

Appropriately qcalified personnel were utilized for inplant team missions.

Staffing of the OSC was slow following the Alert declaration. Radiation Protection (RP)

personnel and supervisors were notified by activating thek pagers. They arrived at the OSC within about 20 minutes of the Alert declaration. However, a plant announcement to activate the onsite emergency response facilities was not heard by the inspectors and some of the plant personnel. The remainder of the OSC personnel did not arrive until about 45 minutes after the Alert declaration. The licensee's evaluation and corrective actions to ensure adequate notification for activation and staffing of the OSC will be tracked as an Inspevion Follow up item (lFl 00-456/98007-01; 50-457456/98007-01(DRS)).

The priorities assigned to each inplant team's activities by the TSC's decision makers were clearly understood by OSC management and communicated to OSC personnel.

Inplant tean briefings provided prior to team dispatch were clear, concise, and included current information on relevant, simulated radiological conditions. RPTs were appropriately assigned to inplant teams. Afte the radiological release was confirmed, all teams 1re escorted by a RPT. Observed inplant teams effectively used hand-held radios to transmit progress reports to OSC management.

The OSC Director and OSC Supervisor provided detailed periodic briefings to the facility staff regarding changing plant conditions, information reported by inplant teams, major event response decisions, and simulated onsite radiological conditions.

Communications with the TSC were effectively maintained.

Status boards were accurately used to track personnel in each technical discipline who were available for assignment to inplant teams. Dispatched teams were competently tracked on a second status board. Team priorities, team tasks, and teams' dispatch times were prominently disolayed on the boards.

One untitH, portable status board in the OSC caused some minor confusion as it contained statements regarding some of the events, times, and events, but did not appear to be consistently used. The information on the board was also difficult to read and not legible from the back of the facility.

After the simulated release began, abnormally high radiation levels (about 54 millirem)

were reported in the OSC. RP personnel recognized that they would not be able to determine whether returning inplant teams were contaminated, or if the OSC was

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contaminated due to this high background radiation levels. RP personnel proactively established a marked off area of the OSC for the retuming response teams to be debriefed and b wait for further assessment of whether they were contaminated.

Teams were chosen based on the work that needed to be performed so that the minimum number of workers wc9d receive dose. The concept of As-Low-As-Reasonably-Achievable (ALARA) was achieved with one exception. One RPT simulated that he had " roped-off" and posted a high sedation area. While an excellent practice during normal conditions, during emergency cordbns and potentially rapidly changing radiation conditions this would haw resu tod in additionu unnecessary dose and would not be a good Al. ARA practice. The licensee's evaluation and corrective actions to prevent additional and unnecessary dose to emergency response team personnel due to posting high radiation areas during an emergency will be tracked as an Inspection Follow up item (IFl 50-456/98007-02; 50-457-98007-02(DRS)).

b.4 Corocrate Emergency Ooerations FaciLtv (CEOF)

The CEOF wss activated per procedures following the Alert declaration by pre-selected personnel who were assembled in a nearby conference room. CEOF staff efficiently procured and set up site-specific reference materials, including EPZ maps that depicted the subareas used by offsite officials to implement protective action decisions.

The overall performance of the CEOF personnel was effective before, during, and after the CEOF's Manager of Emergency Operations (MEO) was in command of the licensee's response. The MEO and his staff maintained frequent communications with TSC and EOF counterparts and provided rneaningfulinputs when appropriate. While command and control of the licensee's response resided in the TSC or Emergency Operations Facility (EOF), CEOF staff promptly responded to requests for technical and other support.

While in command of the licensee's response, the CEOF's MEO demonstrated timely and comprehensive offsite communications by conducting several conference calls with the lilinois Department of Nuclear Safety's (IDNS') senior responder to ensure that this official understood the licensee's response priorities and plant status. The MEO was also responsive to questions and concerns from his IDNS counterpart.

The MEO and his principal aides closely monitored periodic briefings conducted in the TSC. Following these briefings, the CEOF's MEO conducted concise discussions with his TSC and EOF counterparts to ensure that all information on degraded plant conditions, associated priorities, and concerns on potential further degrades were understood. The MEO also promptly forwarded rumors given him by the CEOF's government liaison and public affairs staffs to TSC and CEOF counterparts. The CEOF's MEO then used the facility's public address system to properly inform all CEOF staff of the highlights of the TSC briefings and his follow up discussions with l'is counterparts.

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Transfers of command and control to and from the CEOF's MEO were completed in an l

orderly and timely manner. Since an ongoing transfer of command and control was i

nearly completed when conditions warranting a General Emergency, the CEOF's MEO appropriately supported his EOF counterpart's decision to promptly assume lead responsibilities.

l CEOF staff in each of the facility's functional team rooms made prudent use of status l

boards to list relevant priorities and major response decisions. EPZ maps and a status board were well used to accurately display information on PARS and protective actions I

chosen for implementation by State officials. Computerized displays of plant l

parameters were also efficiently used to monitor and trend degraded plant conditions.

Protective measures staff closely monitored communications between the Station's offsite radiation moni'oring teams and TSC and EOF staffs. The CEOF staff was aggressive in identifying radioactive release information based either on readouts from fixed radiation monitors or reports from offsite survey teams. Supporting dose calculations were performed to independently verify the adequacy of PARS developed by EOF counterparts. Appropriate assessments were also made to determine what release rates could warrant a change to the current PAR.

b.5 Emeroency Ooerations Facility (EOFI Overall performance of EOF responders was appropriate. The EOF was quickly staffed foilowing the SAE declaration by personnel who were pre-staged in the local area.

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Security personnel were notified to establish access control at the EOF following the Alert declaration. Arriving EOF personnel promptly initiated their emergency responsibilities. The EOF's MEO assumed command of the emergency response approximately 80 minutes following the SAE declaration. The tumover of command to the EOF's MEO was performed in a smooth coordinated manner and in accordance with procedures.

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EOF staff worked well as a team. Staff briefings were frequent and informative.

Accident assessment and event re-classification were appropriate. EOF staff maintained proper awareness of degraded plant conditions and the changing priorities of inplant repair activities. The General Emergency was promptly classified using the correct EAL Offsite dose assessment activities were satisfactory. EOF staff performed a dose projection based upon a source term calculated from field team data due to the wide range gas monitor being postulated to be out of service. There was some initial confusion among the dose assessment staff as to whether the release was an elevated or a ground leve! release. This initial confusion was promptly corrected by the Environmental Emergency Coordinator.

PARS were determined in an efficient manner using the appropriate procedures. The EOF staff based the PAR upon plant conditions and continually reviewed dose projection results to determine if the PAR needed to be modified.

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Offsite notifications were complete and made within required time frames. In addition to initial notifications related to the General Emergency, the MEO in'ormed his IDNS counterpart of significant changes in plant conditions and the status of the release.

Conference calls between senior TSC, CEOF, and EOF responders were frequent and effective.

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b.6 Licensee Self-Critlaues The inspectors attended the license's self-critiques in the TSC, OSC, CEOF, and EOF which occurred after the exercise. Exercise controllers solicited inputs from participants in addition to providing the participants with the controllers' initial assessments of participants' performances. The inspectors concluded that these initial self-critiques were thorough and in close agreement with the majority of inspectors' observations.

b7 Scenario and Exercise Control The inspectors assessed the challenge of the scenario and evaluated the licensee's control of the exercise. The scenario was challenging and exercised the majority of the licensee's emergency response capabilities. The scenario was appropriate to test basic emergency capabilities and to demonstrate the licensee's exercise objectives.

Overall control of the exercise was appropriate. No significant controller prompting or exercise control problems were identified.

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Overall Conclusions The exercise was a competent demonstration of the licensee's capabilities to implement its emergency plans and procedures.

Overall performance during the 1998 emergency preparedness exercise

demonstraMd that emergency plan implementation generally met regulatory requirements. (Section P4.1.b)

Overall, emergency response performance in the CRS was technically proficient e

and professional. An Alert was declared in a time!y manner. Offsite agencies were notified within the required times. (Section P4.1.b.1)

The TSC staff's responses were effective for scenario conditions. The

emergency reclassification was and related offsite notifications were timely.

Response priorities were properly established and revised as plant conditions changed. (Section P4.1.b.2)

Overall performance of OSC management and staff was appropriate. Personnel

demonstrated initiative in contending with elevated radiation levels in the facility.

Priorities were clearly communicated to the staff. Facility and response team briefings were competent. (Section P4.1.b.3)

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A technician was observed to unnecessarily post a high radiation area. (Section e

P4.1.b.3)

OSC staffing was slow dne to some plant personnel not hearing an

announcement to staff the OSC. (Section P4.1.b.3)

Overall performance of CEOF personnel was effective. CEOF stsff provided

support to counterparts in other facilities. Communications with onsite and offsite responders were timely and comprehensive. (Section P4.1.b.4)

Personnel performance of EOF staff was appropriate. Personnel quickly

prepared to perform their duties. Adequate PARS were determined in an efficient manner. Offsite notifications were made in a timely manner. (Section P4.1.b.5)

Self-critiques following termination of the exercise were critical and included

inputs from controllers and exercise participants. (Section P4.1.b.7)

V.

Management Meetings X.1 Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on May 22,1998. The licensee acknowledged the findings presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Tulon, Station Vice President J. Barr, Q & SA Assessor T. Bums, Corporate Emergency Preparedness Scenario Development Supervisor S. Butler, O & SA Assessor M. Cas-sidy, NRC Coordinator L. Gerovac, Emergency Preparedness Trainer A. Haeger, Health Physics / Chemistry Supervisor J. Meister, Engineering Manager B. Plant, Lead Controller M. Ray, Emergency Preparedness Coordinator M. Riegel, O & SA Manager G. Schwartz, Station Manager T. Simpkin, Regulatory Assurance Supervisor D. Stobough, Emergency Preparedness Supervisor R. Thacker, Health Physics Supervisor M. Trusheim, Operating Engineer M. Vonk, Emergency Preparedness Director L. Weber, Shift Operating Supervisor B. Wegner, Operations Manager NRG C. Phillips, Senior Resident inspector IDNS T. Esper, Resident inspector i

INSPECTION PROCEDURES USED l

IP 82301 Evaluation of Exercises for Power Reactors IP 82302 Review of Exercise Objectives and Scenarios for Power Reactors J

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ITEMS CPENED Ooened 50-456/98007-01 IFl OSC staffing was slow due to the plant announcement to activate the onsite facilities not being heard during the 1998 EP exercise.

50-456/98007-02 IFl An RPT was observed posting a high radiation area during the 1998 EP exercise which does not support ALARA practices.

LIST OF ACRONYMS USED ALARA As Lcw As is Reasonably Achievable CEOF Corporate Emergency Operations Facility CFR Code of Federal Regulations CRS Control Room Simulator DRP Division of Reactor Projects DRS Division of Reactor Safety EAL Emergency Action Level EOF Emergency Operations Facility EPZ Emergency Planning Zone ERDS Emergency Response Data System ERF Emergency Response Facilities EP Emergency Preparedness ERO Emergency Response Organization IDNS Illinois Department of Nuclear Safety IFl Inspection Follow up Item IP.

Inspection Procedure MEO Manager of Emergency Operations NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation OSC Operctions Support Center PAR Protective Action Recommendation PDR NRC Public Docurnent Room RP Radiation Protection RPT Radiation Protecuon Technician SAE Site Area Emergency l

SAMG Severe Accident Management Guidelines TSC Technical Support Center

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