IR 05000456/1997004

Insp Repts 50-456/97-04 & 50-457/97-04 on 970303-07. Violations Noted.Major Areas Inspected:Review of Emergency Preparedness Program,Aspect of Plant Support

ML20137T122
Person / Time
Site:	Braidwood
Issue date:	04/08/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137T070	List: IR 05000456/1997004 ML20137T066 ML20137T117
References
50-456-97-04, 50-456-97-4, 50-457-97-04, 50-457-97-4, NUDOCS 9704150317
Download: ML20137T122 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION HI

l Docket Nos: 50-456; 50-457 l Licenses No: NPF-72; NPF-77 1 Reports No: 50-456/97004(DRS); 50-457/97004(DRS) Licensee: Commonwealth Edison (Comed) Facility: Braidwood Nuclear Plant, Units 1 and 2 Location: RR #1, Box 79 Braceville,IL 60407 Dates: March 3-7,1997 Inspectors: R. Jickling, Emergency Preparedness Analyst J. Foster, Sr. Emergency Preparedness Analyst Approved by: J. Creed, Chief, Plant Support Branch 1 Division of Reactor Safety

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l ' ~ EXECUTIVE SUMMARY Braidwood Nuclear Plant, Units 1 and 2

NRC Inspection Reports 50-456/97004; 50-457/97004 j This inspection included a review of the Emergency Preparedness (EP) program, an aspect

, of Plant Support. This was an announced inspection conducted by two regional emergency preparedness analysts.

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The emergency preparedness program was effective in maintaining and improving operational readiness of your emergency response facilities, equipment, and personne Emergency response facilities, equipmsnt, and supplies were in excellent material ' condition. Interviews with emergency response personnel demonstrated excellent I knowledge of emergency implementing procedures and responsibilities. Management . , j support was clearly a factor in the program's improvement over the last two years.

- However, a problem was identified with the 1996 Site Quality Verification audit report of the emergency preparedness program.

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* Licensee personnel performed proper classifications and timely notifications during i an actual activation of the Emergency Plan. (Section P1.1)
* The overall effectiveness of the licensee's emergency preparedness training and organization was excellent. (Sections P5 and P6)
* Emergency response facilities and equipment were well maintained and in an excellent state of operational readiness. (Section P2.1)
* Interviews with key emergency response organization personnel demonstrated

, excellent knowledge of the emergency implementing procedures and responsibilities. (Section PS)

* A violation was identified concerning the failure of the auditing team to evaluate and document the adequacy of offsite interface with the State of Illinois. (Section

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* The inspectors completed Temporary Instruction 2515/134, " Licensee Onshift Dose Assessment Capabilities,' and verified the licensee's capabilities met the requirements. (Section P9)

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! P1 Conduct of Emergency Preparedness (EP) Activities l P1,1 Actual Emergemy Plan Activations  ; ! Insnection Scone (82701) , i i ' The inspectors reviewed records and documentation packages regarding plant : response for emergency plan activations that occurred during 1996. Also, the i inspectors reviewed the procedure for the EP staff's assessment of plant response i for actual emergency plan activation Observations and Findings , t An Unusual Event was declared at 12:50 p.m. on January 18,1996, due to a loss of both Unit 2 Station Auxiliary Transformers, lasting greeter than 15 minutes. The event was terminated at 3:22 a.m. on January 20,1996, after offsite power was restored from a System Auxiliary Transforme In accordance with procedure Bw2S 100-1, " Review of Actual Emergency Events."

The licensee's EP staff conducted an assessment of plant personnel's emergency response for the January 18,1996 Unusual Event. Documents and records related to the event had been organized into a complete, detailed package. The EP group's summary report of the event had been provided to corporate EP staff to complete the procedure. Documents reviewed indicated that the event classification and related notifications to offsite authorities and the NRC were made properly and in a tiraely manne Also, the inspectors reviewed a new Nuclear Station Work Procedure (NSWP) A-07,

" Event Response Guidelines," dated February 12,1997, developed to provide guidance on the event response process. The prc,a 'uro provided for decisions to be made regarding the need for establishing an Event Hosponse Team (ERT) based on the significance of an event, guidance for ERT activities, and resulting report Conclusions The Unusual Event was properly classified and notifications to offsite authorities and the NRC Operations Officer were made in a timely manner. Plant EP staff had J performed an excellent review of the event in a timely manner, using the applicable procedur l l

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P2' Status of EP FacWties, Equipment, and Resources

! P Matarial Coruhtian of Emergency Rannonna Facihtas , ' Inanection Scans (82701) L The inspectors evaluated the material condition of the Control Room, Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations i Facility (EOF), and the Generating Stations Emer9ency Plan (GSEP) van. Field

monitoring kits were also inspected. The hcensee demonstrated the operability of

' numerous pieces of equipment, including radiological survey instruments, dose assessment and plant data computers, and communications equipment.

I Observations and Findings i The control room was in excellent material condition with current EP procedures ! availe.le. The FTS 2000 phone system was verified operable.

The TSC's material condition was excellent. Numerous facility enhancements and ' upgrades were discussed and demonstrated. Computers and monitors in the TSC have been upgraded, a speaker phone had been installed for TSC briefings and updates so the OSC, Corporate EOF and Mazon EOF could listen, and the HMI -

 (Human Management interface) Operator interface which provided control room plant data information in the TSC had been installed. A TSC priorities status board

with definitions of the priority levels had also been added.

i ' The OSC was in excellent material condition. An innovative OSC benchmarldng ] rnoeting was conducted last Fall. The benchmarking included all six Comed sites, and initiated standardization of the site's OSCs and procedures. This resulted in three new status boards in Braidwood's OSC for status updates, facility staffing,

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and response team tracking. Improved three way loop phones connected the OSC, TSC, and control room for communicating data and as a command and control line for facility director The GSEP van was in excellent material condition. Supplies were available in ' appropriate quantities. Procedures reviewed by the inspectors were current and ! available. Instruments and equipment were verified functional and calibration dates were current. The van and portable generators were run to verify they were functional. Numerous upgrades to the van were identifie The EOF was in excellent material condition. Telephones, computer terminals, and other equipment were demonstrated to be functional. Current procedures were available and the facility was in an excellent state of readiness. The licensee provided an offective demonstration of the dose assessment co nputer system Records for the prompt alert and notification sirens for 1996 and 1995 were reviewed by the inspectors. Annual operability for 1996 was 97.5 percent with 95 percent for the lowest month's average. The 1995 annual operability average was

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97.1 percent with 95.9 percent for the lowest month's average. Siren operability j exceeded the ecceptability limit of greater then or equal to 90 percen t

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l Overall, emergency response facilities were in excellent material condetion. Several l facility enhancements were noted in each facility. Prompt Alert and Notification l System (PANS) airons were well maintaine ;

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P3 EP Procedures and Deoumentation l

l Inanection Scons (B2701)

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procedures (EPIPs) and emergency plan sections. Also, the Nuclear Tracking

! System (NTS) issues assigned to the Emergency Preparedness Group were l reviewe j 4  ! ! b. Obmarvations and Findanns 'l a

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i Bw2P 200-1, "Braidwood Emergency Action Levels," Revision 7, October 22,  :

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1996, was reviewed by the inspectors. TNs revision added a 15 minute limitation , for the Emergency Director to evaluate conditions and determine the correct ' i classification level for the emergency. This was an enhancement to the procedure.

l The 15 minute limit was allowed by NRC guldsnce (NRR's Position Paper, EPPOS l l #2). This limitation did not allow delay of classification for up to 15 minutes, but i i allowed up to 15 minutes to make a proper emergency classification. This I procedure clearly identified timeliness limitations for emergency classificatio I

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l l Also, this procedure noted if an event momentarily satisfied one Emergency Action l Level (EAL) and stabilized at an EAL for a lower classification, the declaration was

to be made according to the highest initiating conditions reached. Discussions with l

corporate and site EP staff indicated that with the use of the Nuclear Management i- and Resources Council (NUMARC) EALs, the opportunity to transit through a higher l classification and stabilize at a lower classification would be minimized.

SwZP 1000-2, "Offsite Notifications," Revision 6, October 22,1996, was reviewed by the inspectors. A recent change was that the " Additional Information" section of the Nuclear Accident Reporting System (NARS) form should only be used to i explain why a NARS form is being issued, D01 for a change in the classificatio Discussion with the licensee indicated that the offsite agencies that receive the i NARS form had an EAL manual that explained each of the EALs and the potential ,

impact on the public, and agreed additional information would not be neede ! ' I The inspectors reviewed two NTS lasues that had been assigned to the EP group: j ltem 456-103 96-01900, " Failure of Tone Alert Radios to Activate When Receiving a Shortened Activation Signal," and item 456-200-96-04303, "TSC Operability."

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l L-i Both items were required to be addressed within one month. They clearly identified 1 persons responsible, and were appropriately cloeo ] i

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. The EPlPS reviewed were clear and easy to use. The NTS was effective relative to l l EP issues and the method to track and close these issues. No problems were  I i identified in the procedures or documents reviewe '
'P5 Staff Training and QueBfication in EP l

. Innoection Scone (82701) l ! l 1 The inspectors reviewed various aspects of the licensee's training program. The j reviews included interviews with selected key emergency response organization ; j (ERO) personnel (Acting Station Director and a Unit Supervisor who performs as a i communicator in the control _ room), course critique forms, attendance records, : p examinations, and the Staff Augmentation Call List dated February 26,1997. In l j addition to the key ERO personnel interviews, the inspectors observed performance 1

of approximately 20 facility personnel during a TSC table-top training sessio i

Also, selected training instructor modules were reviewed, including S-2, " Generic l GSEP," dated July 29,1996, S-4, " Communications Systems," dated October 21, j

1996, and S-5, " Assessment, Classification, and Notification," dated August 5, j i 199 j Obmarvations and Findinas j interviews with two key emergency response personnel indicated excellent  ! knowledge of procedures and emergency responsibilities. A TSC table top training ; l session observed by the inspectors provided an adequate scenario and provided > more than two thirds of the class " hands on" training with the procedures for answering response type question ' i - l Records indicated that drills and training were formally critiqued. The training L critique forms indicated that the training had been of very good quality and the performance based table-top training and drills were considered effective by the i participant Files from the training records tracking program were compared with the Staff I , Augmentation Call List to verify ERO personnel listed on the call list were qualified.

l All ERO personnel reviewed were currently qualified for their emergency response positions. Training modules reviewed were of outline format with convenient l

references, notes, and questions included in the margin l

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. Numerous training enhancements and upgrades were discussed with EP personne !

' ' Two highlights included the use of performance-based training which included tab'.e I top training and quarterly drills. Positive feedback was noted on most training i i feedback forms. Secondly, an effective, professional ten minute video tape of basic !

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onsite and offsite EP response was to be used for all Nuclear General Employee Training and was to be distributed to all the Comed site ) Conclusions Training files were organized and complete. Modules reviewed were recently revised and rietailed. Improvements in EP training were indicated by the use of ) performance-based training and erthancements made to the progra P6 EP Organization and Administration No significant changes have been made to the EP organization since the last , inspection. Discussions with site and corporate EP staff indicated excellent I management support. Upgrades and enhancements, plus the EP Coordinator's and Trainer's proactive approach to the program have produced significant improvement in the overall program. Management support was clearly a factor in the program's improvement over the last two years. Additionally, the EP Coordinator and Trainer ; have had direct involvement in public relations by facilitating Braidwood tours for i various Federal, State, and local agency emergency response staff P7 Quality Amaurence in EP Activities a. Insoection Scone (82701) l The inspectors reviewed the Emergency Preparedness Program Peer Review report, l lasued October 31,1996, conducted by corporate EP personnel. Also reviewed I was the Site Quality Verification (SOV) Audit Report QAA-#20-96-05, " Emergency Plan and Implementing Procedures," dated March 22,199 b. Observations and Findinas The corporate peer review, which used NRC inspection module 82701 as the outline for the review, concluded that the Braidwood EP program is in "very good to exce: lent condition," and noted that continuing EP program improvements had been mad The SOV staff's audit concluded that the station had been effectively maintaining the GSEP program, and that it was one of the best maintained programs of the Commonwealth sites. No findings or recommendations resulted from the audi The EP audit, conducted by SOV staff, contained an evaluation of the effectiveness I of offsite interfaces which was required by 10 CFR 50.54(t). The evaluation of the adequacy of offsite interface had been accomplished by SOV's review of training records, face to face and telephone interviews, review of communications drill records, and observation of a communications drill. Also, a detailed standardized list of questions had been used during the interview ; i l

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The inspectors identified that the offsite agencies evaluated involved local and

county personnel only; contacts with state representatives were not performed.

!~ The corporate EP staff had provided the names and numbers for the State contacts to the SOV staff, the SOV staff attempted to contact State personnel for the

 . evaluation but were initially unsuccessful in evaluating the interface. There was no followup action to identify whether the evaluation was completed. Discussion with  ;

SOV audit staff indicated that other contacts had been made with state representatives from the lilinois Emergency Management Agency (IEMA) and the lilinois Department of Nuclear Safety (IDNS). However, the evaluation of the adequacy of State interface had not been formally evaluated or documente During discussions with corporate and site EP staff, the licensee considered actions . to correct and prevent this from recurring which included that interface with the  :

State of Illinois would be more efficient if conducted by the corporate office staf l l

10 CFR 50.54(t) states in part, that the review of the EP program shall include an 1

evaluation for adequacy of interfaces with State and local govomments and of l licensee drills, exercises, capabilities, and procedures, and that the results of the i r'aview shall be documented, reported to corporate and plant management. The j 1%ure of SOV to perform and document an evaluation for State interface adequacy

;  !s a violation of 10 CFR 50.54(t) (Violation Nos. 50-456/97004-01 and 50-i  457/97004-01).

i ! . Conclualons The licensee's audits of the EP program, including the corporate peer review provided adequate evaluation of the program. However, a violation was identified , for failure to complete the evaluation of State interface during the 1996 annusi i review of the Emergency Preparedness program.

P9 Temporary instruction 2515/134 Onshift Dose Assessment Inanection Scona (Tl 2515/134)

The inspectors discussed onshift dose assessment capabilities and provisions with licensee personnel, reviewed the EPIPs, and inspected the equipment and programs

used for dose assessment.

i Observations and Findings I [

' The Generating Stations Emergency Plan (GSEP), Section 7.3.3, "Offsite Dose Calculations," addressed dose assessment capabilities. The plan 'mdicated that control room personnel would rely on the Class A computer model (A-model) for

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,  Braidwood and other Comed sites utilized three dose assessment models: .

A-model: run continuously with control room printout i B-model: "MESOREM," primary accident offaite does model C-model: back calculated releases from field team measurements l' Procedure Bw2P 1000-7, "A-Model Operation," described the A-model, the

;  conditions which would cause the system to alarm, and it's interface with control room personnel. The system was designed to run continuously; assess containment radiation levels, vent stack release rates, and meteorological conditions

and compare them with appropriate Emergency Action Level (EAL) values. The

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program would then provide an event classification, downwind dose and dose rate j projections at predetermined distances. The system would automatically print out

alarm messages, informational messages, and reports in the control roo Corporate Emergency Plan implementing Procedure (CEPIP) 3220-01, " Dose i Assessment B Model (MESOREM96, Revision 21," Revision 3, dated October 1996,

was reviewed. No concems were identifie !

, The inspectora reviewed Training Module G3-EP-XL-S25, "ODCS Specialist," l ' Revision 1, dated January 30,1997. The module appropriately described the three 1 dose calculation models, and advised the ODCS specialist to switch the A-model l ^ printout from the control room to the TSC. Training also properly cautioned that I the A-model is only accurate when the plant was operating with four fans in i l' operation. The training module also contained adequate information for logging ) onto the computer system and interacting with the dose assessment model ; 1 Conclusions ) l ' Licensee capability, equipment, procedures, and training for onshift dose )j assessment were adequate. This Tl is closed. Documentation utilized for closing this Tl is attached as Attachment ' f , V. Management Meetinas  ; ! l X1 Exit Meeting Summarv  ! The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on March 7,1997. The licensee acknowledged the findings presented. No proprietary information was identifie , , t l , Attachment: Form for Documentation of On-Shift Dose Assessment Capability l I f f a n '

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PARTIAL LIST OF PERSONS CONTACTED Licensee

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T. Tulon,' Station Manager R. Wegner, Operations Manager l A. Haeger, Health Physics and Chemistry Supervisor i R. Flessner, Site Quality Verification Director  ! M. Vonk, Emergency Preparedness Director i D. Stobaugh, Emergency Preparedness Onsite Programs Administrator K. Appel, Emergency Preparedness Coordinator

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- M. Ray, Emergency Prepared 1ess Trainer    :

L. Rhoden, Training Superviscr T. Simpkin, Regulatory Assura1ce Supervisor l M. Caesidy, Regulatory Assurance M. Turbak, Site Quality Verification

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J. Barr, Site Quality Verification ,

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INSPECTION PROCEDURES USED  ; lP 82701 Operational Status of the Emergency Preparedness Program l , Ti 2515/134 Licensee Onshift Dose Assessment Capabilities i ITEMS OPEN, CLOSED, AND DISCUSSED  ; Ooened

l i 50 456/457-9700 01 VIO Failure to evaluate and document the adequacy of , offsite interface with the State of Illinoi ;

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i LIST OF ACRONYMS USED . l

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CFR~. Code of Federal Regulations CEPIP Corporate Emergency Plan implementing Procedure i EAL Emergency Action Level { EOF Emergency Operations Facility  ! EP Emergency Preparedness j EPIP . Emergency Plan implementing Procedures 1 EPPOS NRC EP Position Paper from NRR l ERT Event Response Team GSEP Generating Stations Emergency Plan l HMl Human Management Interface IFl inspection Follow-up ltem IDNS lilinois Department of Nuclear Safety , LEMA lilinois Emergency Management Agency  ; LER Licensee Event Report MESOREM Dose Assessment Program o

 .NARS Nuclear Accident Reporting System   ;

IJS W P Nuclear Station Work Procedure NUMARC Nuclear Management and Resources Council - NTS Nuclear Tracking System

 - ODCS' Offsite Dose Calculation System OSC Operations Support Center    i PDR Public Document Room    ;

STA Shift Technical Advisor ' SQV Site Quality Verification ) Tl Temporary Instruction i TSC Technical Support Center i UFSAR Updated Final Safety Analysis Report  : VIO Violation l

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ATTACPMENT A FORM FOR DOCUMENTATION OF ON-SHIFT DOSE ASSESSMENT CAPABILITY -* ~ * _Braidood/ Units 1 & 2 /50-456. 50-457 Commonwealth Edison Comoany (Comed) 10/16/96 SITE / UNIT / DOCKET #s LICENSEE DATE l

 '4.01 DOSE ASSESSMENT COMMITMENT IN EMERGENCY Pt.AN :

' Acceptance Criteria Person (s) Contacted Position Title (s) Plan Section Revision N Meets acceptance (Refer to page 1 of this Appendix for containing and Date criteria? further detail on the acceptance criteria) commitment Kevin Appel EP Coordinator GSEP 7. Rev.7F Ye Section 4.01 Item 1 01/95 Emergency Plan contains commitment for on-shift dose assessment capabilit Kevin Appel EP Coordinator GSEP 7.3.3, would Rev.71 Ye Section 4.01 Item 2 call personnel to use 02/96 Emergency Plan contains commitment for *B* model: GSEP backup dose assessment capabilit .3.1, PAR flowchar .02 ON-SHIFT DOSE ASSESSMENT EMERGENCY PLAN IMPLEMENTING PROCEDURE Person (s) contacted Position Title (s) Procedurelladication Revision N Meets acceptance and Date criteria? Kevin Appel EP Coordinator EPIP BwZP 1000-7, Re Ye Section 4.02 Item 1 "A-model Operation *; 03/16/95 Procedure initiates dose assessment Kevin Appel EP Coordinator None "A model" N/A Ye Section 4.02 Item 2 operates Indications initiate dose assessment continuously, unless INOP. Effluent monitor Kevin Appel EP Coordinator EPIP BwZP 200-3, Rev.O, Ye Section 4.02 Item 3 " Station Release Rate 1/19/94 Procedure for performing dose assessment Determination * CEPIP Rev 2,4/9 availabl , " Dose Assessment B Model".

04.03 - ON-SHIFT DOSE ASSESSMENT TRAINING l Person (s) contacted Position Title (s) Personnel Trained Meets acceptance (Title /#1 criteria? Kevin Appel EP Coordinator Unit Supervisors, Shift N/A Ye Section 4.03 Item 1 Engineers, STAS, On-shift Personnel trained for dose assessment approx.18 individuals 2515/134 A+12 issue Date: 09/26/96

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