ML17180B249
| ML17180B249 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 06/02/1995 |
| From: | Dick G NRC (Affiliation Not Assigned) |
| To: | Farrar D COMMONWEALTH EDISON CO. |
| References | |
| TAC-M84864, TAC-M84865, TAC-M84866, TAC-M84867, TAC-M84868, TAC-M84869, TAC-M84870, TAC-M84871, TAC-M84872, TAC-M84873, TAC-M84874, TAC-M84875, NUDOCS 9506220076 | |
| Download: ML17180B249 (6) | |
Text
t' UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. D. L. Farrar, Manager Nuclear Regulatory Services Commonwealth Edison Company Executive Towers West III 1400 Opus Place, Suite 500 Downers Grove, IL 60515
Dear Mr. Farrar:
WASHINGTON, D.C. 20555--0001 June 2, 1995 5"°0-237.
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE PROPOSED USE OF TH~CORPORATE,EOF AS A,N INTEBIM EOF (.JAC NOS. ~84864, )184865, M8486~ M84861, M81~68, M84ffG9, M84870, M84871, M84872, M84873',
M84874, AND M8487S)'
On May II~ 1995, a conference telephone call was held between the NRC staff and members of the Commonwealth Edison Company (ComEd) staff during which we discussed the status of ComEd's proposal to staff and activate, within an hour following an emergency, an interim emergency operations facility (EOF) at the corporate offices until the near-site EOF is staffed and activated.
As part of the discussions, the NRC staff informed ComEd of its remaining open issues and requested additional information. This letter formally requests ComEd to provide the requested additional information.
In NRC Inspection Report 50-237/92022, dated August 20, 1992, the NRC staff identified a concern that the ComEd emergency plan does not provide for timely augmentation of its emergency response organization to relieve the control room and technical support center of off-site emergency response functions.
In response to this concern, ComEd proposed (in its September 1992 emergency plan revision) to activate the corporate EOF, within an hour following an emergency, as an interim EOF until the near-site EOF could be staffed.
In the period since the submittal, NRC has held numerous meetings and conference calls with ComEd personnel.
The NRC staff has observed the implementation of the Corporate EOF as an interim EOF during a number of emergency exercises and drills and has repeatedly identified concerns with ComEd's implementation of its proposed plan.
Earlier concerns focused on ComEd's inability to effectively transfer command and control between emergency response facilities and to adequately perform the functions of an EOF with the limited staff assigned to the Corporate EOF.
As stated in the May II, 1995, conference call, the staff observed the activation, staffing, and operation of the interim EOF during a Braidwood and a Zion exercise in April of this year.
The staff's concerns regarding staffing and operation were resolved based upon their observations. The remaining concern is ComEd's inability to staff the Corporate EOF within one hour following an emergency declaration at one of its nuclear plants.
(---9500220076 950602 PDR ADOCK 05000237 F
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OFFICE NAME DATE D.. Farrar
' Although there has been consider~ble emphasis on ComEd's cap~bility to activate the Corporate EOF within about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, please not~ that even though ComEd has proposed to eliminate the need for prompt staffing of the near-site EOFs, the NRC has not approved this proposed change. A review of recent augmentation drills indicates that it ha~ taken as long a~~% hours to staff one of the near-site EOFs.
Consequently;the need for timely staffing of the near-site EOFs remains.
Until th~ staff approves: the requested change to the interim EOF, it is expected that ComEd wilJ *use its best efforts to activate the near-site EOFs within the one hour goal.*
Although we. believe that a number of th~ ~oncer~s identified earlier have been resolved, progress toward resolution ot*the time for staffing, which was an initial staff concern in 1992, has been very slow.
With this now as the remaining item, we request a response within 30 days of receipt of this letter so that we may ctimplete our evaluation and promptly make our recommendation to the Commission.
A summary of our outstanding concerns and request for additional information is enclosed.
If there are questions regarding this request, please contact Mr. George Dick at (301) 415-3019.
This requirement affects nine or fewer respondents and, therefore, is not subject to Office of Management and Budget review under P.L.96-511.
Docket Nos.
STN 50-456, STN 50-457, STN 50-454; STN 50-455, 50-237,.
50-249, 50-373, 50-374, 50-254, 50-265, 50-295, 50-304
Enclosure:
Request for Additional Information cc w/encl:
see next page DOCUMENT NAME:BYRON\\BY84864.RAI Sincerely, Original signed by:
George F. Dick, Jr., Project Manager Project Directorate III-2 Division of Reactor Projects III/IV Office of Nuclear Reactor Regulation DI STR IBUTI ON:
Docket File PDII I-2 r /f CMoore (6)
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TEssig LCohen CMil l er WReckley PHiland, RIII To receive a copy of this document, indicate in the box: "C" = Copy* without enclosures "E" = Copy with enclosures "N" = No copy
. *See,previous concurrence LA: PDII I-2 I PM : PD II I -2 I TERB I'
\\D:PDIII-~ ~,£ CMOORE GD I CK: avl CMILLER i 'RCAPRA YJ111 05/31/95*
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-OFFICIAL RECORD COPY v
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D. L. Farrar cc:
Mr. William P. Poirier Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355, Bay 236 West Pittsburgh, Pennsylvania 15230 Joseph Gallo Gallo & Ross 1250 Eye St., N.W., Suite 302 Washington, DC 20005 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, Illinois 60532-4351 Ms. Bridget Little Rorem Appleseed Coordinator 117 North Linden Street Essex, Illinois 60935 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue North Rock Island County Office Bldg.
Rock Island, Illinois 61201 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office Rural Route #1, Box 79 Braceville, Illinois 60407 Mr. Ron Stephens, Director Illinois Emergency Services and Disaster Agency 110 East Adams Street Springfield, Illinois. 62706 Howard A. Learner Environmental Law and Policy Center of the Midwest 203 North LaSalle Street Suite 1390 Chicago, Illinois 60601 EIS Review Coordinator U.S. Environmental Protection Agency 77 W. Jackson Blvd.
Chicago, Illinois 60604-3590 Chairman Will County Board of Supervisors Will County Board Courthouse Joliet, Illinois 60434 Commonwealth Edison Company U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 North German Church Road Byron, Illinois 61010-9750 Ms. Lorraine Creek Rt. 1, Box 182 Manteno, Illinois 60950 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, Illinois 61107 Attorney General
'500 South Second Street Springfield, Illinois 62701 U.S. Nuclear Regulatory Commission Zion Resident Inspectors Office 105 Shiloh Blvd.
Zion, Illinois 60099 George L. Edgar Newman & Holtzinger, P.C.
1615 L Street, N.W.
Washington, DC 20036 Commonwealth Edison Company Byron Station Manager 4450 North German Church Road Byron, Illinois 61010 Illinois Dept. of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive Springfield, Illinois 62704 Commonwealth Edison Company Braidwood Station Manager Rt. 1, Box 84 Braceville, Illinois 60407 Chairman, Ogle County Board Post Office Box 357 Oregon, Illinois 61061 Mayor of Zion Zion, Illinois 60099 Dr. Cecil Lue-Hing Director of Research and Development Metropolitan Sanitary District of Greater Chicago 100 East Erie Street
- Chicago, Illinois 60611
,J Chairman LaSalle County Board of Supervisors LaSalle County Courthouse Ottawa, Illinois 61350 Mr. J. Heffley Station Manager, Unit 3 Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765 U.S. Nuclear Regulatory Commission Resident Inspectors Office Dresden Station 6500 North Dresden Road Morris, Illinois 60450-9766 Chairman Grundy County Board Administration Building 1320 Union Street Morris, Illinois 60450 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Assistant Attorney General 100 West Randolph Street Suite 12 Chicago, Illinois 60601 U.S. Nuclear Regulatory Commission Resident Inspectors Office LaSalle Station 2605 N. 21st Road Marseilles, Illinois 61341-9756 Michael I. Miller, Esquire Sidley and Austin One First National Plaza Chicago, Illinois 60603 Mr. D. Bax Station Manager, Unit 2 Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765 Robert Cushing Chief, Public Utilities Division Illinois Attorney General's Office 100 West Randolph Street C~icago, Illinois 60601 LaSalle Station Manager LaSalle County Station Rural Route 1 P. 0. Box 220 Marseilles, Illinois 61341 Chairman Illinois Commerce Commission Leland Building 527 East Capitol Avenue Springfield, Illinois 62706 Mr. Stephen E. Shelton Vice President Iowa-Illinois Gas and Electric Company P. 0. Box 4350
- Davenport, Iowa 52808 Mr. L. William Pearce Station Manager Quad Cities Nuclear Power Station 22710 206th Avenue North Cordova, Illinois 61242 U.S. Nuclear Regulatory Commission Quad Cities Resident Inspectors Office 22712 206th Avenue North
- Cordova, Illi~ois 61242 Station Manager Zion Nuclear Power Station 101 Shiloh Blvd.
Zion, Illinois 60099-2797 Mr. Thomas P. Joyce Site Vice President Dresden Nuclear Power Station 6500 North Dresden Road Morris, Illinois 60450-9765 Kenneth Graesser, Site Vice President Byron Station Commonwealth Edison Station 4450 N. German Church Road Byron, Illinois 61010
REQUEST FOR ADDITIONAL INFORMATION COMMONWEALTH EDISON COMPANY TO SUPPORT REVIEW OF GSEP REVISION 93-01
- 1.
During the meeting held in September 1994, the NRC requested ComEd to propose how to resolve the issue of timely activation of the interim EOF.
In its letter of November 22, 1994, ComEd committed to demonstrate a "real-time" activation of its emergency plan. This activation would permit the NRC to obser.ve the augmentation of the emergency organization in a realistic fashion which would test as much of the augmentation system as possible without placing undue burden on the licensee.
ComEd proposed the demonstration as part of the Braidwood exercise in March 1995 in order to minimize the burden on its staff. During the Braidwood exercise (postponed until April) a new callout system which had been installed to enhance ComEd's augmentation process, failed. A controller had to intervene to inform the exercise participants of the failure and to direct them to use the backup callout systems.
As a result of this failure, ComEd was unable to demonstrate its ability to augment the emergency response organization within about 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
Two issues were raised as a result of the staff's observation of the Braidwood exercise.
They are:
(a)
ComEd has established a Nuclear Duty Officer (NDO) position who activ~tes the callout system: The NDO carries a pager and a cellular phone.
The NDO receives a page from the affected plant when an Alert is declared.
ComEd indicated that the page may take as long as 15 minutes to reach the NDO.
Upon receiving the page from the affected plant, the NDO remotely activates the callout system via a pager and then receives confirmation of the callout system operation by way of a third page.
This system of
- activation is complicated and could result in delaying augmentation of ComEd's emergency response.
(b)
During the Braidwood exercise the NDO was not aware that the callout system had failed.
ComEd explained that the callout system (located in the licensee's computer data center in Joilet, IL., which is remote from the NDO) should send the NDO a signal via his pager upon failure of the system.
One signal is sent if the system fails to initiate. A second signal is sent if the system fails to complete its callout. The staff is concerned with the time delay in the notification of the NDO of possible system failures.
ComEd has stated that a backup system is to be installed which should increase the reliability of the callout system.
Notwithstanding this improvement, the staff is still concerned with the lack of positive indication to the NDO that the system is working properly during an emergency callout.
ENCLOSURE
- The above concerns have the potential to impact ComEd's capability to augment the Corporate EOF within about one hour from the time of declaration of an Alert and with a high degree of reliability. Please explain how ComEd proposes to resolve this concern.
- 2.
Following the Braidwood exercise, the NRC reviewed augmentation drill results and the procedure for performing it. Review of the drill results indicated that it takes about I~ hours for ComEd to staff the Corporate EOF.
In addition, the following concerns regarding the'.
procedure for conducting off-hour augmentation drills were identified:
(a)
The procedure indicates an. acceptance value of ~75 minutes.
(b)
The same procedure indicates that "zero time" is when the NDO receives the notification call. This can raise the actual "acceptable" activation time to 90 minutes.
In both of the procedure citations above, the activation time would be greater than the goal of one hdur from time of declaration of an Alert as stated in Generating Stations' Emergency Plan.
Please indicate how the above are consistent with the staffing goal stated in ComEd's Generating Stations' Emergency Plan.