ML20067D403
| ML20067D403 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/05/1991 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 9102130063 | |
| Download: ML20067D403 (4) | |
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~N Comm::n'::ealth Edison o e.o
- li / 1400 Opus Place
- o Downsrs Grova, lilinois 60515 February 5, 1991 1
Hr.'A. Bert Davis Reglenal Administrator - Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road
-Glen Ellyn, Illinois 60137
Subject:
Quad Cities Fuclear Power Station Units 1 and 2 Response tn Iwo Emergency Preparedness Exercise Weaknesses Inspection 50-254/90022; 50-265/90021 MRC_Dockettim_50-25LanL!i0-265
Reference:
L. Robert Gregor letter to Cordell Reed dated December 21, 1991 transmitting NRC InsWction Report 50-254/90018; 50-265/90018
- t Mr. Davls:
1 Enclosed is Commonwealth Edison Company's (CECO) response to the subject Exercise Heaknesses which were transmitted with the referenced letter and Inspection Re) ort.
The two exercise weaknesses concerned an inadequate res)onse to tle on-site medical emergency, and inadequate analyses by the Tec1nical Support Center's dose assessment staff as well as untimely notification cf the State officials regarding these analyses.
Ceco recognizes the importance of er.:ergency preparedness exercises and protecting the health and safety of the publir.
These were given foremost consideration in developing-tne corrective actions identified to address the exercise weaknesses, and to ensure pieventing recurrences.
i Additionally, we have included our actions to address the improvement items discussed in the referenced inspection report If your staff has any questions or comments concerning this letter, please refer them to Rita Radtke, Compliance Engineer at 708/515-7284.
Very truly yours, Q
T s.
vach Nuclear Li sing Manager cc:
L.N. 01shan, Project Manager - NRR
-T. Taylor, Senior Resident Inspector d 3g
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- T, Ploski, Inspector M
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Dis'cussjon 1he Technical Support Center did not adequately analyze the release from the plant or inform State officials in a timely manner due to several contributing factors.
The commencement of an abnormal release began just prior to noon, but was not reflected on the HARS form transmitted at 1205.
This occurred due to a lack of direction to the NARS communicator as to wnere to obtain information required for completion of the NARS form.
The Environs group did not recognize the existence of significant radiotodine and cesium components of the release.
This was caused by the transmittel of unitiess scenario release rate data from the controller to the Chemist and on to the Environs Director, who subsequently made an incorrect assumption as to the units involved.
Release data would normally be communicated from the Chemist to the Environs Director via an isotopic analysis printout.
These printouts include a description of the Units involved.
Appropriate communication of changes in the affected downwind sector which occurred during a release was not transmitted to the involved States.
This was primarily due to a lack of direction ta the NARS communicator as to the appropriate source of this information.
DrnLtiye Act1001 1)
Significant revisions to the Generating Station Emergency Plan are to be implemented by March 1, 1991. One change to be incorporated by this GSEP revision will be the reporting chain for the NARS Communicator.
Rather than reporting to the TSC's Technical Director, the NARS Coanmunicator will be working for the Assistant Station Director, a newly developed position. Therefore, an appropriate NARS Communicator procedure revision will ensure that this communicator knows that the Environs Director and his staff can provide the most recent release information for the NARS form.
The Environs Director procedure revision will ensure that the Environs Director reviews the appropriate portions of the NARS form prior to transmission to St te officials.
The Assistant Station Director procedure will include ongoing verification that the most recent release information is included on the NARS form.
These procedure revisions will be completed by March 1, 1991, 2)
Commonwealth Edison will ensure that controllers are aware of the necessity to transmit all scenario data to participants with the appropriate units described.
This !atruction will be added to the controller guidance for all exercises after March 1, 1991.
3)
Health Physicists at the Quad Cities Station will receive cross-training with Chemists on the appropriate units and interpretation of information provided on isotopic analyses of gaseous effluents.
This training will be completed during the annual 1991 training cycle, gittDT 13/16
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Response to Exercise Neaknesses
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heLCliLHeAhntill Overall responsa to the on-site medical emergency was inadequate with respect to the following:
the initial medical and contamination assessments of the victim; contamination control techniques demonstrated by the responders; and on-scene command and control.
(Heakness No. 50-254/90018-01)
D.lituislon r
Commonwealth Edison's review identified that these concerns were primarily due to inadequate preparation and control of the drill location and simulated events, which resulted in an insufficient response by drill participants.
Based on this review, it-is not appropriate to make programmatic changes at this time.
He have, however, come to realize the importance of devoting adequate resource: and attention to detail when developing medical drill-scenariot, whether they are to satisfy the annual medical drill requirenent or are part of an emergency exercise.
Corr.ective Actions 1)-
The major corrective action for the identified weakness was to conduct a remedial medical drill on January 29, 1991.
This drill was observed and evaluated by a representative of NRC Region-III and by representatives-of Commonwealth Edison's Corporate Emergency. Preparedness staff.
The conduct of this: drill accurately demonstrated our ability to respond effectively to a contaminated injured person.
2)
Quad Cities Station has arranged for Radiation Management Consultants to conduct first aid training during 1991-for_ station first responders.
2 This tratuing emphasizes.the appropriate handling of a contaminated injured person.
3)
In the-future, Commonwealth Edison will set up and control medical drills that are conducted as a portion of an Emergency Exercise to the same extent as our annual medical drills.
Eterc.11LReAhne1L2 The Technical-Support Center's dose assessment staff did not adequately analyze the following items, and then did not inform State officials of these items in a. timely manner: tommencement of an abnormal release; existence of significant radioiodine and cesium components in the simulated release; and the changes in affected downwind sectors to include portions of Iowa in addition to the-Illinois portions of the Emergency Zone.
(Heakness No.
50-254/90018-02).
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Technical Support Center Environs group members will be trained on non-station sources of release information available to them during an l
I event (e.g. Illinois Department of Nuclear Safety, EOF).
This training will be completed during the annual 1991 training cycle.
5)
The station GSEP organization is changing as a' result of revision 7 to the Generic GSEP Manual.
The new organization includes the position of 1
Chemistry Director, who will be better able to interpret the information l
regarding isotopic analyses of gaseous effluents.
The Chemistry i
Director will implement procedures which contain appropriate steps to ensure that he/she will provide scenario data to the Environs and Radiation Protection Directors and can confirm that the data is, correctly interpreted and applied.
The procedures are to be in place by March 1, 1991.
6)
Revisions to the precedure that provides direction on completion of the NAM form will be made that inform the communicator that even af ter a wind shift, previously affected sectors should continue to be listed on i
the form..In addition, a note will be added to the Environs Director procedure to make him/her aware that previously affected sectors should continue to be reflected when providing updated information to the states.
These procedure revisions will be completed by March 1, 1991.
Finally, Commonwealth Edison's training of Environs personnel.is being upgraded to include more detailed instruction on the handling of wind
.l shift information.
In addition to.the two Exercise Heaknesses previously addressed, two Improvement Items were identified that involved ENS communications.
These-items were:
Persons used as communicators to the NRC should be reminded of the requirements to maintain open line communications upon request.
Persons completing Event Notification Horksheets (ENH) used by these communicators should ensure that all relevant portions'of these forms-are completed, so that the communicator.is adequately knowledgeable of onsite conditions.
Corrective actions for these items included individual discussions with'the
- SCRE and communicator involved in the exercise.
The Station EP Coordinator 1
- stressed to them that an open 1.ine communication request can be expected at l
any time and that as much information as is available should be provided via-t
'the. Event Notification Horksheet.
In addition, a letter will be developed and sent to those-Individuals presently used'as ENS Communicators-and SCREs that will stress the same concerns as above.
Finally, procedures and lesson plans will be reviewed, and revised, as appropriate, to reinforce the importance of these two issues.
Procedure revisions would be complete by March 1, 1991 and lesson plans revisions would be complete by July 1, 1991.
L zuwturn A
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