IR 05000237/1985037

Insp Repts 50-237/85-37 & 50-249/85-33 on 851216-19.No Violation or Deviation Noted.Major Areas Inspected:Emergency Preparedness Program,Including Actions on Previously Identified Items & Emergency Plan Activations

ML20141G281
Person / Time
Site:	Dresden
Issue date:	01/03/1986
From:	Phillips M, Ploski T, Matthew Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20141G271	List: IR 05000237/1985037 ML20141G269
References
50-237-85-37, 50-249-85-33, NUDOCS 8601100114
Download: ML20141G281 (9)

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U.S. NUCLEAR REGULATORY COMMISSION i REGION III Reports No. 50-237/85037(DRSS); 50-249/85033(DRSS)

Docket Nos. 50-237; 50-249 Licenses No. DPR-19; DPR-25 Licensec: Commonwealth Edison Company P.O. Box 767 Chicago, IL 60690 Facility Name: Dresden Nuclear Generating Station, Units 2 and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted: December 16-19, 1985 Inspectors:

[fMN[

T. Ploski

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Date Appreved By: M h i Chief Emergency Preparedness Section h

Date Inspection Summary Inspection on December 16-19, 1985 (Reports No. 50-237/85037(DRSS);

50-249/85033(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the Dresden Station's emergency preparedness program: licensee actions on previously identified items; emergency plan activations; changes to the emergency preparedness program; knowledge and performance of duties (training); Itcenseo audits; and maintenance of emergency preparednes The inspection involved 50 inspector-hours onsite by two NRC inspector Results: No violations of NRC requirements and no deviations from commitments to the NRC were identifled during this inspection. However, one Unresolved Item is identified in the text of this repor G601100114 060107 gDR ADOCK 0 Q7 e

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DETAILS 1. Persons Contacted

• D. Scott, Station Manager

• R. Flessner, Services Superintendent

• J. Burnner, Assistant Superintendent, Technical Services

• P. Law, Quality Assurance Supervisor

• T. Ziakis, GSEP Coordinator T. Britt, GSEP Training Instructor W. Rath, GSEP Training Instructor A. Mosel, Instructor, Production Training Center D. Ringo, Procedures Coordinator K. Daugherty, Procedures Clerk A. Scassia, Offsite Emergency Planner, Technical Services Nuclear T. Blackmon, Lead Emergency Planner, Technical Services Nuclear J. Bowman, Rad / Chem Department

• Indicates those who attended the December 19, 1985 exit intervie . Licensee Actions on Previously Identified Items (0 pen) Item Nos. 50-237/85013-01 and 50-249/85012-01: Revise Emergency Action Level (EAL) Condition No.12 for General Emergency to indicate that this emergency class can also be declared based on environs measurements. The licensee indicated that any changes to the Station's EALs would be issued as part of the next revision to the Dresden Annex to the generic Generating Stations Emergency Plan (GSEP). This annex revision was currently scheduled for issuance during the first quarter of 198 This item remains ope (Closed) Item Nos. 50-237/85011-01 and 50-249/85010-01: During the 1985 exercise, access control to the Technical Support Center (TSC) was not accomplished in a tin.ely manner nor was it performed in a satisfactory manner once establishe As the corrective action to this exercise weakness, the licensee committed to revise the Security Ofrector Checklist found in implementing procedure 100-C7 to better address TSC security concerns. The inspectors determined that this checklist had been revised to better define facility security concerns and requirements. This item is considered close (Closed) Item Nos. 50-237/85011-02 and 50-249/85010-02: Implementation of shift augmentation was not accomplished in a timely manner due to a breakdown in the implementation of the call out procedure. The licensee's corrective action to this 1985 exercise weakness was to provide remedial training on the procedure to all designated call supervisors and to all Shift Engineers (SEs) and Station Control Room Engineers (SCREs). The inspectors examined training session records which indicated that all call supervisors had received this remedial training. The licensee indicated that the SEs and SCREs had received l this training during their training shift; however, the GSEP

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Coordinator's records of his training shif t presentations and his own corrective action tracking system records lacked detail regarding the items covered during his presentations to Control Room personnel. Based on several discussions with various licensee personnel, the inspectors were satisfied that call tree procedures had been included in the coordinator's presentations to Control Room personnel. This item is considered close (Closed) Item Nos. 50-237/85011-03 and 50-249/85010-03: Evacuation of nonessential personnel was not ordered in a timely manner following completion of accountability of onsite personnel. The licensee's corrective action to this 1985 exercise weakness was to provide remedial training on the Station's procedural requirements regarding site evacuation to all Acting Station Directors (SEs), and to those TSC directors who would become involved in site evacuation decisionmaking (Station, Security, and Rad / Chem Directors). The inspectors examined training session records which indicated that those three types of directors had received the remedial training on site evacuation. The licensee indicated that the SEs had received this training during their training shift; however, the GSEP Coordinator's records of his training shift presentations and his own corrective action tracking system records lacked detail regarding how this item has tmen add.ressed in these "

o presentations. Based on several discussions.with various licensee personnel, the inspectors were satisfied that site evacuation provisions had been included in the coordinator's presentations to Control Raom personne The inspectors also noted that assembly / accountability / site evacuation provisions had been addressed in annual training given to all Acting Station Directors and Station Directors during September 198 This item is considered close (Closed) Item Nos. 50-237/85011-04 and 50-249/85010-04: During the 1985 exercise, poor radiological control techniques were observed during the handling of a simulated contaminated / injured worker. The inspectors reviewed records of the September 1985 annual Medical Drill anc; determined that radiological control concerns had been adequately addressed during this onsite drill. This item is considered close (0 pen) Item Nos. 50-237/05011-05 and 50-249/85010-05: During the 1985 exercise, Emergency Operations Facility (EOF) staff failed to provide adequately detailed followup messages in accordance with Procedure EOF- The inspector's determined that the Station's implementing procedure 300-2, Ongoing Emergency Communications, adequately addressed the content of followup messages, por the guidance in NUREG 0654, Revision 1. Procedural guidance was adequate regarding the transfer of the communications responsibility from the Control Room to the TSC. Message documentation was not specifically addressed other than by the use of message forms used for recording other types of information by TSC communicator The inspectors also determined that the following corporate implementing procedures had been revised to adequately address the content of periodic (hourly) followup messages, per the guidance in NUREG 0654, Revision 1:

Corporate Command Center (CCC) Director; Intelligence Director; Recovery Manager; and Advisory Support Director. Followup message documentation

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was not specifically addressed, implying that message documentation would be accomplished as would any other type of communication from the CCC or EO During the Braidwood Station's exercise in November 1985, it was apparent that the licensee was still evaluating the additional staffing needs of the Advisory Support Director to fulfill followup message preparation and communications tasks, in addition to this position's other responsibilities. This item remains open pending successful demonstration of followup message preparation, transmission, and documentation tasks during a future Dresden emergency preparedness exercis . Emergency Plan Activations The inspectors reviewed records of three activations of the Generating Stations Emergency Plan (GSEP) w'iich occurred between March 25 and November 30, 198 All activations were correctly classified in accordance with the Station's Emergency Action Levels (EALs). As indicated in the following table, the NRC and State Agencies were initially notified in a timely manner following each declaration:

GSEP ACTIVATIONS MARCH 25 - NOVEMBER 30,'1985 Declaration Emergency State Agencies a NRC Date Time Class Initially Notified Initially Notified 6/6/85 0305 Unusual Event 0319 0325 8/16/85 0045 Alert 0101 0055 0445 Unusual Event 0445 0446 10/15/85 0505 Transportation 0519 0515 Accident aT imes listed are the later of the times in licensee and Illinois Emergency and Disaster Services Agency (IESDA) record The situation which occurred during the early morning hours of August 16, 1985 was correctly classified as an Alert, and was downgraded to an Unusual Event following restoration of offsite power to the affected unit. Available summaries indicated that the licensee activated the Technical Support Center (TSC) and Operational Support Center (OSC)

following the Alert declaration, as required. However, while the OSC was fully operational within 50 minutes of the Alert declaration, the TSC apparently was not fully operational untti about 90 minutes after the declaration. Although the Licensee Event Report (LER)for this situation was quite detailed and the licensee's operational response to the events of August 16 were praised in Inspection Report No. 50-10/85014; 50-237/85031; and 50-249/85027 (dated September 1985), the emergency preparedness inspectors were unable to determine why 90 minutes had

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elapsed before the TSC became fully operational and whether TSC logs were adequately detailed to reconstruct TSC activities. During a November 1985 review by another inspection team, the logs kept by individual TSC directors had become misplaced. The licensee was continuing efforts to locate the misplaced TSC records. Pending review of TSC records associated with the August 1985 Alert, the TSC organization's response to this situation, in terms of activation timeliness and log keeping adequacy, is an Unresolved Ite (50-237/85037-01 and 50-249/85033-01)

The October 1985 Transportation Accident was declared, per procedures, following the receipt of a report from a West Coast fire department that a truck carrying radioactive waste from the Dresden Station to an authorized disposal site had a leaking container. The container was later determined not to be leaking any material, radioactive or otherwis . Changes to the Emergency Preparedness Program (82204)

The inspectors examined the licensee's provisions for preparing, reviewing, and distributing new or revised emergency plan implementing procedures (EPIPs). These provisions remained unchanged from the last r'outine inspection and were described in Procedures DAP-1. Instructions for Preparing Station Procedures, and DAP9-2, Procedure Routing. A procedures coordinator was responsib.le for selecting predesignated personnel having the qualifications to review various categories of information. The review chain would include the designated " procedures owner" for each procedure series or that individual's designee. The Technical Staff Supervisor, who was also on the review chain, had the option of adding a " verifier", or expert on the subject matter being reviewed, to the review chain. The Training Department Supervisor was not a mandatory member of the review chain, but could be appointed as a verifier. Administrative controls existed so that the coordinator would know which individual on the review chain had possession of a document at any given time. Deadlines were established for completing the review of new or revised procedures. The inspectors reviewed the documentation associated with the approval of a recently revised EPIP and concluded that the process had been completed in accordance with the aforementioned administrative procedures. The licensee maintained a listing of individuals, organizations, or work locations that were assigned controlled copies of EPIPs. Administrative controls were established for distributing new or revised EPIPs, for acknowledging their receipt, and for taking followup action should receipt not be acknowledged after a reasonable perio By correspondence dated November 1985, the NRC received Revision 5 to the generic Generating Stations Emergency Plan (GSEP). This document is currently under review by Regional staff. The licensee indicated that the next revision to the Dresden Annex to the GSEP was currently undergoing internal review and was expected to be issued during the first quarter of 198 a

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Based on the above findings, this portion of the licensee's program was acceptabl . Knowledge and Performance of Duties (Training) (82206)

The inspectors examined some aspects of the Station's annual emergency preparedness training program. All persons assigned to Station Group director positions, including OSC Directors and Shift Engineers, received annual training on their emergency duties in September 1985. Directors received training on those EPIPs for which they had been given primary implementation responsibility, as indicted in the EPIP Manual's Table of Contents. In addition, directors were trained on various combinations of the eighteen standardized modules provided in final draft form by the licensee's Production Training Center (PTC). All directors had been trained on Module 1, titled GSEP Overview and Structure. Other modules were more specific in subject matter and were intended for specific Station Group directors, Environs staff, post-accident sampling personnel, augmentation callers, and other types of support personne PTC staf. had developed L table indicating which specific modules were annual tr.ining requirements for each director .ind support position in the onsite emergency organization. The inspectors noted that this table was different from the GSEP Training Matrix, which related general'

training areas and depth of training to the various onsite emergency organization positions as well as to GSEP training instructors and a drill / exercise controllers. A PTC representative indicated that the Training Matrix was being revised, at least to better indicate the GSEP training areas for licensed personnel other than the SEs and SCREs. The representative also expressed the PTC's intention that, since Shift Foreman and SCREs were in the line of succession to the SE, they were to be given the same Acting Station Director training as given to the SE The inspectors noted that, while the Shift Foreman and SCREs had received some GSEP training during the year, they had not been included in the September 1985 training effor The inspectors reviewed several of the PTC's standardized lesson plans to ascertain how well initial and followup notifications to the State of Illinois and the NRC had been addressed. While dedicated communications systems, initial notification timeliness, and the use of the Nuclear Accident Reporting System (NARS) form were all adequately addressed, the inspectors concluded that neither Module 1,12, nor 15 placed sufficient emphasis on the information needs of the NRC following an emergency declaration; the documentation of conversations with NRC Duty Officers; and the content, transmittal, and documentation of periodic followup messages from the Station to the State of Illinoi Based on the above findings, this portion of the licensee's program is acceptable; however, the following items shall be considered for improvement:

• All personnel in the line of succession to the Shif t Engineer should receive the same training on Acting Station Director responsibilities as is given the Shift Engineer ,

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• The Production Training Center's standardized lesson plans should place greater emphasis on the information needs of the NRC following an emergency declaration; the documentation of conversations with NRC Duty Officers; and on the content, transmittal, and documentation of periodic followup messages from the Station to the State of Illinoi . Licensee Audits (82210)

The inspectors reviewed the records of Quality Assurance (QA) Department audits and surveillances of the Station's emergency preparedness program conducted since March 1985. All records were complete and readily available. Onsite Audit QAA 12-85-19 and Offsite Audit 85-12-II were adequate in scope and depth regarding the requirements of 10 CFR 50.54(t).

The QA Department had adequately tracked corrective actions taken on the audits' open item and observation. The adequacy of the Station's interface with offsite support agencies was addressed in a number of audit questions. The method by which representatives of offsite agencies could be informed of audit findings addressing the adequacy of the Station's interface with offsite groups was discussed at the Septemb annual meeting with these representative Six surveillances were conducted during the period. One involved an auditor attending an exercise scenario development meeting. Two involved QA observation of emergency preparedness drills. One involved a QA auditor observing some Control Room and Operational Support Center (OSC)

activities during the August 1985 Alert. The other surveillances involved three or four auditors observing the 1985 practice exercise and the annual exercise. The level of QA involvement in the practice and annual exercise was appropriat Auditors' comments not only addressed the participants' technical performances, but also their attitudes and the conduct of the critiques. In contrast, the auditor's comments on the two emergency preparedness drills were essentially the type expected from any drill observer. There were no open items or observations resulting from the six surveillance Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

• Surveillances of emergency preparedness drills and exercises should also address conduct of critiques and/or the GSEP Coordinator's tracking and resolution of improvement items resulting from the critique . Maintaining Emergency Preparedness The inspectors reviewed the GSEF Coordinator's records of the following types of drills: annual assembly / accountability drill; annual environs drill; annual medical drill; semiannual Health Physics drills, which included collection and analyses of samples using the High Range Sampling System (HRSS); quarterly off-hours augmentation drills; and monthly communications drills. Drill records were complete and indicated that

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critiques had followed those drills which were more than communications test All drills were conducted separate from the annual exercise. The assembly / accountability drill was conducted on a weekday during normal work hours. The annual medical drill essentially involved only licensee personnel, as both the local ambulance service and hospital declined to participate in the drill. The former had participated in the Station's 1985 exercise and the latter had participated in an August 1985 drill involving the licensee's Braidwood Station. Both the ambulance service and the local hospital did, however, receive additional training during September 1985 from the medical consultants who helped conduct the onsite dril Augmentation drills were conducted at twice the frequency indicated in the GSEP, and about one month after each quarterly update of the Station's emergency responders' telephone listing. The monthly communications drills also satisfied the annual and quarterly communica-tions test requirement The GSEP Coordinator's tracking system records indicated that he had initiated corrective actions on a number of items identified by the NRC during the annual exercise and on a number of items identified by the licensee during the various drills. However, the inspectors noted two problems associated with the coordinator's tracking system. First, no corrective actions had apparently yet been initia'ted following the September 1985 medical drill and any of the fourth quarter drill Second, as indicated in Paragraph 2, the coordinator did not always maintain complete records regarding corrective actions he had completed in response to some items, including two 1985 exercise weaknesses which involved his conducting remedial training session The inspectors examined records of training offered annually to representatives of offsite support agencies. Training to groups who may require site access was provided in February 1985. The agenda included access procedures and onsite radiation protection. The annual media briefing, presented by licensee and State agency personnel, was conducted in April 1985, and was also attended by some journalism students who later served as news media during the 1985 exercise. The briefing agenda included the following topics: the purpose of emergency planning at

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nuclear power plants; fundamentals of radiation and radioactivity; an overview of the GSEP, including emergency classifications and associated response activities; the Illinois Plan for Radiological Accidents; and some basics of nuclear power plant operation. In September 1985, the annual meeting was held at the Mazon E0F with representative of offsite support organizations for the Dresden, LaSalle County, and Braidwood Stations. The agenda included an overview of the GSEP, including the onsite and corporate emergency response organizations; the licensee's respunse actions associated with each emergency classification; emergency class definitions and example Emergency Action Levels (EALs); offsite protective action decisionmaking, emergency communications systems; the Stations' fire protection and security programs; and the licensee's Quality Assurance program, including the method by which offsite agency representatives can obtain relevant audit results. Letters of invitation and attendance lists were available for these annual meetings in addition to agendas and more detailed notes for some of the presentation , a I

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The inspectors reviewed records of periodic inventories of onsite

! emergency supplies which were conducted in accordance with EPIPs 500-1 l through 500-6. All inventories had been completed. There were no

! apparent problems regarding replenishment of missing or depleted supplie The inspectors reviewed records of bulk deliveries of the Dresden Station's Emergency Information Booklet which were accomplished between mid-March and mid-April 1985. Available records listed the delivery locations, delivery dates, number of copies delivered, and the persons who received the booklet Over 2300 copies of the booklet were delivered by bulk delivery to many types of locations within the Station's ten mile EPZ, including: offices of the Illinois Emergency Services and Disaster Agency, city halls, industries, schools, clubs, motels, nursing homes, senior citizen homes, public parks, marinas, and libraries. The licensee indicated that the mailing of brochures to individual residences within the EPZ was accomplished during the same time period; however, the inspectors did not request to review mailing list record Based on the above findings, this portion of the licensee's program was acceptable; however, the following items should be considered for improvement:

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• Corrective actions should be initiated and adequately documented in a timely manner following critiques of periodic drills and -

exercise * The GSEP Coordinator should maintain adequately detailed records of all completed corrective actions, especially those involving presentations made to licensed personnel during their training shift . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, of noncompliance, or deviations. An Unresolved Item disclosed during this inspection is discussed in Paragraph . Exit Interview The inspectors met with those licensee representatives denoted in Paragraph 1 at the conclusion of the inspection to present and discuss their preliminary findings. The licensee agreed to consider the items discussed and indicated that none of the information was proprietary in natur ~