ML20202D423
| ML20202D423 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/30/1986 |
| From: | Ainger K COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| 1828K, NUDOCS 8607140128 | |
| Download: ML20202D423 (3) | |
Text
___ _ - -_ - _____ _______ _ ________ - _
' i, s Commonwealth Edison
.[... / 72 West Adams Street, Chictgo, Illinois V
Address Reply to: Post Offica Box 767 Chicago, Illinois 60690 -0767 June 30, 1986 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Station Units 1 and 2 IE Inspection Report Nos.
50-454/86-013 and 50-455/86-011 NRC Docket Nos. 50-454 and 50-455 Reference (a): May 15, 1986 letter from W. D. Shafer to Cordell Reed
Dear Mr. Keppler:
Reference (a) provided the results of an inspection by Mr.
patterson, Ms. Smith and others of your office on April 29 through May 2, 1986. During this inspection of the Byron Station emergency preparedness exercise, two exercise weaknesses were identified. Attachment A to this letter contains Commonwealth Edison's response to the exercise weaknesses appended to reference (a).
Please direct any questions regarding this matter to this office.
Very truly yours, Ka K. A. Ainger Nuclear Licensing Administrator 1m Attachment cc: Byron Resident Inspector 1 $86 8607140128 860630' PDR ADOCK 05000454 G
PDR 1828K
s.
ATTACHMENT A EXERCISE WEAKNESS #1 The NRC was not notified within one hour after the Site Area Baergency was declared as required by 10 CPR 50.72(a)(3). This notification was not initiated until four hours and 47 minutes after the declaration Site Area Energency.
In addition, the NRC was not notified of any major change of emergency events throughout the exercise. These omissions included an uncontrolled release of radioactivity and issuance of two protective action recommendations (PARS).
RECPONSE We believe the above observation resulted from confusion between us and the NRC duty officer in the 1cvel of his participation in this GSEP exercise.
As noted in the inspection report, objective 2.b states " Demonstrate l
the capability to notify the NRC within one hour of the initial incident".
Initially, upon declaration of the exercise alert, the NRC was properly notified via the ENS.
This notification did satisfy exercise objective 2.b which was previously agreed upon by the NRC.
During the initial notifica-tion, we communicated to the NRC duty officer that we were in a GSEP exercise and our next notification will be when the exercise is over. The intent of this message was to inform him not to expect notifications as the exercise progressed. We thought it would be prudent not to tie up the ENS line with exercise message traffic. A lack of comments or objections by the duty officer indicated concurrence to us.
Nonetheless, to eliminate possible confusion in future GSEP exercises, we will revise Byron Station Procedures BZP 100-Tl " Station Director - Checklist of Initial GSEP Responsibilities" and BZP 310-1
" Initial Notifications and GSEP Responses" to clarify the Station Director's responsibilities in contacting the NRC during GSEP exercises. The clarifi-cation will ensure that all required notifications will be made during GSEP exercises. These procedure revisions will be emphasized in the periodic GSEP training program.
In addition, future exercise ground rules and objectives will be written to clarify how to satisfy notification requirements.
The procedure revisions discussed above will be completed by July 17, 1986.
., EXERCISE WEAKNESS #2 The Emergency Operations Facility (EOF) did not consider evacuation time estimates when making the second and final PAR for the public within the 10 mile Emergency Planning Zone (EPZ). This was contrary to Emergency Implementing Procedure BZP 300-AZ, Recommended Protective Actions for Actual or Imminent Gaseous Release Conditions.
Also, this PAR was issued approximately eight minutes after an uncontrolled release took place at 1400 and included 0-2 mile radius evacuation. This recommendation could have endangered residents who would have been evacuated through the plume.
RESPONSE
Cognizant GSEP personnel responsible for making protective action recommendations will be reminded during training that the evacuation time estimates should be considered when determining which protective action recommendation to make to offsite governmental officials. This training will be completed by December 31, 1986.
Additionally, to expedite the evaluation of protective action response options, we are currently developing a computer program version of ED-24, " Determining the Recommended Offsite Protective Action Response Option", which includes consideration of evacuation time estimates. The computer program version of ED-24 is scheduled to be operational by June 30, 1987. Once this version of ED-24 is available, it should expedite the evaluation of protective action response options in order to provide timely j
protective action recommendations to offsite governmental officials within the 15 minute interval required by the regulations.
It is important to note, however, that the final determination on the advisability of any protective action recommendation lies with the offsite governmental officials. This is because these governmental officials have direct access to the key, non-plant related factors necessary to finalize any protective action recommendation such as EPZ population distributions, transportation availability, special facility requirements and roadway conditions and availability.
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