ML20207S911

Insp Repts 50-295/87-02 & 50-304/87-02 on 870223-27.No Violation or Deviation Noted.Major Areas Inspected:Emergency Plan Activations,Emergency Preparedness Program,Emergency Detection & Classification & Audits

ML20207S911
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	03/12/1987
From:	Ploski T, Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20207S912	List: IR 05000295/1987002 ML20207S911
References
50-295-87-02, 50-295-87-2, 50-304-87-02, 50-304-87-2, NUDOCS 8703200395
Download: ML20207S911 (18)

See also: IR 05000295/1987002

Text

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

ReportsNo.-50-295/87002(DRSS);50-304/87002(DRSS)

Docket Nos. 50-295; 50-304

Licenses No. DPR-39; DPR-48

- Licensee:

Commonwealth Edison Company

Post Office Box 767

Chicago, IL 60690

Facility Name:

Zion Nuclear Generating Station, Units 1 and 2

Inspection At:

Zion Site, Zion, Illinois

,

Inspection Conducted:

February 23-27, 1987

N

3l2lg7

/

Inspectors:

T. Ploski

Date

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r/ N. Williamsen

/

Date

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Approved By:

W. Sne 1, Chief

Wit /s ,

Emergency Preparedness

Date~

Section

Inspection Summary

Inspection-on February 23-27, 1987 (Reports No. 50-295/87002(DRSS);

No. 50-304/87002(DR55))

Areas Inspected:

Routine, unannounced inspection of the following areas

of the emergency preparedness program:

licensee action on previously

identified items; emergency plan activations; operational status of the

emergency preparedness program; emergency detection and classification';

protective action decisionmaking; notifications and communications;

changes to the program; shift staffing and augmentation provisions;

knowledge and performance of duties (training); and licensee audits.

Results:

No violations, deficiencies, or deviations were identified.

,

An Unresolved Item is discussed in Paragraph 3 of the Inspection Report.

,

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DETAILS

. 1.-

Persons. Contacted

• G. Plim1, Station Manager.

• C. Schultz,. Regulatory Assurance Supervisor

• W. Stone, Quality Assurance Supervisor

• A. Nykiel, GSEP Coordinator

• L. Lanes, Rad Chem Staff-

• W. Cramer,. Training Department Staff

• J. Yon Quality Control Staff

• G. O'Neill, Corporate Emergency Planner

T. Blackmon, Cor) orate Emergency Planning Supervirer

W. Otterson, GSE) Training Instructor-

J. Wennerholm, Shift Foreman

D. Schueller, Shift Foreman

S. Kaplan, Station Control Room Engineer (SCRE)

M. Manning, SCRE

E. Campbell, Master' Instrument Mechanic

T. Printz, Assistant Tech Staff Supervisor

W. T'Niemi, Master Mechanic

J. Barr, Corporate' Emergency Planning Staff

T. Blake, Training Instructor

C. Lundstrom, Assistant Storekeeper

~K. Mahoney, Staff Assistant

• Indicates those who attended the February 27, 1987 exit interview.

2.

Licensee Action on Previously Identified Items

(0 pen) Items No. 295/84010-01; 295/85008-01; 304/84010-01; and

304/85009-01:

These items related to the need for the licensee to

re-evaluate specific Emergency' Action Levels (EALs).

By correspondence

dated January 12, 1987, the staff provided comments to the licensee on

the proposed revisions to the Zion Station's EALs.

As indicated in

Paragraph 5 of this Inspection Report, the staff has interacted with

the licensee to resolve the concerns expressed on the proposed EALs.

It is anticipated that all the concerns will be resolved prior to the

1987 exercise. These items remain open.

(Closed) Items No. 50-295/86001-02 and 50-304/86001-02:

During the 1986

exercise, excessive time was taken to declare the EOF fully operational

and in command of emergency response activities.

A letter explaining

the philosophy of facility minimum staffing was distributed to appropriate

exercise participants. This item is closed.

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(Clos'ed) Items No. 50-295/86001-01 and 50-304/86001-01:

During the

1986 exercise,thelicenseefailedtodemonstratetheexerciseobjective

of notifying the NRC Operations Center within one hour of the initial

emergency classification. A review of notification requirements and

relevant procedures was conducted as a part of scheduled licensed-

operator requalification training, as the licensee had comitted.

This training was also provided to persons assigned as Station Directors.

Personnel unable to attend a training session accomplished the remedial

training through required readings.

This item is closed.

(Closed) Items No. 295/86007-01 and 304/86007-01:

The footnotet

associated with the emergency plan's Figure 6.3-1 must be included in

procedural guidance reproduced in Emergency Plan Implementing Procedures

(EPIPs) 100-1 and 110-1.

The inspector determined that these footnotes

had been added to the protective action recommendation guidance contained

in EPIPs 100-1 and 110-1.

This item is closed.

(Closed) Items No. 295/86007-02 and 304/86007-02:

Revise the "GSEP

Callout Checklist", as well as its source document (EPIP 320-1), to

specify that every, type of Station Group Director must be called out for

any Alert declaration.

The inspector reviewed the current revisions of

both documents and determined that both had been revised to accurately

reflect this emergency plan commitment.

This item is closed.

3.

Emergency Plan Activations

The inspector reviewed licensee and NRC records associated with all four

emergency plan activations which occurred between March 21,'1986 and

February 21, 1987.

Records reviewed included:

the Station s EALs;ineer's

Licensee Event Reports (LERs) for the period in question;ilable); and

Shift Eng

logs and NARS forms associated with each event (where ava

summary records of each declaration available from the NRC Operations

Center.

All four situations were properly classified as Unusual Events.

The

States of Illinois and Wisconsin were adequately informed of.the three

events which occurred during 1986, while the NRC Operations Center was

initially informed of all four events in an adequate and timely manner.

However, Nuclear Accident Reporting System (NARS) forms associated with

the February 1987 event had apparently been misplaced onsite and were not

available for the inspector's review.

Thus, the inspector could not

verify the contents of the initial notification message or the times that

both States had been initially notified.

The licensee did not provide

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evidence during this inspection, obtained from the appropriate Illinois

and Wisconsin state agencies, as to when they had received the initial

notification messages for the February 1987 Unusual Event.

The adequacy

of the initial natifications to the States of Illinois and Wisconsin for

the February 1987 Unusual Event declaration is an Unresolved Item.

(304/87002-01)

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GSEP ACTIVATIONS'

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March 21,'1986 through February 21 1987

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' Declaration:

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• Information unavailable during this inspection.

With the exception of the-Unresolved Item, this_ portion of the licensee's

program is acceptable.

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4.

-Operational Status of the Emergency Preparedness Program (82701)

a.

Emergency Plan and Implementing Procedures

By correspondence dated May 31, 1985, the staff approved Revision 4~

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of the Zion Annex to the Generating Stations Emergency Plan (GSEP).

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In October 1986, the licensee submitted proposed Revision 6 to the

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GSEP.

By letter dated January 6; 1987, the licensee was-notified

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that Revision 6 was acce

The staff did

not accept the licensee'ptable with one exception.

s proposal to significantly reduce

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consideration of evacuation time estimates during offsite protective.

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action decisionmaking.

It was, therefore, agreed that the wording

of the GSEP would not.be changed from that found acceptable in

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Revision 5/5A regarding the use of evacuation time estimates pending

resolution of the NRC staff's concern.

On February 27, 1987, the

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licensee provided the inspectors with a copy of proposed Revision 6A

to the GSEP, which was intended to address the staff's concern and

also introduce several other changes in the GSEP. The' inspectors'

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agreed to provide comments on Revision 6A by March 17, 1987, which

was also set as the final-date for comments from the licensee's

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nuclear stations to its corporate emergency staff.

A random review of changes to the Zion Station's implementing

procedures was conducted to determine if changes had been reviewed,

approved and distributed in accordance with licensee procedures-

and NRC requirements.

Procedural changes were usually initiated

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by the GSEP Coordinator, reviewed by cognizant personnel, and

approved by the Services Superintendent.

Copies of changes to

implementing procedures were sent to appropriate individuals and

,

organizations in accordance with 10 CFR 50.54(q).

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The inspectors spot-checked the EPIPs for consistency with the GSEP

and/or with each other.

Section 6.1 of the GSEP stated that for

events classified as an Alert, Site Area Emergency, or as a General-

Emergency, the licensee would provide followup messages to State and

Llocal authorities, with message contents per the guidance in

NUREG-0654, llevision 1.

However, EPIP 100-1, " Acting Station

Director (Shift Engineer) Implementing Procedure," required that

such followup messages be transmitted for all emergency declarations,

' including the Unusual Event class.

EPIP 190-1, ." Communications Director," included guidance for the

approval and contents of periodic followup messages that was in

accordance with the GSEP.

However, the> procedure did not indicate

how these messages would be documented, as regards their contents,

their approval prior to transmittal, and the persons who received

the messages.

Activation and operation of the TSC and OSC were addressed in

EPIP 410-1 "0nsite Sup) ort Centers." Habitability criteria for

thesefaciiitiesandotleronsitelocationswerespecifiedonlyin

EPIP 180-1, " Rad / Chem Director." Thus, a statement in EPIP 410-1

that indicated that the TSC would be evacuated if radiation levels

became excessive in the Station or Environs Director's opinion was

in that " excess" radiation levels were already defined

misleading /, Chem Director's procedure.

in the Rad

EPIP 410-1 also indicated

that TSC functions would be re-established by some TSC staff from

the CR following a TSC evacuation. locations for re-establishing OSC ac

However

should the primary OSC

be evacuated.

Based on the above findings, this portion of the licensee's program

is acceptable; however,.the following items should be considered

for improvement:

EPIP 100-1 should be revised to indicate that periodic followup

messages should be provided per the commitment in the GSEP.

EPIP 190-1 should include guidance on how to document followup

message contents, approval, and the message recipients.

EPIP 410-1 should be revised to indicate that radiation

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levels warranting onsite ERF evacuation have been specified

in EPIP 180-1.

The licensee should identify in an approariate EPIP one or

more alternate locations for an OSC in tie event that the

primary OSC becomes uninhabitable.

b.

Emergency Facilities, Equipment, and Supplies

The inspector toured the Control Room (CR), onsite Emergency

Response Facilities (ERFs), and the nearsite Emergency Operations

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Facility (E0F) with the GSEP Coordinator. The inspector also

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discussed changes to.the EOF and Joint.Public Information Center

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(JPIC) with the coordinator-and.a member of the corporate emergency

< planning staff.

Work'.had begun .in the~ CR to create a large center desk workspace.

-In the interim, emergency communications equipment described in the:

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GSEP, Zion Annex to the GSEP, and the Emergency Plan Implementing

Procedures (EPIPs) had been repositioned on desks away from the

central ~ area.of the CR.

Sufficient copies of blank Nuclear Accident

Reporting, System (NARS) forms and the NRC' Duty Officer's event

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notification checklist were. in the Station Control Room Engineer'.s

-(SCRE). desk.

Controlled copies of the GSEP and EPIPs were also

available-in the Control Room.

~The TSC was located'as described in the Zion Annex to the GSEP.

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Although the workspace was configured for use as a TSC,.it has

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been utilized for some. years as a normal workspace and records

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storage area for operating shift personnel.

The Shift Engineer's

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office.in the TSC would become the NRC office upon arrival of Site

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Team personnel. Workstations for director personnel were ready

for use in the western portion of.the room near the status boards

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and dedicated emergency telephone equipment.- Commercial HPN

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telephone instruments were installed and operable in the TSC.

One

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instrument was in the SE's office and the other was at the Environs.

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Director's workstation.

Several telephones were reserved for'NRC

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use in the TSC.

Each was linked to multiple commercial lines and'

inplant extensions.

Central files personnel were responsible for

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maintaining controlled documents kept in the TSC.

Emergency

areparedness related documents included:

the GSEP; Zion Annex;

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Zion Annex (Volume V) to the IPRA; the State of Wisconsin (IPRA);-

EPIPs; generic Illinois Plan for Radiological Accidents

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Emergency

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Plan; the NRC Region'III plan; and Environmental Director

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-(ED-series) and Env_ironmental Emergency (EG-series) procedures.

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Based on observations during past emergency _ preparedness exercises,

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the TSC is a congested workspace.

Locations of some dedicated

-phones and status boards are inconvenient.

Status board design and

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layout have also been criticized. The licensee indicated that the

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TSC'slayouthadbeenonesubjectofa1986humanfactorsassessment

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performed by a contractor.

However, the GSEP Coordinator indicated

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that-few changes to the facility's layout would likely be made prior

to the 1987 exercise.

In November 1986, the licensee informed the resident inspectors that'

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the TSC's ventilation system could not be demonstrated to maintain a

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positivepressurerelativetoadjoiningareas.

Thus, in the event

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of high airborne activity and excessive leakage, the facility could

become uninhabitable. Other regional staff are monitoring the

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licensee's efforts to correct this problem.

Nevertheless, the

licensee has committed to construct a new TSC at a yet to be

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determined location within the protected area. The inspector

discussedthisprojectwiththeStationManagerandtheGSEP

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Coordinator. :The former' estimated that a decision would be made-

by mid-1987 ~asLto where the new TSC would be built,-and that -

construction could take approximately 18 months. . The inspector

reviewed an internal draft report, dated January 1987, regarding

plans for. 'a multi-story. Service Building extension project.

The-

report did~not identify a TSC as part of this construction: project.

-The. Station Manager indicated that the new TSC might not be in the.

proposed Service Building extension.

In any event, the inspector

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concluded that a comprehensive, formal appraisal-of the Zion

Station's-ERFs by the NRC should not take place until the.new TSC

has been completed.

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The Station's Operational Support Center-(OSC) was a split facility.~

OSCsupervisoryandmaintenancepersonnelwouldassembleinadjacent

offices located on the second level of the Service Building, while

radiation chemistry staff would gather-in the Rad Protection work

areas on the 617 foot elevation of the Auxiliary Building.

However,

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the licensee indicated that there were plans to test the feasibility

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- of having a consolidated OSC for all OSC personnel on the second level

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of the Service Building.

It was expected that a decision would be

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made prior to the 1987 exercise as to whether the OSC would remain

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a split:rather than a consolidated ERF.

The ins)ector noted that

OSC telephones and status boards were stored wit1in'or in the hallway

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outside the two Service Building offices that would be utilized as

OSC workspace.

The nearsite E0F was located as described in the Zion Annex to

the GSEP. The.E0F was essentially a dedicated workspace, although

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portions of the facility were infrequently used for meetings.

However, the licensee soon planned to implement Revision 6 to the

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emergency plan, which included a restructured E0F organization.

This

would necessitate some rearrangement of E0F workstations, including

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- related telephones and computer equipment. While the GSEP Coordinator

was able to show the inspector a revised E0F internal layout, actual

work on rearranging the workstations had not begun.

The licensee'also

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planned to have other refinements, such as electronic status boards,

installed and fully operational by May 1987.

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Controlled documents stored in the E0F included:

The IPRA; Zion

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- Volume V to the IPRA; the Wisconsin Emergency Plan; Zion Technical

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Specifications; Station, EOF, and Corporate Command Center EPIPs;

Systems Operations Instructions; an Offsite Dose Calculation Manual;

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and ED'and EG-series procedures.

Central files staff maintained

such controlled documents, while the GSEP Coordinator was responsible

for maintaining office supplies.

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The licensee was in the process of moving the Joint Public Information

Center (JPIC) from the second floor of the E0F building to a building

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in Highland Park, Illinois.

A cognizant member of the licensee's

corporate staff indicated that the new facility was scheduled to be

ready for use by May 1, 1987.

The inspector was told that internal

and external construction work was well underway.

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~By correspondence dated December 5, 1986, the licensee formally

requested Commission approval to change the location of its '

Backup E0F for only.the Zion Station from the present facility in.

l(CCC) yville, Illinois to the existing Corporate: Command Center-

Libert

in downtown Chicago. The States of Illinois'and Wisconsin -

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have formally agreed to this proposed change,.which has also been

supported by regional staff. As of mid-February, the Commission had..

not issued a decision on the. acceptability of changing the-Backup

E0F's; location.

-The inspectors reviewed-the inventory records and. inspected.the

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contents of the "GSEP Van" utilized by field survey teams and the-

OSC's' supply cabinet. All: inventories had been performed per-

. procedural requirements.

However, the inspectors.noted several

discrepancies in the GSEP Van's contents. A fuel' storage container

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inside the van was low on fuel and was not secured within the vehicle.

Respirators stored in the van and.in extra ." environs team" kits had

no identifications.as to.last date of inspection to better ensure

they-were still usable.

Several~small ladders were lying unsecured

on the floor. of the van.

Although the van and environs kits included

multiple survey instruments and detectors, there was only one

radiological-instrument cable in-the van and in each kit.

Finally,-

the~ current inventory record was not available inside the kits.

Based on the above findings, this portion.of the licensee's

)rogram is-acceptable; however, the following items should

)e considered for improvement:

The-licensee's corporate and Station staffs should keep

Region III emerger,1cy, preparedness staff informed on progress

being made on modifying or relocating onsite and offsite ERFs

prior to the 1987 exercise.

Station staff should also keep

Region III emergency preparedness staff informed of longer

range plans and schedules for building a new TSC.

Fuel containers and ladders stored in the GSEP Van should be

securely attached to the vehicle.

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The van and environs kits should be equipped with more than

one radiological instrument cable and a copy of the current

inventory record.

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Respirators stored in the van and environs kits should

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have their latest date(s) of inspection available at their

storage locations.

c.

Organization and Management Control

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.At the time of this inspection, the Station's GSEP Coordinator

reported to the Services Superintendent through the Regulatory

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Assurance Supervisor.

However, the coordinator expected that,-

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prior to July 1987, his reporting chain to the Services

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Superintendent would become the Rad Chem Supervisor, followed by

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_the Assistant Superintendent forLTechnical Services. During.the.

11ast 12 to 18 months,.the coordinator had also been designated as

the' Human Performance Evaluation System (HPES) Coordinator and the

Station Goals Coordinator.- However, another. individual had been.

assigned as the full-time HPES Coordinator in early 1987. The GSEP

Coordinator understood that his-goals coordinator duties would also

be reassigned sometime in the Spring 1987. 'Thus, the GSEP Coordinator

position was in the process of becoming more of a full-time duty

versus the trend over-the previous 12 to 18 months.

Although the GSEP Coordinator was a Station employee, he was

also responsible to the corporate Supervisor of Emergency Planning .

through a corporate Emergency Planning Supervisor.

Beginning in the

first quarter of 1986,-this-Emergency Planning Supervisor had assigned

a member of the corporate emergency planning staff to conduct

quarterly reviews of the GSEP Coordinator's activities. -This practice

had also been established at the licensee's other nuclear stations.

It was intended to ensure that the coordinators were performing

all required tasks and to enhance ~ the working relationships between

. corporate and Station. emergency planning staffs.

The quarterly

reviews were essentially announced 1-day visits with the Station's

GSEP Coordinator to cover a pre-arranged agenda.

These visits were

' correctly not being viewed as independent audits of the program.

Results of these visits were adequately documented, and had been

forwarded to Station management and to corporate emergency

planning supervisors.

The-inspector also reviewed the minutes of 1986 quarterly GSEP

Coordinator counterpart meetings and the schedule for the.1987

quarterly meetings.

Topics covered at such meetings included:

results of.recent NRC. inspections, Quality Assurance audits, and

.INP0 evaluations of emergency preparedness; scheduling of drills

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. involving corporate staff; current offsite emergency. planning

issues; status of development of Revision 6 to the GSEP; development

of the GSEP Surveillance Program to improve the standardization of

the coordinators' activities and emergency planning initiatives

begun at the various Stations;.

A review of Letters of Agreement was conducted by the inspector.

Agreement letters signed by local off-site agencies were on file

at the Station.

Copies of signed letters from technical support

organizations with contracts to provide emergency services to any

of the licensee's Stations were also available onsite.

All letters

were current and identified the services to be provided.

Based on the above findings, this portion of the licensee's program

is acceptable.

d.

Training

The inspectors conducted interviews with the following members

of the onsite emergency organization in order to assess their

understandings of their emergency response roles:

two Shift

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Foremen-(SF), two SCREs, one Rad Chem Director, two Maintenance /

OSC Directors, one Technical Director, three Communications

Directors, one Administrative Director, and one Stores Director.

The SF/SCRE walkthroughs were conducted with separate teams of

personnel, each team consisting of a SF and a SCRE. These

walkthroughs focused on emergency detection and classification;

protective action decisionmaking; and initial offsite notification

requirements. As persons in the line of succession to the Shift

Engineer (SE) as Acting Station Director, both the SF and.SCRE

would perform the aforementioned Acting Station Director

responsibilities-in the absence or incapacitation of the SE, or could

assist the SE in the performance of these duties.

The questioning

involved actual use of the Nuclear Accident Reporting System (NARS)

and National Warning System (NAWAS) communications equipment in

addition to having personnel complete a NARS form.

The interviewees

demonstrated an adequate familiarity and understanding of procedural

guidance in all areas of questioning.

However, both teams of

personnel, and a Rad Chem Director who was interviewed separately,

exhibited some unfamiliarity with computer equipment utilized to

obtain real-time, onsite meteorological data.-

Several persons

also exhibited uncertainty when asked to interpret the wind

direction data they had acquired.

In general, all the other interviewees were adequately aware of

their emergency duties and responsibilities.

However, when asked

how they would obtain additional communicators for the TSC, each of

the three Communications Directors indicated that he would either

request that another Communications Director be summoned or would

request an available person from the OSC staff.

The availability

of additional communicators to man dedicated communications equipment

in the TSC is further discussed in Paragraph 9 of this report.

Both OSC Directors displayed an adequate overall understanding of

their duties, despite the fact that they were provided with minimal

procedural guidance.

Although the GSEP contained an extensive list

of duties and responsibilities for the OSC Director position, the

primary procedural guidance for this director was a few statements

in the facility activation procedure (EPIP 410-1), which essentially

instructed the director to report to the OSC, manage the facility,

and maintain communications with the CR and TSC.

The inspector

concluded that the interviewees' knowledge of their emergency duties

was based more on previous training experiences than on the scant

procedural guidance available to them during a facility activation.

The inspectors noted that procedural guidance available to Technical

and Operations Directors also did not reflect all the responsibilities

contained in the GSEP, although guidance for both positions was in

position-specific EPIPs and was more complete compared to that

available to the OSC Director.

The licensee must revise a

EPIPs so that procedural guidance for the OSC, Technical, ppropriate

and

Operations Directors reflects all their duties and responsibilities,

as summarized in the GSEP.

This is an Open Item. (295/87002-01 and

304/87002-02)

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'In addition to the open item, the following item should'be

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considered for improvement:

-CR personnel and Rad Chem Directors, who may'have to acquire

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real-time,.o'nsite meteorological data during an emergency plan-

activation should receive ' additional familiarization training

-on the computer equipment used.to obtain the data and on the

~

interpretation of these data.

e.

Independent Reviews / Audits (also 82210)~

,

The annual independent review of the program was adequately done

'in 1986.. Quality Assurance-(QA) staff based at Zion performed the

"onsite" annual audit, while QA personnel based at other locations

. performed the "offsite" annual audit, which addressed emergency

.

preparedness.

The two audits satisfied the requirements of

.10 CFR 50.54(t), including addressing the adequacy of the licensee's

interface with offsite support organizations.

No deficiencies

requiring a formal response were identified in either audit.

The licensee described the mechanism-for supplying relevant audit

information during the December 1986 meeting with offsite support

agencies. The results of the audits were adequately documented

and given to'both plant and corporate management. According to

)rocedure' ZAP 6-52-2, the audit reports will be filed for one year

)y QA before being stored permanently in microform.

Besides the annual audit, station-based QA staff did a number of

surveillances of.the program since the last inspection.

.Surveillances addressed:

both July 1986 off-hours augmentation

drills; the' January 1987 off-hours augmentation drill; the-

May 1986 emergency plan activation and the November 1986

environmental monitoring drill.

Allsurveillanceswereadequately

,

documented.

Followups on deficiencies were done in a timely manner.

3

The findings were not' considered " closed" until the corrective

action had been verified as being completed.

For example, the

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QA finding on the November drill was not closed out until the

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missing markers for several offsite monitoring-locations had been

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replaced, as physically verified by QA staff.

The QA plans for 1987

included four surveillances of drills and tests; an audit of the

exercise; the annual audit; plus surveillances of GSEP activations.

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Although the audits of the program were adequate, some audit

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questions lacked the depth found in the surveillance program.

For

example, more than ten audit questions dealt with various equipment

. checks and supplies inventories.

However, the auditors typically

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addressed these checklist questions by referencing records, rather

F

than by also occasionally verifying the accuracy of a current

inventory record.

One checklist question dealt with the annual

t

issuance of emergency information brochures.

However, rather than

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referencing distribution records or spot-checking local brochure

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deliveries versus those records, the auditor's res)onse to the

checklist question essentially restated the distri)ution

requirement, with a general reference as to when the latest

distribution was to have occurred.

-The inspector discussed the corrective action program with the GSEP

Coordinator and reviewed relevant records.

The coordinator had the

majorresponsibilityfordecidingwhichitemsidentifiedduring

drill or exercise critiques would be acted upon.

He maintained

an informal tracking system for documenting what actions had been

initiated by himself, other Station staff, or by corporate staff.

However, based on a review of tracking system records associated

with 1986 drills and the exercise the inspector concluded that the

tracking, system was not always effectively utilized. While some

records indicated both the actions initiated and their completion

status, other records indicated only the actions requested of

another work group, such as the Rad Chem Department revising a

procedure.

The coordinator could not say for certain whether or

not such requested actions had been completed. While the tracking

during the 1986 exercise, y utilized for items identified by the NRC

system had been effectivel

the coordinator could not produce tracking

system records related to the " items worthy of followup" that had

been identified in the licensee's self-critique report on that

exercise.

Most of these self-critique items were, however,

analogous to those. identified in the NRCs inspection report.

The GSEP Coordinator had performed an evaluation of the 1986 emergency

)lan activation records with the aid of a non proceduralized checklist.

iis evaluation of the February 1987 Unusual Event was incomplete, as

the associated NARS forms had apparently been misplaced onsite. The

checklist had been simplified from that seen during previous

inspections.

However, it was an adequate aid for documenting the

evaluation of records associated with Unusual Event declarations.

Based on the above findings, this portion of the licensee's program

is acceptable; however, the following items should be considered

for improvement:

During annual audits of the program, more emphasis should

be placed on physically verifying the accuracy of certain

inventory records, rather than primarily relying on reviews

of the records themselves.

The completeness and currency of the GSEP Coordinator's

corrective action tracking system should be more closely

monitored by QA staff or by corporate emergency planning

staff.

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5.

Emergency Detection and Classification (82201)

a proposed revision to the Station,s Emergency Action Levels (y submitted

By correspondence dated October 23 1986, the licensee formall

EALs) and a

su) porting "PWR EAL Philosophy" document.

Regional staff viewed this

su)mittal as more than a reformatting and standardization effort on the

part of the licensee.

Instead, the staff considered the submittal as a

majorrewriteoftheEALs,whichwouldalsoaddressNRCconcernson

certain EALs which had been expressed as open or improvement items in

various emergency preparedness inspection reports since 1984.

Regional

staff responded to the submittal by letter dated January 12, 1987.

Since

that time the staff has discussed its concerns on some of the proposed

EAls with the licensee's corporate emergency planning staff.

The .

licensee's corporate and Station staffs discussed res)onses to the NRC

concerns prior to a meeting with the inspectors on Fe)ruary 27, 1987.

The licensee indicated that it would formally respond to the staff's

EAL concerns in March 1987.

Based on the above findings, this portion of the licensee's program

is acceptable.

6.

Protective Action Decisionmaking (82202)

The inspectors determined that procedural guidance on onsite and offsite

)rotective action decisionmaking was in conformance with that in

Revision 5/5A of the GSEP. As indicated in Paragraph 4 of this report,

the licensee has provided the staff with a proposed Revision 6A to the

GSEP with the intent of resolving the staff s concern regarding the use

of evacuation time estimates in the decisionmaking process.

Revision 6A

is currently under staff review.

Based on the above findings, this portion of the licensee's program

is acceptable.

7.

Notifications and Communications (82203)

All of the monthly, quarterly, and annual communications tests that were

required since the previous routine inspection have been done.

With two

exceptions discussed below, the communications equipment all tested out

adequately or, in those few cases where there was an equipment failure,

the equipment was repaired in a timely manner and suffered no recurrence.

The first exception was the NARS phone in the Kenosha County Sheriff's

office.

In May and June of 1986 and also in the three month period

ending in February 1987, the NARS phone was discovered to be inoperable

during the monthly communications tests.

Illinois ESDA, who is responsible

was notified after each failure and had the phone

for the NARS system,in three of the five cases, the NARS phone was reported

repaired.

However,

failed again when the next monthly test was performed.

Communications with

the sheriff's office were then adequately demonstrated using commercial

phones.

The second exception was an extension in the E0F.

This phone

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failed in the annual communication drill in 1986, was repaired and failed

again in mid-1986, was repaired and failed again in the 1987 annual drill.

However, repairs subsequent to the drill in February 1987 were expected

to be permanent.

The final monthly testing of the old Health Physics Network (HPN)

telephones was in August 1986.

The new commercial HPN phones became

o)erational in September 1986 and have been tested monthly ever since.

TierehavebeennoproblemswIththenewHPNphoneslocatedintheTSC

and E0F.

The ins)ectcr's review of the phone tests included the NARS phone in the

Backup EOF, located in the basement of the Lake County Sheriff's office.

The Lake County Sheriff Office also has a NARS phone.

The inspection

revealed that the NARS phone in the Backup E0F was only tested annually,

whereas other NARS phones have been tested monthly.

The reason for the

relatively infrequent testing of the Backup E0F's NARS phone was that

the Backup EOF was normally locked and no one would be present to answer

the phone.

Regarding backup communications capabilities in the event of loss of

normal power to telephone equipment, a battery-backup radio was available

in the CR for communications with the Load Dispatcher.

Some plant

telephones would remain operable during a power failure, although they

would not " ring" to announce incoming calls.

Microwave (grey) phones

onsite would still connect the Station to the Corporate Command Center

and E0F.

In addition, there were other trunk lines in the nearsite EOF.

The licensee stated that there were also sufficient walkie-talkie radios

available onsite which could be taken to the E0F to maintain communications

capabilities with persons in that facility in the event of a failure of

primary communications equipment.

The annual communications drill was held in February 1987.

This drill

was organized by the corporate emergency planning staff.

Although the

documented, formal critique was not available onsite, the licensee stated

that all equipment performed satisfactorily on the day of the test except

for the E0F base station radio, the yellow phone in the TSC, and one

extension in the E0F.

The licensee indicated that repairs had already

been completed on all three problems.

The annual communications drill

included the verbal transmission of data from a NARS form, with

instructions to mail the completed forms to corporate. When the

documented critique of the annual communications drill is issued, it

will include a review of the accuracy of the NARS forms that were

filled out by the various respondents.

Based on the above findings, this portion of the licensee's program

is acceptable; however, the following item should be considered

for improvement:

The NARS phone in the Backup E0F should be tested more frequently

than annually.

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8.

Changes to the Emergency Preparedness Program (82204)

Changes to the Station's program have been described in Paragraphs 4,

5, 6, and 9 of this report.

Based on the above findings, this portion of the licensee's program

is acceptable.

9.

ShiftStaffingandAugmentation(82205)

The numbers and ty)es of personnel required for shift staffing and

augmentation met tie criteria of Table 8-1 of NUREG-0654, Revision 1.

Figure 4.2-3 of the GSEP had the augmentation provisions for the

emergency organization.

Augmentation drills have been performed

semiannually, in accordance with EPIP 320-1, " Activation of the GSEP

Station Group".

This arocedure had a callout matrix consistent with the

referenced Figure in t1e GSEP.

This procedure was also the reference

document for the "GSEP Callout Checklist", which was an informal

single page, prioritized listing of GSEP position titles and names and

phone numbers /pager numbers that was used by Security when performing a

Station Group callout.

The callout list was doubly prioritized, first by

category (withthetechnicaldirectorsbeinghigheronthelistversus

non-technical personnel) and then by travel times to the site for persons

in each category.

The inspector reviewed records of the augmentation drills performed since

the previous routine inspection.

An inadequate augmentation drill was

performed on July 2, 1986, followed by a satisfactory remedial drill on

July 16, 1986.

The latest augmentation drill was January 28, 1987.

The

two recent augmentation drills demonstrated an adequate capability for

staff augmentation during an emergency in that the time from the beginning

of the drill to the estimated time of arrival of the necessary personnel

was 67 minutes for the drill on July 2, 1986 and 61 minutes for the drill

l

on January 28, 1987.

The July 2 augmentation drill was properly evaluated as having failed by

the two QA staff members who observed the drill.

The reason was that the

security officer used an out-of-date Callout Checklist.

This resulted in

Security getting an affirmative reply and a estimated time of arrival for

the Communications Director position from a man who was no longer

assigned to that position.

The QA auditors informed Security that an

out-of-date checklist had been used.

flowever, when the filled-out GSEP

Callout Checklist was delivered to the GSEP Coordinator, it was the

current checklist, and the Communication Director whose name was checked

off was a scheduled director, contrary to the observation of the two QA

auditors during the drill and contrary to the recollection of the

Communication Director whose name was on the current checklist as the

person who had been contacted.

The corrective action taken inclued a

remedial augmentation drill on July 16 which was successful.

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Quarterly updates to the phone numbers in EPIP 320-1, and hence to the

informal GSEP Callout Checklist, were done in a timely manner by the

GSEP Coordinator, who persoaally checked with each person on the list

to ensure that the phone numbers were current.

The present version of

EPIP 320-1 allowed for mid quarter updates to the Callout Checklist used

by Security.

The GSEP Coordinator would perform mid quarter updates as

he becomes aware of personnel changes.

However, there is no mechanism in

place to alert the Coordinator of any personnel changes which would

require a mid quarter change to the checklist.

The pool of personnel listed in the above documents who can fill the

various emergency response positions was too small to ensure that all

Station Group director positions can be filled on an around-the-clock

basis during a prolonged activation.

Each position did not have three

qualified individuals.

Only two individuals were listed for the Environs

Director and Security /0SC Director", there were only four names listed.

Director positions.

In the combined category of

" Maintenance Director

Since both positions would likely be staffed in a prolonged Station Group

activation, a pool of four persons is insufficient to ensure adequate,

long-term coverage.

The licensee must ensure that there are at least three qualified personnel

for each Station Group director position.

Also, for the consolidated

Maintenance /0SC Director position more than four individuals must be

identified,asbothpositionswouldlikelyremainactivatedsimultaneously

during a prolonged activation.

This is an Open Item.

(295/87002-02and

304/87002-03)

The callout procedure did not identify personnel who would be used as

supplemental TSC communicators under the direction of the Communications

Director, or as status board plotters / administrative aids under the

direction of the Administrative Director.

Based on discussions with the

GSEP Coordinator and observations during annual exercises, the inspectors

concluded that the licensee had definite personnel in mind to fill these

positions during exercise situations.

For example, licensed personnel

from the Training Department would be supplementary TSC communicators.

The licensee must establish procedural provisions for the callout of

trained communicators, status board plotters, and clerical support

personnel to assist the Station Group.

This is an Open Item.

295/87002-03 and 304/87002-04)

In addition to the open items, the following items should be considered

for improvement:

Future off-hours augmentation drills should continue to be monitored

by QA staff and/or the GSEP Coordinator.

An administrative mechanism should be established for informing

the GSEP Coordinator of changes to Jersonnel assignment, training

status, or contact information whic1 may warrant revision to the

Station Group's callout provisions.

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10.

Knowledge and Performance of Duties (Training) (82206)

In addition to the walkthroughs described in Paragraph 4d of this report,

the inspectors reviewed records associated with the Station's emergency

preparedness training program.

In some cases, 1986 training consisted of

classroom sessions.

However, training for the majority of persons having

key roles in the onsite emergency organization consisted of structured

reading assignments for each position followed by a proficiency

examination with a minimum passing score 70 percent.

The examinations

were made up from an approved bank of questions.

Each exam had been

proctored.

In most cases, the corrected examinations had been reviewed

with the trainee to ensure correct answers and level of expected

performance were onderstood.

However, this review was not documented

or even required by current policy.

No overall policy or guidance document was in effect to govern the GSEP

training, program.

Such a document was in the process of being developed

as a training instruction and was reviewed in draft form by the inspectors.

This instruction was planned for implementation in March or April 1987.

Most of the forms, exam cover sheets and documentation used in GSEP

training had no authorizing or identifying markings or " prepared by"

information.

This would be corrected upon issue of the policy document

with the forms and cover sheets included as enclosures to the policy.

A program review system was being used to assure program weaknesses were

being factored into the training program. This included weaknesses or

shortcomings that were identified through exercise or. exam performance.

This program review was included in the draft training instruction.

A review of training documentation showed all participants in the onsite

emergency organization were current in their continuing training.

This

review was conducted using the completed reading assignment sheets and

the completed examinations. The computerized training tracking system

was not structured to provide personnel training status or to identify

incomplete training.

The accuracy of records on the current status of

individuals' training was attributed to the conscientiousness of the

training instructor assigned to GESP training and rather than to the

computer system.

Medical emergency response training to Radiation Cheaistry Technicians

(RCTs) had been upgraded in early 1987.

The licensee's medical services

contractor had conducted six, 1-day training sessions on the handling

andcareofcontaminated, injured,plantpersonnelsothatall36RCTs

could benefit from such training as opposed to the few RCTs who would

be involved in an annual medical, drill.

Following a morning training

session dealing with the onsite aspects of handling an accident victim

the RCTs toured the local hospital facilities to which an accident victim

would be taken.

The inspector understood that, although the local

ambulance service had been invited to participate in this extra training

effort, the service's employees did not attend any of these sessions.

17

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The inspector reviewed adequately detailed records of 1986 emergency

preparedness drills and the annual exercise.

The inspector concluded

that all required drills, and an unannounced exercise, had been conducted

and critiqued during 1986. A 1987 drill schedule had been developed and

addressed all drill requirements.

An annual meeting for the Zion Station's offsite support agencies was

held in December 1986.

The agenda included a discussion of example EALs

'and a discussion on how persons could obtain information on internal

audit results relative to the interface with offsite support agencies.

Based on the above findings, this portion of the licensee's program

is acceptable; however, the following item should be considered

for improvement:

The com)uterized system utilized to record persons' training records

should )e modified to enable a user to readily identify individuals

who will shortly require some requalification training.

<

11.

Unresolved Item

Unresolved items are matters about which more information is required

in order to ascertain whether they are acceptable, violations, ion is

or

'

deviations. An unresolved item identified during this inspect

discussed in Paragraph 3.

12.

Exit Interview

On February 27, 1987, the inspectors met with those licensee

representatives identified in Paragraph 1 to present their

preliminary inspection findings.

The licensee agreed to consider

the items discussed and did not indicate that any of the information

was proprietary in nature.

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