IR 05000295/1986001

Insp Repts 50-295/86-01 & 50-304/86-01 on 860128 & 0210-11. No Violation Noted.Major Areas Inspected:Emergency Preparedness Exercise & Actions Associated W/Dec 1985 Alert Declaration.Exercise Objectives & Summary Encl

ML20214E330
Person / Time
Site:	Zion  File:ZionSolutions icon.png
Issue date:	02/28/1986
From:	Allen T, Foster J, Patterson J, Phillips M, Ploski T, Matthew Smith, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214E327	List: IR 05000295/1986001 ML20214E326
References
50-295-86-01, 50-295-86-1, 50-304-86-01, 50-304-86-1, NUDOCS 8603070330
Download: ML20214E330 (21)

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I U.S. NUCLEAR REGULATORY COMISSION

REGION III

Reports No. 50-295/86001(DRSS); 50-304/86001(DRSS)

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Docket Nos. 50-295; 50-304 Licenses No. DPR-39; DPR-48 Licensee

Commonwealth Edison Company P. O. Box 767 Chicago, IL 60690

Facility Name: Zion Nuclear Generating Station, Units 1 and 2 Inspection At: Zion Site, Zion, IL Inspection Conducted: January 28 and February 10-11, 1986 Inspectors:

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T. Ploski

Date T 1 8 Date

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k j J. Foster 2# F4 Dite ' t Z ZAfd D&te

/ fit M. Smith I) hjd/

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N. Williamsen k/#/#4 Date'

Approved By: M. illips, Chief z#/P4

.: Emergency Preparedness Date Section Inspection Summary Inspection on January 28 and February 10-11, 1986 (Reports No. 50-295/86001(ORSS); 50-304/86001(DRSS))

Areas Inspected: Routine inspection of the Zion Station's emergency preparedness exercise, involving observations by eight NRC representatives of 8603070330 860220'

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key functions and locations during the exercise. The inspection also involved a review of licensee sctions associated with a December 1985 Alert declaration at the Zion Station. The inspection involved 150 inspector-hours onsite by six NRC inspectors and two consultant Results: No violations of NRC requirements were identified during this inspection. However, several weaknesses, which will require corrective action, are identified in the text of this report and are summarized in the Appendix to the report's transmittal lette i l

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DETAILS 1. Persons Contacted NRC Observers and Areas Observed T. Ploski, Control Room, Technical Support Center (TSC), Emergency Operations Facility (EOF)

T. Allen, Control Room, TSC, EOF J. Foster, Control Room, TSC F. McManus, Control Room, TSC N. Williamsen, Operational Support Center >(OSC) and In plant Teams F. Carlson, OSC and In plant Teams M. Smith, OSC, EOF J. Patterson, Corporate Command Center (CCC)

Commonwealth Edison E. Fuerst, Production Superintendent, Zion Station T. Rieck, Services Superintendent, Zion Station T. Blackmon, Lead Controller, EOF L. Holden, Controller, Control Room R. Budoule, Controller, Control Room A. Nykiel, Controller, TSC R. Aker, Controller, TSC R. Francis, Contro.ler, OSC J. Brandes, Controller, OSC T. Markwalter, Controller, EOF T. Cromeans, Quality Assurance Department K. Hesse, Human Factors Staff, CECO K. Budzeika, Human Factors Staff, CECO The above listed licensee personnel attended the February 11, 1986 exit intervie . Licensee Action on Previously Identified Items (Closed) Open Items No. 50-295/85008-02 and 50-304/85009-02: Due to procedural inaccuracies, collection of a reactor coolant sample utilizing the High Range Sampling System (HRSS) was difficult. As indicated in Paragraph 6.c of this report, an inspector accompanied a team that collected a reactor coolant sampl The inspector determined that the team exhibited no difficulties in following sample collection instructions contained in Procedure ZCP 701-2. (This procedure was being revised during the first quarter of 1985, but was not yet available for use by the technicians involved in sample collection tasks during the March 1985 exercise, as required training on the revision had not been completed). This item is considered close (Closed) Open Items No. 50-295/85008-03 and 50-304/85009-03: Inadequate communications equipment was utilized by teams collecting post-accident reactor coolant and containment air samples, in view of their having to

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wear respiratory protection in potential airborne contamination area As indicated in Paragraph 6.c of this report, a reactor coolant sample was collected during the exercise; however, collection of a containment air sample utilizing equipment in another plant location was not demonstrate The inspector accompanying the reactor coolant sampling team concluded that adequate communications equipment was effectively utilized by the tea However, interpersonal communications equipment problems and associated corrective actions were different for persons involved in reactor coolant versus containment air sample collection task Since collection of a containment air sample was not demonstrated in the 1986 exercise, this Open Item will be closed but a new Open Item (50-295/86001-03; 50-304/86001-03)

will be created for the need of a future demonstration of the adequacy of communications equipment utilized by a containment air sample collection tea . Activation of the Generating Stations Emergency Plant (GSEP)

The inspector reviewed licensee and NRC records associated with an actual Alert declaration the Zion Station that occurred on December 14, 198 The Station Control Room Engineer (SCRE) onshift during the event and the Station's GSEP Coordinator were also interviewe Unit 2 had been shutdown for a refueling outage since early September 198 Decay heat removal was being provided by the 2B Residual Heat Removal (RHR)

system, while the 2B charging pump provided make-up flow to the Reactor Coolant System (RCS). At about 3:25 a.m., the 28 RHR pump became airboun The Unit 2 Nuclear Station Operator (NS0) observed zero flow and low amperage indications and secured the 2B RHR pump. The RCS level readout then became erratic before pegging high. The 2B charging pump was then tripped. An operator was dispatched to check the 2B RHR pump, as it was suspected that the pump or its motor had faile The 2A RHR pump was started, but was deenergized because of abnormal current and flow indications. At about 3:30 a.m., it was realized that RCS level was inadequate for RHR pump suction and that the indicated high level was an instrumentation spike. Therefore, the 2B charging pump was restarted and RCS make-up was established. An equipment operator was sent into containment to verify RCS level using a tygon standpipe. At about 3:55 a.m.,

RCS level had sufficiently increased to allow adequate RHR pump suctio The 2A RHR pump was restarted, but was again deenergized because of abnormal flow and current indications. Based on the Nuclear Accident Reporting System (NARS) entries and discussion with the SCRE onshift during this event, the inspector determined that the Shift Engineer then correctly declared an Alert for " loss of all systems capable of maintaining cold shutdown" at about 4:10 a.m., and not at 3:25 - 3:30 a.m., as was indicated in the Licensee Event Report (LER) and on some NRC record When abnormalities were first observed by Control Room personnel about 3:25 a.m., the Shift Engineer initiated several equipment investiga-tions. He concluded from the results of these equipment checks that an Alert should be declared about 4:10 a.m., due to problems with both RHR trains. The Alert was terminated at about 4:40 a.m., following the restart and normal operation of both RHR pumps.

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Following the Alert declaration, the Shift Engineer instructed the SCRE to perform all required initial offsite notifications, beginning with the NRC Operations Center. When the NRC Duty Officer requested that the licensee maintained an open line with the Operations Center, the SCRE correctly obtained the assistance of a reactor operator for this task so that other required initial notifications could be accomplishe The SCRE indicated that the NRC Operations Center was called prior to any State agenc The NRC Duty Officer logged 4:17 a.m. , as the notification tim Thus, the NRC was initially notified well within one hour of the Alert declaratio Licensee and NRC records indicated that the SCRE had difficulties when attempting to utilize the NARS telephone, per procedures, to simultaneously notify the Illinois Department of Nuclear Safety (IDNS), Illinois Emergency Services and Disaster Agency (IESDA), Wisconsin Department of Emergency Government (WDEG), and the licensee's System Power Supply Officer (SPS0).

Due to static on the dedicated NARS telephone line, the SCRE had to notify each organization separately rather than simultaneously. NRC records indicated that IESDA was initially notified of the Alert declaration by the SCRE at 4:10 a.m. , which is several minutes before the notification time logged by the NRC Duty Officer, who was called by the SCRE before any attempt to call the States via the NAR NRC records indicated that the WDEG reported an initial notification call at 4:35 a.m., or 25 minutes after the Alert declaration. The SCRE recalled that the IESDA duty officer was the only one of the four persons contacted who was able, with some difficulty, to understand the initial notification message due to the amount of static on the NARS line. The SCRE then contacted the SP50 using a different dedicated line. The IDNS and WDEG were then initially notified via separate commercial telephone calls, using telephone numbers available from appropriate emergency plan implementing pr)cedures. The SCRE made the initial notification calls in consecutive order, with possibly one verification call-back occurring during the notification calls. The inspector concluded that the initial notifications of both States had been completed in an acceptable, although not optimum, manner considering the number of individual calls that were made by one person after encountering equipment problems with the dedicated NARS line. The inspector also concluded that the SCRE was adequately aware of initial notification requirements and the alternate means available to accomplish offsite agency notifications in the event of problems with the NARS equipmen Based on a review of the NARS forms and the Shift Engineer's log for this GSEP event, the inspector concluded that the times of the various initial notification calls had not been adequately documented by the license While the NARS form listed the names of the SPSO, IESDA, and IDNS persons contacted, the times that these individuals were initially notified and later notified of the Alert termination were not documented. The initial notification and termination message NARS forms did not indicate that the WDEG had even been contacte This information was available in detail from NRC records. While the Shift Engineer's log indicated that a GSEP event had been declared per EAL 12 and that appropriate Illinois and Wisconsin organizations had been contacted, no specific event declaration or initial notification times were contained in the lo ._= _ _ _ .__

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The Station's GSEP Coordinator evaluated the licensee's response to this abnormal situation using the " Actual GSEP Events Review Checklist." The completed checklist contained no indications that the coordinator found any problems with the manner in which the notification times and persons contacted had been documented, despite the aforementioned omissions regarding the initial notification times for the Illinois agencies and the SPSO, ar.d the fact that the initial nstification NARS form did not indicate who had been contacted at the WDEG and at what tim The GSEP Coordinator informed the inspector that he had also subsequently met with the Shift Engineer regarding a problem involving prompt notification of Station Group personnel following the Alert declaratio Action had also been taken to check the NARS telephone equipment and to make any necessary repair However, none of these corrective actions taken by the coordinator were documented on the review checklis Based on the above findings, the following items should be considered for improvement:

• The licensee should adequately document all Federal, State, and local organizations notified following any emergency plan activation. Such documentation should include the persons contacted and the time (s)

they were contacte * To ensure that maximum benefit is derived from the " Actual GSEP Events Review Checklist," someone having emergency preparedness expertise other than the GSEP Coordinator should function as technical reviewer of completed checklist * Corrective actions taken as a result of an internal review of the Station's response to an emergency plan activatiun should be adequately documente . General An unannounced exercise of the licensee's GSEP was conducted at the Zion Station on February 10-11, 1986. The exercise involved the utility, with only minimal communications participation by State and local authoritie Only several exercise controllers and NRC personnel were cognizant of the actual exercise date prior to that dat There were no indications that exercise participants had prior knowledge of the exercise date. The exercise tested the licensee's capability to respond to a hypothetical accident scenario. Attachment 1 describes the exercise objectives and scope of licensee participatio Attachment 2 is a narrative summary of the exercise scenari . General Observations Procedures This exercise was conducted in accordance with 10 CFR 50, Appendix E requirements using the GSEP, Zion Annex to the GSEP, and the Station and corporate organizations'. emergency plan implementing procedure .

. Licensee Response The licensee's overall response was generally coordinated, orderly, and timely. Had these events been real, actions taken by the licensee would have been sufficient to allow State and local authorities to take appropriate acticns to protect public health and safet Observers Licensee observers and eight NRC observers monitored and critiqued the exercise, Exercise Critiques The licensee held a critique following the exercise on February 10, 198 The NRC critique was conducted on February 11, 198 . Specific Observations

, Control Room

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Per scenario instructions, the on-duty Shift Engineer (SE) requested i

that the shift in training report to the Control Room to become the

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onshift crew for purposes of the exercise. To avoid disrupting normal Control Room activities, exercise participants, controllers, and observers generally remained in the immediate vicinity of the center desk, which quickly became a very congested area. The typical presence at the center desk of one or more operators not involved in the exercise also contributed to the overcrowding at this locatio In addition, exercise participants tended to speak to each other in very subdued voices, to the extent that one controller finally requested that the SE brief all present on what he and his staff had j thus far accomplished. An Operating Engineer, who had been in the room for five or ten minutes as an exercise participant, then remarked that such a briefing would be welcome. The SE then gave the requested briefin Approximately fifteen minutes later, the SE promptly and correctly l classified an Alert for loss of plant systems needed to maintain cold shutdow '

Initial notifications to appropriate Illinois and Wisconsin agencies were then completed in accordance with procedures.. An incorrect entry was made on the Nuclear Accident Reporting System (NARS) form used to document initial notification messages to State agencie The entry indicated that there was a potential-for a :

radioactive release, although no such potential existed based on known plant condition One exercise objective was that Control Room personnel would

demonstrate the capability to notify the NRC Operations Center within ,

one hour of the initial emergency classificatio Exercise ground .

rules stated that notifications to the Operations Center would i

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actually be made, rather than being simulated by having a controller serve as the NRC Duty Officer. However, neither Control Room personnel nor Technical Support Center (TSC) personnel contacted the Operations Center within an hour of the Alert declaratio As later verified by a controller and an NRC observer, the Operations Center was not contacted by exercise participants until several hours later, which was shortly after a Site Area Emergency had been declared by the Corporate Command Center (CCC) Directo Participants in the Emergency Operation: Facility (EOF) later recognized that Station personnel had failed to notify the NRC of the Alert declaratio The failure to demonstrate the exercise objective of notifying the NRC Operations Center within one hour of the initial emergency classification is an Exercise Weakness. (50-295/86001-01 and 50-304/86001-01)

Prior to the TSC becoming fully operational, records generated in the Control Room were marginally acceptable to permit later reconstruction of significant scenario events and major decisions made by S In addition to the Exercise Weakness, the following items should be considered for improvenant:

• Exercise participants should be better segregated from onshift personnel to minimize disrupting normal Control Room ac'.ivities; however, participants must retain easy access to needed procedures, drawings, and communications equipmen * Controllers should not prompt participants into taking actions which they might not otherwise have take * An objective for a future Zion Station exercise should be the demonstration of the capability of Control Room personnel to maintain adequate records of scenario events and their responses to these event Technical Support Center The Station Director (SD) designee reported to the TSC after having been adequately briefed in the Control Room by the SE. He initiated extra efforts to locate Station personnel to fill several vacant TSC director positions, as some qualified personnel were found to be exercise controllers while others were involved in a Station goals meeting at the nearsite Emergency Operations Facility (EOF). The TSC was declared fully operational at the time that a Rad / Chem Director had just entered the facility, which was about 35 minutes after the Alert declaration. An Environs Director, who was the final director needed to complete the minimum TSC staffing requirement described in the emergency plan, arrived within 10 minutes after the facility had been declared operational; however, the brief lack of an Environs Director was not significant for this accident scenari __

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Good periodic brielings were conducted by the SD during the exercis Use of message forms and logkeeping by individual directors was adequate. Although T:C and EOF organization charts were completed in the TSC, an available CCC organization chart was not filled in, despite the fact that persons in that facility had lead responsibili-ties for emergency response activities for several hour Status boards were not used to maximum benefit for trending plant parameters or for displaying other types of scenario information by categor Instead, a chronology of scenario events was maintained on a flip chart, and completed sheets of information were taped to the TSC's walls. However, for this exercise scenario, the inspectors did not conclude that key TSC staff were insufficiently aware of changing plant conditions, progress being made on important repair tasks, and key decisions made by personnel in other Emergency Response Facilities (ERFs).

Although the SD did not realize that the NRC Operations Center had not been notified by Control Room personnel following the Alert declaration, he was well aware of the emergency plan's commitment to provide hourly followup messages to State agencies. There was some confusion, however, regarding how the TSC's Communications Director should document such messages. While that director's implementing procedure adequately addressed followup message frequency and content, it did not include a form to facilitate message composition and docunentation. The followup message information was eventually written on a NARS Form, a form that had been developed and utilized to standardize the format and documentation of only initial notification messages to State and local authoritie NRC observers in the E0F later noted that its Advisory Support Director (ASD) utilized a readily available folloWJp message checklist to simplify his followup message preparation, approval, and documentation task Various TSC directors exhibited good understandings of their emergency responsibilitie Shortly after arriving in the TSC, the Administrative Director began making arrangements for clerical support that could later be needed in the EOF. The Rad / Chem Director ensured that TSC staff had proper dosimetry and arranged for periodic habitability surveys of onsite ERFs. This director also ensured that personnel were selected for two environs teams, and that these teams then checked their kits and vehicles and remained on standby until their deployment was necessar One exercise objective was the demonstration of the TSC directors'

abilities to deal with several simulated problems, such as illness and contamination, reported by persons within the Station's main assembly are Entries in the Rad / Chem and Security Directors' logs indicated that both correctly understood the problems in the assembly are and that appropriate corrective actions were initiated, including the sending of Radiation Chemistry Technicians (RCTs) from the OSC to the assembly

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are However, it was not apparent that exercise participants in the CCC and EOF were informed of these simulated problems and corrective actions taken, although the potential existed for the media to later learn of these problem Based on the above findings, tnis portion of the licensee's program was adequate; however, the following items should be considered for improvement:

• When possible, key personnel arriving in an emergency response facility should be briefed on the emergency situation before they are expected to be fully prepared to perform their emergency du',ie * Key personnel in ar, eeergency response facility should remain aware of the identities of their counterparts in other facilitie * Appropriate TSC directars should be provided with additional procedural guidance regarding the manner in which periodic followup messages te State agencies are to be documente * The Station Director should ensure that his counterparts in offsite emergency respon:;c facilities are adequately informed of all onsite activities which have potential media interes c. Operational Support Center and In-plant Teams The licensee's OCC consisted of the Radiation Protection office and two rooms in the Service Building. One room served as an assembly area for maintenance technicians awaiting assignment, while a small conference room was a communications center for OSC supervisory personnel. In previous exercises, a lunchroom had served as the technicians' assembly area. However, due to ongoing remodeling activities, the Station Manager's office was used as the technicians'

assembly area during this exercise. At the exit interview, the licensee indicated that a new lunchroom being constructed on another floor could become the technicians' assembly area upon completio The licensee committed to keep Regional staff informed of the interim and final locations of all segments of the Service Building OS Activation of the Service Building OSC occurred promptly after the Alert declaratio A controller assisted OSC supervisors in locating the facility's telephones and in determining how to tell which telephone was ringing. Beginning about one hour after OSC activation, technicians in the Station Manager's office were given occasional briefings on scenario events, which included the fact that an Alert had been declared much earlie Although a status board was effectively utilized in the supervisors' room to record scenario events and OSC habitability survey results, a status board was not available in the technicians' assembly area to keep transcient

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personnel better informed of such information in between the ,

occasional briefings. OSC supervisory personnel adequately briefed teams on assigned tasks, and utilized appropriate plant systems drawings in several problem solving discussions. A reasonable decision was made that a frisker station was not needed at the Service

! Building OSC for this accident scenario. Supervisory personnel also

! demonstrated the capability to plan for shift relief for maintenance l personne The Radiation Protection office was promptly organized for emergency response activities following the Alert declaratio Periodic habitability surveys of onsite Emergency Response Facilities (ERFs)

i were initiated soon after these facilities were activated. Status

boards and plant layout drawings were not effectively utilized during this exercise. Few status board entries were made. The Alert emergency classification remained posted until several hours after the Site Area Emergency declaration. Plant layout drawings were not utilized to display radiation level data until late in the exercise and, even then, were not kept curren Assembled Radiation Chemistry Technicians (RCTs) were not periodically briefed on scenario event However, in plant maintenance and survey teams were adequately briefed on radiation hazards they might encounter while doing assigned task All in plant teams that were observed were accompanied by an RCT with proper, currently calibrated radiation detection equipmen A team dispatched to collect a reactor coolant sample utilized adequate communications equipment while performing this tas The j team had no difficulty in following the revised sample collection a procedure which differed from the one used during the 1985 exercis '

However, the inspector noted that the reactor coolant sample collection panels had many apparently unofficial label changes, such as crossed-out valve position markers and changes indicated by marking

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Although the bulk of the radiation chemistry staff exhibited a positive attitude toward the exercise, the inspectors noted that an individual tasked with calling in additional RCTs for the exercise had difficulty in getting several personnel to agree to report for dut Several personnel simply refused to report onsite for various reason However, actual augmentation of onsite RCTs was not an exercise objectiv Based on the above findings, this portion of the licensee's program was adequate; however, the following items should be considered for improvement:

• Exercise conu Plers should not assist participants in setting up equipment in an ERF or in advising how to utilize this equipmen Such familiarization training should be addressed in annual training sessions or drills.

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• Status boards, supplemented by occasional briefings, should be utilized to keep all OSC personnel adequately informed of major scenario events and decision * Plant layout drawings should M utilized to keep personnel adequately informed of the laic t available onsite radiation level dat * The reactor coolant sample collection panels should not have (apparently) unofficial changes, as crossed-out valve position markers or hand written instruction * Exercise controllers should inform players attempting to augment onsite personnel whether such augmentation is actually to be accomplished or only planne d. Corporate Command Center The CCC was quickly activated after the Alert declaratio Its director soon determined which personnel qualified for various E0F and CCC positions were unavailable due to their serving as exercise controllers or, conversely, were more readily available than normal due to their already being at the near site EOF for a Zion Station goals meeting. Within about 30 minutes of CCC activation, the CCC Director had decided which available emergency response personnel would assume responsibilities in the CCC and which would go to the E0F if future scenario events warranted that facility's activatio The CCC Director declared the first Site Area Emergency after it became apparent that subcooling margin would be lost on Unit 2 due to total loss of the Residual Heat Removal (RHR) system. Later, he declared another Site Area Emergency following a brief release from a Unit 1 gas decay tank. Both declarations were correct and timel Due to the plant conditions associated with each declaration, a correct decision was made not to upgrade to a General Emergency just because two Site Area Emergencies had been classified. After some brief confusion regarding the cause and likely duration of the simulated release, an appropriate protective action recommendation was made to offsite authorities. All initial notifications to State agencies and to the NRC were promptly completed after both declaration TSC and EOF staffs were also informed of these declarations by CCC staf CCC staff generally exhibited good understanding of their emergency duties. Adequate individual logs were kep The director effectively managed the facility during the exercis Environs staff kept aware of scenario meteorological conditions and the activities of the Station's environs teams. They quickly realized that the release was unrelated to the earlier loss of RHR to the shutdown unit. The Manpower Logistics Director planned for a staggered shift change in the CCC. News information staff kept the EOF staff informed of all

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press releases approved in the CCC. Key plant parameters were monitored on computerized displays not visible to most CCC personne Status board usage did not improve until several hours after CCC activation, and then only after some prodding and detailed instruction by the CCC Director. Prior to the CCC Director's intervention, many key parameters being tracked on computerized displays were not plotted on status boards visible in the main CCC workspace, and posted emergency classification and declaration time information were not always accurat Based on the above findings, this portion of the licensee's program is adequate; however, the following item should be considered for improvement:

• A member of the CCC Director's staff should ensure that status boards contain current and accurate informatio e. Emergency Operations Facility

i Activation of the EOF was ordered by the CCC Director at 4:05 p.m..

The EOF was declared fully operational by the Recovery Manager at

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05 p.m.. The excessive time taken to declare the EOF in command and control of emergency response activities is an Exercise Weaknes (50-295/86001-02 and 50-304/86001-02)

After E0F activation was ordered, General Office staff already at the facility for a goals meeting decided which EOF organization positions would be filled on an interim or more permanent basis, pending the arrival of additional corporate personne In recognition of the possibility that, had scenario events been real, local media could come to the EOF despite the fact that the CCC was in overall command of emergency response activities, an interim

Emergency News Center Coordinator was appointed. This individual had his CCC counterparts transmit copies of all press releases and/or media briefing information to the E0F for his and the future

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Recovery Manager's (RM) review. Meanwhile, another individual maintained facility access control until properly relieved of this responsibilit During the E0F's activation process, the future RM and his staff performed well in monitoring scenario events and the responses of TSC and CCC staffs to these events. Counterpart communications and logkeeping were initiated by key personnel after their initial briefings in the EO About one hour after EOF activation had been ordered, the CCC Director and future RM made a correct decision not to transfer command and control of emergency response activities to the EOF because the minimum EOF staff, as defined in the emergency plan, had not yet arrived in the EOF. The most important missing member of this minimum staff was the Environmental Emergency Coordinator (EEC),

who arrived in the EOF about 5:15 p.m.. This individual began to be

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briefed on scenario events including recent significant changes due to the gas decay tank rupture and associated releas He also established communications with his counterparts in the CCC and TSC and began working on offsite dose projections. By about 4:45 p.m.,

however, the EEC indicated that he was still not ready to assume all his emergency duties due to lack of environs staff in the E0 (His E0F staff then consisted only of a Zion Station Environs Director.) The future RM had already determined that additional environs staff personnel were enroute from the Byron Station and it was clear that all Zion Station environs staff were already committed to the exercise as controllers or as TSC staff member After about 5:45 p.m., therefore, the RM failed to recognize the fact that the minimum EOF staffing requirement had been met, including an allowance for reasonable time for adequate briefing of the EE He also did not realize that the EEC then needed only to draw on the expertise of available environs personnel in the CCC and TSC, rather than delay facility activation indefinitely, pending the arrival of environs staff from another station. The EEC ultimately reversed his position regarding his staffing needs in the EOF and informed the RM that he could assume his duties as long as the CCC's environs group would not be disbanded. An orderly transfer of command and control from the CCC Director to the RM then occurred at 6:05 p. The long awaited environs staff personnel from Byron arrived in the E0F five to ten minutes later. In summary, the EOF should have been declared fully operational at about 5:45 p.m.. By that time the EEC had been briefed on scenario events; had established communications with his CCC and TSC counterparts, who had already been addressing various environs concerns for some time; and had already begun generating offsite dose projections with the assistance of one qualified individua After the EOF was declared fully operational, the RM continued to adequately brief his staff on scenario events and to solicit their inputs. His staff researched whether all previous initial notifica-tions to the States and NRC had been accomplished and correctly concluded that the NRC had not been notified of the Alert declaratio The Advisory Support Director (ASD) completed one followup message to the States of Illinois and Wisconsin per the emergency plan commitment. Message documentation was facilitated through the use of a checklist. The completed checklist was approved by the RM prior to message transmittal. However, the ASD did not document the persons who received the followup message nor the times that they were contacte Until late in the exercise, dose assessment personnel in the TSC, EOF, and CCC incorrectly utilized a default release duration value of six hours for the release from the gas decay tank. The release lasted approximately 10-15 minutes. There was good concern in the EOF regarding whether or not the release path had been isolated, before the RM was willing to issue a NARS message indicating that the

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release had been terminated. The inspectors conclud'ed that better communications between environs and plant systems assessment staffs in the TSC, EOF, and CCC could have occurred to more quickly obtain a more realistic estimate of release duration, and more certainty regarding the potential for an increased release rat During Recovery mode cperations, dose assessment staffs generated reasonable estimates of total offsite doses using a more realistic value of release duration. The initiation of the Recovery mode of operations and specific Recovery mode tasks were dictated by the issuance of a scenario messag In addition to the Exercise Weakness, the following items should be considered for improvement:

• Persons tasked with communicating periodic followup messages to offsite authorities should ensure that the persons contacted and the times of these contacts are adequately documente * Dose assessment staffs and staffs knowledgeable in plant systems should more closely interface on matters related to release duration estimation and potentials for changes in radioactive release rate * In a future exercise, participants should be given more freeplay to demonstrate the capability to identify what is needed in order to declare a Recovery mode of operations, and more freedon to initiate Recovery mode task . Exit Interview The inspectors met with those licensee representatives identified in Paragraph 1 at the conclusion of the inspection to discuss their preliminary findings. The licensee committed to keep Regional staff informed of the interim and final location of the Service Building OS The licensee indicated that none of the information discussed was proprietary in natur Attachments: Exercise Objectives and Scope of Participation Exercise Narrative Summary

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ZION STATION EXERCISE

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1906 OBJECTIVES

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PRIMARY OBJECTIVE:

Demonstrate the capability to implement the Commonwealth Edison Generating Emergency Plan (GSEP) for Radiological Accidents to protect the public in the event of a major accident at the Zion Statio Demonstrate this capability to qualify for an unannounced Exercise in accordance with NRC

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guidanc SUPPORTING OBJECTIVES: .

1) Incident Assessment and classification Demonstrate the capability to assess the accident conditions, to determine which Emergency Action Level (EAL) has been reached, and to classify the accident level correctly in accordance with GSEP, 2) Notification and Communication Demonstrate the capability to notify the principal offsite organizations within 15 minutes of declaring an accident classificatio Demonstrate the capability to notify the NRC within one hour of the initial inciden Demonstrate the capability to contact organizations that would normally assist in an emergency, but are not participating in this Exercise ( INPO, Murray & Trettel, Westinghouse, etc.)

3) Radiological Assessment Demonstrate the capability to calculate offsite l dose projection Demonstrate the capability of Environmental Field Teams to conduct field radiation surveys and collect air, liquid, vegetation and soil samples when neede Demonstrate the capability to conduct in plant radiation protection activitie Demonstrate the capability to collect and simulate analysis of air or liquid samples onsit A/l

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EION STATION EXERCISE 1986 OBJECTIVES Demonstrate the ability to perform calculations with radiological survey information, trend this information, and make appropriate recommendations concerning protective actions, Demonstrate the ability to make appropriate recommendations concerning the issuance of rotassium Iodid '

4)* Emergency Facilities Demonstrate the capability to activate the emergency . organization and staff the nuclear station Emergency response Facilities in accordance with procedures for an unannounced Exercis Demonstrate through discussion and staff planning, the ability to perform a shift change in the EOF and CC ) Emergency Direction and Control Demonstrate the ability of the Directors to manage the emergency organizations in the implementation of the GSE Demonstrate, through discussion, the response to a hostile group of contractors in an assembly are ) Recovery and Re-entry Demonstrate the capability of the emergency response personnel to identify requirements, programs, and policies governing damage assessments and implementing procedures for recovery and re-entr A/ final /wja

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SCOPE OF PARTICIPATION Commonwealth Edison will participate in the Zion Station Exercise by activating the on-site emergency response organization, CCC, TSC and the EOF as appropriate, subject to limitations that may become necessary to provide for safe efficient operation of the Station and other CECO nuclear generating stations, the on-site emergency response organizations, CCC, TSC and EO Activation of the TSC and other on-site participants will be conducted on a real time basi The shift on duty will receive the initial scenario information and respond accordingl .

The Nuclear Duty Person, and the balance of the Recovery l Group, will be notified and respond on a real time basis to Zion Statio The Zion Station, February, 1986, Exercise is an unannounced event to test the integrated capability of Commonwealth Edison preparedness plans, and to assure adequate resources to verify CECO's capability to respond to a simulated emergenc SITE ASSEMBLY WILL BE SIMULATE Commonwealth Edison will demonstrate the capability to make contact with contractors, whose assistance would be required by )

l j the simulated accident situation, but will not actually incur j l

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the expense of using contractor services to simulate emergency I response except as prearranged specifically for the Exercise.

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Commonwealth Edison will, arrange to provide actual transportation and communication support in accordance with existing agreements to the extent specifically prearranged for the Exercis Commonwealth Edison will provide unforeseen actual assistance only to the extent the resources are available and do not hinder normal operation of the Compan A/1/wja

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tion Nuclear Station GSEP Exercise No. 24 February, 1986 EION UNANNOUNCED GSEP EXERCISE February 1986 NARRATIVE SUMMARY zion Unit I has been operating at full power (99.5%) at steady state for forty-two (42) consecutive day RCS activity levels have been elevated and have been increasing slowly during the last sixty three (63) cay Activity is presently 0.88 uCi/gm dose equivalent I-13 The Failed Fuel Monitor (IRT-P htl8 ) and the Letdown Failed Fuel Monitor (IRT-PR27) activity levels are elevated. The VCT is being

" burped" to the Waste Gas Sy s tem apprcximately every f or ty- eig h t (48) hours to reduce area cose rate Zion Unit II is in Cold Shutdown, (Mode 5). Reactor head is secure The Unit has been ott line for nineteen (19) days for a refueling outag The RCS is scheduled to be drained down to the nozzle midplane elevation (584'6") to repair an overlookea pluggable tube on 2A Steam Generato RCS level is initially at the (589' 4 ")

elevatio SERVICE REPORT Unit I Reactor Containment Fan Cooler IC, is Out Of Service (OOS)

to investigate source of.high vibratio Monthly Performance Test is to be cone on present shift for the Auxiliary Feeowater Pump Unit II Safety Injection Pump 2A, is Out Of Service (OOS) to repair Discharge Check Valve (2SI-8922A). Safety Injection Pump 2B is Out Of Service to replace impelle Charging Pump 2A is operatin Charging Pump 2B ic Out Of Service to replace the miniflow line check valve (2VC8542A).

Charging Pump 2C is Out Of Service to replace internal pump seal B Diesel Generator is Out Of Service for refueling overhau Residual Heat Removal Pump 2B is operatin Residual Heat Removal Pump 2A is operabl RWST to charging pump suction valves 2MOV-VCll2 D, E are OOS to repair limitorque operators. They are in the closed positio A/wjm

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Zion Nuclear Station GSEP Exercise No. 24 February, 1986 PRECURSOR EVENTS T= 0 (1230)

Message given to Operations shift indicating commencement of the Exercise and requesting the Shift in training to report to the Control Room to act as Exercise Shif PRIOR TO T = +15 (1245)

Initial plant status information presented to Exercise Shif '

T = +30 (1300)

Equipment Attendant (EA) is reporting difficulty in opening the residual Beat Removal System to Refueling Water Storage Tank valve (2818735). Approximately fifteen (15) minutes later, the valve (2SI8735) is throttled open and the EA is at the valve with radio communication established to the Control Roo T = +50 (1320)

Pumping down of reactor cavity is initiate During this operation, Residual Heat Removal Pump 2B begins to cavitat EA located at valve, reports water leaking from piping upstream of valv ALERT - EAL 612 T= +65 - 90 (1335-1400)

Loss of all systems for maintaining Cold Shutdow A Residual Heat Pump is aligned to be started to cool reactor cavity, bus fault occurs on Bus 249. All loads are shed off Bus 24 Loss oi 2A Residual Heat Removal Pump result SITE EME RG ENCY -

EAL $15 T = +255 (1645)

Loss of 350F subcoolin Subcooling limit exceeded due to loss of hesidual Heat Removal capabilit (Ch a r g ing Pumps, RHR Pumre and SI Pumps are not available.)

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Zion Nuclear Station GSEP Exe rc is e . No . 24 February, 1986 SITE EMERGENCY - EAL #24  ;

T = +270 (1700)

Rupture of Gas Decay Tan Control Room Operator receives High Radiation Alarm on both the low and high range Gas Decay Tank Monitors (ORT-PR10A/B). Auxiliary Building Stack Monitor (ORE-14)

and Auxiliary Building SPING Radiation Monitor (lRIAPR49) High Radiation Alarms received in Control Roo Radwaste EA receives High Pressure alarm on LA Gas Decay Tan Cont rol mode for this

, tank is placed in the "0FF" positio EA observes dec rea s ing pressure in the 1A Gas Decay Tank due to Sa fety Relief Valve (0W G9 3 00D ) failed in the open po s it io T= +280 (1710)

1A Gas Decay Tank ind i ca t e s O psi Disruption occurs in an Assembly Area due to three (3) contract personnel a t t empt in g to leave the are .

RECOVERY After T = 410 (1920)

2 A Sa fe ty Injecti'on Pump is available for Reactor coolin B Residual Heat Removal Pump is available for Reactor coolin i

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