IR 05000454/1988018

Insp Repts 50-454/88-18 & 50-455/88-16 on 880919-22.No Violations Noted.Major Areas Inspected:Action on Previously Identified Items,Emergency Plan Activations & Status of Emergency Preparedness Program.Two Open Items Identified

ML20155E592
Person / Time
Site:	Byron
Issue date:	10/03/1988
From:	Ploski T, Matthew Smith, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20155E583	List: IR 05000454/1988018 ML20155E579
References
50-454-88-18, 50-455-88-16, NUDOCS 8810120350
Download: ML20155E592 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

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Reports No. 50-454/88018(ORSS); 50-455/88016(0RSS)

Docket Nos. 50-454; '0-455 Licenses No. NPF-37; NPF-65 Licensee: Commonwealth Edison Company Post Office Box 767

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Chicago, IL 60690 Facility Name: Byron Nuclear Generating Station, Units 1 and 2  !

i Inspection At: Byron Site, Byron, Illinois [

i InspectionConductep: Aptember 19-22, 1988

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Inspectors:

7~/M4v " R d f_

l M. Smith -

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T. Ploski #/5MhP' !

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I Approved By: William Snell, Chief /&d P I r/ Emergency Preparedness

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Inspection Summary Inspection on September 19-22, 1988 (Reports No. 50-454/88018(DRSS); *

1 50-455.'88016(ORSS)) i

Areas Inspected: Routina, unannounced inspection of the following areas  ;

j of the Byron Station emergency preparedness program: action on previously '

identified items (IP92701); emergency plan activations; (IP 91700), and  !

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the operational status of the emergency preparedness program (IP82701).

Section 5 of this report provides an updsted summary of the THI Safety

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Issues Management System (SIMS) Items related to Emergency Preparednes l The inspection involved two NRC insp,:.: tor L Results: Two open items were identified during this inspection. One item

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i ada7eTied proceduralizing a required position in the Technical Support Center;  ;

I and the other item involved the development of training procedures to ensure r

the training program for onsite personnel is conducted and coordinated c5 l required. Plant management commitments during the exit meeting to promptly ,

j respond to these identified concerns clearly demonstrated the high level of k

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program support at Byron Station. The Emergency Preparedness Program remains l strong and the licensee's capability to respond to an onsite emergency remdins i j adequate. No violations of NRC requirements, deficiencies, or deviations were  !

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) identified as a tesult of this inspection.

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DETAILS J ,

Persor.s Contacted R. Pleniewicz, Station Manager

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• R. Ward, Services Superintendent

• J. Golden, Supervisor, Emergency Planning D. Winchester, Quality Assurance Supervisor

• M. Snow', Regulatory Assurance Supervisor

• A. Chernick, Training Supervisor

• M. E. DiPonzio, TSEP Supervisor R. Lucas, Security Administrator

• Whitemore, GSEP Coordinator

• acki, Training Instructor

• ttle, Regulatory Assurance Staff

• r irnat, Regulatory Assurance Staff ,

• S. Kraus, Quality Assurance Auditor

• J. Dean, Nuclear Safety, Onsite

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T. Gierich, Shift Engineer L. Wehner, Regulatory Assurance Engineer

, Licenseo Actions on Previously Identified Items (92701)

(Closed) Open Items 454-87031-01; 455-87029-01: A violation was issued for failure to adequately follow and implement the GSEP by classifying and declaring an emergency condition per EAls. EAL 16 had been revised as the licensee committed to in their response letter dated Decem'o er 15, 1987. This item is close (Closed) Open items 454-87031-02; 455-87029-02: Staff designated as OSC Supervisors had not received training as required in procedure Records reviewed during this inspection indicated annual training was being

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administered through the use of reading packages for 1988, and had been conducted in October 1987. The persons designated to this emergency position had been placed on the GSEP Coordinator's tracking system to

[ receive annual requalification training. This item is close . Emergency Plan Activations Licensee and NRC records of actual emergency plan activations were !

examined for the period beginning July 1,1987. Records included:

J Control Room logs; Deviation Reports; message forms documenting verbal communications with State and NRC Outy Officers; evaluations of licensee

. records performed by the GSEP Coordinator; records generated by NRC Duty j Officers; Licensee Event Reports (LERs); and records generated by Technical Support Center (TSC) staff during an October 1987 TSC activatio , ,

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The licensee correctly classified eight Unusual Events during the perio Records indicated that State, County, and NRC officials had been notified within regulatory time limits following each declaratio Based on a review of LERs, there were no other incidents through August 1988, that warranted an activation of the Emergency Plan. Records generated by plant personnel were well detaile The licensee has continued a long-standing practice of proceduralizing a modified version of the NRC's Event Notification Workshee Personnel are reqJired to Complete this worksheet prior to contacting the NRC Duty Officer to ensure that the NRC will be adequately informed of :bnormal plant condition Comparison of forms completed by licensee staff and NRC Duty Officers indicated that the licensee's proceduralized methodology has been effective in transmitting accurate information to the NR The GSEP Coordinator's compilation and evaluation of licensee records associated with plan activations are thorough and coin tet Based on the above findings, this portion of the licensee's program was acceptabl . Operational Status of the_ Emergency Preparedness Program (82701) Emergency Plan and Implementing Procedures The licensee's plan and procedures related to onsite and offsite protective action decisionmaking were adequate. Any changes since the last inspection were adequately reviewed by licensee management and did not impact negatively on the overall state of onsite and offsite emergency preparedness. Changes to the plan were appropriately reflected in emergency plan implementing procedures with one exceptio Revision 6 of the Generating Stations Emergency Plan (GSEP) defines the position of "Station Director's Communicator" as a member of the onsite emergency organization. In addition to performing comt.v.icator tasks, responsibilities assigned to this position by the GSEP included assisting the Station Director in evaluating offsite Protective Action Recommendations (PARS) and Emergency Action Levels (EAls). However, the position of Station Director's Communicator had not been proceduralized in the Station's Emergency Plan Implementing Procedures (EPIPs).

Based on discussions with the GSEP Coordinator and the Training Instructor, none of the individuals listed in the emergency organization's callout procedure as "TSC Communicators" had been trained to assist the Station Director in evaluating PARS and EALs for relevancy to abnormal plant conditions. Training of preselected individuals on EAL and PAR procedural guidance will better ensure adequate response to State official and NRC requests for further information regarding recommendations to protect public health and safet i

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. Proceduralization of the "Station Director's Communicator" position, as defined in the GSEP, and training of an adequate number of personnel to fill this position will be tracked as Open Item No. 454/88018-0 Implementing Procedure BZP 400-2, "Role and Staffing of the OSC,"

indicated that emergency workers within the OSC would be evacuated to another location if dose rates approach 100 millirem per hour in or around the OS However, adequately detailed guidance on radiation levels which would require evacuation of non-essential personnel from onsite assembly areas was not addressed in emergency plan implementing procedures. Such personnel may have to be kept onsite for an indefinite period after accountability if greater hazards exist within the Owner Controlled Are Generic EAls for PWRs are developed; however the finalized version had not been approved or distributed at the time of this inspectio This project was in the development stage during the last routine inspection for Byron conducted in 1987.

i In addition to the Open Item, the following item should be considered for improvement:

• The licensee should provide procedural guidance for determining whether onsite assembly areas for non-essential personnel are habitable from a radiological standpoin b. Emergency Facilities, Equipment, Instrumentation and Supplies

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The Emergency Response Facilities (ERFs) were as described in the Byron Annex to the GSEP and relevant EPIP.s. Several equipment improvements were evident during a tour of the TSC. Safety Parameter Display System (SPDS) terminals were hung from the ceiling rather than being atop tables or cart Control Room

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alarm printers had been installed and were operable for each unit. fwo color graphic printers had been provided for the parameter trending system so that computerized trends of selected plant parameters could be generated in hardcopy, or in transparency form for use with an overhead projector. These improvements would make trended data more readily available to technical staff. A random sample of TSC telephones and computer terminals were checked and found to be operable. The Emergency Operations Facility (E0F),

located in Dixon, Illinois, was not toured during this inspectio Records of twelve proceduralized checklists, dating from either late 1987 or January 1988 through the third quarter of 1988, indicated that the GSEP Coordinator and an assistant had completed all periodic communication equipment checks, first aid supplies inventories, and inventories of Health Physics and office supplies reserved for use by emergency response personne Locations covered by these checklists included: onsite and offsite ERFs, the Control Roo l

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gatehouse, onsite assembly areas, onsite decontamination /first aid room, and a local hospita Checklists required verification 'that equipment and kits were in their predesignated leration and tnai. kit contents were complete. Appropriate checklists included verification of periodic replacement of perishable items and that current calibration stickers were available on survey instrument Review of the twelve types of checklists also clearly indicated that identified problems had been corrected in a timely manner and that inventories had been performed following the use of kit supplie The licensee was in the process of evaluating options for the modernization or relocation of the E0F and/or the Joint Public Information Center (JPIC) located in Dixon, Illinoi A final decision on this issue was expected later in 198 Based on the above findings, this portion of the licensee's program was acceptable, c. Organization and Management Control The GSEP Coordinator's assigned responsibilities remained the same and included managing the onsite GSEP training program. During 1988, the coordinator also functioned as Rad Chem Supervisor for approximately one quarter of the year, which included participation in the budgeting proces Excellent contact was maint'ined with local offsite authoritie Due to the coordinator's kn Aedge of the emergency preparedness program and his time in his position, he was able to overextend himself and function adequately in these extra dutie However, in the process, his ability to adequately document and maintain adequate records control has lessened. The primary example of this problem is the coordination of th? GSEP training progra Administrative procedures for the development, tracking and overall coordination of a GSEP training program were unavailable for revie Approved lesson plans reflecting the approved training matrix were unavailable. A process to review, approve and update lesson plans and related documents was unavailable. Records for the training propram were scattered between the GSEP Coordinator's of fice and the training center. The development of approved training procedures to ensure an adequate GSEP training program is in effect will be tracked as Open Item No. 50-454/88018-0 A review of the organizational structure of plant staff indicated no changes were made that would affect the ability of plant personnel to protect the health and safety of the publi The GSEP Coordinator had developed his own computer program to track several emergency planning programs under his control. These programs were implemented to track his annual responsibilities for program maintenance and emergency organization annual training requirements.

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The Licensee's Letters of Agreement with local emergency support organizations are updated annually. This practice, along with meetings and telephone conversations at intermittent intervals to ,

check on organizational changes and equipment needs, ensures adequate support from local offsite support group '

With the exception cf the Open Item regarding the development of training program administrative procedures, this portion of the licensee's program was acceptabl d. Training Training was administered through the use of reading packages for requalification; table tops for special areas of concern such as

security and log keeping; and informational subjects, such as a video of the Federal Full Field exercise of 1987. Duplicate training sessions were scheduled each mont Thti plant manager issued a training schedule at the beginning of the year with instructions 1 to all emergency organization personnel to attend one of the monthly i scheduled training sessions.

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Five members of the onsite emergency organization were interviewed regarding their emergency duties. These interviewees included two Station Directors; one Acting Station Director; one Security Director; and one TSC Communicato All interviewees demonstrated adequate familiarity with their emergency responsibilities and relevant

, emergency plan implementing procedure Based on the above findings, this portion of the licensee's program was acceptable.

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e. Independent Reviews /Audi_ts, t

Quality Assurance (0A) Department records of audits and surveillances of the Station's emergency preparedness program were reviewed for the period July 1987 through August 1988. All records were complete and readily available. The 1987 and 1988 at.11ts satisfied the

requirements of 10 CFR 50.54 (t). Records indicated that timely and adequate corrective actions had been completed and verif.ed on identified problems for all but the most recent surveillance.

' Corporate emergency planning staff had a late September deadline to formally respond to several concerns identified during a recent surveillance of an annual environmental monitoring drill.

l The annual audit program consisted of an onsite audit, performed by (QA) staff based at the Station, and an offsite audit performed by QA staff based at other locations. The annual onsite audits focused

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I on the emergency preparedness program, while emergency preparedness was one of a number of topics addressed in the offsite audit The

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structure of the 1988 offsite audit was improved from former offsite audits and resulted in an audit that was more indepth and broader in scop '

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QA Department guidelines required one surveillance of the orogram i every six months. Increased interest in the program was demonstrated by the QA staff performing seven surveillances in the last half of 1987 and four surveillances so far in 1988. In addition to surveillances of drills and exercises, adequacy of the labeling of onsite sampling points and maintenance of current controlled documents in the EOF were also topics of program surveillance The QA staff also observed offsite aspects of the 1988 medical dril The nature of questions and findings in the onsite surveillance and

, audits also indicated that the auditors had a good understanding of the licensee's emergency preparedness progra ,

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

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was acceptabl . TMI Safety Issues Management System (SIMS) Items On October 31, 1980, the NRC issued NUREG-0737, which incorporated'into f

one document all THI-related items approved for implementation by the i Commission at that time. On December 17, 1982, the NRC issued Supplement 1 to NUREG-0737 to provide additional clarification regarding ,

4 Regulatory Guide 1.97 (Revision 2) - Application to Emergency Response

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Facilities, Emergency Response Facilities, and Meteorological Data, as well as other areas. The status of the completion of these TMI SIMS

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items are internally tracked by the NRC.

i The below listing provides the status of the SIMS items related to emergency preparedness. The listing indicates how the item was tracked as of August 22, 1988, on SIMS, as well as what we have determined to be the correct and current status of the item. In some cases, the status of items tracked by SIMS are incorrect and/or should be updated based on

recent inspection finding The comments provide a background and basis for the current status.

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II SIMS Status: Not Listed  :

Current Status: Open This item refers to implementation of Chapter 8 of Supplement 1 to i NUREG-0737, and should be closed upon completion of the yet to be l' scheduled ERF Appraisal.

" III.A. SIMS Status: Not Listed Current Status: Closed

! This item involved short term improvements to the emergency preparedness l program and was closed at the conclusion of the Emergency Preparedness (

i Implementation Appraisal: Reports No. 50-454/83-56; 50-455/83-39 I dated February 3, 198 '

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III.A.I. SIMS Status: Closed Current Status: Closed This item involved interim upgrades to the ERF's and was closed at the conclusion of the Emergency Preparedness Implementation Appraisal:

Reports No. 50-454/83-56; 50-455/83-39 dated February 3, 198 III.A.I. SIMS Status: Not Listed Cu-rent Status: N/A This item involved design criteria for upgraded ERF's, but was subsequently determined to be not applicable (N/A).

III.A.I. SIMS Status: Not Listed Current Status: Closed Because this item involved ERF modifications that were incorporated into MPA-F-63, 64 and 65, this item was closed based on the Emergency Preparedness Implementation Appraisal: Reports No. 50-454/83-56; 50-455/83-39 dated February 3, 198 III.A. SIMS Status: Not Listed Current Status: Closed This item involved the submittal of upgraded emerger.cy plans. This item was closed with the issuance of Supplement No. 4 to the SER dated May 1984 (NUREG-0876).

III.A. SIMS Status: Not Listed Current Status: Closed This item involved the submittal of emergency procedures. This item was closed at the conclusion of the Emergency Preparedness Implementation Appraisal: Reports No. 50-454/83-56; 50-455/83-39 dated February 3,198 III.A. SIMS Status: Not Listed Current Status: Closed This item involved an acceptable interim meteorological progra This item was closed at the conclusion of the Emergency Preparedness Implementation Appraisal: Reports No. 50-454/83-56; 50-455/83-39 dated February 3, 198 III.A. SIMS Status: Not List 1d Current Status: Open This item involves an acceptable final meteorological program and will not be closed until completion of the as yet unscheduled ERF Appraisa _

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4-III.A. SIMS Status: Not Listed Current Status: Open This item involves an acceptable Class A meteorological model and will '

not be closed until completion of the as yet unscheduled ERF Appraisa III.A. SIMS Status: Not Listed Current Status: Open This itein involves a licensee's review of their Class A meteorologica model and will not be closed until completion of the as yet unscheduled ERF Appraisa III.A. SIMS Status: Not Listed Current Status: N/A  ;

This item required the licensee to provide a description of the Class B meteorological model to the NRC. Based on the current structure of the ERF Appraisal program, the NRC is not reviewing submittals of the Class 8 mode Therefore this item is not applicable (N/A).

III.A. SIMS Status: Not Listed Current Status: Open This item involves an acceptable Class B meteorological model and will l not be closed until completion of the as yet unscheduled ERF Appraisa MPA-F-63 SIMS Status: Not Listed Current Status: Open

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This item involves a review of the TSC during the ERF Appraisal and should be closed upon completion of the as yet unscheiuled ERF Appraisa MPA-F-64 SIMS Status: Not Listed Current Status: Closed This item involved a review of the OSC, which was completed during the October 14, 1987 exercise: Reports No. 50-454/87040(DRSS);

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50-455/87034(DRSS) dated November 3, 198 MPA-F-65 SIfiS Status: Not Listed Current Status: Open

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This item involves a review of the EOF during the ERF Appraisal and should be closed upon completion of the as yet unscheduled ERF Appraisal.

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Current Status: N/A

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This item involved the Nuclear Data Link, which has been superseded by the Emergency Response Data System (ERDS). Therefore this item is not

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Exit Interview The inspectors met with licensee representatives denoted in Paragraph 1, on Sep+. ember 22, 1988. The inspectors summarized the scope and results of the inspection, and discussed the likely content of the inspection repor The licensee indicated that none of the information discussed was proprietary in nature.

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