IR 05000237/1991023

Insp Repts 50-237/91-23 & 50-249/91-23 on 911008-11.No Violations Noted.Major Areas Inspected:Annual Emergency Preparedness Exercise,Involving Review of Licensee Exercise Objectives & Observation of Exercise

ML17174A949
Person / Time
Site:	Dresden
Issue date:	10/30/1991
From:	Ploski T, Simons H, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17174A948	List: IR 05000237/1991023 ML17174A947
References
50-237-91-23, 50-249-91-23, NUDOCS 9111110215
Download: ML17174A949 (26)

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report Nos. 50-237/91023(DRSS); 50-249/91023(DRSS)

Docket Nos. 50-237; 50-249 License Nos. DPR-19; DPR~25 Licensee:

Commonwealth Edison Company Opus West III Downers Grove, IL 60515 Facility Name:

Dresden Nuclea~ Generating Station, Units 2 and 3 Inspection At:

Dresden Site, Morris, Illinois Inspection Conducted:

October 8-11, 1991

-.--- *-;?,,,;/ // /

Inspectors:

/

~ /fc.'<~

T. Ploski

. ~-sJJ* I~

A.~

/

Accompanying Inspectors:

W. Rogers D. Hills S. Adams G. Brya Approved By:

Inspection Summary Date Date

'

Ins ection on October 8-11, 1991 (Re ort Nos. 50-237/91023(DRSS);

50-249/91023 DRSS Areas Inspected:

Routine, announced inspection of the Dresden Station 1 s annual emergency preparedness exercise, involving:

a reviev1 of the licensee 1 s exercise objectives, scenario and controller performance (IP 82302); followup on licensee actions on previously identified items (IP 82301); review of actual emergency plan activations since April 1991 (IP 82701); and observation of the exercise (IP 82301).

Results:

No violitions, deficiencies, or deviations were identifie Overall performance to a challenging exercise scenario was goo One exercise weakness was identified for failure to declare an Unusual Event in response to a simulate;d civil disturbance resulting in the responses of station security 9111116215 911101 PDR ADOCK 05000237 Q

PDR

• and local law enforcement personne Two concerns were also identified regarding recordskeeping by Operational Support Center supervisory personnel and inadequate concern by one of these supervisors for the respiratory protectjon needs of several inplant team Exercise participants effectively coordinated their efforts and adjusted their priorities as unrelated equipment failures affected both operating reactors to different degree However, participants in the Technical Support Center (TSC)

had to overcome very high noise levels from numerous conversations in order to accomplish their task Some inplant teams should have been dispatched in a more timely manlie Key TSC and Emergency Operations Facility staffs*

effectively interfaced with State counterparts.

• • DETAILS Persons Contacted NRC Observers and Areas Observed T. Ploski, Control Room Simulator (CRS), Technical Support Center (TSC),

Emergency Operations Facility (EOF)

S. Adams, CRS, TSC, EOF W. Rogers, CRS Simons~ Operational Support Center (OSC), Inplant Teams D. Hi 11 s, C RS.

G. Bryan, TSC Illinois Department of Nuclear Safety

~- Zuffa, Resident Engineer Licensee Personnel E. Eenigenburg, Station Manager J. Kotowski, Production Superintendent K. Yates; Administrator K. Peterman, Regulatory Assurance Supervisor D. Sharper, Emergency Preparedness Coordinator R. Holman, Emergency Preparedness Coordinator B. Mayer, Nuclear Quality Programs T. Gallaher, Nuclear Quality Programs D. Lowenstein, Regulatory Assurance Analyst R. Carson, Corporate Emergency Preparedness Supervisor L. Holden, Corporate Emergency Planner D. Stobaugh, Corporate.Emergency Planner The above State of Illinois and licensee staff attended the October 10, 1991 exit intervie The inspectors contacted other licensee personnel during the inspectio '

• Licensee Action on Previously Identified Items (IP 82301)

(Closed) 0 en Item No: 50-237/90007-03:

The Dresden Station 1 s Emergency Action Leve s EALs provided too ew criteria for classifying emergencies based on the failure of one or more fission product barrier By letter dated June 14, 1991, the NRC informed the licensee that Revision 6 of the Dresden Annex to the Generating Stations Emergency Plan (GSEP) had been approve Revision 6 included expanded and acceptable criteria for assessing the failure of each of the three fission product barriers. This item is close.

Actual Emergency Plan Activations (IP 82701)

On July 9, 1991, the licensee correctly declared an Unusual Event for the commencement of a Unit 2 reactor shutdown required by the Technical

• *

Specifications. While performing a walkdown, an _operator discovered a primary coolant leak at a penetration between a reactor water cleanup heat exchanger room and the reactor building. Air operated primary containment isolation valves ~ere closed; however, no decrease in the leak rate was apparen The leak was later stopped by closing a non-safety related valve for which credit could not be taken..

The Unusual Event was declared in a timely manne State and NRC officials were notified within the regulatory time limits in an adequately detailed manner, based on comparisons of licensee and NRC record Updates to these officials were accurate; however, the licensee's self-evaluation noted that onshift personnel did not utilize the proper communications line and proper message form when updating State officials. The self-evaluation indicated that these concerns would be addressed in the next semi-annual training cycle for licensed personne On September 23, 1991, the licensee correctly declared an Alert for the loss of certain Control Room (CR) annunciators for Unit Other CR indications were no~ affecte The Unit 3 reactor was defueled at the time; however, the relevant EAL was not operating mode dependen Records indicated that the root cause of the loss of the annunciators was a blown fus The Alert was declared in a timely manne State and NRC officials were initially notified within the regulatory time limits and were given adequately detailed information, based on comparisons of licensee and NRC record The Technical Support Center (TSC) and Operational Support Center (OSC) were activated and became fully operational within about 64 and 38 minutes of the Alert declaration, respectivel Although the loss of annunciators last~d approximately 14 minutes, the Alert remained in effect for almost four hours while the licensee conducted a root cause assessmen The licensee's self-evaluation of the declaration was ongoin The Emergency Preparedness Coordinators (EPCs) had compiled most records and had drafted several evaluation report Nuclear Quality Programs (NQP) staff observed activities in the CR and TSC and had drafted their-evaluation repor The licensee's final evaluation reports and any associated corrective actions will be evaluated in a future inspectio No violations or deviations were identifie Exercise (IP 82301)

An announced daytime exercise of the Dresden Station's emergency plan was conducted at the Dresden Statio~ on October 9, 199 The exercise included the full scale participation of the State of Illinois and Grundy, Will and Kendall Countie The exercise tested the capabilities of licensee, State and local em.ergency organizations to respond to a simulated accident scenario resulting in a major simulated release of radioactive material.

4 The attachments to this report describe the licensee's exercise objectives and the exercise scenario~

General Observations Procedures This exercise was conducted in accordance with 10 CFR 50, Appendix E requirements using the licensee's Generating Stations Emergency Plan (GSEP), Dresden Annex to the GSEP and related Emergency Plan Implementing Procedures (EPIPs). CoQrdination The licensee's response was coordinated, orderly and timel I scenario events had been real, actions taken by the licensee would have been sufficient to allow State and local officials to take appropriate actions to protect the public's health a.nd safet Observers The licensee's controllers and evaluators monitored and critiqued this exercise along with six NRC observer Critiques The licensee held critiques with participants in each facility following the exercis On October 10, 1991, lead controllers summarized the licensee 1.s preliminary exercise strengths and

\\veakriesse The inspectors discussed their preliminary inspection fin~ings, which had been developed independently, during the exit interview which was also conducted on October 11, 199 A Public Critique was scheduled by FEMA at the Joint Public Information Center on October 11, 1991, so that FEMA and NRC staff could present their organizations' preliminary assessments of offsite agencies'

and the licensee 1s exercise performances, resp~ctively. This critique was cancelled when no members of the media or the general public had arrived by 15 minutes after the critique had been scheduled to begi.

Specific Observations Control Room Simulator (CRS)

The exertise began at 7:30 a.m. when the Shift Engineer (SE) was informed that plant security personnel were responding to the site 1 s property line where a_ group of simulated protestors v1ere staging a peaceful demonstratio One protestor was reported to have begun a sit-in within the property line. The SE reviewed only the security-related Emergency Action Levels (EALs) and concluded that, pending further information on the situation, an Unusual Event declaration was not yet warranted since normal plant operations were not being disrupte However, by 7:45 a.m. the Shift Control Room Engineer (SCRE) had made courtesy notifications to the NRC resident inspector and a simulated NRC duty office At about _7:50 a.m., the SE received updated information f~om several supervisory-level persons, who were stationed in an onsite response facility, that the County Sheriff 1s Department 11 had been called and that the licensee considered the demonstration to be a "news worthy" even A 4-hour non-emergency notification was promptly made to simulated NRC officials,per 10 CFR 50.72(2)(vi).

However, an Unusual Event declaration was still not considered necessary so that State and county officials could be informed of the situatio Since the SE was not receiving information directly from the demonstration scene, ft is unclear whether he was aware that the scenario postulated that five persons were simulating over 30 demonstrators and that several security personnel responding to the scene were intended to represent at least 15 responder It is also unclear whether the SE understood that Sheriff's Departmerit personnel were responding to the sit Shortly after 8:00 a.m., the SE stated that he would suspend periodic inspections of the cooling lake 1 s dike pending further reports on the demonstratio The SE was then told that one protestor had been arrested and that the other protestors were

. leaving the scen The SE gave no indication of declaring an Unusual Event per EAL No. 8e (civil disturbance disrupting operations) or EAL No. 9a (condition warranting increased awareness by State and/or local officials).

At that point, an exercise controller issued a contingency message requiring an Unusuai Event declaration in order to preserve the scenario 1 s time lin Th~ SCRE initially notified State and NRC officials of the Unusual Event declaration in a timely manne The failure to declare an Unusual Ev~nt per the criteria of either EAL No. Be or EAL No. 9a is an Exercise Weakness (No. 50-237/91023-01).

While the simulated protest demonstration was in progress, the SE and licensed and non-licensed operators effectively interfaced in assessing the operability of the 2A core spray pump's discharge valv The valve was correctly declared to be inoperable ~nd a maintenance team was requeste However, the inoperability time was incorrectly stated as 8:00 a.m.*, when the SE made his inoperability decision, rather than 7:46 a.m. when the valve failed to function as require The SE promptly declared an Alert at 8:43 a.m. after receiving indications of an unisolable nitrogen gas leak from the Unit 3 toru The leak was correctly recognized as a breach of one fission product barrie The SE stated his intention to rapidly shutdown Unit 3 from approximately 85 percent powe An Operating Engineer and a controller simulating an Assistant Superintendent advised the SE that a gradual shutdown was more appropriate and permitted by Technical Specifications. A gradual reactor shutdown was then initiate A good announcement was made over the station's Public Address (PA) system regarding the reason for the Alert declaration and the need to evacuate the Unit 3 torus are A good decision was also made to secure nitrogen makeup to the torus and to increase the ventilation rate in the Unit 3 torus are **

For about 30 minutes after the Alert declaration, the SCRE was essentially a communicator having no time to become involved in such matters as the discussions regarding Unit 3 shutdow He handled verification callbacks from two State agencies regarding the Unusual Even He drafted accurate initial notification messages to State and NRC officials for the Alert declaration. State and simulated NRC officials were initially notified of the Alert in a timely manner. _

However, a SCRE should not become so over burdened with communicator duties that the shift technical advisor role may not be fulfille An orderly transfer of command and control from the SE to the Technical Support Center's (TSC 1s) Station Director (SD) took place at 9:00 This transfer of lead responsibility was accomplished by telephone and includ~d a thorough chronological briefing by the SE, who then informed his crew of the transfer of comman At 10:00 a.m., CRS personnel responded quickly and in accordance with procedures to a spurious Group 1 isolation signal on Unit 2, the associated reactor trip and the failure of one steamline 1 s isolation valve to clos When some control roqs failed to automatically and fully insert, operators manually activated systems to fully insert thes~ control rod An Operating Engineer remained in the CRS following TSC activation and assisted the SE in his final briefing of the SD prior to the SD 1 s assuming command of the licensee's emergency respons The Operati.ng Engineer simulated activation of the Emer~ency Response Data Syste However, on two occasions, the Operating Engineer directed operators to perform actions prior to advising the S An operator was instructed to report the current radiation levels in both Units' toruses, since TSC staff suspected an inconsistency between their data and CRS indication Later, an operator was instructed to accomplish a valve lineup so that technicians could collect a post accident sampl The Operating Engineer gave this instr~ction while the operator was performing a shutdown cooling procedur However, neither instance adversely affected the overall functioning of the CRS cre The SE was soon made ~ware of both of the Operating Engineer's instructions to the operator One Exercise Weakness was identifie No violations or deviations were identifie ~.

Technical Support Center (TSC)

The TSC was activated following the Alert declaration and became fully operational within 20 minutes of that declaratio Tse* staff did a very good job throughout the exercise of properly identifying which equipment failures were associated with Unit 2 and which were associated \\'/ith Unit 3, so that corrective action efforts 1*1ere properly directe The SD and his key staff did a good job in revising priorities assigned to inplant teams and to various TSC staff as onsite conditions change Several status boards were effectively used to.list changing priorities and the inplant teams'

progres *

TSC personnel often had to overcome very high noise levels when accomplishing such tasks as periodic briefings and communications with counterparts in other response facilitie At times, various TSC staff indicated that they could not hear persons talking to them on the telephone.. On several occasions, the Operations Director exhibited*a lack of awareness of information provided in recent briefings, such as when all onsite personnel had been accounted for and when it was determi~ed that prerequisite conditions had been met for entry into long term shutdown coolin This lack of awareness was probably due to the high noise level He was promptly given correct information on these matters once he asked these question However, noise levels within the TSC were often so loud that persons had to shout to communicate with each other, despite the repeated efforts of the SD and others to have personnel lower their voice Noise levels should be much better controlle The SD promptly and correctly declared a Site Area Emergency at 10:00.a.m. due to Unit's failure to automatically shutdow State and simulated NRC officials were initially notified in a timely and accurate manne The SD correctly ordered the simulated assembly and accounting of all onsite personnel following this declaration. Appropriate TSC staff interfaced to select the optimum site evacuation route for nonessential personnel; however, this route ~as not finalized until almost 20 minutes after onsite accountability had been declared to be complete Considering the fairly constant wind direction conditions and the lack of radiological or other environmental hazards, the appropriate evacuation route should have been mor~

quickly determine The decision to simulate evacuating nonessential personnel was then mad Evacuees would have been given cards specifying the roads to one of several predesignated reassembly areas where they would have been monitored for contamination had scenario events been rea Although these cards included a sketch of the destination point, that location should also have been named on the card for the benefit of onsite evacuees who may not be familiar with the identities of othef licensee-owned facilitie Following the Site Area Emergency declaration, the SD adequately responded to several information requests from a decision maker of the Illinois Department of Nuclear Safety.. Several role players simulating members of an NRC Site Team later arrived in the TS Their information requests were also satisfied, although one director seemed uncertain when asked whether a primary containment radiation level above about 100 R/hour was an indication of core degradatio By 10:20 a.~., the SD was informed of indications of elevated radioactive release rates to the environment, as detected by plant

~tack monitoring equipmen The SD promptly i~tructed his staff to inform State officials that a simulated radioactive release had begu A Protective Action Recommendation (PAR) was also issued in *

accordance with this licensee's Emergency Pla The SD recommended that persons within a two mile radius of the plant site and further downwind seek shelte As release rates and Unit 2 containment radiation levels rapidly increased, the SD quickly conferred with his Radiation Protection and Maintenance Directors. Since there was no possibility that an inplant team could isolate the release pathway within the next few minutes, the SD conservatively declared a General Emergency at 10:35 a.m., although release rate and containment radiation levels were somewhat below the numerical values procedurally requiring that declaratio In order to preserve the scenario time line desired by participating offsite agencies, exercise controllers blocked* this emergency reclassification decision and associated offsite notifications until about 10:50 In the interim, the SD and his State counterpart conferred regarding offsite pr9tective action The SD elected to adhere to procedural guidance, while voicing no disagreement with the State official's decision to implement more conservative protective actions, apparently based on early indications of radioiodines in the release which the TSC staff could not yet confir TSC staff were informed of the SD's PAR and those protective actions which State officials h.ad chosen to implemen The*SD provided a good briefing to his Emergency Operations Facility (EOF) counterpart as that facility was being staffe An orderly transfer of lead responsibilities to the EOF's Manager of Emergency Operations (MEO) later took plac As onsite conditions stabilized, the SD and his staff complied with the MEO's request to perform initial onsite recovery plannin The*

TSC's major concerns were communicated to key EOF staf The exercise included the collection of a reactor coolant sampl Following sample collection, TSC staff were expected tb estimate the extent of core damage based on a postulated set of sample analysis results issued after the actual sample's analysis became availabl However, the exercise was terminated before TSC staff could perform_

their calculations based on the coolant sample dat Instead, their core damage estimates were based only on containment radiation level dat Selected TSC staff should have been allowed to estimate core damage based on both coolant sample results, even if other TSC staff had concluded their exercise participatio No violations or deviations were identifie Operational Support Center (OSC) an Inplant Teams The OSC was fully operational within 30 minutes of the Alert declaration; however, the OSC Director should have told his assistants and assembled technicians when he considered the OSC to be adequately staffed and ready to support CR and TSC decision makers' need **

Overall communications between the OSC and TSC were very goo The use of a PA system linking these faciliti~s simplified informing OSC staff of changing onsite conditions, changing repair priorities and other major decision With one minor exception, OSC personnel kept the TSC accurately informed of the status of each inplant tea Overall recordskeeping by the OSC Director and Supervisor was inadequat The director's log was n6t maint~ined after 8:40 a.m.,

while the supervisor kept no log of his activities. Although inplant teams were adequately briefed prior to dispatch, some briefing forms were not initialed by the director or the supervisor to indicate approval of information provided in the briefing Teams were debriefed upon ~eturn to the OSC; however, a debriefing form was not completed for one inplant tea Inadequate recordskeeping by the OSC Director and OSC Supervisor is an Open Item (No. 5D-237/91D23-D2).

• Status board usage was generally good; however, a status board used to track information regarding inplant teams only had provisions for posting information on five team The board included provisions fQr posting the teams' simulated exposures; however, these data were adequately maintained on hardcopy records rather than on the status boar The DSC Director demonstrated his capability to remain well aware of information regarding each inplant team despite the lim~tations in the use of this status boar Another status board should be available as a means of tracking technicians assigned to the OSC by their area of expertise, so that DSC supervisory personnel can readily ascertain whether they have sufficient resources in a given area of expertise to meet TSC staff's demand During the exercise, the OSC Director occasio~ally went into the room where technicians awaited assignment and relied on his personal knowledge of the technicians in order to update himself on how many persons having certain expertise were available. It is unknown whether other DSC Directors would have such detailed knowledge on a group of technicians who may staff the OSC on any given da The OSC Director demonstrated good concern for deployed inplant teams and nonessential personne He ensured that periodic communications were maintained with deployed team When radiation levels were simulated to increase in one onsite assembly area, the Director quickly ordered it to be abandoned and relocate Radiation Protection Technicians (RPTs) accompanied inplant repair teams whenever appropriat The RPTs' survey results were posted in the OS Several inplant teams would have needed respiratory protection had scenario events been rea The DSC Supervisor provided the teams assigned to attempt repair of the nitrogen gas leak and closure of the stuck open steamline isolation valves with proper dosimetry, protective clothing and some readily available respirator However, when some team members informed him that their respirators

-*

were not the proper size, the supervisor advised them not to worry about that problem, rather than procuring the proper size respirators from another onsite locatio The RPT accompanying one of these teams was also told by the supervisor not to worry about verifying the respirator qualifications of this inplant team'.s personnel prior to dispatc The OSC Supervisor's inadequate concern for the respiratory protection for several inplant teams is an Open Item (No. 50-237/91023-03).

Inplant teams were adequately briefed on assigned tasks and obtained the tools needed to perform these task Inplant teams typically left the O~C within 25 to 35 minutes after TSC staff had requested that an inplant team be dispatche The timeliness of inplant team dispatch was adversely affected to some extent by changing priorities necessitated by changing plant condition However, the slow dispatches of two teams were noteworth At 9:00 a.m;, a post accident sampling team was requeste The team left the OSC at 10:10 A team to attempt closure of the stuck open steamline isolation valves was requested at 10:15 Although this was considered to be the 11 top priority 11 job, team formation did not begin for 15 minute The team did not leave the OSC until 10:50 a.m~ The licensee should re-evaluate the process for forming, briefing and dispatching inplant teams from the OSC with the goal of having teams dispatched in a more timely manner after they have been requeste *

TvJO open items v1ere identifie No violations or deviations were identifie Emergency Operations Facility (EOF)

The decision to activate the EOF was made following the Site Area Emergency declaratio An orderly transfer of most lead responsibilities from the TSC 1s SD to the EOF 1 s Manager of Emergency Operations (MEO) occurred about 90 minutes later. This transfer of emergency classification, state notification, Protective Action Recommendation (PAR) decisionmaking and onsite emergency worker authorization responsibilities had been delayed while TSC staff dealt with changing plant conditions which warranted a General Emergency declaration and an initial offsite PA The MEO ensured that his staffs in all ~esponse facilities and the State count~rpa~ts were informed of his assumption of these lead responsibilities. Control of the licensee's field survey teams.and communications with simulated NRC officials were later transferred from TSC to EOF staf The EOF staff's overall interface with State counterparts in Springfield, Illinois v1as very goo The MEO and his key staff \\vere informed of the State's request for offsite ~urvey assistance from the Department of Energy and a later State decision to declare portions of Grundy, Will and Kendall Counties as disaster area The MEO discussed stabilizing onsite conditions and a potential need to revise the current offsite protectiv~ actions with his State counterpar A correct decision was made not to further revise the offsite protective action T~e MEO and his State counterpart also

• ensured that their staffs shared data from both organizations'

offsite survey teams.

. Key EOF staff periodically briefed all personnel within the facility on changing onsite and offsite conditions and the major decisions of the MEO and State counterparts. Status boards were adequately maintained to supplement these briefing By 1:00 p.m., the Proteetive Measures Director and his staff had computed an estimated total release and its impact on the estimated population in affected portions of the Emergency Planning Zon They also computed an estimate of the potential offsite radiological impact in the event of a total failure of the Unit 2 primary and secordary containment These calculations were factors in the correct decision not to recommend relaxation of the offsite protective action Shortly before 1:30 p.m., the MEO directed TSC and EOF staffs to begin onsite recovery planning and to determine whether the situation could be reclassified from a General Emergency to an onsite Recovery phase, based on criteria in the emergency plan and its procedure A correct decision was made to remain in a General Emergency at least until Unit 2 achieved a cold shutdown condition and walkdowns of Units 2 and 3 containments and needed safety systems could be completed and evaluate The need to ensure redundancy of systems required to maintain both Units in a cold shutdown condition was recognize The MEO and key EOF staff then explained their decision and its bases to the senior State official prior to exercise terminatio No violations of deviations were identifie Joint Public Information Center (JPIC)

The JPIC was activated and utilized by licensee and State public information staffs during this exercis However, NRC staff did not evaluate the performance of licensee staff in this facility for a meaningful period of tim No violations or deviations were identifie Offsite Radiological Monitoring Teams The licensee activated two monitoring teams in accordance with the emergency plan and procedure The teams were not accompanied by NRC staff during the exercis Instead, the teams' movements and results were mdnitored by NRC evaluators in the TSC and EO The teams were deployed to locations dmmwind of the Dresden Statio Communications between the teams and TSC or EOF staffs control~ing their movements were goo However, the team positioned closest to the site exhibited some difficulty in initially determining the simulated plume's approximate boundarie **

Control of the teams was smoothly transferred to EOF staff soon after that facility became fully operationa No communication breakdowns with the teams were observe The teams' locations downwind of the site and their survey.results were adequately documented by EOF staff. Survey results were shared with State personnel directing the activities of the State's survey team No violations or deviations w~re identifie.

Exercise Scenario and Controller Activities (IP 82302)

The licensee's exercise objectives and complete copies of the scenario were submitted in accordance with the established schedul The licensee was responsive to scenario comments from the NR The most challenging aspect of the scenario was that it postulated unrelated equipment degradations which affected both operating reactors to varying degree Participants met the challenge by not confusing*

which unit had been affected by which equipment proble Other challenging aspects of the scenario incl0ded:

use of the Control Room Simulator; use of the post accident sampling system; use of a response cell of.controllers to portray NRC staff in order to maintain open line communications with TSC and EOF personnel; use of several roleplayers, primarily in the TSC, to portray early arriving members of an NRC Site Team; and activation of the JPIC and offsite survey team Several equipment mockups were available to provide a more realistic challenge to inplant repair teams; however, not.all were utilized :;s repair priorities changed in response to changing plant conditions. Security personnel also responded to a simulated civil disturbance at the start of the exercis The scenario timeline was, however, somewhat predictabl Events warranting the initial emergency declaration ar:d emergency reclassifications typically were postulated to begin on the hour or half hou Licensee controllers generally did a good job of controlling exercise play so that objectives could be me The scenario timeline was reasonably followe No significant instance of improper controller action was identifie No violations or deviations were identifie.

Exit Interview On October 11, 1991, the inspectors met with those licensee and State representatives identified in Paragraph 1 to present and discuss the preliminary inspection finding The licensee indicated that none of the matters discussed were proprietary in natur The licensee was informed that overall performance to a challenging exercise scenario was goo One exercise weakness was identified for failure to declare an Unusual Event in response to a simulated civil disturbance resulting in the responses of station security and local law enforcement personne Two conc~rns were also identified regarding records keeping by Operational Support Center supervi_sory personnel and **

inadequate concern by one of these supervisors for the respiratory protection needs of several inplant team Exercise participants effectively coordinated their efforts and adjusted

. their priorities as unrelated equipment failures affected both operating reactors to different degree However, participants in the Technical Support Center (TSC) had to overcome very high noise levels from numerous conversations in order to accomplish their task Some inplant teams should have been dispatched in a more timely manne Key TSC and Emergency Operations Facility staffs effectively interfaced with State counterpart Attachments: Licensee's exercise _6bjectives Scenario narrative summary

..

PRIMARY OBJECTIVE DRESDEN NUCLEAR POHER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 Commonwealth Edison will demonstrate the ability to implement the Generating Station Emergency Plan CGSEP) to provide for protection of the publ.ic health and safety in the event of a _major accident at the Dresden Nuclear Power Station. The 1991 dem0ns_tration will be conducted during the hours which qualify as a daytime exercise in accordance with NRC guideline SUPPORTING OBJECTIVES l. Assessment and Classifitation Objectives Demonstrate the ability to assess, within fifteen C15) minutes, conditions which warrant initiating a GSEP classifi~ation. CCR, TSC EOF). Demonstrate the ability to determine applicable Emergency Action Levels CEALs> within fifteen (15)

minutes of initiating classificatio CCR, TSC, EOF>

2. Notification and Communication

• Objectives Demonstrate the ability to correctly fill out a NARS for CCR, TSC, EOF) Demonstrate the ability to notify appropriate State and local organizations within fifteen C15) minutes of an Emergency Classification~ CCR, TSC, EOF)

• Demonstrate the a.bility to correctly fill out ENS Notification worksheet CCR, TSC, EOF) De!llOnstrate the ability to notify the NRC immediately following State notification and within one (1) hour after making an Emergency Classificatio CCR, JSC, EOF) Demonstrate the ability to provide hourly information updates to the States and within thirty (30) minutes of changes in latest reported conditions on the State Agency Update Checklis CCR, TSC, EOF) Demonstrate the ability to contact appropriate support organizations that would be available to assist in an actual emergency within one (1) hour of conditions warranting their assistance. ( M+T, Teledyne)

CCR, TSC, EOF) Demonstrate the ability to maintain an open-1 i ne of convnuni cation* with the NRC on ENS upon reques CCR,. TSC, EOf)

ZDRESDEN/19/l

• • L DRESDEN NUCLEAR POHER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 Demo.nstrate the ability to maintain an open-line of co1M1unication with the NRC on HPN upori reques CTSC, EOF>

Demonstrate the ability to provide hourly information updates to the NRC and within thirty (30) mjnutes of changes in reportable conditions when an-open-line of convnunication is not maintaine CENS and HPN)

CCR, TSC, EOF>

3. Radiological Assessment and Protective Actions Objectives a. *Demonstrate the ability to collect and document radiological surveys taken for conditions presented in the scenari CTSC, EOF, OSC)

.

.

- Demonstrate the ability to trend radiological information for conditions presented in the scenari CTSC. EOF, OSC) Demonstrate the ability to take appropriate protective actions for onsite personnel in accordance with Station.procedures. (e.g. respiratory protection. protective clothing, Kl)

COSC, TSC) Demonstrate the ability to adequately prepare and brief personnel for entry into High Radiation Area_s in accordance with Station procedures and policie Demonstrate the ability to issue and administratively control dosimetry issued to teams dispatched from the OSC in accordance with Station procedure COSC} Demonstrate the ability to establish radiological control in accordance with Health Physics prbcedure CTSC. OSC, EOF) Demonstrate the ability to contro 1 personne 1 ex*posure in excess of 10CFR20 limits in the course of lifesaving and other emergency activitie Demonstrate the ability to monitor. track. and document radiation exposure for inplant operations and maintenance teams in accordance with plant procedure CTSC, OSC)

ZDRESDEN/19/2

'.

DRESDEN NUCLEAR POWER STATION 1991 GSEP EXERCISE OCTOBER. 9, 1991 Demonstrate the ability to perform decontamination of*

radioactively ~ontaminated individuals and equipment in accordance with Station procedure COSC) Demonstrate the ability to identify *appropriate Protective Actions Recommendations CPARs) within fifteen (15) minutes of obtaining an Offsite Dose Projection or using a Protective Action Flowchar CTSC; EOF)

. Demonsttate the ability to calculate Offsite Dose Projection in accordance with appropriate

procedure CTSC, EOF) Demonstrate the ability to perform contamination control onsite in accordance with plant procedure (e.g. area access control, drinking water, food supplies, return to normal use criteria)

CTSC, OSC) Demonstrate.the ability to collect RCS and Containment Atmosphere samples using Post Accident Sampli System (PASS) e~uipment in accordance with PASS procedures and proper Health Physics control (CT, OSC) Demonstrate the ability to perform Core Damage Assessments in accordance with the EPIP CTSC, EOF)

ZDRESDEN/19/3

• Emergency Facilities Objectives DRESDEN NUCLEAR POWER STATION 1991 GS..EP EXERCISE OCTOBER 9, 1991 Demonstrate the ability to establish minimum staffing in the TSC and OSC within thirty (30) minutes of an Alert or higher Classification during a daytime event in accordance with procedure CTSC, OSC)

• Demonstrate the ability to augment the Control Room staff within thirty (30) mintites of an appropriate Emergency Classification ln accordance with th~

. procedure CCR) Demonstrate the ability to transfer Command and Control authority from the Control Room to the TS CCR, TSC) Demonstrate the ability to transfer Comm~nd and Control authority from the TSC to the EO CTSC, EOF) Demonstrate the ability to establish minimum staffing in the Emergency Operations Facility and Joint Public Information Cente~ within approximately one (1) hour of the Site Emergency classification in accordance with EOF and JPIC procedure (EOF, JPIC) Using information supplied by the Exercise scenario, demonstrate the ability to record, track, and update information on the Status Boards at least every thirty (30) minute CCR, TSC, OSC, EOF) Demonstrate the ability to document Operations and Maintenance Team activities in logs and on appropriate Status Board COSC) Demonstrate the ab1lity to track in--plant job status in logs and on appropriate Status Board (CR, TSC, OSC, EOF)

ZDRESDEN/19/4

• • -

DRESDEN NUCLEAR POWER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 Demonstrate the ability to exchange counterpart activity informatioh between the ERFs at least every sixty (60) minutes. - CCR, TSC, EOF, OSC)

- Demonstrate the ability to update and disseminate information from the Electronic St~tus Board~

nsc. rnn Emergency Direction and Control Objectives Demonsfrate the ability of the Directors and Managers to exert command and control in their respective area of re~ponsibility as specified in procedures. -(CR, OSC, TSC,' EOF)

- Demonstrate the ability to coordinate and expedite*

Operation and Maintenance activities during critical and urgent repair and emergency repai nsc. osc. EOF> De~onstrate the ability to prioritize resources for Operations and Maintenance activities during critjcal and urgent repai~ and emergency repai nsc. EOF. OSC) Demonstrate the ability to acquire and transport emergency equipment and supplies necessary to mitigate or control unsafe or abnormal plant condition CTSC, EOF, OSC) Demons-tr ate the ability of the Shi ft Enginee Station Director, OSC Director and MEO to provide briefings and updates concerning plant status.- event classification; and activities in progress at least every sixty (60) minute CCR, TSC, OSC, EOF) Demonstrate the ability to provide access for the NRC Site Team 1 n accordance with Ac.cess Control pro.cedure CTSC, EOF)

- Demonstrate the ability to interfa~e with the NRC Site Tea CTSC, EOF) Demonstrate the ability to identify and designate non-essential personnel within thirty C30) minutes after deciding to evacuate the sit CTSC, EOF)

ZDRESDEN/19/5

• DRESDEN NUCLEAR POHER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 Demonstrate the ability of 1nd1v1duals in the Emergency Response Organization to perform-their assigned duties and respdnsib11ities as specified in *

Generic GSEP, CCR, TSC, OSC, EOF>

. Public Information Objectives

_ Demonstrate the ability to respond to Media requests within sixty (60) minutes in accordance with CECo policies and procedure Demonstrate the ability to prepare accurate Press Releases within ninety (90) minutes of significant events while in a Site or General Emergency classificatio CJPIC> Demonstrate the ability to present Media Briefings within ninety (90) minutes of significant events while in a Site or General Emergency classificatio Demonstrate the ability to use visual aids to support Media Briefing information in accordance with CECo policies and procedure CJPIC) Demonstrate the ability to maintain a CECo representative in the JPIC at all time CJPIC) Recovery Objectives a.. Demonstrate the ability to determine long-term recovery staffing requirement CTSC, EOF ZDRESDEN/19/6

DRESDEN NUCLEAR POHER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991

. OBJECTIVES TO BE DEMONSTRATED EVERY Fl.VE YEARS 8.. Miscellaneous Objectives Demonstrate the ability fo establish the relationship between effluent monitor readings and onsite and offsite exposures/contamination for various meteorological conditio CTSC, EOF, Field Teams)

• Demonstrate the ability to det~rmine the magnitude

.of a release based on plant system parameters and effluent monitor CTSC, EOF) Demonstrate the ability to calculate release rate/projected doses if the primary instrumentation used for assessment is offscale or inoperabl CTSC, EOF) Demonstrate the abn Hy to collect and count field samples in accordance with Environmental Sampling proc~du~es. (field Teams, TSC, EOF) Demonstrate the ability to perform dose rate measurements in the environment for conditiohs presented in.the scenario.* (Field Teams) Demonstrate the ability to dispatch the Environs Teams within. forty-five (45) minutes of determination of the need for field sample CTSC, OSC) Demonstrate the ability to control/coordinate Environs Teams activities in accordance with ED and EG procedure CTSC, EOF, Field Teams) Demonstrate the ability to transfer control/coordination of Environs Teams activities from the TSC to the EOF in accordance with Station and EOF procedure Demonstrate the ability of the Security force to respond to an emergency situation in ac~ordance with procedure <Security)

• Demonstrate the ability of the Security force to coordinate actions and interact with.the Emergency Response Organizatio <Security) *

ZDRESDEN/19/7

• • • • Public Inform~tion Objectives DRESDEN NUCLEAR POHER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 Demonstrate the abi 1 i ty to a 1 ways maintain a CECo representative in-the JPIC 1n accordance with CECo policies and procedure CJPIC) Demonstrate the ability to exchange event'

information with Non-CECo JPIC representatives for Media Briefings in accordance with CECo polichs an ~rocedures. CJPIC)

- Demonstrate the ability to coordinate information with Non-CECo JPIC representatives for Media Briefings in accordance with CECo policies and procedure CJPIC) Demonstrate the ability to activate Rumor Control 10. Recovery_

• Objectives

. Demonstrate the ability to identify the criteria to enter a Recovery classification in accordance with procedure CTSC, EOF) Demonstrate the ~bility to coordinate recover actions with the Stat CTSC, EOF)

ZDRESDEN/19/8

DRESDEI~ NUCLEAR POWER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 NARRATIVE SUMMARY GENERAL:

The weather has been relatively normal for the past 30 day The forecast for the next 3 days states that daily temperatures will reach the low 60's with winds of 3 to 5 mp There are no signs of precipitation in the forecas *

UNIT l:

The midnight shift had returned the Unit l Di.esel Fire Pump to service following coolant and 011 replacement by the Mechanical Maintenance Departmen All applicable operating surveillances have been complete The Unit 1 Diesel Fire Pump was declared operable and removed from theLCO board at 0500 hr The Unit 1 Service Air Compressors have had numerous reports of operating loudl Mechanical Maintenance has found no problems with compressor operation and attributes the loudness to building echo, caused by

. close areas of Unit 1 being sealed off as part of the Unit l

• decommissionin UNIT 2:

The unit. has been on 1 i rie for 110 days and has been operating at 99%

power for the past 3 day Power history for the last 2 weeks shows load drops by the Chicago Load Dispatcher, all limited to 50 Mwe ot less. All.load drops have occurred on the midnight shift with a *

return at full power by 0900 hrs., in acc6rdance with DGP 3-LPCI and HPCI monthly surveillances were successfully completed yesterday.* The Core Spray monthly surveillance including valve operability is scheduled to be performed at the start of the shif There are no syst~ms with abnormal line-ups and no time clocks in effec UNIT: 3. Unit 3 is currently operating at 851. power, limited by condensate demin differential pressure- (42#). Contractors have the Unit 2 and 3 regeneration ro6ms 0.0.S., along with the radwaste resin transfer lines for the past 2 weeks; as part of the Radwaste Upgrade Projec The work is scheduled for completion in 3 day Additional note: Unit 3 will.set a new record run at 1953 hrs.,

today!

ZDRESDEN/l8/l EXPECTED ACTIONS Work will continue on the Unit 2 and 3 regeneration room by the contractors. Operators will continue to operate at full power on Unit 2; and at 851. power on Unit The SCRE wi 11 obtain a copy of the Core Spray Monthly Surveillance COOS 1400-1) and Core Spray Valve Operability Checks should be commenced shortly after assumption of the shift. A failure of the 2. A Core Spray discharge valve CM02-1402 24A) torque switch will be found..

Operations will initiate work requests as needed to make the repairs.* The SCRE should reference Tech Spec 3.5.a.2, to ensure that the appropriate ECCS pumps and oa* sel Generators are operable.* The shift will declare the Core Spray ~ubsystem. *

inoperable, make the approgriate noti lcation and identify that the unit is on a 7 day cloc The EM repairing the Core Spray discharge valve will be contaminated upon exiting the work are **

DRESDEN NUCLEAR POWER STATION 1991 GSEP EXERCISE OCTOBER 9, 1991 NARRATIVE SUMMARY UNUSUAL EVENT 0730-0800 At-0730, a group of 25 Anti-N~clear Demonstrators gather at the property line of Dresden Nuclear Station. The protest is in honor_

of the 11thirty-first anniversary 11 of Dresden's dedication as the world's first privately built nuclear generating station. The group is located on the entran~e road, handing out pamphlets to all persons, explaining how CECo and the workers at Dresden are placing the public in danger and destroying the environmen This is causing traffic delays and confusing the employee At 0730 hours0.00845 days <br />0.203 hours <br />0.00121 weeks <br />2.77765e-4 months <br />, the leader of the protest group tre~passes onto the CECo owned site which is clearly identified as private propert EXPECTED ACTIONS S~curity will dispatch a security officer to confront the group leader and inform him that he is trespassing on CECo property and must leav He should also be told that if he fails to leave, the Grundy County Sheriff will be contacted to assist in his removal.* After some discussion, the protester refuses to leave the propert The Security Officer should contact the Security Shift Supervisor, who should notify the Dresden Station Security Supervisor (Security Director) and Shift Engin~er. The Shift Engineer should declare an UNUSUAL EVENT bas~d on EAL 8.e. *

(Civil Disturbance) and the Dresden Security Supervisor should perform procedure DXP-20 Security should confront the trespassing prote~ter ~nd insist that he leave the property. The protester will refuse to stay off the company propert The Grundy County Sheriff's Department will be c~lled for assistanc The County Sheriff will arrive and ask the protesters to dispand and leave the are All but one will comply with their reques H~ will be arrested and taken to jai ALERT 0800-1000 At 0800, the Control Room will receive a torus higb/low level alarm which will reset without reoccurrence. A contractor working in Unit 3 Torus catwal*k area will stand on pipe penetrating from the torus CX-3056).

The weld that attaches the pipe to the Torus cracks and a small wisp of air is heard coming from the wel The contractqr foreman will notify the SCRE of the inciden ZDRESDEN/18/2

DRESDEN NUCLEAR POWER STATION

.

1991 GSEP EXERCISE

. OCTOBER 9. 1991 NARRATIVE SUMMARY At 0915 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.481575e-4 months <br />. the Unit 2 CRD flow c6ntroller fails in*the clos~d direction. Attempts to take manual control of the valve will* be su~cessfu EXPECTED ACTIONS The SCRE should notify the NSO and the Shift Enginee An operator should be dispatched to identify the 1 eak 1 ocati on a.nd determine whether it can be isolated. The line should be

• i den ti fi ed as the "Torus Leve 1 Si ghtgl ass Upper Tap... and that*

the leak is incapable of being isolate *

The SCRE and SE will identify the leak as a breech of Primary Containment and classify the event as an ALERT based on EAL 2.g., Loss of 1 Fission Product Barrier. The Shift Engineer should take correcttve actions to remove Unit 3 from power operatio The ramp rate may be reduced as weld repairs are attempted to stop the lea The Technical Support Center will be manned and assist in obtaining the resources necessary to rep~ir the lea The failure of the CRD Flow Contro1ler will be repaired by*

replacing the controlle The SCRE will notify the Instrument Maintenanc~ Department of the failur The Shift may attempt to

• take local control of the valve to reestablish CRD flo SITE EMERGENCY 1000-1100 A spurious Group 1 isolation will occur on Unit 2, with one steamline failing to isolat The valves will fail to close due to mechanical binding. making them incapable of closing by any mean The reactor will fail to scram automatically. but the manual ARI pushbuttons will allow the rods to insert.. A small break will nccur in the unisolated steamline in the X-are The break will cause the blowout panels between the X-area and the Low Pressure Heater Bay to lift. This will complete the path to the turbine building

.ventilation system and result in an unisolable release path to the environmen The pressure spike on MSIV closure will cause a power spike and fuel fa 11 ur Then the amount of failed fuel wi 11 increase in response to procedural mitigation efforts..

At 1045 a blown *fuse will cause a total loss of normal TSC lightin ZDRESDEN 11'8/.3

DRESDEN NUCLEAR POWER STATION 1991 GSEP EXERCIS OCTOBER 9, 1991 NARRATIVE SUMMARY EXPECTED ACTIONS The CRD flow controller wil) be repaired.* The reactor will be *

shut down and the Shift Engineer and Nucle~r Engineer should be able to determine that Stand-by Liquid control inj~ction is not neede The Shift should declare a SITE EMERGENCY based on EAL 2.o."Steamline break with incomplete isolation of a main steamline."

The release of fission products will be just below the SPING high alarm setpoint. Thts alarm will alert the crew of the breach of cont~inment~

• *

The loss of lighting in the TSC will be investigated by electricians dispatched from the OS Computer terminals in the TSC will continue to function normall GENERAL EMERGENCY 1100-1300 The fuel failure will continue to grow during the steam coolin Field team measurements in the field will require the declaration o a GENERAL EMERGENC ZDRESDEN/18/4 EXPECTED ACTION~

GENERAL EMERGENCY will be declared on EAL The operating crew will carry out the actions of DEOP 300-2, Radioactive Release Contro The end result will be an emergency*

depressurization of the reactor ending the offsite releas Once the release has stopped recovery planning will be initiated in the TSC and EOF in conjunction with the State.