IR 05000010/1981016
| ML20039A612 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/11/1981 |
| From: | Axelson W, Defayette R, Grant W, Paperiello C, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20039A609 | List: |
| References | |
| RTR-NUREG-0737, TASK-2.B.3, TASK-TM 50-010-81-16, 50-10-81-16, 50-237-81-27, 50-249-81-20, NUDOCS 8112180517 | |
| Download: ML20039A612 (38) | |
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No,' 50-10/81-16; 50-237/81-27; 50-249/81-20 Docket Nos. 50-10; 50-237; 50-249 Licenses No. DPR-2; DPR-19; DPR-25 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago. IL 60690 Facility Name: Dresden Nuclear Generating Station, Units 1, 2, and 3 Inspection At: Dresden Site, Morris, IL Inspection Conducted:
'ovember 2-10, 1981 Inspectors:
M.
Phillips
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(Team leade )
W.
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Approved By on, tie Emerge cy paredness Section N
<t 'ub nf fI C. J./ a er19 o, Chief, Emerg ncy Pr aredness and Program Support Branch Inspection Summary Emergency Preparedness Appraisal on November 2-10, 1981 (Reports No. 50-10/81-16; 50-237/81-27; 50-249/81-20)
Areas Inspected: Special announced appraisal of the state of onsite emergency preparedness at the Dresden Nuclear Generating Station involved seven general areas: Administration of the Emergency Preparedness Program; Emergency Organization; Training; Emergency Facilities and Equipment; Pro-cedures which implement the Emergency Plan; Coordination with Offsite Agencies; and Exercises, Drills, and Walkthroughs. The inspection involved 208 inspector-hours onsite by three NRC inspectors and one consultant.
Results: No items of noncompliance or deviations were identified; however, several significant findings were identified in the areas of procedures (Section 5); coordination with offsite agencies (Section 6.2.2); and Exercises, Drills, and Walkthroughs (Section 7.2).
8112180517 811214'
gDRADOCK 05000010 PDR
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DETAILS 1.0 Administration of Emergency Plan 1.1 Responsibility Assigned-Responsibilities from the Corporate level for emergency planning begin with the Division Vice President, Nuclear Stations. The Supervisor of Health Physics and Emergency Planning serves as the Corporate Emergency Planning Coordinator (EPC) and reports to'the Division Vice President, Nuclear Stations. The EPC has a staff of Health Physicists, Emergency Planners, and Meteorologists to assist him in implementing his respon-sibilities.
At the Dresden Station, the Administrative and Support Services Assistant Superintendent has the responsibility to coordinate station compliance with the requirements of GSEP and provide a training program to ensure knowledgeable performance by assigned personnel.
1.2 Authority Personnel assigned an emergency function are given authority to perform assigned duties by GSEP in specific tables in the plan. The Shift Engineer serves as the Acting Station Director in the event of an emergency.
For CECO, the Station Director is in charge of the overall onsite emergency response and reports to the Corporate Comand Center (CCC) Director or Recovery Manager (depending on the accident classification) during an emergency. The Shift Foreman becomes the Acting Station Director if the Shift Engineer becomes unavailable. The Recovery Manager is the designated individual from CECO who has requisite authority and knowledge to manage the overall recovery operations.
1.3 Coordination Coordination of the onsite and offsite organizations and the corporate emergency organization is the responsibility of the Administrative and Support Services Assistant Superintendent. Coordination of planning between the licensee and offsite groups is the responsibility of the EPC.
1.4 Selection and Qualification Selection criteria for personnel responsible for assigned emergency plan functions are based on the individual's normal responsibilities in the same organization and follow ANSI N18.1.
The EPC is appointed by the Division Vice President, Nuclear Stations, and is qualified to perform the emergency planning function.
1.5 Quality Assurance of Emergency Preparedness Program The corporate and site administration relies on the Quality Assurance organization to audit the emergency preparedness program which includes the plan and implementing procedures. They ensure performance in the-2-
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areas of training and training records, exercises and drills, and docu-mentation and implementation of corrections to deficiencies reviewed and considered valid.
Thecorroratemanagero{jQA was interviewed during the LaSalle emergency preparedness appraisal.-
The GSEP QA Engineer was interviewed concerning the station QA program. This program included a review of the training and training records, implementation of the GSEP, distribution of GSEP and EPIP changes, calibration of instrumentation used during emergencies, and offsite interfaces. QA records indicated that audits of the GSEP, Dresden EPIPs, and offsite interfaces had been conducted during May 1981, and September 1981.
Deficiencies identified are tracked by the QA department to assure correction.
The QA inspector prepares an inspection procedure based on his review of the plan and procedures. This procedure changes for each audit depending on what areas the QA inspector wants to examine. The inspection procedure is approved by QA management prior to the audit; however, no overall policy exists to ensure that all areas are audited at least once during the year. Further, QA inspectors independently pick the areas to be examined in the GSEP, rather than QA management. The QA engineer stated that this concern had been looked at, but since the GSEP was still under-going major revisions, an overall audit matrix would not be useful at this time.
The Quality Assurance program provided a complete audit to ensure that corrective actions are implemented and required recourse actions be taken by the manager of QA for items not resolved by the required response date.
The licensee clearly understood the requirements of 10 CFR 50.54(t) and outlined how the requirements for independent audits would be met.
Station QA personnel are independent from the station management and report to QA management in Chicago.
Based on the above findings, these portions (Sections 1.1, 1.2, 1.3, 1.4, and 1.5) of the licensee's program is acceptable; however, the following matter should be considered for improvement:
The licensee should develop a QA procedure to ensure that all areas
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of Emergency Preparedness as specified in the GSEP and EPIPs are audited.
This should be done when major GSEP revisions have been completed.
2.0 Emergency Crganization 2.1 Onsite Emergency Organization The inspectors verified that an effective emergency organization was in place by a review of the emergency organization and responsibility assign-ments described in the GSEP and EPIPs.
The structure of the onsite emergency organization is provided on the attached Organization Chart, shown as Figure 2.1.
The organizational implementation ensures that an 1/
IE Inspection Reports No. 50-373/81-14; 50-374/81-09.
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Acting Station Director is onsite in the Control Room at all times. Each Station Group Director's position includes at least three individuals qualified to act as that Director to ensure an adequate line of succession for all positions. The Station Superintendent is responsible for the selection of all individuals needed to fill the various GSEP Director positions. There is no formal documented selection criteria established; however, this selection is usually based on the normal working duties of these individuals and the standards developed by the Institute of Nuclear Power Operations (INPO),
i.e., Rad / Chem Supervisor becomes Rad / Chem Director, Maintenance Assistant Superintendent or Master Mechanic becomes Maintenance Director, etc.
All of the senior Station Group Directors along with one alternate were interviewed and found to be aware of their emergency responsibilities and authority. Each had a working knowledge of the emergency plan and the implementation of the sections for which they are responsible.
Based on the above findings, this portion of the licensee's program is acceptable.
2.2 Augmentation of the Emergency Organization 2.2.1 Offsite Emergency Organization The augmentation of the offsite emergency organization is made by contacting the Corporate Command Center (CCC) Director. Either he or the designated CCC Duty Officer activates the corporate personnel shown in Figure 2.2 for the less serious emergencies such as an Alert.
When a Site Area or General Emergency is declared, the full offsite recovery organization is dispatched to the nearsite Emergency Operations Facility (EOF) to support the onsite emergency organization. This expanded augmentation is shown in Figure 2.3, which delineates the management structure for the various functional areas.
An adequate line of succession exists for each offsite Director or Manager position. Although there is no documented selection criteria established,
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the Division Vice-President, Nuclear Stations selects all individuals needed
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to fill the various offsite GSEP positions using the standards developed by INPO.
Supporting contractors and vendors are specified in the plan, and written agreements are in effect. Main responsibilities for offsite Directors and Managers include: public information; overall management of the emergency, including repair and corrective actions; offsite radiological assessment; radwaste operations; manpower planning; and logistical support.
The licensee has not procedurally specified how the EOF will achieve full functional operation within one hour as specified in Section 4.3 of NUREG-0696.
The licensee has sufficient personnel available to accomplish this, but has not addressed this in their notification procedures. This is discussed further in Section 5.4.1 of this report.
Based on the above findings, this portion of the licensee's program is acceptable.
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2.2.2 Onsite Emergency Organization The Acting Station Director (usually the Shift Engineer) initially augments the onsite emergency organization by contacting appropriate personnel on the call list. During other than normal working hours he notifies the Operations Duty Supervisor to activate the Station Group using a phone tree procedure.
This procedure was tested by the licensee on October 7, 1980. From initiation to completion of the calls it took 35 minutes. However, no craft personnel were called due to Union overtime agreements. These personnel are on the call
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list. The licensee did not determine the amount of time required for the per-l sonnel contacted to reach the site, and therefore could not determine whether the expertise specified in Table B-1 of NUREG-0654, Revision 1, required to respond within 30 and 60 minutes of an emergency could have responded within this time frame. None of the phone lists used are prioritized to ensure staffing of the TSC and OSC in accordance with the regulatory position of Table B-1 of NUREG-0654, Revision 1.
Section 5.4.1 of this report describes procedural inadequacies relevant to shift augmentation.
Based on the above findings, the licensee's program appears to be acceptable; however, the following matter should be considered for improvement:
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The licensee should conduct an offshift augmentation drill to ensure that the regulatory position of Table B-1 of NUREG-0654, Revision 1, will be met.
This drill should be documented, conducted on a quarterly basis, and identified deficiencies corrected.
3.0 Training / Retraining 3.1 Program Establishment The inspectors discussed the training program with the Training Supervisor and members of his staff. All new employees receive some training on emer-gency response activities during their orientation and annually thereafter.
This is general information and describes the emergency plan, responsibilities of non-essential personnel, assembly areas, and when employees are to report to these assembly areas. More specific training is given to those personnel who have roles to play in responding to the emergency. For example, if a new Station Director is appointed, he will receive one-on-one training as soon as practicable on his duties and responsibilities in an emergency. Starting this year, all licensad personnel are on a six week work cycle in which one week is spent in training.
For the Shift Engineers, one such session dis-cusses Table 200-T1, Classification of GSEP Conditions and Emergency Action Levels, and relates these conditions to the EPIPs. Rad / Chem Technicians (RCTs) receive one full day of training annually in which they are physically shown the GSEP trailer, the EOF, and offsite monitoring locations.
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addition, prior to drills they are given training on their responsibilities.
CECO implemented a training program for First Aid which will be given to those personnel who would need it.
The program was developed by the Illinois Chapter of the American Trauma Society.
Annual training is also offered to offsite personnel, although they do not always participate in it (this is training which is in addition to the annual exercises).
Interviews with representatives of offsite organizations who had participated indicated that the training was satisfactory.
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Based on the above findings, this portion of the licensee's program is acceptable.
3.2 Program Implementation The inspectors conducted several walkthroughs with Dresden employees (e.g.,
Shift Engineers, Shift Foremen, RCTs, station group. directors, and security personnel), and these walkthroughs demonstrated that the training program was adequate. The employees either knew the proper response to a given scenario or were able to immediately find the proper procedure.
The inspectors reviewed a sampling of the training records held by the Training Supervisor and found them to be indicative of the training received.
Attendance was confirmed by the employee's signature on attendance sheets.
Based upon the above findings, this portion of the licensee's program is acceptable.
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The Control Rooms for Units 2 and 3 are adjacent to one another and are mirror images of each other. The Control Room for Unit I forms a "T" with the other two Control Rooms. Unit 1 is currently on an extended outage. With this combination, there is more than adequate space for personnel in the Control Rooms during an emergency.
The communications equipment is located at the juncture of the
"T" formed by the three Control Rooms and is easily accessible to all three Units.
This equipment consists of:
an ENS telephone to the NRC; a Nuclear Accident Reporting System (NARS) telephone to State and local agencies; a dedicated telephone to the TSC; a dedicated telephone to the OSC; plant extension telephones; one commercial line; and GSEP radios. The radio has receivers in the EOF, the Corporate Command Center (CCC), the plant superintendent's car, and the duty officer's car.
The environs hand radios also use the same frequency as the GSEP radios.
Copies of the emergency plans and procedures are located near the telephones.
The inspector randomly checked the procedures manual for recent changes and found the latest change had been made two days prior to the inspection in-dicating they are being maintained current.
Based upon these findings, this portion of the licensee's program is acceptable.
4.1.1.2 Technical Support Center (TSC)
The inspectors observed the permanent TSC facilities. The facilities appear to be adequate to meet the criteria of NUREG-0696, except that the Safety Parameter Display System and the Offsite Dose Calculation System will not be-6-
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fully operable before October 1982. The licensee, on June 1, 1981, submitted his actual design for this TSC to the NRC for evaluatica. Final approval will be made by the NRC Division of Emergency Preparedness following evaluation of the submittal and provided all of the criteria of NUREG-0696 are met.
The permanent TSC is located in a newly constructed building which adjoins the south side of the old administration building inside the security fence.
An inspector timed his walk to the Control Rooms and determined that this took 90 seconds. The TSC is divided into rooms to accomodate various per-sonnel.
It has a ventilation system which is comparable to the Control Room system (including particulate (HEPA) and charcoal filters); has a permanently installed air monitor; has a communication system which includes two commercial telephones for NRC use; a NARS extension; a dedicated line to the Control Room; several commercial lines; and a radio system. The TSC also has maps of the Dresden site and surrounding area, updated copies of emergency plans and procedures, a SYFA computer terminal for dose assessment, and provisions for a telecopy machine.
The TSC has a separate room which contains a reproduction machine, typewriter, and microfiche reader and copier, and also contains a microfiche storage cabinet which will have all pertinent plant drawings and documents.
It also has a decontamination room with protective clothing and portable radiation detection equipment. This TSC is now being used by the licensee.
Based upon these findings, this TSC is acceptable as a temporary TSC. However, this is also an Open Item pending completion of the TSC and final approval by the NRC Division of Emergency Preparedness.
4.1.1.3 Operational Support Center (OSC)
ThelicenseeisintheprocessofrelocatingtheOSCbgyedonconcerns identified by the NRC in a previous inspection report.-
These concerns were that the noise level in the OSC interfered with radio and telephone communications, that there was no systematic debriefing of returning survey /
sampling teams to obtain pertinent survey information, that there was no means for recording and displaying such information in the OSC, and that the OSC would not be capable of functioning effectively for a protracted period of time. The new OSC will be the radiochemistry foreman's office and adjacent rooms. The licensee plans to officially shift the OSC to this new location on December 7, 1981, after all shift crews have been retrained as to its location. Overflow of personnel at the new OSC can be handled by the locker rooms which are close by.
The new OSC has ready access to radiological monitoring equipment and protective clothing.
If the new OSC becomes uninhabitable, the licensee will still be able to use the ground floor of the Unit 1 Turbine building next to the Domestic Water Tank (old OSC). This is a satisfactory backup OSC. Both the primary (new)
and backup (old) OSCs have adequate communications availability. The Operations Director is responsible for the operation of the OSC. The new OSC should satisfy the concerns identified above.
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IE Inspection Reports No. 50-10/81-13; 50-237/81-26; and 50-249/81-19.
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amB The OSC is an Open Item pending its shift to the radiochemistry foreman's office.
4.1.1.4 Emergency Operations Facility (EOF)
The interim EOF is located approximately mile southwest of the facility in the General Electric Training Center and has more than enough space to accomodate personnel who would be staffing it.
The environs and recovery managers share one room, the NRC has a room by itself, the recovery group has an overflow room, and there are other classrooms which could be used, if needed.
The interim EOF has a locked cabinet which contains some supplies and equipment that would be needed; e.g., the plug-in telephones, emergency plans and procedures, plant drawings, film badges, and dosimeters.
It does not contain any radiation monitoring equipment, sample counting equipment, air samplers, or protective clothing. These must be brought in each time.
The interim E0F has maps of the area around Dresden and also has several color aerial photographs of differing scales on which the emergency zone sectors and environs dosimeter locations have been marked. Smaller copies of these maps are carried by the environs monitoring teams making it extremely helpful for the team to give its location to the E0F and to locate the dosimeters. Adequate primary and backup communications cap-abilities exist from the EOF to the TSC, CCC, State and local agencies, and the NRC. The environs group also has a radio to communicate with the environs monitoring teams. The NRC has not installed an ENS or HPN telephone.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
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The licensee should prepare an emergency kit which contains the required radiation detection equipment and which could easily be transported to the interim EOF when it is activated.
4.1.1.5 Post-accident Coolant Sampling and Analysis 5.4.2.4 Post-accident Primary Coolant Sampling Procedures 5.4.2.5 Post-accident Primary Coolant Analysis Procedures A review was made of the interim post-accident primary coolant sampling and analysis program to determine its adequacy in meeting the requirements of NUREG-0737, Task Item II.B.3, Post-accident Sampling Capability. The review included discussions with the Chemistry Supervisor and Rad / Chem Technicians (RCTs). Walkthroughs of the procedure were conducted with the RCTs and observed by the inspectors during both this appraisal and the recent GSEP exercise. The inspectors also reviewed Emergency Plan Implementing Procedure EPIP 300-9,
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Post-accident Sampling of Reactor Coolant; Chemistry Procedure DCP 1100-39, Reactor Water Isotopic Analysis; and Operating Procedure DOP 1600-16, Post-accident Sampling of Primary Containment and Reactor Water.
The results of the review indicated that adequate interim Post-accident Primary Coolant Sampling and Analysis facilities and equipment exist to accomplish this task.
If the counting facilities cannot be used, the licensee indicated that analytical facilities at LaSalle County Station would be used.
The results of the review of the implementing procedures indicated that adequate procedures to accomplish this task are in place.
The results of the walkthroughs and exercises of the procedures indicated that RCTs have adequate knowledge of the procedures and could properly perform this task.
A permanent system will be installed and will be operational in the near future. The system will be a modified Sentry System which will be capable of collecting post-accident samples in accordance with NUREG-0737. This is an Open Item.
4.1.1.6 Post-accident Containment Air Sampling and Analysis 5.4.2.6 Post-accident Containment Air Sampling Procedures 5.4.2.7 Post-accident Containment Air Analysis Procedures A review was made of the interim post-accident containment air sampling and analysis program to determine its adequacy in meeting the requirements of NUREG-0737, Task Item II.B.3, Post-accident Sampling Capability. The review included discussions with the Chemistry Supervisor and Chemists. The inspec-tors also reviewed EPIP 300-8, Post-accident Sampling of Primary Containment Atmosphere; Chemistry Procedure DCP 1400-7, Reactor Off-Gas Isotopic Analysis; and Operating Procedure DOP 1600-16, Post-accident Sampling of the Primary Containment Atmosphere and Reactor Water.
The results of the review indicated that adequate interim facilities and equipment exist for post accident containment air sampling and analysis.
The results of the review of the implementing procedures indicated that adequate procedures are in place to accomplish this task.
A permanent Sentry system described in the previous section will be installed.
This is an Open Item.
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4.1.1.7 Post-accident Gas, Particulate, and Iodine Effluent Sampling and Analysis 5.4.2.8 Post-accident Stack Effluent Sampling Procedures 5.4.2.9 Post-accident Stack Effluent Analysis Procedures.
A review was made of the interim post-accident gas, particulate, and iodine effluent sampling and analysis program to determine its adequacy in meeting the requirements of NUREG-0737, Task Iten II.F.1, and the planning standards of NUREG-0654, Revision 1.
This review included discussions with the Chemistry Supervisor, Chemists, and RCTs; tours of the Control Room and sampling points; and a review of EPIP 300-10, Post-accident Sampling and Release. Rate Deter-mination of Radioiodines and Particulates; EPIP 300-11, Post-accident Noble Gas Release Rate Determination; and DCP 1400-8, Isotopic Analysis of Charcoal Cartridges and Particulate filters.
The results of the review of the facilities and equipment, implementing procedures, and exercises indicate that adequate interim emergency facilities, equipment, and procedures to support emergency response are provided and properly maintained.
The licensee is installing permanent high range inline iodine, gas, and.
particulate effluent monitors in accordance with the requirements of.NUREG-0578.
This system, which consists of a SPING, will be operational-by January 1,1982, but will not meet all of the requirements of Task Item II.F.1 in NUREG-0737.
The SPING system could be unaccessible for sample collection during the release-of a Regulatory Guide 1.3 source term. Because of this, the licensee plans to-install a Victoreen system which will initiate when the SPING. switches to its highest range. The Victoreen system will be installed during the fourth quarter of 1982. These are Open Items.
4.1.1.8 Post-accident Liquid Effluent Sampling and Analysis l
l 5.4.2.10 Post-accident Liquid Effluent Sampling Procedures
5.4.2.11 Post-accident Liquid Effluent Analysis Procedures A review was made of the post-accident liquid effluent sampling and analysis program to determine its adequacy in meeting the requirements of NUREG-0737, Task Item II.B.3, Post-accident Sampling Capability and the planning standards.
in NUREG-0654, Revision 1.
The review ii. luded discussions with the Chemistry Supervisor, Chemists, Technical Staff Engineers; a tour of the High Rad Sampling System; and tours of Rad Waste sampling points.
The results of this review indicate that the licensee is currently using the regular liquid effluent sampling facilities,~ equipment, and procedures to support emergency response. There are, however, no precautionary state-ments in the sampling and analysis procedures that warn the user of possible high sample activity in post-accident samples.
The licensee's installation of the High Rad Sampling System will allow remote sampling of reactor liquid effluent systems. This is an Open Item.
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This portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
Liquid effluent sampling and analysis procedures should be revised to
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contain precautionary statements that warn the user of possible high sample activity in post-accident samples.
4.1.1.9 Offsite Laboratories The licensee's Procedure ED-21 addresses the offsite laboratories. Appendix I of this procedure lists the capabilities, equipment, and analyses that can be performed by each of the offsite labcratories operated by Eberline.
In addi-tion, the licensee's normal REMP contractor, Hazelton Environmental Science, also has sufficient capability to satisfy the emergency requirement for offsite laboratory services. For relatively hot samples, the licensee has available the counting labs at their Zion, LaSalle, and Quad-Cities Nuclear Stations.
Based on the above findings, this portion of the licensee's program is acceptable.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The assembly area is the corridor between Unit 2 and Unit 3 Turbine Building Trackways on the first floor of the Turbine building and was chosen because of its shielding capabilities.
It extends the full length of Units 2 and 3 and has an Area Radiation Monitoring System (ARMS) detector in the center between the two units, and in each reactor feedwater pump area.
It also has claxon alarms next to the ARM detectors in the feedwater pump area. The area for each unit has a dedicated telephone to security,two dial (extension)
telephones, and wall-mounted emergency lighting.
Provisions have been made to move the assembly area to another location, if necessary, such as to the Maintenance Shop.
Based upon these findings, this portion of the licensee's program is acceptable.
4.1.2.2 &
4.1.2.3 Medical Treatment and Decontamination Facilities The inspectors examined the licensee's first aid kits and their location.
Kits were complete as listed in EPIP 500-1.
The kits were located just outside of the exit points for most controlled areas. These locations provided the instruments required to make a personnel survey and the first aid supplies required to treat an injury. The licensee has provided a personnel decontamination station and first aid room which was equipped with stretcher, blan!:ets, first aid kits, decontamin'ation agents, and a shower with controlled drains.
The facilities provided were strategically located and consistent with those defined in the emergency plan.
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Based on the,above fir.hing this portion of the licensee's program is acceptable.' ~
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r 4.1.3 Expanded fupport Facilities The inspectors examined Expanded Support Facilities. The licensee will augment emergency resource personnel from Zion, LaSalle, and Quad-Cities Nuclear Power Stations. Space is available for contractor (i.e., General Electric and Sargent & Lundy) personnel in the interim EOF, if this EOF includes.the entire General Electric Training building. Space for five NRC^ personnel is also provided in the interim EOF. Adequate communications (i.e., three seperate outside telephone lines) are available to support these NRC personnel.
If additional resources are needed; i.e.,
trailers, they can be provided through the CCC's Manpower and Logistics Director.
Additional commanications equipment can be provided through the Communica-tions Director.
Based on the above findings, this portion of the licensee's program is acceptchle.
4.1.4 News Centers The licensee has made provisions in the interim EOF at the GE Training Center for'a News Center which will accomodate a small number (about 20-25) of media personnel. The room is one of the regular classrooms and is equipped with audiovisual equipment and blackboards. Arrangements have also been provided for four plug-in telephones for use by the media. Training for Commonwealth personnel on the use of the facility is provided by the Supervisor of News Information on an annual basis.
In the event this is not large enough, the licensee has stated that arrange-ments have been made to use the Drake's Farm Restaurant which is about five miles from the site and is large enough to accomodate larger numbers of people.
However, the licensee was unable to locate any documentation of these arrange-ments.
The permanent News Center will be in the EOF to be built near Mazon.
It will have accomodations for the News Information Department and will have most of the equipment needed for press briefings such as audiovisual equipment, type-writers, easels, etc.
Although it will not have sufficient numbers of telephones, negotiations are underway with Illinois Bell to transport a mobile van to the EOF when it is needed. The van contains a microwave switching unit for 50 telephone circuits.
Based on the above findings, this portion of the licensee's program is ac-ceptacle; however, the following matter should be considered for improvement:
The licensee should document with a formal Letter of Agreement the
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. arrangements to use Drake's Farm Restaurant as a backup Emergency News Center.
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4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency Kits and Survey Instrumentation The inspectors reviewed the location and contents of the emergency kits.
The Technical Support Center Emergency Kit Storage Room contained the material listed in EPIP 500-5 and 500-6, and also contained an instrument calibrator.
The kits stored in the GSEP trailer located about 1000 feet from the station entrance were complete and identified as field survey kit No. I and No. 2.
The portable radios to be used by field survey teams are kept on charge in the chemistry foreman's office and picked up by the survey teams prior to picking up their emergency kits.
The contents of the emergency kits were as specified in EPIP 500-2, except for maps which were in a separate flat pack. A copy of the GSEP and EPIPs were available in the kits.
The kit at the St. Joseph Hospital Emergency Room for treating contaminated patients was complete, the instruments were functional and their calibration was current.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.1.2 Area and Process Radiation Monitors.
A review was made of the area and process radiation monitoring program to determine its adequacy in meeting the planning standards of NUREG-0654 for area and process radiation monitors under accident conditions. The review included discussions with the Radiation Protection Supervisor, tours of the Control Room monitor readouts and some plant area monitoring locations.
Section 7.3 of the Dresden Annex contains a description of this accident assessment equipment.
The inspectors noted that two high range containment radiation monitors are being installed. The range of these monitors is from 1 R/hr to 1 E+08 R/hr.
This is an Open Item.
'The results of this review indicated that adequate methods, instrumentation, and' equipment for assessing and monitoring plant conditions are in place and properly maintained.
4.2.1.3 Non-Radiation Process Monitors A review was made of the non-radiation process monitoring program to determine its adequacy in meeting the planning standards of KUREG-0654 for non-radiation process monitors under accident conditions. The review included discussions with the Chemistry Supervisor, Shif t Control Room Engineers, and an observation of the Control Room readouts. Table DA 7-2 of the Dresden Annex contains a listing of the non-radiation process monitors.
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The results of the review indicated that the non-radiation process monitors were operable and functional. Discussions with the Shift Control Room Engineer showed that they had a clear understanding of the use of these monitors for
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emergency detection classification and assessment. Monitor readouts were located in the Control Room and were readily observable.
Based on the above findings, this portion of the licensee's program is
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j acceptable.
4.2.1.4 Meteorological Instrumentation The bases for the review of the licensee's meteorological measurements program included Regulrtory Guides 1.23 and 1.97, and the criteria set forth in NUREG-0654, -M96, and -0737.
The licensee provided a brief description of the meteorological measurements program in GSEP, the Dresden Annex, and the Offsite Dose Calculation System (.Iuly 1980, Revision 2). The integration of the meteorological data into the licensee's dose assessment scheme was described in the Environmental Director's (ED) Series of procedures. The inspectors reviewed the licensee's preventative maintenance program and schedule maintained by Murray and Trettel personnel (the licensee's meteorological contractor).
The inspectors determined that the licensee's meteorological capabilities address the requirements of NUREG-0737, Task Item III.A.2 set forth in NUREG-0654, Appendix 2 in adopting the compensating measures to milestone three. The meteorological measurements system can provide the basic para-meters necessary to perform the dose assessment function, namely, wind direction and speed and an estimate of atmospheric stability. Data from the meteorological measurements system are provided on strip charts located at the base of the meteorology tower and in the. Control Room; however, the strip charts in the Control Room did not have the correct chart paper, nor did the scale on the paper match the scale on the recorder; and it was impossible to determine the time trace based on the use of this chart paper.
All mersurement systems appeared to be in operation and had been calibrated in accordance with the licensee's set schedule. The licensee's preventative maintenance program was reviewed and found to be acceptable by the inspectors.
In the event of system unavailability from the Dresden meteorological measure-ments _ system, the licensee can access any of their other systems or Hurray and Trettel forecasts through the use of the SYFA computer system which is located in the TSC and Control Room. This backup capability is described in the ED series of procedures.
Control Room personnel are advised of severe weather conditions which could impact the site by the System Power Load Dispatcher, who is equipped with NOAA's Weather Wire. Provisions have been made for transmission of meteoro-logical information from the plant to offsite authorities using a combination of communication systems. Direct telephone access by NRC staff to individuals responsible for performing dose calculations can be accomplished using any one of the dedicated lines for NRC use located in the EOF or TSC, or the NRC Health Physics Network currently located in the TSC only.
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Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
Meteorological. chart recorders in the Control Room should be equipped
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with chart paper which matches the scale of the instruments and indicates the rate of speed of the recorder (i.e., time marked).
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The inspectors examined storage locations and the types and quantities of respiratory protection equipment available for dse in an emergency. The licensee's supply of supplied air systems was adequate in numbers and located throughout the facility near the point of use. Reserve or backup respiratory equipment was available in the supplied air storage building and on the cascade rack within the facility. Adequate refill facilities were available in the supplied air storage building.
The licensee's program for control and cleaning of respiratory equipment was adequate and provided a central location for the normal dispensing and control of respiratory pro-tection. An adequate supply of respirator type equipment is available. The Dresden station has access to respiratory protection from other Commonwealth Edison plants in the region.
Based on the above findings this portion of the licensee's program is acceptable.
4.2.2.2 Protective Clothing The inspectors examined the location and quantity of protective clothing available on site. The supply and reserves were adequate.
In addition, the licensee had emergency supplies in the TSC storage room and in the GSEP trailer. The licensee has supplemental supplies available from other CECO
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plants in the region.
Br ed on the above findings, this portion of the licensee's program is acceptable.
4.2.3 Emergency Communications A review was made of the Emergency Communications System to determine if it was as described in the Emergency Plan and Implementing procedures and if it meets the planning standard criteria of NUREG-0654, Revision 1.
The review included Section 7.2 of the GSEP and Dresden Annex; EPIP 300-2, On going Emergency Communication; discussions with the station GSEP Coordinator; and observations of the communications system.
The results of the review indicated that all of the equipment identified in
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the GSEP was available. There is a 24-hour / day capability to notify NRC, State, and local authorities. The inspectors found the provisions for routinely checking operability of the emergency communications equipment and
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devices were in place and are being implemented, with the exception of the communications checks conducted with the NRC (see Section 5.5.1).
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies Needs for onsite damage control include temporary shielding, lifting equip-ment, welding equipment, high level radiation waste handling and storage capabilities, and decontamination supplies and equipment. The inspectors determined that these needs could be met from onsite supplies. Extra equipment, if required, can be obtained from nearby LaSalle or Braidwood Nuclear Stations through the Manpower and Logistics Director at the CCC.
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Based on the above findings, this portion of the licensee's program is acceptable.
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4.2.5 Reserve Emergency Supplies and Equipment The Dresden Nuclear Station has an inventory of supplies, including: pro-tective clothing, radiation detection instruments, respiratory equipment, first aid supplies, decontamination supplies and equipment, and dosimetry.
for the radiological environmental monitoring teams.
In addition, Dresden Station can obtain supplies including compatible radiation detection ins-trumentation, communications, and transportation equipment'from LaSalle and Zion sites. The Stores Director has a procedure to inventory and obtain any emergency reserve supplies. Adequate quantities of emergency reserve supplies are maintained at specified minimum stock levels onsite.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.6 Transportation The. licensee has provided one dedicated van for emergency use.
In addition,
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maintenance vehicles are assigned for field survey teams and other emergency use on an as needed basis. The keys to the dedicated vehicle and maintenance vehicles are kept in the TSC. An adequate number of motor vehicles are available.
Based on the above findings, this portion of the licensee's program is acceptable.
5.0 Procedures 5.1 General Content and Format The inspectors reviewed all of the GSEP implementing procedures. With the exception of the Station Group Directors' Checklists (EPIP 100-C1 through 100-C11), procedures were arranged in one of the following two formats with
the following general headings:
(a) scopa, (b) policy and methods, (c)
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references; or (1) purpose, (2) references, (3) prerequisites, (4) precau-tions, (5) licitations and actions, (6) procedure (actual body of procedure),
(7) checklists, and (8) technical specification references. The latter format coincides with the licensee's administrative procedure for procedure format. Procedures were written to cover all of the functions specified in the GSEP, and were organized by function. All Station Group Directors also had a checklist to ensure that required responsibilities were implemented.
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These checklists referenced the appropriate functional procedure.
d Based on the above findings, this portion of the licensee's program is acceptable.
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures None of the licensee's abnormal operating procedures (DGAs) or annunciator procedures contain any sections relative to Emergency Action Levels contained in the GSEP or EPIP 200-T1. The licensee feels that notification of the Shift Engineer that an emergency condition may exist is a craft capability for an operator and need not be delineated in every abnormal occurrence procedure.
The licensee has prepared Revision 9 to DAP 7-1, Operations Department Organ-ization. This revision makes the notification of the Shift Engineer a specific responsibility of the Shift Control Room Engineer (SCRE). The SCRE will notify the Shift Engineer of any conditions that potentially could require notifications and activation of the GSEP. IIis decision will be based on a review of events occurring with the initiating EALs specified in EPIP 200-T1.
The licensee has not as yet issued this procedural revision, nor have they conducted training of the SCREs in this regard. This is an Open Item pending the issuance of this revised procedure and training of the SCREs in this new responsibility. The inspectors will conduct walk-throughs with SCREs to verify that this training has been completed during a followup inspection.
Based on the above findings, this portion of the licensee's program is an Open Item pending the issuance of DAP 7-1, Revision 9, and training of the SCREs in their new responsibility.
5.3 Implementing Instructions Separate GSEP Checklists existed for each Station Group Director. These procedures specified each Director's responsibilities, and the management level within the GSEP to which he reports. These procedures also referenced the functional procedures to be used to implement each Director's respon-sibilities.
The Shift Engineer (SE), as the Acting Station Director, has complete authority over the initial operations of the Station Group; and is responsible for the initial classification of the event under GSEP and making the proper initial notifications and protective action recommendations.
Individual Emergency Classifications, e.g., Alert, Unusual Event, etc., comprise sub-sections of the notif2 cations procedare and Station Director Checklist (EPIP 100-C1). Emergency Classifications are made based on observable information which is readily available using EPIP 200-T1, which is the table of EALs versus Emergency Classifications. The Station Director's Checklist requires the SE or Station Director to classify the event, make appropriate
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notifications, verify that the Station Group has been activated in accordance with the seriousness of the Emergency Classification, and establish communica-tions networks. Appropriate references indicate which procedures are to be used for each action.
Although the notification procedure (EPIP 300-1) contained a table of protective action recommendations based on Emergency Classifications, walkthroughs of several SEs using General Emergency scenarios indicated that they were unable to determine what protective action recommendations should be made (see Section 7.2).
None of the Shift Engineers was familiar with the means of determining if the offsite projected dose exceeded the recommended dose levels given in EPIP 300-1.
Although Shift Engineers did specify what actions they would have the Rad / Chem Technicians (RCTs) under their direction perform, these actions were varied from SE to SE using the same scenario. The Station Director Checklist did not prioritize what actions the RCTs under their direction should take (i.e., surveys or appro-priate sample collections), especially if the emergency occurred during the backshift.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
The licensee should revise EPIP 100-C1 to direct the RCTs under the
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direction of the Shift Engineer to conduct appropriate surveys or collect appropriate samples until the arrival of the Rad / Chem Director.
5.4 Implementing Procedures 5.4.1 Notification For all Emergency Classificatione, EPIP 300-1, Initial Notifications and GSEP Responses, delineates who shall be notified and what onsite organiza-tions must be augmented based on the classifications. The sequence for these actions is also specified in this procedure. Notification action levels are consistent with 10 CFR 50.72.
All copies of the EPIPs contain the Notifications Phone List. This phone list is formated identically with EPIP 300-1, and contains the necessary primary and backup phone numbers and methods for making all necessary notifications. For an Alert or higher Emergency Classification, the Operations Duty Supervisor will initiate a telephone chain that will result in complete manning of the OSC and TSC. The Operations Duty Supervisor is on 24-hour /da; call and can be reached at any time. When initial notification and augmentation is performed, planned messages are used to ensure that persons contacted know what class of emergency exists and where they are to report. These messages are included in the Notifications Phone List.
The Notifications Phone List does not prioritize the calls so that the TSC can be manned in accordance with the regulatory positions of Criterion 2.3 of NUREG-0696 and Criterion II.B.5 of NUREG-0654, Revision 1.
This is necessary to ensure that the TSC is able to -function as soon as possible.
The Notifications Phone List must ensure that the design objectivcs of shift augmentation as specified in the above criteria are met.
The licensee provided a dtscription of their current augmentation capabilities at the
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The Notifications Phone List must be prioritized to ensure that at least eleven personnel can respond within 30 minutes.
Figure 5.4 shows the means by which offsite agencies are notified based on
the Emergency Classification. There is a direct phone connection between the Control Room and the System Power Load Dispatcher. Since most notifi-cations to offsite agencies will be made by the Corporate Command Center Director (CCC Director), the licensee has set up a duty of ficer system, requiring that one of the individuals qualified to act as the CCC Director be on 24-hour / day call. This form of notification was set up by the State of Illinois and agreed to by the licensee. This system has been demonstr-ated to be timely.
Notifications to offsite groups are made using the NARS form. The Operations Director's Checklist and Notifications Phone List include a verification that the System Power Load Dispatcher and the Station
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Director have been notified.
Procedure CC-1 specifies which offsite support organizations are to be notified and the degree to which offsite augmentation is implemented based on the Emergency Classification. The CCC Director will notify all personnel required to man either the CCC or both the CCC and EOF using a telephone call list. Although this phone list is available to all CCC Directors at all times, this phone list has not been prioritized to ensure thct a Recovery Manager will be at the EOF within 60 minutes of determining that the EOF must be activated. This is specified in Criterion II.B.5 of NUREG-0654, Revision 1, and Criterion 4.3 of NUREG-0696.
Based on the above findings, the following actions must be taken to achieve an acceptable program:
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The licensee shall prioritize the Notifications Phone List such that augmentation capabilities defined in Criterion II.B.5 of NUREG-0654,.
Revision 1, will be met.
The CCC Director's call list shall be prioritized such that a Recovery
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Manager will be at the nearsite EOF within 60 minutes of determining that the E0F must be activated.
5.4.2 Assessment Actions The inspectors reviewed the licensee's Environs Group (EG) Series procedures, Environmental Director (ED) Series procedures, EPIP 100-C11 (Environs Director Checklist of Initial GSEP Responsibilities), EPIP 100-C8 (Rad / Chem Director Checklist), EPIP 100-C3 (Technical Director Checklist), and EPIPs 300-8 through EPIP 300-15. These procedures all address assessment actions during
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an emergency. These procedures were reviewed against the planning standards and criteria of NUREG-0654, Revision 1.
Neither EOF-3 nor ED-1 describe the means by which Federal and State radio-logical assessment personnel will be updated every 15 minutes. ED-20 provides forms for information that would be provided to the Illinois Department of Nuclear Safety; however, there are no such provisions for Federal personnel
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(NRC and DOE), nor are there provisions for follow-up verification or con-tinuous updating of such information.
The results of the review indicated that adequate methods, systems, and procedures for a sessing and monitoring actual or potential offsite con-sequences of a r adiological emergency condition are in use; and procedures for assessing and monitoring plant parameters during an emergency are adequate.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
EOF-3 and ED-1 should be revised to specify the means for updating
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Federal and State radiological assessment personnel at least every 15 minutes.
5.4.2.1 Offsite Radiologiccl Surveys 5.4.2.2 Onsite Radiological Surveys Radiological surveys are conducted by the licensee using procedures in the EG series. With the exception of EG-2 and EG-7, all EG procedures are under revision. These revisions were reviewed by the inspectors, and were found adequate with the following exception: none of the EG procedures describes the means for determining if the field teams are actually submerged in the plume, or are under an overhead plume.
Methods and equipment to be used for performing radiological surveys are specified; however, a Cutie Pie (ionization detector) is used for performing
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surveys. This instrument could become internally contaminated if used within
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a noble gas plume, and the resulting measurements would be in error.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matters should be considered for improvement:
Revision 1 to EG-3 should be revised to identify the means by which a
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field team can determine whether they are inside or beneath a radio-logical plume (i.e., if open window readings on the GM are significantly higher than the closed window readings, the team is submerged in the plume). This will also ensure that air samples collected will be-representative of the plume.
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A precaution should be included in the appropriate EG procedures indicating
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that Cutie Pie survey instruments should be bagged to prevent noble gases from entering the ionization chamber and giving false readings.
5.4.2.3 In Plant Radiological Surveys The inspectors interviewed the Rad Chem Supervisor to obtain a determination of the emergency radiation protection procedures that would be used by RCTs during an emergency. The normal station Radiation Protection Procedures (RPPs) would be used. These procedures would be augmented by EPIPs which address specific emergency actions to be taken.
There is no procedure which tells how to conduct a radiation survey in an emergency; i.e.,
the instruments to be used and how to interpret the instru-ment response in the presence of noble gases. Emergency Radiation Protection procedures should be in place which provide information on the precaution that should be observed (e.g., noble gas interference with ion chamber readings, Kr-88 decay to Rb-88) when performing the emergency actions assigned by the Station Director.
EPIP 300-4 defines the emergency dose limits for rescue and recovery per-sonnel and states that RCTs will use station instrumentation and appropriate radiation protection procedures to determine the extent of radioactive con-tamination and radiation exposure in affected areas. Emergency instructions should give specific information (e.g., appropriate precautions and limita-tions) for the immediate use of emergency personnel.
Based on the above findings, this portion of the licensee's program appears to be acceptable; however, the following matter, should be considered for improvement:
Instructions should be included in an emergency procedure which define
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how to make a radiation survey during an emergency. These instructions should include appropriate precautions, such as noble gas interference with ion chamber readings, and Kr-88 decay to Rb-88 (gas to particulate).
Techniques for determining the source of the radiation levels measured should also be included; i.e., external source vs inside an airborne source.
5.4.2.12 Radiological Environmental Monitoring Program (REMP)
Emergency environmental monitoring is coordinated by the Environs Director using Procedure EG-1, which covers all aspects of offsite sampling and surveying.
If a full REMP program is deemed appropriate for a particular emergency, the management structure outlined in Procedure ED-1 would be followed. The ED and EG series of procedures cover all aspects of the REMP program, including arrangements for contractor laboratories, additional per-sonnel for monitoring and analysis, and dose assessment through the ingestion exposure pathway. The licensee also has the capability to implement this program through the assignment of personnel from any of the other nuclear stations operated by the licensee.
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Based on the above findings, this portion of the li;ensee's program is acceptable.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The inspectors reviewed EPIP 300-4, Emergency Personnel Dose Limits and Radiological Controls for Rescue and Recovery Operations; EPIP 200-12, Area High Radiation; EPIP 200-13, High Airborne Activity; and EPIP 200-14, High Radioactive Surface Contamination.
The radiation exposures authorized under emergency conditions are defined in EPIP 300-4 to ensure that the Commonwealth Edison Radiation Control Standards, 10 CFR 19 and 20, and the EPA " Manual of Protective Action Guides,"
are not exceeded.
EPIP 200-13 describes actions to be taken to protect personnel and mitigate the consequences of high airborne activity conditions.
There is no overall procedure which governs the implementation of radiation protection for personnel during emergencies, rather several uncoordinated procedures exist which address various parts of the overall radiation pro-tection program. After the Rad Chem Director has assumed the responsibility for the radiological protection of station personnel during an emergency, the need continues for guidance of an overall procedure.
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Based on the abovd Tiadings, this portion of the licensee's program appears to be acceptable; however, the following matter should be considered for improvement:
An overall emergency radiation protection procedure should be developed
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which covers precautions to be taken, respiratory protection, and radia-tion exposure controls during emergencies.
5.4.3.2 Evacuation of Owner Controlled Areas The inspectors reviewed EPIP 300-3, Assembly and Evacuation of Personnel, and determined that it was adequate. The licensee will evacuate site per-sonnel for a Site Area or General Emergency, or if other dangers exist that present a threat to the safety of onsite personnel. The Station Director is responsible for determining if an assembly / evacuation will be conducted, the Operations Director is responsible for implementing the assembly / evacuation, and the Rad / Chem Director is responsible for deter-mining the safest evacuation route to the designated relocation center.
Evacuation routes are marked in the facility, and the main assembly area is easily identifiable.
Locations of assembly areas ate found in the Plan and EPIP 300-3.
A continuous two-minute siren alerts personnel to report l
to the assembly areas.
The Security Director is responsible for account-ability.
If instructed to evacuate the site, non-essential personnel will
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be directed to one of the four pre-selected eassembly points specified in the Plan and EPIP.
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Pased on the above findings, this portion of the licensee's program is acceptable.
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5.4.3.3 Personnel Accountability EPIP 300-3, Assembly and Evacuation of Personnel; and EPIP 100-C7, Security Director Checklist, were reviewed by the inspectors. Although the Security Director is required to account for all personnel in accordance with EPIP.300-3, this procedure does not currently address accountability. The licensee has prepared Revision 2 to EPIP 300-3 which does describe how accountability will be accomplished within 30 minutes of the initiation of the assembly siren. The method described in this revised procedure was used to account for all personnel within 30 minutes d 23, 1981, drilldiscussedinapreviousinspectionreport.gyingtheSeptember Although this revised procedure was reviewed by the inspectors and found to adequately account for all personnel at all times, this is an Open Item pending the issuance of this revision. The licensee plans to install a security card reader system sometime during 1982 which will be capable of automatically performing accountability.
Based on the above findings, personnel accountability is an Open Item pending the issuance of EPIP 300-3, Revision 2.
5.4.3.4 Personnel Monitoring and Decontamination The inspectors reviewed EPIP 300-3, Assembly and Evacuation of Personnel; EPIP 300-6, Survey of Injured Personnel; EPIP 300-7, Personnel Decontamina-tion; and EG-10, Offsite Personnel Decontamination. The licensee defines the methods and techniques for decontamination of personnel. These pro-cedures are adequate to ensure that personnel will be properly decontaminated once contamination is detected. RCT monitoring teams will be dispatched to ensure that site evacuees are monitored and decontaminated. EG-10 provides for the survey, release limits and decontamination of relocated personnel and the survey and release of vehicles.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.3.5 Onsite First Aid and Rescue The inspectors reviewed EPIP 300-4, Emergency Personnel Dose Limits and Radiological Controls for Rescue and Recovery Operations; EPIP 300-5, Emergency Treatment of Injured Personnel; and EPIP 300-13, Rad-Chem Technicians Action at the Hospital.
The licensee has provided guidance to emergency personnel on the dose they may accept in performance of first aid and rescue. This guidance is based on guidance given by the Environmental Protection Agency. The licensee has provided adequate instructions on the level of decontamination effort and.
placed it as a second priority to treating the injuries. The interface with the ambulance and the hospital are clearly stated in the procedure.
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IE Inspection Reports No. 50-10/81-13; 50-237/81-26; and 50-249/81-19.
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licensee's program is acceptable.
5.4.4 Security During Emergencies The inspectors interviewed the Station Security Director, two Supervisors of Security, and four Security personnel. They stated they had been trained in the GSEP and its relationship to the Nuclear Station Security Plan. The personnel interviewed exhibited a high degree of knowledge and understanding of their roles during emergencies. Each of the supervisors and the security personnel was walked through an emergency scenario and each indicated an adequate knowledge of GSEP. All security personnel are issued and wear dosimetry while on shift.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.5 Repair and Corrective Actions Repair and corrective actions are not addressed with a specific Implementing Procedure. Repair and corrective actions will be implemented by the Maintenance Director. There is no specific procedure in the EPIP series which addresses safety considerations for repair or corrective action teams. These teams would normally be accompanied by an RCT, who is under the direction of the Rad / Chem Director. The Rad / Chem Director is responsible for the radiation protection and dosimetry aspects of each task, giving attention to ALARA considerations in the planning. This area is addressed in his procedure.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.6 Recovery The CCC Director (limited activation) or the Recovery Manager (full activation)
has the authority to deactivate the GSEP organization. The procedures used (either EOF-1, CCC-1, or EOF-9) specify how he will close out or recommend reduction in emergency classifications. This is based on an evaluation of stabilized plant conditions in comparison with Emergency Action Levels, and consultation with NRC, State, licensee, and NSSS vendor representatives.
The positions in the recovery organization are shown in Figure 2.3.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.7 Public Information The inspectors reviewed Procedures CCC-4 and EOF-4 which relate to public information activities and verified that they were acceptable. These procedures were adequate in scope and content, and specifically delineated the responsibilities of the Information Director and Emergency News Center Director.
These responsibilities included collection, verification, and dissemination of information on emergency situations to the public via the news media; issuing approved press releases; coordinating the release of
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Based on the above findings, this portion of the licensee's program is acceptable.
5.4.8 Fire Protection The licensee has not prepared fire preplans, but has agreed to do so if l
required by NRC. This matter is currently under review by the NRC's Office of Nuclear Reactor Regulation. The licensee's Fire Hazards Analysis Report does contain drawings of all plant areas. These drawings are colorcoded to indicate to the user if the fire can affect safe shutdown equipment. This report is located in the TSC and Fire Marshall's office. The Shift Engineer, who is responsible for implementing GSEP, does not have a copy of this Analysis Report. Walkthroughs with some Shift Engineers and Shift Foremen (Fire Brigade Chief) indicated that it is difficult to determine from the fire alarm panel in the Control Room whether the fire can or cannot affect safe shutdown equipment.
l EPIP 200-4, Fire Fighting, describes the EALs for emergency classifi-I cations, and requires the Shift Engineer to initiate GSEP as appropriate.
Although this procedure relates EALs to the d: gradation of equipment such that an LC0 requires shutdown, the procedure does not. provide a means for determining when this may occur. This would be facilitated if the Shift Engineer had a copy of the Fire Hazards Analysis Report available in the Control Room.
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Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
A copy of the Fire Hazards Analysis Report should be placed in the
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Control Room to assist the Shift Engineer in determining whether equipment has been degraded to the point that an LCO requires shutdown.
I 5.5 Supplemental Procedures l
5.5.1 Inventory, Operational Check, and Calibration of Emergency l
Equipment and Supplies The inspectors reviewed the following Emergency Plan Implementing Procedures:
j EPIP No.
Title 500-1 Quarterly Inventory of First Aid Supplies 500-2 Annual / Quarterly GSEP Trailer Inventory 500-3 Quarterly St. Joseph Hospital Emergency Cart Inventory 500-4 Monthly Decontamination and Medical Area Inventory 500-5 Quarterly Technical Support Center Inventory 500-6 Quarterly Operational Support Center Inventory 500-7 Operational Checks of Communications System 500-8 Quarterly EOF Inventory
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The licensee has provided checklists to be initialed when each item in the inventory is verified. A listing is provided of the instruments that are required with functional test and current calibration verified by initials.
A log sheet is provided for listing deficiencies found.
The Emergency Notification System (ENS) is checked daily except for weekends and holidays. The Nuclear Accident Reporting System (NARS) is checked monthly on the first Tuesday of each month from the following locations:
Control Room, Technical Support Center, Emergency Operation Facility, and the Corporate Command Center.
The GSEP radio and phone system in the Control Room, Technical Support Center and the Operational Support Center require weekly checks in the procedure.
The licensee does not include in their communications check procedure the test for communications with the NRC Regional and Headquarter's Operation Centers from the Control Room, TSC and EOF as required by Section IV.E.9.d in 10 CFR 50, Appendix E.
Based on the above findings, the following action must be taken to achieve an acceptable program:
EPIP 500-7 shall be revised to ensure that the communication checks with
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the NRC as required by 10 CFR 50, Appendex E,Section IV.E.9.d are con-ducted.
5.5.2 Drills and Exercises Drills and exercises are administered and conducted in accordance with written scenarios developed in advance of the drill. All drills provide for licensee observers who submit written comments following the drill.
These comments, in addition to directives received from corporate head-quarters, are used to make changes in future drills, to upgrade emergency procedures, and to take corrective actions where necessary. The inspectors reviewed records of a recent drill and determined that a written scenario had been used and written comments had been provided by licensee observers.
Quarterly communications and fire drills, annual medical and' radiological monitoring drills, semi-annual health physics drills, and an annual exercise are conducted. The medical drills are coordinated with Radiation Management Corporation (RMC).
Based on the above findings, this portion of the licensee's program is acceptable.
5.5.3 Review, Revision, and Distribution of Emergency Plan and Procedures The station EPIPs are prepared or revised in accordance with Dresden Administrative Procedure DAP 9-2, and distributed in accordance with DAP 9-1.
These procedures describe the onsite reviews, required approvals, and distribution responsibilities. The determination of who approves each type of procedure is addressed in accordance with DAP 9-2.
The Procedures Manager described the approval mechanism and the means for determining onsite
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and offsite distribution of cottrolled emergency preparedness documents.
Corporate emergency procedures (EOF, CCC, ED, and EG series) are prepared by cognizant corporate staff, reviewed by the Radioecology/ Emergency Planning Supervisor, and approved by the Division Vice-President, Nuclear Stations.
Based on the above findings, this portion of the licensee's program is acceptable.
6.0 Coordination With Offsite Groups 6.1 Offsite Agencies The licensee has made arrangements with offsite organizations whose help may be needed in the event of an emergency. These organizations are:
1.
Illinois Department of Nuclear Safety 2.
United States Department of Energy 3.
Illinois State Police, District No. 5 4.
G.E. Morris Facility 5.
Illinois' Emergency Services and Disaster Agency 6.
Coal City Emergency Squad 7.
Will County Sheriff 8.
Grundy County Emergency Services and Disaster Agency 9.
Will County Emergenci Services and Disaster Agency 10.
Morris Fire Department 11.
Coal City Fire Department 12.
Grundy County Sheriff 13.
St. Joseph Hospital, Joliet, Illinois 14.
Minooka Emergency Services and Disaster Agency 15.
United States Coast Guard Station 16.
United States Army Corps of Engineers 17.
Channahon Emergency Services and Disaster Agency 18.
Kendall County Emergency Services and Disaster Agency 19.
Murray and Trettel, Inc.
20.
Radiation Management Corporation 21.
Hazleton Environmental Sciences 22.
Illinois Emergency Services and Disaster Agency, Region V An annual renewal of the Letters of Agreement was sent to all of the above organizations on September 18, 1981, with a request that it be signed and returned. The letter also offered to acquaint individuals in the organ-izations with the Dresden Nuclear Power Station and to answer any questions about radiation safety and emergency planning. As of the time of this appraisal, all but three letters had been signed and returned. The missing letters were from the Minooka Emergency Services and Disaster Agency, Illinois Emergency Services and Disaster Agency (Region V), and the Illirois Department of Nuclear Safety. The reasons for the unreturned letters are:
Minooka ESDA The Director was recently replaced and the licensee has been making efforts to contact the new director.
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Illinois ESDA The Director recently had a serious operation and has Region V been hospitalized. The Licensee has contacted Illinois ESDA Region III (which is nearby) to check on the status of the letter.
Illinois According to a representative of DNS, there is no problem Department of with the agreement and DNS will respond when needed.
Nuclear Safety However, staff attorneys have recommended against signing a letter because of a difference of opinion between the State and the licensee on when the initial payment of fees to the State is due under recently passed legislation.
The inspectors conducted interviews with representatives of five of the above organizations and talked with three others by telephone.
In all cases the individuals expressed complete satisfaction with the cooperation they receive from the licensee and of the programs offered to them. They were aware of their responsibilities and confirmed that they would respond when called.
They are confident they can get on site, if necessary, with minimum delays and this has actually been done in several instances by one of the local fire departments. The organizations have controlled copies of the licensee's emergency plan and are given changes when they occur. In the case of the State agencies, they are familiar with the EALs and are in full agreement with their respcnses to the various categories of accidents. The Nuclear Accident Reporting System (NARS) form was developed jointly by the State and the licensee and is used by the licensee to notify the State.
Based on the above findings, this portion of the licensee's program is acceptable.
6.2 General Public and Transient Populations 6.2.1 Information Distribution Emergency information pamphlets describing what to do in case of an emergency at the Dresden Nuclear Station were mailed to the general permanent population within the ten mile EPZ.
In addition, bulk deliveries were made to motels, parks, and other such places where the transient adult population would be located. A log is kept of locations and dates of these bulk deliveries.
The pamphlets contained a statement that further information could be obtained by contacting the licensee's public information office, but very few requests for such information were received. The pamphlet also gave the address of the State and local agencies who could provide more information. The licensee stated a similar mailing will be made next year and that other alternatives are being considered for future years, such as putting the information in the telephone book. The pamphlet contains information on radiation, actions to take in the event of an emergency, and the means by which the public would be notified of an emergency.
Based on the above findings, this portion of the licensee's program is acceptable.
- 28 -
~ - -
-
- -..
6.2.2 Prompt Notification of the Public Currently, CECO has not installed a prompt public notification system meeting the design objectives of Appendix 3 of NUREG-0654, Revision 1.
Established schedules for the system are as follows:
ITEM DATE Survey Completed Complete Equipment Bids Solicited Complete Equipment Ordered Complete Equipment Received November 16, 1981 Equipment Installed February 22, 1982 Fully Operational March 22, 1982 10 CFR 50, Appendix E, Section IV.D.3 requires, in part, that the licensee shall demonstrate by February 1,1982, that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. The design objective shall be to have the capability to essentially complete an initial notification of the public within the plume exposure pathway EPZ within about 15 minutes.
The licensee has not submitted to NRC a description of the prompt notifi-cation system being installed. This must include a description of how the following design objectives will be met:
(1) the system will assure direct coverage of 100% of the population within 5 miles of the site; (2)
arrangements will be made to assure 100% coverage within 45 minutes of the population who may not have received the initial notification within the entire plume exposure EPZ; and (3) capability for providing both an alert signal and an informational or instructional message to the population on an area wide basis throughout the ten mile EPZ, within 15 minutes.
Based on the above findings, the following action must be taken to achieve an acceptable program:
.
The licensee shall submit a description of the prompt public notification system including sufficient information for NRC review to ensure that the design objectives of Appendix 3 in NUREG-0654, Revision 1, are met.
This description must clearly indicate when the system will be fully operational.
6.3 News Media The inspectors discussed the current news media program established by the licensee relevant to disseminating and coordinating accurate information to news media organizations. A Reporter's Guide brochure has been prepared and covers the following subjects:
operating cycle of a BWR, radiation, emergency planning, training, and a glossary of common reactor / radiation terms. This guide was dissec4nated to radio /tv/ newspaper media personnel just prior to the annual exercise, which was held on September 30, 1981. Training for media personnel is offered by the licensee, and special press days for briefing and tours are conducted in conjunction with the annual exercise.
Based on the above findings, this portion of the licensee's program is acceptable.
- 29 -
-
-
-
-
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-. -
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.
.
.
.
.
-
.
.
-.
6.4 Contractors and Vendors The inspectors discussed the functions and tasks of the NSSS vendor (General Electric) with the onsite GE representative at the Dresden Site.
GE will provide within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, a team of experts to. assist and support the licensee.
GE maintains a 24-hour / day duty system for rapid activation of the service. Further, an analysis support group in San Jose, California will assist the GE team and the licensee. A Letter of Agreement with GE has been executed. EOF procedures exist to coordinate advisory support from GE and other support organizations such as the Institute of Nuclear Power Operation (INPO).
Based on the above findings, this portion of the licensee's program is acceptable.
7.0 Drills, Exercises, and Walkthroughs 7.1 Drills and Exercises All drills / exercises required by the plan and procedures have been conducted in accordance with established criteria and coordinated with offsite agencies.
Based on the above findings, this portion of the licensee's program is acceptable.
7.2 Walkthroughs of Emergency Response Personnel The inspectors conducted several walkthroughs of the following emergency tasks: emergency detection, notification, protective action decision making, offsite environmental monitoring, dose calculations, and post-accident sampling using the interim procedures. The onsite emergency response walk-throughs included several Shift Engineers, Shift Foremen, Station Group Directors, Rad / Chem Technicians, security personnel, and Health Physicists.
Most individuals interviewed were aware-of their emergency responsibilities and roles. Training was provided to those interviewed. Walkthroughs of Rad / Chem Technicians and Health Physicists involving offsite environmental monitoring and post-accident sampling indicated that they were properly trained in plume monitoring techniques and the interim post-accident sampling techniques. All individuals were aware of proper sample / survey
,
locations. Walkthroughs of security personnel indicated that they'were
.I aware of proper implementation of security procedures during emergencies.
Walkthroughs of Station Group Directors indicated that they were aware of their. emergency responsibilities and the means for. implementing them.
Walkthroughs of Shift Engineers and Shift Foremen (Acting Station Directors)
indicated a basic lack of ability to make protective action decisions.
Al-though most individuals were able to correctly classify emergencies and make proper notifications given different scenarios, they were unable to make adequate protective action decisions. Although Table I of EPIP 300-1 provides protective action guidelines, few of the Acting Station Directors referenced this table, and those that did had difficulty in determining the correct protective action recommendation. None of these individuals was-aware 'of the means for determining whether projected doses offsite exceeded
- 30 -
-.J
the EPA recommended Protective Action Guides (PAGs). A revised protective action recommendation table was used by the licensee at the exercise con-ducted at the Dresden site. This table has been incorporated in the EOF and CCC series of procedures; however, it is not used in the licensee's carrent Station EPIPs, nor is it in the current version of the licensee's GSEP. This revised table is superior to the licensee's current table in that initial protective action recommendations are consistent with the guidance in Appendix 1 of NUREG-0654. The licensee must incorporate this new table into their GSEP and appropriate EPIP(s), and train all Station Directors and Acting Station Directors in its use.
- Based on the above findings, the following action must be taken to achieve an acceptable program:
The licensee shall incorporate the revised protective action recom-
.
mendations table (Table 6.3.1) into the GSEP and appropriate Station EPIPs. All Station Directors and Acting Station Directors shall be trained on the use of this table for protective action recommendations decision making.
8.0 Licensee Actions on Previously Identified Items Related to Emergency Preparedness For the purposes of tracking, all of the following previously identified items are considered closed, and those items not completed have been re-opened in this report. These previously identified items are as follows:
The location of the interim OSC is inadequate, and as such the OSC
.
could not function effectively for a protracted period of time.
An accountability procedure should be drafted so that all licenree
.
personnel can be accounted for if an assembly should occur at any time.
The interim post-accident coolant sampling procedure is inadequate.
.
Incomplete emergency training of RCT personnel.
.
Lack of adequate shielding at sampling stations for containment and
.
reactor coolant samples and in the hot laboratory.
Poor hot sample handling practices indicating incomplete rehearsal of
.
emergency procedures.
Inadequate procedure for estimating emergency noble gas release.
.
Lack of guidance on the use of portable instruments for plume monitoring.
.
9.0 Persons Contacted CECO Personnel
- D.
Scott, Station Superintendent
- D. Farrar, Assistant Superintendent, Administration and Support Services
- 31 -
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R. Ragan, Assistant Superintendent, Operations J. Eenigenburg, Ascistant Superintendent, Maintenance
- W. Brenner, Emergency Planner, CECO
,
- R. Stobert, QA Enginee'
'
M. Dillon, Fire Marshall
- T. Blackman, Procedures Manager
- D. Reece, GSEP Coordinator S. Mcdonald, Chemistry Supervisor B. Berg, Rad / Chem Technician T. Smith, Technical Staff, Engineering P. Garnier, Chemist J. Toscas, Public Affairs Staff, CECO T. Schneider, Chemist B. Saunders, Director of Security W. Pietryga, Shift Control Room Engineer
0. Flowers, Rad / Chem Engineering Assistant i
- T. Gilman, HP Supervisor
- G. Myrick, Rad / Chem Supervisor
!
L. Leonard, Public Affairs Staff, CECO
!
D. Petkus, Public Affairs Staff, CECO B. Zank, Training Supervisor J. Schrage, Health Physicist W. Rath, Training, Staff D. Niswonger, Storekeeper D. Rink, Storekeeper Staff R. Mitzell, Shift Foreman V. Rockovski, Shift Engineer R. Falbo, Office Supervisor R. Black, Shift Engineer R. Goodin, Shift Engineer M. Wright, Operating Engineer M. Parcell, Shift Foreman J. Wujciga, Operating Engineer R. Holman, Shift Engineer J. Mayer, Security Staff P. Markezich, Administrative Staff D. McDowell, Shift Foreman J. Bell, Maintenance Staff D. Strobel, Shift Engineer T. Ciesla, Assistant Technical Staff Supervisor J. Golden, Supervisor, Health Physics and Emergency Planning, CECO
- J. Brunner, Technical Staff Supervisor J. Almer, Operating Engineer C. Rawlins, Rad / Chem Engineering Assistant D. Pagel, Health Physicist R. Facchina, Shift' Engineer R. Arnoldi, Rad / Chem Engineering Assistant L. Litterski, Meteorologist, CECO B. Mayer, Computer System Supervisor, Ceco K. Collins, Environmental Engineer, Ceco R. LaPlaca, Environmental Engineer, CECO
- 32 -
--_-
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Non CECO Personnel R. Burrill, GE Representative G. Zucchi, Burns Security D. Rolando, Burns Security H. Majetich, Burns Security A. Everette, Burns Security G. Duncan, Burns Security M. Harris, Burns Security J. Temple, Grundy County ESDA R. Coleman, Morris Fire Chief G. Phillips, Grundy County Sheriff's Department D. Ulivi, Coal City Fire Chief R. Madsen, St. Joseph Hospital Safety Coordinator D. Ed, Illinois Department of Nuclear Safety D. Weiss, Illinois ESDA
- Denotes those present at the exit interview.
10.0 Exit Interview The inspectors and senior management from NRC Region III met with licensee representatives (denoted in Paragraph 9) at the conclusion of the appraisal on November 10, 1981. The inspectors summarized the scope and findings of the appraisal.
- 33 -
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