IR 05000255/1985033

From kanterella
Jump to navigation Jump to search
Insp Rept 50-255/85-33 on 851216-19.No Violation,Deficiency or Deviation Noted.Major Areas Inspected:Emergency Preparedness Program,Including Emergency Detection & Classification & Training
ML20136J136
Person / Time
Site: Palisades Entergy icon.png
Issue date: 01/06/1986
From: Patterson J, Phillips M, Williamsen N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20136J125 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.A.1.1, TASK-TM 50-255-85-33, NUDOCS 8601130220
Download: ML20136J136 (13)


Text

,. _

.r

'.'

-

i s

U.S. NUCLEAR REGULATORY-COMISSION

. REGION-III

,

Report No.:50-255/85033(DRSS)

~

. Docket No. 50-255 License No. DPR-20 2 Licensee: Consumers Power-Company 212 West Michigan Avenue

' Jackson, MI : 49201

' Facility Name':. Palisades Nuclear Power Plant

. Inspection At: 1 Covert, MI

~

Inspection Conducted:

December 16-19, 1985-1$ &

% b/Yb

,

Inspectors:

~J. Patterson

~

Date(/

-

'Y^

jh.&-w N Williamsen.

(M*(9 / WI

'

-

Date

'

,/2

.

Approved!By: - M. _ P.

hillips, C ef-

[/fN Emergency' Preparedness Section Date ~

Inspection Summary Inspection on December 16-19, 1985 (Report No. 50-255/85033(DRSS))

Areas Inspected: Special, unannounced inspection of the following areas of the emergency-preparedness program:

emergency detection and classification; notifications and communications; and, training related to the licensee's y

commitments ;to improve their emergency preparedness program, particularly those areas defined-as a result _of the August 20, 1985 annual emergency exerci se.-

The inspection involved 73 inspector-hours onsite by two NRC

inspectors. ~

Results:

No violations,-deficiencies'or' deviations were identified as a result.of this inspection.

e

0

.

-

.

.. _-

-

...

.-

.. - -_----

'

qt,

.

.

-

DETAILS

,

1.

' Persons Contacted

~

J. Firlit, General Manager, Palisades Plant

  • P. Loomis, Emergency Planning Administrator, Corporate

"

.*J. Brunet, Site Emergency Planning Coordinator

'*W. Beckman, Radiological Services Manager

  • D. Fugere, Emergency Planner, Corporate
  • L. Kenaga, Staff Health Physicist
  • D. Fitzgibbon,~ Senior Licensing Engineer b

- *R.- Fenech, Technical Engineer

  • W. Merwin, Training Administrator, Palisades

A. Katarsky, Senior Nuclear Planner, Corporate

.

J. Lewis,. Technical Director C. Kozup, Operations Superintendent R. Frigo, Lead Shift Engineer S.Ghidotti,--Shift Supervisor M. King, Shift Engineer / Shift Technical Adviser, (SE/STA)

B. Bauer, SE/STA r

-

M. Genrich, SE/STA J. Hanson, SE/STA D. Sibo,-Emergency Operations, Michigan Station Police (telecon)

N._Willars, Health Physics Technician

'

R..Walters, Health Physics Technician D._Stoneberg, Health Physics Technician

'M. Hobe, Emergency Preparedness Training Instructor, Midland Training

,

Center (telecon)-

.

2.

Licensee Actions on Previously Identified Items Related to Emergency Preparedness a.

'(Closed) Open Item No. 255/85007-01:

Notifications to offsite-agencies _were untimely for a Notification of Unusual Event (NUE)

r on January 23, 1985.

Subsequent evaluation of this event by the licensee concluded that the Technical Specification Requirement 3.17.4 was'not violated, and therefore the NUE should not have been declared. The NRC's evaluation of the incident determined that if the SED chose to declare-the event as an NUE, this was done as a

.

result'of his best professional judgment ~and subsequent discussions i

L and evaluations ~cannot correct the initial failure to carryout a timely notification.

,

To address NRC concerns as a result of this incident, the inspector

.

verified that additional training sessions on EALs and their related classifications have been conducted.

Table-top drills were also

part of the training format. The correct classification and

-reporting of 26 NUEs since April 1985 clearly demonstrates that this concept is better understood by Control Room personnel.

This

item is considered closed.

2

.

-. ~

-

.

.

.-

. _

. _._ ___.__ _ _

,_ _ _ _ _ _ _ __ _. _. - _ _

_ _ - _.

..

..

.

.

b.-

(Closed).Open Item No. 255/85007-02: ' Based on interviews with six Shift Engineers (SE) who also served as Shift Technical Advisors (STA) in the March 18-22, 1985 inspection, it was concluded that the licensee should consider methods to lessen some of the direct emergency responsibilities assigned to the SE/STA as the initial Site Emergency Director.

Also, a related objective was to ensure that he can adequately perform his STA duties in accordance with

,

the description in Task Item 1.A.1.1 of NUREG-0737.

The inspector concluded through review of related training session information and interviews with four SE/STA's, the Lead SE, and a Shift Supervisor (SS) that the SE/STA, in general, now feels more at. ease in accepting these emergency duties.

All SE/ STAS interviewed still preferred to make their own initial notification to State, Counties and_the NRC, even though the site EP Group has provided additional training for Auxiliary Operators (A0s) to make these notifications.

As listed in the preceding paragraph (a), actual demonstration in response to 26 NUEs has not uncovered any difficulty in performing these functions.

This item is considered closed.

c.

(Closed) Open Item No. 255/85007-03.

A Severity Level IV violation

,-

l was assessed as a result of the March 18-22, 1985 inspection.

Lack of required annual training for two Operational Support Center (OSC)

designees, two Health Physics Support Group Leader designees for the Technical Support Center (TSC), and one Chemistry Supervisor designee for the OSC was identified.

To prevent recurrence, in addition to training those with emergency functions as listed above, the licensee has completed an in-depth

revision of their emergency preparedness training module requirements, so that each individual, by emergency title, knows which training modules he or she is required to complete successfully within a certain month.

This schedule will be monitored by the EP group, and a short memo will be sent to each individual's supervisor reminding him of the high priority of this emergency training and to schedule his staff as identified in the memo.

This more systematized method, with the cooperation of the Midland Training Section and licensee management, should eliminate or greatly reduce the possibility of omitting EP Training.

Based on these findings, the inspector considers this item closed.

d.

(Closed) Open Item No. 255/85007-004.

A review of the training program records for emergency preparedness identified the lack of an audit trail which would indicate which emergency courses are required for each emergency position as well as the frequency required for these courses.

The present review of the current training program showed that an improved audit trail is now available.

A memo has been sent to the supervisor of the emergency position designee 60-90 days before the date that the required courses are given to assure that the person shall attend.

Also, l

several training modules have been revised as part of the corrective actions taken following the 1985 exercise.

Clarification of l

l l

!

'

-

_ _. -

_ _ -.__.__ _

._ -

- _.

. -.

t

-

.

'

,

management roles in the E0F and management interface with the TSC and Control Room are also a part of the actions taken to improve the training program.

This item is considered closed.

e.

Corrective Actions Initiated As a Result of Management Meeting on

,

'

May 3, 1985 (Report No. 50-255/85012(DRSS)

(1) Palisades Plant General Operating Procedure (GOP) No. 13, Revision 1 dated June 14, 1985 has been revised to include statements in Section 6.1.1 that require certain actions to take place if a Primary Coolant System (PCS) leak rate calculation indicates greater than 1 gallon / minute unidentified PCS leakage or. greater than 10 gallons / minute total PCS leakage.

This relates to Commitment 2(a).

The first step listed in GOP-13 was to activate the Site Emergency Plan (SEP) and refer to the Site Emergency Plan Implementing Procedure, EI-1, for emergency classification.

Thus, the EALs and Procedure GOP-13 are now cross referenced for a quicker, more accurate definition of PCS leaks that would require an emergency classification.

Many nuclear plants new have four hour Limiting Conditions.of Operation (LCO) to respond to any PCS leak greater than 1 gallon / minute unidentified which could be NUE.

Palisades does not have this condition, but has applied to the NRC for this four hour LCO.

Also, the inspector reviewed several changes in the EALs that were initiated as a result of the March 1985 inspection, (Report No. 21/85007) including a major revision of stack release information including identification numbers for various stack monitors and containment high range monitors.

These were found to be satisfactory.

These EAL changes and revisions should assist the SE/STA and his Control Room staff to better utilize the EALs and make the correct classification in a timely manner.

The licensee's actions taken to meet Commitment 2(a) are considered satisfactory.

(2) Commitment 2(b) related to special training on the EALs for all SR0s.

This training was conducted by the Site Emergency Planning Coordinator and the Lead Shift Engineer and was completed by June 1, 1985. Through interviews and review of documentation, the inspectors concluded that this corrective action was satisfactory.

(3) Commitment 2(c) was to provide additional simulator training from the previous five days training per year to eight days per year for all licensed operators.

Through a review of training records and interviews the inspectors concluded that

.

this commitment has been met.

'

,

-

,

~

-

,

-

.

(4) Commitment 2(d) was to provide' classroom training on the SEP as-

>

part of the annual requalification training.

This SEP training had been provided to all personnel as part of the initial training.

For requalification training, however, the students

'

had an option of classroom training with an instructor or self-study with assignments and then take an exam.

This first requalification SEP training class chose the self-study method.

A post-training session evaluation by the licensee, found this self-study approach not to be the most efficient and reliable.

,,

,

Since a specific time limit wat not included on this commitment,

'

the licensee must still provide the classroom training on the SEP with an instructor for future requalification training.

This item will be tracked as Open Item No. 255/85033-001.

(5) Commitment 2(e) concerns a review of each emergency event and recommendations to management, when varranted.

The Emergency Plsnning Group has been reviewing each emergency event, maintaining a separate file on activations of the SEP_ including the notification documentation, and recommending corrective actions where wcrranted to the Manager, Radiological Services.

The inspectors also noted the distribution of the details and results of each emerger.cy event to the Senior Licensing Representative ~on site, the Training Department, and Document Control as well as the Manager, Radiological Services.

This commitment originated as a suggestion by the inspection team following the December 1984 inspection (Report No. 255/84029).

The Licensee's action on Commitment 2(e) is considered satisfactory.

3.

Activiation of the Site Emergency Plan i

The inslectors reviewed and evaluated 26 activations of the SEP from May 23, 1985 urtil December 19, 1985.

All amergency~ classifications were correctly made based on the appropriate EAL.

Also, all notifications were made to State and local Counties, and the NRC within the required times. All emergency events were NUEs.

Types of plant conditions which contributed to the 26 activations may be roughly categorized as follows:

9 - Related to PCS leakage or calculation of leak rates 5 - Leakage from specific valves which indirectly caused an NUE

'

3 - Instrumentation, due to missed surveillance test, etc.

3 - Instrumentation, other than above reasons.

6 - Other - Control Rods, Diesel Generator, HVAC, Control Room, Pressure Operated Relief Valves, Fire, Seiche (high level lake water)

Total - 26

,

This is a large number of NUEs, but the licensee is taking steps to reduce the number of emergency classifications in the future.

For example (as listed in Section 2.e), the licensee has applied to NRC

_.

.

o.

.for a four-hour LCO in' which to' correct a'PCS l'eak and/or identify the

. leak rate more accurately.

This should reduce the number _of NUE declarations. 'The long range solution is to conduct a' general review

~ and probable revision of applicable Technical Specifications in conjunction with the related EAL in the emergency implementing procedures.

-

'4.

< Status of' Corrective Actions Initiated to Improve Emergency Preparedness.

Prouram including Res>onses to Emergency Exercise Weaknesses as Identified ein leport No. 50-255/35016 from August 20, 1985 Exercise As'a result of,the licensee's poor performance.in the 1985 annual emergency exercise and other weaknesses in the emergency preparedness

. program two management meetings (September 5 and 20, 1985) were held at

_

.. 'the request of Region-III with Palisades Plant management.

At the second T management meeting Consumers Power Company presented their commitments and goals to improve the emergency preparedness program within specific time lines as well_as actions to be taken to eliminate a repeat of the i

.

conditions which lead to the six 1985 emergency exercise weaknesses.

,

The licensee chose to broaden the scope'of EP areas which they planned to. improve to include certain " improvement type" items from the 1985 exercise report and some items which they identified in the exercise independent _of the NRC findings. These corrective actions were identified by Issue 1 through 16. 'All were identified, reviewed, and evaluated by a

the-inspectors, even though some had completion dates in the future.

An

_ individual assessment was made on each issue. Where applicable, a caveat

.is included which will not allow the NRC to close any of the six open items assigned to the six respective exercise weaknesses until that item can be effectively demonstrated in the PALEX-86 exercise.

However, training related items and procedure changes plus other actions were r assessed independently as part of each issue.

Resolution of each issue is as follows:

Issue 1

.This issue related to an incident in the Control Room in the 1985 exercise when a controller had to prompt the players to issue an A

" Alert" classification.

' Resolution of this. issue included a complete review and revision of the.EALs which was completed.by October 11, 1985.

Specifically,.a

. change in,the Hazards Category of EALs was made which changes a statement that " toxic gases that could affect plant operations, etc." to " toxic gases that do affect plant operations." This eliminated misinterpretatioiiwhich was a contributor to the failure to classify the Alert.

The review and revisions of EALs have been previously described in Section 2.d.1 and are applicable in both references.

A review outline of the PALEX 86 scenario, to better define the actions'and contingency messages and proper controller actions, has been. developed and plans have been initiated to circulate this

,

,

_

.-

-

.

,

outline both onsite'and offsite to the participating State and local

. agencies..This part of the resolution is due July 5, 1986.

Conclusion Icsue 1 has been satisfactorily addressed, with the second part of the issue, a review of the PALEX 86 scenario on schedule.

Issue 2 To assure better utilization of the support groups in the TSC, as

-

well as~to improve communications and coordination with the Control Room, certain changes were made.

,

Resolution was accomplished as confirmed by the inspector who reviewed a change in the TSC organization chart which now has the Control Room reporting to the Operations Support Group and bypassing the Operations Support Team and two other support teams.

The Operations Support Group Leader reports directly to the Site Emergency Director (SED).

Table-top exercise discussions were: held between the SED and his counterparts in the Control Room, namely the SE/STA and the. Shift Supervisor (SS).

This training, as verified by

_

the inspector, was completed on November 30, 1985.

Conclusion

' Issue 2 has been satisfactorily completed as evaluated by the inspectors.

Issue 3 This issue concerned the general observation of the 1985 exercise

~

,

that there was too much simulation by the players., '

,

Resolution has been addressed by inserting a statement in all SEP lesson plans for training modules that simulation shall be kept to a minimum in practice drills as well as the annual exercise.

A drill /

exercise " Ground Rules" bulletin has been distributed to all those with emergency response functions stressing avoidance of simulation.

The October 11, 1985 drill which included OSC players and offsite radiation monitoring teams used real conditions and equipment such as anti-contamination clothing, respirators, signs, ropes, step-off pads, also actual radiation readings were requested of the monitoring teams by controllers.

The inspectors review considered the corrective actions on Issue 3

'

to be satisfactory, while reserving the possibility of observing an actual drill in the future involving players with emergency funct.icns,

'

prior to PALEX 86.

Completion dates as stipulated in the licensee's response have been met.

,

V (-

%

-

..

-

-

-.. -

- _

-..

~..

.. _ __ _ _

__

. _ _ _...

.....

._ _

'

-

,

. -

'

,

,

I~

-

-Issue 4

.This. issue related<to poor contamination control practice in the OSC areas. -Step-off puds were not used, and contamination and radiation boundaries were nyt set up.

Resolution has been addressed by stressing the reduction in simulation
(IssueL3) and emphasizing improvement of "dri11manship" through-training sessions. including the October 11, 1985 drill.

The inspector reviewed'the lesson plan for this drill and found it thorough and.

.

objective.in scope.

Interviews with three Health Physics (HP).-

'

Technicians,(determined that the maps of Van Buren County and Berrien

' '

County, which were.in the offsite' kits were outdated and did not i'

correspond with current locations and road signs.

This made it Edifficult for the offsite. teams to follow instructions from a

-

-Communicator who was using'a different map..This was discussed at i

~the' exit meeting, and it will be considered an open item until-resolved satisfactorily. Open' Item No.- 255/85033-03.

A-table-top exercise / discussion of the radiological impact of the

'1985 exercise scenario was held.

HP staff with OSC responsibility and the'TSC responsibility in the exercise, discussed from an

" analytical approach,' how to detect and quantify the radiological v

hazard.

' The' inspectors learned from information received in interviews that some.HP technicians felt that a step-off pad could be confusing to

non players and'its presence would slow down work going on in the plant.

A comment was made that a method.must be developed so that non players would not be impeded by the s_tep-off pad and could avoid it some way. The inspectors concluded that the step-off pad should

'

,

~

still-be..used to add _ realism, and the problem was not insurmountable.

.

'

'

The EP Coordinator, with management support, should use a step-off pad'and any other. equipment-needed to meet realistic' conditions of

>

-

M:

controlling surface contamination.

Until this emergency-mechanism

.is installed and used11n a drill, this is. considered an.0 pen Item iai

'

'N (No.=255/85033-04).

%['

Issue 5 This issue involved poor techniques in sampling and handling plus y;6 some simulation'in obtaining the post accident samples and an excessive elapsed time of-approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

-

4:

Resolution was addressed by modifying Lesson Plan EPT-02-07 to gn emphasize that the OSC Director must consult with the TSC HP Section

>

L Group Leader.to establish priorities relating to PASS' samples when

"

'..

conflicts occur.

The second part of Issue 5 resulted in a more comprehensive organization chart for Controllers to assure sufficient

'

Controllers will be available for PALEX 86.

Comprehensive training

.m i'V'

for Controllers is not scheduled for completion until July 1986.

- This SEP training included OSC personnel as HP Supervisors, Chemistry

,

i s

4

,a-i,.

m.

mL w

.

_

-

.,,

_

_--.,e

.. ~

..,. -.... -. -..,, _..

..., - -, - -, _. ~, - - - -, - -

,

e

-
g

.

-

f~

TS'upervisors, Chemistry Technicians, and HP Technicians.

Corrective

'

actions for-Issue 5 are considered satisfactory and completion dates have been met.

~.y a.

Issue 6

-

'This issue' involved player. attitude' problems.as observed in the 1985

'

exercise. -In a'few instances, players appeared to be distracted from

~their primary role of emergency response.

Other types of examples-of

'

improperJattitudes were observed in-some of the Emergency Response

' Facilities-(ERFs) and with.some emergency. teams.

' Resol'utions of this problem has been addressed by the licensee issuing-

_. '

d /'

-a. generic' list of performance standards which are geared to improve i

N

"dri11manship." Also, a more specific set of instructions entitled

" Player Performance Instructions'!' has been distributed to all who have emergency response responsibilities. 'These lists will be issued

.;,

periodically throughout~the year and revised as appropriate.

This

"

>

part of. Issue _6 has been completed satisfactory.

.

To'get earlier. involvement and input to the annual exercises, the objectives of PALEX-86 will be distributed to the plant staff by

' July l30,.1986.

These objectives will not include any specific exercise information that would affect the exercise scenario or

.

' spontaneity of the occurrences.

This action should be a positive measure for players' morale as well.

<

Issue 7

{This' issue relates.to poor audibility of the Public Address-(PA).

system in;the Maintenance Support Center (MSC) and the OSC.

This issue was resolved by installing a speaker in the MSC and-upgrading the' speaker'syster 19 the OSC by increasing the range of

.the; volume contro1~of the ins alled speaker.

This has been tested

_

. for audibility.by the Th ger y Preparedness Coordinator, and this

. issue was satisfacto l'.i cco,eted by October 30, 1985.

y '

Issue 8 This issue related to comments.from the NRC observers in the TSC 5for the 1985 exercise as well as informal discussions with licensee

'

+( h.

management on the adequacy of:the TSC as a functional ERF with the

.

prcsent arrangement of office cubicles which proved awkward from an 3p, i ^, _

efficiency standpoint in the 1985 exercise.

%p An evaluation of the TSC' design and layout is being made; however,

^'t

~it-.is in the formative stage.

Management has not reviewed any

.' proposed changes yet'.'

No time deadline is set on this issue. To

.

A track the progress.of this TSC design issue, this item will be

. considered Open Item No. 50-255/85033-005.

.g W

Q:

,

-

%

%

.

.

..

.-,

...

-. -. -

.

-

-

.

.. _.

.

p

>

,

.

_

-

}v

.

-

.

f

'

.:

.

??.

--

A

,

Issue 9-

,

.This issue:related to the inadequacy and poor placement of'the trend

,

graphs.in the TSC.

Trend graphs'using larger scale increments for (plotting to include five reactor parameters for trending were-recommended.by plant reactor operations staff. LThese-larger. trending

,

.

-

graphs ~.were. received from the vendor during the inspection. The inspector examined them briefly and'found.them acceptable.

The

,

~

graphs will.be mounted in.the TSC as soon as possible.

This~ item is

_

,

,

considered closed.

.

o

-

,

"

' Issue 10

'

.M

'f~

i

.This-issue relatedfto better training for exercise Controllers to improve their performance during practice drills and the annual NRC

_

evaluated exercises.

-

To resolveLthis. issue the-licensee has. established a 1986 Scenario Committee.

Also, more Controllers will be available through issuance Lof a new organizational chart to assure enough Controllers for

PALEX-86 (reference Issue 5 listed previously). 'A draft of the i

PALEX-86. objectives has'been issued ~and the State and County.

objectives have been defined through interface with the licensee's

.

Emergency Plar.ning Administrator. Comprehensive Controller-training h

is scheduled to be completed by August 1986 just prior to PALEX-86.

^

This' training program; which also includec scenario discussion and 1 training, will be monitored by NRC.

m Issue 11

-

Thistissue related to a shortage of Controllers in the 1985 Exercise, particularly for the OSC repairiteams and other support functions.

Resolution of this issue has been reviewed and evaluated by the inspectors as part'of Issue 5 and Issue 10, except for the 1986 time

. lines'for completion by August 1986.

Issue 12 This issue related to an. independent finding by the licensee which

~

was.that:the utility, State, and local government representatives in the Joint Public Information Center (JPIC) did not act as a team in

'the Command Center prior to scheduled briefing.

'

,

This issuetis being resolved by training of licensee personnel and also by practice drills with State and local government representatives prior'to PALEX-86.

Progress on this issue will be evaluated near the scheduled completion date of July 29, 1986.

.

Issue 13 This issue related to the misunderstanding by some 1985 exercise

,

players of the responsibility and authority within the EOF,

.

y

-

.-..

-g--e

-~.,,,,,-ve-y-,.w,-,r.,1.,,,,y-w,,-.

w

,

,.v y, e

v...r-,,,y-

, -,e,,,%,..1,i m,

w,,

..

...n...,,----m---.--wy 3-

..~-+..,s

--w

-

--

,

g

-

. y..

e

... _

-

w

~

1particular1yLfor the positions of E0F Director and HP Team Leader.

_

. -

~ Resolution of.this issue involved a revision of General Office

"' '

.Res'ponse Team (G0RT)/ EOF Implementing Procedure GEN-1-Overview and

'

'

Procedure l EOF-1 (Emergency Officer), both which were revised as of October, 28,1985_to clearly state that'any conflicts between the Site

' Emergency Director (TSC) and the:E0F Director will be. resolved by the

-

.

-

Emergency Officer.

Procedure EOF-2, Emergency Operations Facility Director, also has been~ revised as of October 28, 1985'to emphasize the priority of responsibilities for this position particularly as related to1the. EOF Director and his counterpart in the TSC, namely

'

the_ SED.

Also,.a hands-on training drill, which' included certain management representatives _who would be assigned to the EOF, was bald on' November.'19, 1985.

The E0F Management Training Module has been

.. improved to include more specifics on defining management roles in the E0F.

This revision has.been corpleted.

Only inclusion of these

~

. changes in: defining emergency positions in the E0F still need_ to be

made in an' Emergency Plan revision, specifically Sections 5.4.1,

.5.5.10, and 5.5.15.

This part of.the revision will be monitored

'

,

,

'

under Open Item No. 50-255/85033-006.

+

Issue'14 TThisissue:related!totheinabilityoftheEOFHPteamtoadequately

' assess the magnitude, location, and composition of the radioactive plume. This resulted in Objective 9 of the 1985 exercise not being cfully accomplished.

To resolve this_ issue, the. licensee has completed some facets while others will not be completed until July 1986.

A drill involving GORT

and the offsite monitoring teams in a mini-scenario.was held prior to October 15, 1985. A drill critique and discussion followed where

' specific emergency functions and related scenario' conditions were a

reviewed.' 'Also, a decision was made to use only qualified knowledge-

-

"able HPs as communicators with offsite monitoring teams. This should improve the quality of this position for future emergency events--

'

real or otherwise.

A more efficient and practical method is being

-

developed for. controlling the offsite teams;..however, none was formalized at the inspection time.

An EPIP procedure is being revised on how to better. utilize the radiation survey data from the offsite-teams. Plans are being developed by HP specialists in the Corporate Emergency Planning Group to use HP-dose rate trend graphs in the' EOF which will compare whole body and thyroid dose rates as calculated in the EOF with actual dose rates reported by the offsite n-teams. This plan is still in. draft form, but from information received by the inspector this plan is on schedule and should be

' effective by the agreed time ~of July 1986.

The inspector concluded that much technical review and diligence have

'

gone'into meeting Issue 14.

Meaningful progress has been made to increase the dose assessment and plume tracking capabilities in the

'

' EOF.

This issue will be followed to completion by the NRC as Open Item No. 50-255/85033-007.

+

.'

.

Issue-15'-

This11ssue related to the. EOF HP team failing to properly perform

required dose assessment, functions resulting in some confusion

_

between the utility and the: State of Michigan on source term and calculated' dose rates.

.To resolve this issue, a table-top discussion of the 1985 exercise

'

scenario was held October 3,21985,-involving 19 personnel.

Areas

discussed were the importance of establishing a so' ce term, the
need to communicate with the TSC HP team and the State of Michigan,

.

and'an emphasis on the prime responsibility of the E0F, namely to

. protect the health and safety of.the public.- Additional-training is' planned on dose assessment for key personnel whose duties could sinclude this competence. -The first session has been scheduled for

.the first quarter of 1986.

Additional drills planned for March-April

'

1986 involving _the EOF.HP team with the Palisades TSC. 'The current

'

manual dose assessment procedures are being computerized to include such components as_the calculated source terms, decay factors, dose calculations, and notification form completion.

The inspectors confirmed that this facet is being worked on; the-completion date-is June 1986.

- Since three of the four areas planned to meet this cor ve action

,

,

are not scheduled-for completion with varying dates June 1986,

these actions must be considered incomplete except for the initial-

-table-top discussion on October 3, 1985.

The three areas described

.above will be monitored by NRC under Open. Item No. 50-255/58033-008.

! ssue 161 I

This issue concerned lack of any decisive management as demonstrated by the interim EOF Director prior to arrDal of EOF Director and

'other corporate personnel in the 1985 exercise.

-To resolve this, the licensee has revised Procedure EOF-3 to establish a position of EOF Administrator whose responsibilities are clearly defined to manage the E0F and direct actions ~of plant personnel prior to arrival of the EOF Director.

Hands-on training was conducted on December 4, 1985 for three of the four designated EOF Administrators.

The EOF. Management Training Module will be enhanced to include more

. specific information on-this and other management roles in the EOF.

The inspector determined that this phase was on schedule.

Procedure EI-4.3, Section 4.2.b has not yet been modified to eliminate the position and title of " EOF leader", the position in question as the main concern in this issue.

This procedure is scheduled for revision.

~

J5.

. Exit Interview

-

The inspectors held an exit interview on December 19, 1985 with those licensee representatives-denoted in Section 1 of this report.

The

' -

. inspectors' determined from the licensee that none of the information

_

<

.-

+.

.

discussed was proprietary in nature. _The inspectors discussed the scope

'and preliminary findings of the inspection.

The scope included a synopsis of the 16 issues and the status of their response as corrective actions to the six' exercise weaknesses and other areas of emergency preparedness. The inspectors emphasized that this was a special inspection to evaluate the corrective' actions taken as followup to three management meetings held since the March 1985 inspection.

The Chief, Emergency Preparedness and Radiological Protection Branch, Region III, was also present for the exit interview and made some remarks on the progress made by the licensee on their emergency preparedness program as evaluated by the inspectors.

-

13