IR 05000266/1987012

Insp Repts 50-266/87-12 & 50-301/87-11 on 870601-05.No Violations,Deficiencies or Deviations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Action on Previous Open Items & Activation of Emergency Plan

ML20216J496
Person / Time
Site:	Point Beach
Issue date:	06/19/1987
From:	Christoffer G, Foster J, Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20216J492	List: IR 05000266/1987012 ML20216J486
References
50-266-87-12, 50-301-87-11, NUDOCS 8707060051
Download: ML20216J496 (14)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-266/87012(DRSS); 50-301/87011(DRSS)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Power Plant, Units 1 and 2 Inspection At: Point Beach Site, Two Creeks, Wisconsin Inspection Conducted: June 1-5, 198'7 ,

Inspectors: J. Foster Team Leade

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Dat,4 f 77

' o 4# 7 Date 60. GJf, 1 G. M. Christof r C/.9/s7 jp Date~

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Approved By: W. In)dil, Chief 6//f/T7 Emergency Preparedness Section Date~

Inspection Summary Inspection on June 1-5, 1987 (Reports No. 50-266/87012(DRSS); '

I IE 50-301/87011(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the Point Beach Nuclear Power Plant emergency preparedness program: action on previous Open Items; activations of the licensee's emergency plan; emergency detection and classification; dose projection; protective action decisionmaking; notifications and communications; changes to the emergency program; shift staffing and augmentation; knowledge and performance of duties (training); licensee audits; maintenance of the EP Program; and LER revie This inspection involved three NRC inspector Results: No violations, deficiencies or deviations were identifie gDR ADOCK0500g6 l

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. 1 DETAILS 1. Persons Contacted Wisconsin Electric Power Company

• J. Zach, Plant Manager

• J. Knorr, Regulatory Engineer

• 0. Stevens, Emergency Preparedness Coordinator

• D. Schoon, Licensing Engineer

• J. Smith, Training Specialist

• H. Glerson, Training Coordinator R. Bruno, Superintendent Training E. Ziller, Shift Superintendent W. Hennig, Duty Technical Advisor K. Rathgaber, Nuclear Plant Specialist, Chemistry

• Denotes those attending the exit interview on June 5, 198 The inspectors also contacted other licens' e e personnel, including members of the Technical, Operating, and Training staf The NRC Resident Inspector was also contacte . Licensee Actions on Previously Identified Items I 1 (Closed) Open Item (266/83018-01; 301/83017-01): Procedures utilized I to classify events did not result in timely classification The licensee was requested to reexamine the responsibility of the SS and the DCS in the classification of emergencies. Relevant procedures l were revised to eliminate the steps which had delayed event !

classification. This item is close j (Closed) Open Item (266/84013-04; 50-301/84011-04): Emergency Action Level Revie Discussion with licensee personnel and a review of documentation indicated that an EAL task force had been formed to review the EALs with the guidance in NUREG-0654, and to consider including reference to fission product barrier analysis. In addition, consideration was given to deleting references to grab or chemistry samples, due to the time required to perform such testing in an accident situatio Documentation indicated that the EAL Task Force had first reviewed specific EALs identified by the NRC as in need of review, then had reviewed all EALs against the guidance contained in NUREG-065 One of the major results of the review was the correlation of reactor coolant iodine concentrations and failed fuel monitor readings to the EALS, enabling removal of a time-consuming sample analysis. The results of the above review were then incorporated into the EALs (EPIP 1.2, Revision 15, dated October 30,1986). This revision changed Categories 2, 4, and 5 to reflect fission product barrier analysis, delete "NRC only" classifications, add station

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blackout in excess of 15 minutes'to the Alert category, and delete j most of Section 5.0 (procedure). Changes were also made to portions 1 of Categories 4, 7, and 8 additionally, Category 9 was' moved to i Category-13. Events within categories were rearranged, renumbered, and page breaks were adjusted for readabilit Further review.resulted.in Revision 16 (dated February 20,1987)

which incorporated rearrangement of, categories into those which have a potential .for escalating to a General Emergency, Site Area Emergency, Alert,.or Unusual Event, with the General Emergency categories coming firs Miscellaneous-changes were also made to the logic of the EALS for clarit Licensee personnel indicated that' Revision 17 to the EALS, to incorporate recent exercise experiences, and to further clarify !

items, is in process. This item is close l c. -(Closed) Unresolved Item.(266/85005-03; 301/85005-03): Lack of Security EALS. At.a meeting held on August 13, 1986,.it was determined that a change to the Security Plan, to provide for security event classification and notification.of offsite authorities, would be acceptable. The licensee developed a set of security EALs.as a part j of the Point Beach Security Plan (PBSP), Section 1.10 (Revision 3, dated October 14, 1986). The inspector reviewed documentation and discussed this item with licensee personne On February 19, 1987, a meeting with the Manitowoc County Sheriff's Department was held to discuss security. EAL communication, and an event coding system was agreed upon. On March 18, 1987, a drill incorporating security events was held, partially to test the new procedures and communications practice Problems experienced in this drill led to further evaluation of the proper location and nomenclature for security EALs. These procedures were subsequently moved to the Duty and Call Superintendent Handbook as DCS (June 3, 1987) " Requirements and Guidance for Immediate Notification to NRC of Significant Events at PBNP", Section 6.0 " Security Reporting." The nomenclature for security events was also changed i to Security Unusual Event, Security Alert, Security Site Area Emergency,.and Security General Emergency, to clearly differentiate j these events from non-security event !

On June 4, 1987, the licensee provided training to the personnel of the Manitowoc County Sheriff's Department on the revised procedures for security events and notification siren usag Licensee personnel stated that the communications procedures and codes.for, security events

'had been added to the Sheriff's Department procedures. -This item i ' close (Closed) Open Item (266/85018-01; 301/86017-01): Location'of Site !

Manager during the previous exercise was unclear. Changes have been made to the Emergency Plan'and EPIPs to indicate that senior onsite .

responsibilities automatically reside with the Plant Operations '!

Manager in case of.the absence of the Site Manager from the sit '  ;

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In addition, changes have been made to the Emergency Plan to allow 1 an individual who is " Site Manager qualified" versus the Site Manager to activate the' EOF, and encourage the Site Manager to remain in the TSC until the EOF is. activated. EPIPs 3.1, 4.1, 6.5, and 6.7 were revised to reflect the above changes. This item is close ;

t (0 pen) Open Item (266/85018-02; 301/85017-02): OSC procedures, and )

logging responsibilities were unclear or deficient during the previous !

exercise. Discussion with licensee personnel indicated that EPIP J has been revised to delete the erroneous reference to OSC activatio l The licensee is evaluating the use of the entire floor where the '

OSC/TSC is located, and how procedures affecting these facilities might best be implemente The format for an OSC Team Status board is also under evaluatio This item will remain open pending completion and formalization of OSC procedure f. (Closed) Open Item (266/85018-03; 301/85017-03): Access card /TLD location problem during previous exercise. EPIP 12.1 " Reentry Procedures for Emergency Operations" (Revision 7, dated February 20, j 1987) has been revised to provide for TLDs to be worn within i protective clothing, and the cardkey (security badge) is to be worn outside of the protective clothing. This will enable rapid access to security doors while wearing protective clothing. Form EPIP-32

" Search and Rescue and Emergency Operations Checklist" was also revised to note the above action This item is close (Closed) Open Item (266/85018-04; 301/85017-04): Health Physics practices for the turbine team during the previous exercise. The I licensee has revised the supplies available in the TSC/0SC to include 3 plastic boots and hoods, and changed the checklist (form EPIP-32)

attached to EPIP 12.2 (Revision 7, dated February 20,1987) to provide for each entry team to have dual survey instruments and bag instruments ,

if a steam environment is anticipated. This item is close j l (Closed) Open Item (266/85018-05; 301/85017-05): The radiation !

control point for the TSC/0SC appeared inadequate during the previous l exercise. Licensee personnel duplicated and evaluated the conditions I which caused the inflow of air from the turbine area to the TSC/0SC I area. Factors involved were found to be turbine building temperature, outside temperature, wind direction and speed. A variety of available operator actions were found which would reverse the airflow. Draft 4 procedures, which included checking for airflow direction and reversing j inflow, were utilized during a drill on March 18, 1987, and were found l to be workable. EPIP 6.5, Section 3.3 (dated April 28, 1987) provides i for assuring that airflow is from the TSC/OSC to the turbine building floo Associated form EPIP-20 "TSC Activation Checklist," now contains a step for verification of airflow directio This item is close l

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l 3. Activations of the Emergency Plan ,

The licensee has had no activations of the Emergency Plan (actual events)

since the last inspectio No violations.of regulatory requirements or deviations from commitments were identifie . Emergency Detection and Classification (82201) l The notification procedures (EPIPs) include criteria for the initiation of offsite notifications and for development of protective action !

recommendations. These procedures require that offsite notifications j for each of the four emergency categories be completed within fifteen I minute !

Licensee documentation showed that the Emergency Action Levels (EALs) had been discussed with State and local officials in 1986, and that current plant EALS had been provided to the Wisconsin Department of Emergency Government on January 20, 198 The inspector interviewed a Shift Superintendent and a Duty Technical Advisor regarding their emergency responsibilities. Both understood that the ultimate decision to declare an emergency could not be delegated by the former to a subordinate. Both demonstrated the capability to classify several sets of abnormal plant conditions in accordance with the plan's EAL Both individuals were adequately aware of the regulatory time limits for initially notifying State, county, and NRC officials following any emergency declaration, and were adequately familiar with procedural guidance used to formulate and document the initial notification message No violations of regulatory requirements or deviations from commitments were identifie !

5. Protective Action Decisionmaking (82202)

The responsibilities for formulating and recommending protective actions to offsite authorities were adequately stated in the plan and EPIP The inspector interviewed a Shift Superintendent and a Duty Technical Advisor. Both clearly understood the minimum offsite protective action recommendation for any General Emergency declaratio Both were adequately familiar with the procedural provisions for performing onsite assembly / accountability, plus the evacuation of non-essential onsite j personnel if conditions so warrante No violations of regulatory requirements or deviations from commitments were identifie _

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6. Communications (82203)

The licensee's notification procedures are consistent with the emergency classification and Emergency Action Level schemes. There are adequate provisions for verifying messages. Current and complete procedures exist for alerting, notifying, and activating emergency response personne The previous Inspection Recorts No. 50-266/86013(DRSS) and No. 50-301/86012(DRSS) indicated.(improvement item) that the Emergency Plan did not require activation of the TSC for an Alert. During this current inspection, the licensee stated that EP 5, Revision 28 (in draft)

provides for the activation of the TSC at the Alert leve Additionally, this revision will require that the TSC be activated in approximately )

30 minutes and fully operational in one hour. The E0F may be activated I during an Alert. If such is the case, the Site Manager will activate I the E0F within one hour with plant personnel, and within two hours by Corporate personnel. This action is considerec' to be consistent with NRC guidanc A second improvement item, also discussed in the above report, was that there was no guidance in the EPIPs on when to make update notifications to State, local and NRC personnel. The licensee's EPIPs currently require that offsite agencies will be updated approximately hourl A prompt notification system for providing prompt instructions to the public within the EPZ was adequately maintaine The communications equipment in the emergency facilities was operable and documentation indicated that the required communication drills had been conducte The portable communications system used by radiation monitoring teams ,

was adequat It was noted that EPIP 1.2, Section 3.2 provides for notification of the NRC of security threats (via the " red phone") within one hour. This is i not consistent with the requirements of 10 CFR 73.71, which provides for I notification of the NRC at differing timeframes according to the severity of the security threa ,

i No violations of regulatory requirements or deviations from commitments l were identified. However, the following item should be considered for 1 improvement: I

• EPIP 1.2, Section 3.2, should be revised so as to be consistent s with 10 CFR 73.71, or refer to appropriate Security notification j procedure i

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. Changes to the Program (82204) )

d The' inspectors reviewed documentation related to changes to the Emergency l Plan (EP) with regard to processing, distribution, and implementatio L-The Emergency Plan, EP 8.0 (Revision 28) " Maintaining Emergency l

Preparedness," provides for three governing documents: The Emergency i Plan, Emergency Plan Implementing Procedures (EPIPs);'and the Emergency

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Plan Maintenance Procedures (EPMPs).

The Point Beach Emergency Plan is classified.by the. licensee as a " major" procedure. Changes to,-or cancellation of " major" procedures require review by the Manager's Supervisory Staff with approval by the Plant j

. Manager. The EP implementing procedures are classified as " minor" procedures. Changes to minor. procedures require approval of Emergency Preparedness supervision and the cognizant supervisor prior to implementatio The EPMPs are Non Nuclear Safety Related (NNSR) procedures,- .

which require less review for revisio The overall process assures that changes to the EP program are reviewed by the proper level of managemen '

EPMP 4.0 (Revision 1, dated December 26,.1986) " Review-of Changes to-

' Emergency Plan & Emergency Plan Procedures," is intended to assure that

. persons involved in the functional areas.affected by changes are provided the opportunity to review the changes prior to implementation, and insure that changes are evaluated for their impact on overall emergency 1 preparednes For EPIP and EPMP changes, matrices are provided in 4 EPMP 4.0 Attachments 4.0-1 and 4.0-2 to assist in identifying affected group The EP Coordinator evaluates changes and determines which functional areas are affected. Proposed procedure changes are then routed to the groups identified. An area representative reviews and concurs in the changes by signing Form EQR-26 The EP Coordinator summarizes the disposition of EP changes in terms of impact on the overall level of emergency preparedness. The General Superintendent or his designee reviews and approves initial issue, changes, and cancellations of EP and EPIP procedure The inspector reviewed documentation associated with EP Section (Revision 25), and Section 5.0 (Revision 27), both dated January 9, '

1987, and determined that applicable procedures had bten followe No' violations of regulatory requirements or deviations from commitments were identifie . Shift Staffing and Augmentation (82205)

The minimum shift staff, as described in Section 5.of the Emergency Plan, consists of: a Shift Superintendent; an Operating Supervisor; two Reactor Operators; four Auxiliary Operators (one-licensed); one Duty Technical Advisor; and one Radiochemical Technician. This minimum staff, which-would be on shift 88 hours0.00102 days <br />0.0244 hours <br />1.455026e-4 weeks <br />3.3484e-5 months <br /> per week, was in accordance with an exemption granted by the NRC from the shift staffing levels ~ contained in Table B-1 of NUREG-0654, Revisio m. .. . . - .. . . . . . - . - . . . - . - .. -.. . . . - . .

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l As described in the plan and in EPIP 14.2 " Paging System Operation,"

shift augmentation would be initiated by the Shift Superintendent i contacting a Duty and Call Superintendent (DCS) who,.in turn, would contact a Secondary DCS and a Health Physics Supervisor. All supervisory personnel contacted by pager or through telephone calls from the Duty and Call personnel were then responsible for contacting staff level personnel sufficient to respond to the emergency situation. This augmentation system was designed such that the TSC could be actuated within 30 minutes, and the E0F activated within one hou Per Emergency Plan Maintenance Procedure (EPMP) 2.2, the Emergency Planning Coordinator was primarily responsible for assuring quarterly updates of plant, offsite support agency, emergency responso facility, and corporate emergency telephone number information that was contained in EPIPs 22 through 25, respectively. At the beginning of this inspection, the current revisions of these EPIPs were dated February 1987. The EP Coordinator was in the process of reviewing the second quarter 1987 revisions to these four EPIPs, and indicated that the quarterly updates were typically issued during the last month of the quarte In accordance with EPMP 3.3, " Drills and Exercises," the capability i to augment onshift personnel in a timely manner would be demonstrated by conducting off-hours augmentation drills. These drills would be conducted semiannually until there would be four consecutive successful drill At such time, the augmentation drills could be reduced in frequency to once a year. Since the July 1986 drill, the licensee has conducted a successful augmentation drill in February 198 No violations of regulatory requirements or deviations from commitments were identifie . Knowledge and Performance of Duties (Training) (82206)

The licensee has provided annual training for offsite emergency personne A review of training records verified all training of offsite personnel was conducted at the required frequenc The inspector reviewed the licensee's program for training personnel involved in the emergency program, and tracking the completion of training modules to assure individuals assigned emergency responsibilities were qualified for their position The inspector determined through interviews and a review of documentation that a training program for personnel'with emergency response responsibilities is established and adequately maintaine As a result of findings by the Institute for Nuclear Power Operations (INP0) during their program for accreditation of training programs, (and an internal audit finding), the licensee determined a need for specialized training for individuals in some emergency preparedness positions. These positions were previously believed not to require any additional specialized training because the daily dt. ties of the position and the

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s emergency duties were virtually identical. Currently, the licensee is developing, or has developed, specialized lesson plans for these emergency positions (i.e., Administrative Supervisor, Data Fecility Supervisor).

i The licensee has set a goal to train at least two individuah for each j of the above positions before the 1987 Exercise. All other individuals j in affected positions will receive specialized training by the end of j calendar year 198 Procedures provide that all Point Beach Nuclear Plant (PBNP) employees are provided basic emergency response training as a part of the General Employee Training Program. All personnel not assigned major response duties were to be retrained biannually in the content of the Emergency Plan and the EPIPs. Personnel who are assigned major roles in the emergency response organization receive annual training on substantive changes in the Emergency Plan and EPIPs, in addition to participation in a drill for each position they may be assigned on a biennial basi Walkthroughs were conducted with several members of the licensee's Emergency Response Organization, partially to determine the adequacy of their trainin The results of the walkthroughs are documented in Sections 4, 5, and 10 of this repor No violations of regulatory requirements or deviations from commitments were identifie l 10. Dose Calculation and Assessment (82207) ,

Radiological Dose Calculation and Assessment are governed by EPIP " Radiological Dose Evaluation" (Revision 13, dated January 5, 1987), )

and EPIP 1.8 " Emergency Off-site Dose Estimations" (Revision 10, dated January 5,1987). EPIP 1.8 is utilized for immediate initial dose projections and emergency classifications, while EPIP 1.4 is utilized ,

for more detailed dose projection when more information is availabl !

Computerized calculations of the values in both the above EPIPs are possible utilizing the Radiation Monitoring System (RMS). The j computerized system automatically provides EPIP 1.8 results first, then calculates and displays the values for EPIP 1.4 calculations, using either actual on-line data or " drill" dat ,

Individual walkthroughs were conducted with two Duty Technical Advisor These positions had emergency response duties for dose calculation and assessment, and for making protective action recommendations. Each person evaluated scenarios involving a simulated Steam Generator Tube Rupture and a LOCA with released airborne radioactivity and asked to determine offsite dose rates, accumulated doses, and recommended protective actions. Each person demonstrated the capability to correctly analyze the scenario, calculate dose rates and accumulated doses, and to recommend appropriate protective actions,

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l The walkthroughs were performed using the RMS computers in the Technical Support Center. The computer program automatically incorporated dose calculations into protective action recommendations which were color coded (e.g., red for evacuate, white for sheltering, and green for no action required) on the display monitor.- Graphs, overlays, and tables used for the manual determinations were reviewed during the previous routine inspection and found acceptable, and are unchanged from that inspectio The walkthroughs indicated that responsible personnel can adequately conduct dose calculations and assessments using the RMS computer. Both ?

individuals were able to delineato evacuation areas (per the displayed ;

color code), and were aware of dose gradients between displayed 1'

evacuation area It was noted that minor difficulty existed in detailing the exact boundaries of map sectors, as the map and overlays consist of black lines on a white background. Licensee personnel indicated that a revision to the map, utilizing colored sectors, is under consideratio No violations of regulatory requirements or deviations from commitments were identifie . Licensee Audits (82210)

The inspector verified that the licensee had in place provisions for conducting an independent annual audit of the Emergency Progra The inspector reviewed the two 1987 audits performed relative to Emergency Plannin Ai!dit A-P-87-03 reviewed the Emergency Preparedness program itself, and was conducted by corporate personnel during March 23-25, 1987. The audit was adequately comprehensive and detailed, resulting in two findings, and nine comments / recommendations. Findings from the audit were tracked via Audit Finding Reports (AFRs). A review of the Audit Finding reports indicated that corrective action had been or was in the process of being taken where appropriat A separate section of the Audit dealt with the adequacy of the interface j with off-site authoritie CFR 50.54(t) requires that the portion of 1 the audit dealing with the adequacy of offsite interfaces be made available

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to offsite authorities, and licensee personnel indicated that the audit is provided to offsite authorities when specifically requested. Documents indicated that offsite authorities had been made aware of the availability of the audit l Audit A-P-87-06 reviewed Emergency Preparedness training, and was conducted i by corporate personnel during May 5, 7, 8, and 14,1987. This audit resulted in one finding. The Audit Finding Report generated by the audit was reviewed. Corrective action had been or was in the process of being

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lA taken. The finding indicated that no specialized training had yet been given to individuals in seven emergency response organization position This finding related.to'a previous audit finding, still in the process of corrective actio No violations of regulatory requirements or deviations from commitments were identified, i

12. Maintaining Emergency Preparedness (82701)

A-review was made of the licensee's letters-of-agreement with offsite groups and agencies. The letters-of-agreement were current, with the-bulk of the agreements having been renewed during the'first quarter of 1987. As indicated in internal Memorandum NEVP-87-90, the licensee had recently learned that the response actions of the United States Coast Guard (USCG) would be somewhat different than had been perceived. The Commander of the Coast Guard District had informed the license that Coast Guard personnel would not be ordered into the 10-mile Emergency Planning

. Zone (EPZ) to assist in evacuating boaters. Instead,.the USCG would broadcast a warning message and would implement measures to prevent boaters from entering the lake portion of the EPZ. The licensee had-determined that the Manitowoc County plan' included provisions for a county aircraft equipped with a public address speaker to broadcast a warning message while flying over the. lake portion of the EPZ. Also, the Sheriff's Department had several boats available which could be utilized to help evacuate boaters from the~EPZ. The licensee indicated that discussions with the USCG were continuing regarding that organization's emergency support role The inspector reviewed records of the 1986 annual' exercise and the following drills that had taken place since June 1986: annual medical emergency drill; semiannual radiological monitoring and health physics drills; annual site accountability and evacuation drill; annual search and rescue drill; and annual chemistry (PASS) dril I The licensee took credit for conducting most of these drills during i either the annual exercise, two practices that preceded the annual exercise (and involved different scenarios), or during a special, utility-only drill that took place in March-1987. This utility-only drill included activities that could be credited as an accountability

' drill, a search and rescue drill, a chemistry drill, and a radiological monitoring drill. However, the final internal report on this special, integrated drill had not yet been issued. ' The September 1986 exercise included successful site accountability, radiological monitoring, and medical emergency drills. The' inspector also determined that two successful accountability drills had been conducted during both August 1986 practice exercise :

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Emergency Plan Maintenance Procedure (EPMP) 3.3 ha'd been revised to l clarify its wording regarding the frequency of the annual medical drills j and related training to local hospital and ambulance service staff. The i drills and training-take place annually. However, the ambulance would-respond to drills at'the Point' Beach or the Kewaunee Plant on alternate years. Similarly, annual training to offsite medical support personnel has been provided by the licensee or by Kewaunee' Plant' personnel on alternate years. For example, adequately detailed records indicated that training was provided in. April 1987, to hospital and ambulance service employees'by Kewaunee Plant personnel, while the May 1987 medical drill involved personnel from Point Beach, the local hospital, and one ambulance servic Available drill records were complete and included lists of critique comments. The EP Coordinator was initially responsible for. identifying which critique items should be acted upon. His management would then review his recommendations and would approve items for corrective actio A check of the dates on which the drills were conducted determined that all were within the frequencies required by the Emergency Plan and procedure .!

EPMPs'1,1 and 1.2 specified the requirements for conducting periodic 4 inventories of health physics-related material and equipment which would be available following an emergency plan activation. These procedures and associated checklists included provisions for: functionally testing appropriate equipment; reviewing the calibration dates of survey instrumentation; and promptly correcting identified deficiencie These inventories were performed by Health Physics Department staf Completed inventory checklists were reviewed by the Health Physics Supervisor and were then filed in his department. The inspector reviewed the completed checklists and determined that all monthly, quarterly, and semiannual inventories had been performed on schedule through May 1987, the first quarter of 1987, and the second half of 1986, respectivel EPMP 1.3 contained provisions for quarterly inventories of documents and office supplies for the TSC, E0F, and Alternate EOF (AEOF). Onsite inventories have been performed by clerical staff, while the EP Coordinator has performed the AE0F' inventories. All required 1987 inventories had been complete Discussions with licensee personnel, and a check of field monitoring kits and TSC cabinets determined that copies of inventory sheets had been placed in kits and cabinets. A random check of the instrumentation contained in the kits and ca'oinets determined that calibration dates a would not expire prior to the next scheduled inventor I The EP Coordinator is a full-time position. He reports to the Regulatory Engineer, who was his predecessor. Both individuals report to th ~

Assistant Supe'rintendent for Engineering Quality and Regulatory Services (EQ&RS) and then to the Plant Manager. An engineer from the licensee's .

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corporate licensing staff provides support to the Coordinator on an "as needed" basis. The Coordinator estimated that the corporate engineer devotes about 50 to 75 percent of his time to supporting the EP Progra In addition, a staff engineer from the plant's EQ&RS group also assists ;

the Coordinator. However, in Emergency Planning Specialist, having some '

emergency preparedness and Health Physics expertise, has been recently-hired and will assist the Coordinator by July 1987, in lieu of the EQ&RS enginee I Since the 1986 routine inspection, the Coordinator has utilized an

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Emergency Planning Punchlist (EPPL) as a' computerized tracking system for his work activities including: performing periodic inventories and callout procedure updatu; responding to NRC inspection, internal audit, and INP0 assistance visit findings; and completing corrective actions on items identified from emergency preparedness drills. The inspector reviewed and discussed the EPPL with the Coordinator and was informed that the EPC typically assigned priorities and due dates for items on ,

the lis The Coordinator's supervision has been provided with summary l reports of EPPL information in order to monitor his progress, review priorities, and to ensure that needed support would be provided from other plant departments when neede l In response to several items identified by the NRC during the 1986 exercise (Inspection Reports No. 266/86018 and No. 301/86017(DRSS)

plus several internal concerns, the licensee is reevaluating the layout of the TSC and OS The licensee is also developing a separate EPIP regarding activation and operation of the OSC. The TSC and OSC are adjacent areas on the 8-foot elevation of the TSC building. Both ,

facilities are within the same emergency ventilation system's envelop Because of such factors, the inspector understood that the TSC and OSC are sometimes been viewed as a single emergency response facility (ERF). j The TSC is a relatively large workspace on the 8-foot elevation which 1 is occasionally used as a classroom. The OSC consists of an L-shaped I classroom, a health physics supply room, and the connecting hallwa EPIP 7.2.2, " Activation of Chemistry and Health Physics at the TSC/0SC" includes provisions for activating a continuous air monitor in the TSC/0SC hallway, establishing a contamination control point, and for ensuring that personnel would have adequate dosimetry. However, dose l rates that would warrant an evacuation of any onsite area, including an

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ERF, were found in EPIP 6.1, " Limited Plant Evacuation." Also, EPIP 6.3,

" Plant and Exclusion Area Evacuation to Offsite Assembly Areas," i specified that the backup OSC was the Site Boundary Control Center 1 (SBCC) and that the alternate TSC was the Control Roo E0F activation and evacuation were addressed in EPIPs 6.7 and 6.8, respectively. The former procedure included instructions for activating the facility's emergency ventilation system and radiation monitor EPIP 6.8 described the methodology for evacuating the E0F, which is also known as the SBCC, and for activating the Alternate E0F (AE0F),

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I which was the Kewaunee Plant's E0F, located in Two Rivers, Wisconsi EPIP 6.8 also specified whole body and thyroid rates for which facility evacuation "will be considered". Evacuation of the EOF and activation of the AEOF were adequately demonstrated during the 1986 Exercis No violations of regulatory requirements or deviations from commitments were identifie . Licensee Event Report Review During the inspection, a review of Licensee Event Reports (LERs) generated ,

during 1987 were reviewed to determine that events had been properly i classified under the EP program. The inspector reviewed the following LERs:

LER N Unit Brief Description 8t3-004-01 1 Misaligned control rods indicated 85-005-00 1 Reactor trip on loss of red instrument bus 86-006-00 1 Turbine runback during inverter transfer 87-001-00 1 Reactor trip during E0L testing l 87-002-00 1 Containment leakrate exceeding TS limits 1 87-003-00 1 Containment isolation valve leakage 86-004-00/01 2 Failure of main steam isolation valve to close 8(-005-00/01 2 Containment isolation valve exceeding TS limits 86-006-00 2 Reactor trip signals due to work activities 86-007-00 2 Degraded steam generator tubes 86-008-00/01 2 Reactor trip during BOL testing 87-001-00 2 Steam flow channel setpoint deviation All events were found to be properly classified as not falling under the EP program (no emergency Action Level had been met).

No violations of regulatory requirements or deviations from commitments ]

were identifie j

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14. Exit Interview (30703)

The inspectors met with the licensee representatives denoted in j Paragraph 1 on June 5, 198 The inspectors summarized the scope ,

and results of the inspection and ditcussed the likely content of the inspection report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur