IR 05000312/1985026
| ML20198C322 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 10/22/1985 |
| From: | Fish R, Prendergast K, Temple G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20198C304 | List: |
| References | |
| 50-312-85-26, NUDOCS 8511120051 | |
| Download: ML20198C322 (11) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION V
j Report No.
50-312/85-26 i
Docket.No.
50-312
. License No.
. Licensee:
Sacramento Municipal Utility District
P. O. Box 15830-Sacramento, California 95813
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Facility Name:
Rancho Seco Nuclear Generating Station i
j Inspection at:
Clay Station, California
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i Inspection conducted':
August 26-30; 1985
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Inspectors:
'Y-QC _,.f
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K. Prendergast, Einbrgency Preparedness Analyst
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Gb M. Tdmple,,EmeYgency Preparedness Analyst Date Signed j
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Team Members:
J. D. Jamison, Pacific Northwest Laboratories i
L. Smith, Pacific Northwest Laboratories (EG&G)
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I Approved By:
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R. F. Fish, Chief, Emergency Preparedness Section Dafe Signed
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Summary:
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Inspection on August 26-30, 1985 (Report No. 50-312/85-26)
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- Areas Inspected: Announced inspection of the emergency preparedness exercise
and associated critique, followup on corrective actions resulting from
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previous exercises / drills, and followup on Shift Supervisor training. This
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i inspection involved about 173. hours of onsite time by two NRC inspectors and
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two contractor team members.
Inspection Procedures 82301, 92706, and 82206
were covered.
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Results: No significant deficiencies or violations of NRC requirements were
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identified.
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l 8511120051 851023
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i PDR ADOCM 05000312 i
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DETAILS 1.
Persons Contacted
,SMUD
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R. Rodriguez, Assistant General Manager, Nuclear R. Myers, Supervisor, Emergency Planning D. Finley, Emergency Preparedness Specialist R. Le Neave, Emergency Preparedness Specialist B. Spencer, Supervisor, Operations F. Kelley, Acting Manager, Chemistry and Radiation Protection A. Frazer, Shift Supervisor R. Calombo, Supervisor, Regulatory Compliance P. McCormick, Control Room Operator S. Whichard, Control Room Operator J. Delrue, Shift Technical Advisor i
B. Rogers, Engineering Specialist l
J. Reese, Plant Health Physicist
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W. James, Emergency Planner
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B. Stiver, Mechanical Engineer G. Coward, Plant Superintendent
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Contractors W. Hellums, Emergency Planner, IMPELL M. Borter, Emergency Preparedness Specialist, IMPELL 2.
Exercise / Drill Records Review l
The Emergency Planning Group has established a computerized system identified as the configuration control report (CCR) for tracking items identified during drill / exercises that require corrective action.
Although not fully implemented an instruction has been developed to
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. implement the system. All of the items identified during the licensee's critique process from the 1984 exercise were found on the CCR. An examination determined that of the twelve original items, only three
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remain open. Corrective actions on a sampling of closed items appeared to be appropriate.
Several suggestions for improving emergency preparedness were contained i
~in the NRC Inspection Report 50-312/84-20 for the 1984 exercise.
Based on the inspector's discussions with Emergency Planning personnel and a
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review of CCR, it does not appear that NRC identified improvement areas were entered into the system to track corrective actions.
It should be
noted that four items were identified by both NRC and the licensee and these four items appeared on the CCR. The Supervisor of Emergency Planning reported that he had performed evaluation of the NRC recommenda-tions contained in 50-312/84-20, however, no supporting documentation was produced. Region V intends to follow this matter to ensure that NRC r
recommendations are evaluated in the future (85-26-01, Open).
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A review of records for the 1984 and 1985 annual medical drills was performed. SMUD corrective action items identified during the annual i
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medical drill reports were evaluated by the Emergency Planning staff, tabulated, and tracked in an Emergency Planning corrective action list.
As the corrective actions were completed, the Emergency Planning staff evaluated the corrective action and, if appropriate, the item and date of completion was entered into the system to indicate that the item was closed.
It was noted that the formal review of the 1985 medical drill had not been completed, and therefore, had not been placed in the newly established CCR system for tracking. One item identified during the 1985 critique was related to the availability of an individual trained in advanced first aid for all operating shifts. The Emergency Plan (Section 6.2.6) discusses the level of first aid coverage to be available for all operating shifts.
From the revicw of the above stated drills, it appears that the CCR system should adequately provide the documentation and status of items generated during drills / exercises.
However, it was noted that the medical drill critiques also contained items from SMUD's participating contract,apport organizations such as hospitals, ambulance services, etc.
From a review of the CCR, no one appeared to be tracking the resolution of items generated by of fsite contract support. This item should be reviewed by the licensee and will be listed as open item (85-26-02, Open).
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3.
Shif t Supervisor Interviews a
During the inspection, the inspector conducted interviews and
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walk-throughs with three Shif t Supervisors to assess their ability to function as an Emergency Coordinator in accordance with the licensee's Emergency Plan. Of the three persons interviewed, two are in the regular Shif t Supervisor rotation. The third has been a Shift Supervisor in the past but is currently a Senior Control Operator and serves in the Shif t Supervisor position only occasionally.
The interviews lasted 1 1/2 - 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> each and were conducted in the Shift Supervisor's Office and Control Room. The following areas were examined.
- Formal EP training and experience.
- General familiarity with the plan and its objectives.
- The position and responsibilities of the Shift Supervisor in the Emergency Response Organization, including those responsibilities that cannot be delegated.
- Ability to classify hypothetical accident situations, initiate notifications and determine protective action requirements.
- Familiarity with NRC information bulletins regarding a recent emergency condition at another plant of similar design.
The following observations relate to these interviews and walk-throughs.
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The Shift Supervisors were vague about the type and level of a.
Emergency Plan training they had received during the past year.
Documentation of required Emergency Plan training'was not available for all of the required Shif t Supervisor training for 1984.
However, from subsequent discussions with the Acting Nuclear Training Superintendent, these records have been located and will be reviewed at a later date.
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b.
To date there has been no Emergency Plan (EP) training for Shif t-Supervisors for the calendar year of 1985.s _According to the Nuclear Training Superintendent-(Acting), training for_the Shift Supervisors is scheduled prior to the end of the,1985 calendar year which will meet their annual training / retraining requirement.
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All of the interviews demonstrated some confusion exists regarding c.
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the making of Protective Action Recommeddations (PARS). Evaluation of this condition is complicated by the' fact that th'e licensee has provided no guidance for making PARS based on factor's other than offsite dose projections. Also, AP-528, " Prot'ective. Action Guide",
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states in Section 5.1 that " Based on projected doses and PAGs, notify and recommend protective actions to the appropriate. local and
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State authorities", while the Plan, Section 6.2.2b sta' es "The District will not recommend a specific protective meast re".
A July 29, 1983 memorandum from Pierre Oubre' to the Nuclear Operating Superintendent, subject Protective Action Recommendations, had supposedly clarified this situation.
k' hen ^ pressed for an explanation of what they would put in line 6 of the Initial Notification Form (Form A, Attachment 7.2, AP-506), two of the Shift Supervisors could not describe how to arrive at a PAR, and were not aware of the automatic protective actions implemented by the counties at the site area emergency (SAE), and general emergency (GE) classification.
In the light of these walk-through observations, the licensee should insure the EP and implementing procedures are updated to reflect the current Training Program, and review training in this area to assure the Also a responsibilities for PARS are adequately defined and implemented.
review of the frequency of Emergency Plan training is recommended based on the responses to the scenario and the interviewees familiarity with the Emergency Plan and implementing procedures.
4.
Emergency Exercise Planning The Emergency Preparedness Coordinator has responsibility for assuring that the annual emergency exercise is conducted. A member of the Emergency Planning staff was assigned to act as the Lead Controller with the responsibility of developing the scenario package and conducting the The Lead Controller was assisted by members of SMUD Emergency exercise.
Planning and ceatractor personnel, none of whom were participants in'the exercise. By letter dated August 19, 1985, Region V acknowledged receipt of the objectives and scenario and concluded that they were appropriate.
l The exercise document, generated under the direction of the Lead Controller, included the objectives, instructions to the exercise controllers, guidelines for participants, the exercise scenario, messages to be given during the exercise, the initial and subsequent plant l
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parameters, meteorological and radiological data, and exercise
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evaluation / response forms. The exercise document was tightly controlled
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before the exercise. The controller / evaluators were given the scenario document on Friday, August 23, 1985, with specific instructions to keep the document strictly confidential. The players did not have access to the exercise document or information on the scenario event. Advance copies of the scenario package were also provided to the NRC observers.
This emergency preparedness exercise was intended meet the requirements of IV.F.2. of Appendix E to 10 CFR 50.
Controllers / evaluators were stationed at each of the licensees emergency response facilities (ERFs),
e.g. Control Room (CR), Technical Support Center (TSC), Operation Support Center (OSC), and the Emergency Operation Facility (E0F).
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Controller / evaluators were also dispatched with repair / monitoring teams.
All controllers acted as evaluators and had knowledge related to the activities they were evaluating. The final briefing of controllers was conducted on August 26, 1985. During this briefing controllers were asked to pay particular attention to. problem areas identified during the dress rehearsal conducted the previous week.
Clarifications were also made to the NRC concerning the simulation of using self contained breathing apparatus (SCBA). All of the NRC observers were present during this controllers briefing.
5.
Exercise Scenario-
The exercise scenario started with the declaration of an Unusual Event and ultimately escalated to a GE condition. The initiating' event, which occurred at approximately 6:30 p.m.,
was a breach of security by.four armed intruders.
Bombs were planted which damaged the nuclear service
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transformer and caused the reactor to trip. The diesel generators failed to operate and a code safety valve on the "B" steam generator failed to
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reseat. The "B". steam generator then developed a double ended tube r
rupture. This rupture t : companied with reactor feed problems eventually
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leads to fuel damage. A short time later an alternate source of power is secured, the core is recovered and the plant is brought to a stable
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condition, thus terminating the exercise.
6.
Federal Observers Four NRC inspectors evaluated the licensee's response to_the scenario.
The NRC observed activities in Control Room, TSC, E0F, and OSC. The NRC also observed the activities of teams dispatched from the OSC to evaluate plant conditions and make repairs. The NRC Resident Inspector observed portions of the licensee's response; however, he was not part of the NRC evaluator team.
7.
Control Room The following aspects of CR operations were observed during the exercise:
activation, detection and classification of emergency events, notification (note: notification to the counties was simulated at their request), and mitigation of the accident. The following are NRC observations of the CR activities.
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The Shift Supervisor was thorough and careful in his assessment of a.
initial plant conditions ensuring that his crew understood the implications of each status item.
b.
The Control Operators and STAS demonstrated familiarity with the classification procedures.
Free decision making' was observed when the Shift Supervisor
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correctly decided not-to require assembly upon learning of the terrorist attack. Assembly at this time would have been detrimental to the safety of the operations crew at the plant.
d.
General announcements and the use of the plant public address (PA)
system could be improved.
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(i) The Shift Supervisor and TSC Director made no general announcements of, plant conditions to keep the plant staff informed of plant developments and the reasons for the event
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classifications.
(ii) The PA announcements for the emergency declarations were not conducted completely in accordance with the plant emergency procedures, AP-503, 504, and 505.
(iii) Several PA announcements were~apparently unclear or inaudible in certain areas because requests to repeat the announcements were received.
(iv) PA announcements were not heard at all in the OSC.
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Technical Sunport Center'
The following aspects of TSC operations were observed: activation, accident assessment / classification, dose assessment, notification, and
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support of the CR in their efforts to mitigate the consequences of i
' accident. The following are NRC observations of the TSC activities.
i (a) The individuals in the TSC were kept well informed. tor the Emergency Coordinator.
(b) Excellent coordination was observed between the' Radiation Assessment Coordinator, the Security Coordinator, and the Emergency Coordinator.
(c) Emergency procedure AP-501 contains the responsibilities of the Emergency Coordinator. Among these responsibilities are the responsibility to classify the event and to recommend protective
actions. However, there were no specific protective action recommendations made (or simulated) to offsite authorities observed during the exercise..The automatic protective actions, i.e.
sheltering out to two miles for a SAE and sheltering out to five miles for a GE, were assumed to have been initiated. However, since plant. conditions will generally be the precurser to a release, and based on plant conditions of fuel failure at-approximately
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9:45 p.m., evacuation may have been a more conservative action.
This area was also discussed during closing conference.
(d) The plant " assembly" status boards were not filled out, this might have provided individuals in the TSC with information pertaining to plant evacuation status or offsite protective action status.
(e) A plant drawing or map was not available in the TSC to show the relationship of the radioactive plume to the plant, this drawing could also have been used in directing emergency workers to the safest route to their objective.
9.
OSC The following aspects of OSC operations were observed: Activation, functional capabilities, the disposition various in-plant teams, and coordination with the TSC. The following are NRC observations of the OSC activities.
a.
The issuance of dosimetry was well planned and enacted.
b.
Communication between the OSC and in-plant teams was performed satisfactorily.
c.
The PA system in the OSC was inaudible. Consequently, individuals in the OSC were not kept informed of developments in the plant or the security problem.
d.
Accountability started at 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> and was noted complete at 2100 hours0.0243 days <br />0.583 hours <br />0.00347 weeks <br />7.9905e-4 months <br /> with three individuals still unaccounted for. Personnel were paged over the PA system; however, given,the audibility problems associated with the system and the hostage / intruder situation, perhaps search and rescue should have been initiated or at least considered when three people were still unaccounted for.
In addition, the personnel ~ accountability status board, which has a location to list the names of individuals who are unaccounted for, did not depict any individuals as missing. This may have caused confusion. The licensee is investigating this problem.
e.
A plant drawing or map that could be utilized to show radiation dose rates around the plant or the best and safest route to an objective was suggested as an improvement item.
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The monitorintfrepair teams status boards do not appear to be formatted to show all necessary information (location, return time).
As a recommendation for improvement it is suggested that the coordinators in the OSC decide if a new format would be easier to manage.
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10.
Emergency Operations Facility i
The following aspects of EOF operations were observed: Activation, functional capabilities, offsite dose assessment and interface with t
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offsite officials. The following are NRC observations of the EOF activities, The Emergency Manager held frequent briefings with EOF key personnel a.
and Sacramento County officials and frequently forwarded plant status information to EOF personnel over the PA system.
b.
The Emergency Plan, implementing procedures, and plant diagrams were readily available and used as required.
c.
Status boards and record forms were maintained and updated frequently.
d.
It appeared that security held up activation of the EOF for approximately 40 minutes while trying to obtain the permission of the TSC to activate the EOF. The reason for this delay should be reviewed to eliminate its reoccurrence.
Emergency procedure AP-501 delegates to the. Emergency Manager upon e.
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activation of EOF the responsibility to make protective action recommendations to the offsite authorities. However, as observed in the TSC there were no specific protective action recommendations made to offsite authorities. The Sacramento County emergency procedures contain provisions for initiating automatic protective actions to be taken in the event of SAE or a GE.
At a SAE, the County automatically shelters to two milea and at a GE the county shelters to five miles with the option to evacuate. During the
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exercise when a SAE was declared, the Emergency Manager called a i
briefing to discuss protective actions with the County officials.
From discussions with individuals in the EOF it appeared that the County had already initiated their protective actions which were to shelter to two miles at the SAE and to shelter to 5 miles at the GE classification. The Emergency Manager did not specifically discuss PARS with the offsite authorities.
11.
Critiques Formal licensee critiques were held in the EOF on September 29, 1985, the day following the exercise at the plant..The purpose of the critique was to summarize the findings of the exercise and to discuss weaknesses or deficiencies identified by the licensee. The following represent some of the licensee's findings that were discussed during this meeting.
Security setup.a defensive line that could have been penetrated from a.
the rear or the side.
b.
There was confusion over-the differences between a security alert and an emergency alert-(observed by the NRC also).
c.
PA announcements could be improved in' content and were not audible l
in all areas of the plant.
In addition, mechanical problems put the siren out of service during exercise.
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I d.
There was confusion observed in the CR and TSC over the status of accountability with three individuals unaccounted for.
The flow of information concerning the security event was not e.
consistently passed.to the control room, f.
The TSC-was unaware that operations was sending people into the
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plant for repair work.
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The transfer of information from the TSC to the OSC could be improved. The OSC did not appear to be kept apprised of the
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security / intruder situation.
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h.
Repair teams should_ consistently report their progress to the OSC to keep plant operations aware of significant events or precautions to be taken.
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A pass sample was successfully performed during this exercise. The comments of the licensee's PASS team include ( accessibility problems while wearing SCBAs and that procedures were hard to follow and
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could be improved.
12.
Exit Interview The exit interview was held on August 30, 1985. The attachment to this report identifies some of the licensee personnel present at this meeting.
The NRC was represented by the four evaluator team members and Mr. G. Perez, resident inspector. During this meeting the licensee was informed of the preliminary findings of this inspection and that these findings are subject to discussion and approval by Regional Management.
There were no violations of NRC requirements specifically identified during this inspection. Concern was expressed over the ambiguity that exists with respect to the protective action recommendations made to the offsite authorities and the status of Shift Supervisor training. The following were specifically discussed during the exit interview.
AP-501 of the emergency procedures requires the Emergency a.
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Coordinator to make a protective action recommendation (PARS) to the
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offsite authorities. KUREG-0654 also references the responsibility of the licensee to make PARS to offsite authorities.
IE Notice 83-28, Criteria for Protective Action Recommendations for General Emergencies, further clarifies this responsibility. The intent of the Federal guidance is to assure the offsite authorities receive as much warning as possible so as to have adequate time to complete their protective action.
It is noted that the offsite agencies have automatic protective actions, at the SAE and the GE classifications.
The offsite authorities automatically shelter to two miles at the SAE and shelter to five miles with the option to evacuate at the GE classification. However, there were no specific PARS observed during the exercise. Also during the Shift Supervisor interviews individuals stated "we do not make PARS" to the offsite authorities.
Considering the condition of the plant during the exercise with significant fuel damage and reactor feed problems along with a S/G tube rupture, evacuation may have been a more conservative action
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than sheltering and perhaps should have been discussed. The
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licensee was apprised of our concerns over this issue and during the exit interview, the licensee committed to the resolution of this problem. Because of the significance of providing offsite authorities with as much warning as possible, the Region intends to follow corrective action on this. item (85-26-03, Open).
b.
Because of problems observed in the training portion of this inspection (Section 3), the licensee was informed that further inspection effort would have to be accomplished in this area.
However, at this time the completion of training for Shif t Supervisors appears to be an unresolved item.
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Note: Subsequent to the. completion of this inspection, the licensee forwarded to this inspector the training records referred to in Section 3 of this report. However, Shift Supervisor training for
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1985 is not complete and will be examined in a future inspection (85-26-04, Open).
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l Other items specifically discussed during the exit interview are contained within the body of this report in Sections 3 thru 11.
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Attachment Exit Interview Attendees H. Lowe, General Manager R. Rodriguez, Assistant General Manager, Nuclear P. Oubre', Manager, Nuclear Operations L. Keilman, Manager, Nuclear Engineering G. Coward, Plant Superintendent R. Powers, Supervisor, Nuclear Engineering R. Myers, Supervisor, Emergency Planning R. LeNeave, Emergency Planning Specialist R. Dieterich, Supervis'or, Licensing
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