IR 05000315/1982005

IE Emergency Preparedness Appraisal Repts 50-315/82-05 & 50-316/82-05 on 820315-26.Noncompliance Noted:Failure to Maintain,In State of Readiness,Adequate Interim Emergency Operations Facility

ML20055A661
Person / Time
Site:	Cook
Issue date:	06/24/1982
From:	Axelson W, Grant W, Januska A, Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20055A654	List: IR 05000315/1982005 ML20055A653 ML20055A655
References
50-315-82-05, 50-315-82-5, 50-316-82-05, 50-316-82-5, NUDOCS 8207190295
Download: ML20055A661 (47)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

l Reports No. 50-315/82-05(DEPOS); 50-316/82-05(DEPOS)

Pocket Nos.- 50-315; 50-316 Licenses No. DPR-58; DPR-74 Licensee: American Electric Power Service Cor Indiana and Michigan Electric. Company 2 Broadway New York, NY 10004 Facility Name: Donald C. Cook Nuclear' Plant, Units 1 and 2-Inspection At: Donald C. Cook Site, Bridgman, MI Inspection Conducted: March 15-26, 1982

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Inspectors:k 'l. 4 , l 9 f(7_

(Team leader) U

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! A.G.hnuska 84 Approved By: h A.e son, Chief V

'LR l 971 Emergenc* Preparedness Section

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. ./) a riello, Chief'

Emefgency Preparedness and N _14 /'

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Program Support Branch f Inspection Summary l Emergency Preparedness Appraisal on' March 15-26, 1982 (Reports No. 50-315/82-05(DEPOS); 50-316/82-05(DEPOS))

i Areas Inspected: Special announced appraisal of the state of onsite emergency preparedness at the Donald C. Cook Nuclear Plant involved seven general areas:

Administration of the Emergency Preparedness Program; Emergency Organization; Training; Emergency Facilities and Equipment; Procedures Which Implement the Emergency Plan; Coordination with Offsite Agencies; and Exercises, Drills, and-Walk-throughs. The inspection involved 404 inspector-hours onsite by two NRC inspectors and two consultant Results: One apparent item of noncompliance was identified regarding 10 CFR 50.47 (Level III violation - failure to maintain, in a state of readiness,

an adequate interim near-site EOF from which effective management direction i and control can be implemented - Sections 2.2.1 and 4.1.1.4).

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8207190295 820630 PDR ADOCK 05000315 G PDR

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1.0 Administration of the Emergency Plan 1.1 Responsibility Assigned The American Electric Power Supply Corporation (AEPSC)-Assistant Vice President and Chief Nuclear Engineer has overall authority and responsibility for emergency response planning. The staff assistant coordinates the emergency preparedness program at the station level, including the development and updating of the station Emergency Plan (EP) and Emergency Plan Implementing Procedures (EPIP).

1.2' Authority Personnel who are assigned emergency functions are given the authority to perform those assigned duties. The onsite emergency organization is directed and controlled by the Plant Manager who becomes the Onsite Emergency Coordinator (OSEC). He insures that the proper State / County authorities, NRC and AEP Corporate officials are notified. The Plant Manager or his alternate has responsibility to make recommendations to State / County authorities responsible for offsite emergency measures during the initial phase of the nucicar incident. Upon the arrival and activation of the AEP Emergency Response Organization (AEP - ERO)

at the Emergency Operations Facility (EOF) the responsibility to notify and recommend actions to State / County authorities for offsite emergency measures shall be the responsibility of the Recovery and Control Manager (RCM). Alternates to the Plant Manager for an emergency condition are in the following order:

(1) Assistant Plant Managers (in order of Seniority).

(2) Operations Superintenden (3) Production Supervisor of affected uni (4) Shift Engineer on dut .3 Coordination The Staff Assistant is responsible for coordination of the ,

Donald C. Cook Nuclear Plant Emergency Plan with offsite groups

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including State and' county authorities. The Staff Assistant, at the

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plant, and the Section Head, Radiological Support Section, Corporate j insure the coordination _of' corporate and station planning activities, f 1.4 Selection and Qualification ,

i Selection criteria are established for the Emergency Planning and

, Preparedness Staff. Management and Operational personnel at the

Donald C. Cook Nuclear Plant (DCCNP) follow the selection criteria

, as outlined in ANSI N18.1.

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Based on the above findings these portions (1.1, 1.2, 1.3 and 1.4)

l of the licensee's program are acceptable.

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2.0 Emergency Organization Onsite Emergency Organization (I&MECo)

The inspectors verified that an onsite emergency organization was in place and that personnel were available to staff the emergency organi-zation and assume responsibility of assignments as described in the Emergency Plan and Procedures. The structure of the onsite emergency organization is provided on the organization chart in Figure The Shift Supervisor on duty becomes the Onsite Emergency Coordinator when an emergency condition exists and is responsible for the emergency response functions until relieved by the Plant Manager or his alternat The Shift Supervisor will call any additional members of the Plant Organization as shown in Figure 2.2. Upon arrival, the Plant Manager and Shift Supervisor review the emergency situation and the Plant Manager assumes the responsibility for overall management of plant and emergency response function (OSEC). However, upon arrival and activation of the American Electic Power Emergency Response Organi-zation onsite (Figure 2.1) the OSEC responsibility will pass to the Recovery and Control Manager who will direct the onsite emergency organization from the EOF (Recovery and Control Center). The OSEC is also responsible for activating the emergency notification system and assigning staff to all emergency functions. The personnel who are to serve in key onsite emergency management positions, along with two alternates have been predesignated. The selection of technical individuals who would support these managers would be based on the normal working duties of these individual The inspectors interviewed personnel who are designatad to act as onsite emergency managers and alternates. All personnel were found to be aware of their emergency responsibilities and authority and had a working knowledge of the Emergency Plan and Procedures for which they are responsibl Based on the above findings, this portion of the licensee's program is acceptable.

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DONALD C. COOK NUCLEAll PLANT AEP EMERGENCY RESPONSE ORGANIZATION CORPORATE HEADQUARTERS ADVl10RY $UPPORT REC 0VERY& CONTROL NEWS & PUBLIC RELAT10N5 STATE CONWUNICATIONS GROUP BANAGER MANAGER COORDINATOR W, NRC, CON SULT AN T 5 .- . .

LOCATION: EOF . LOCATION: E0F LOCATION: J0 INT PUBLIC INFORMATION CENTER y

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ADulN/ LOC 15 TIC 5 TECHNICAL SUPPORT ENGIN EERING, DESIGN t $CHEDULE & PLANNING R ADI ATION CONTROL &

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W A$TE H ANDLING MG MANAGER ' MANAGER & CONST. N AN AGER 'NANAGER

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LOCATION: EOF LOCATION: EOF LOCATION: T. . LOC ATION: EOF LOCATION: EOF PLANT OPERATIONS

, MANAGER LEGENO

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E0F - Emessency Operailess Facility LOCATION: f.5.C/ T. Technical support Caste 0.5. A. - Operallesal Support Area '

C. Castrel Rees PLANT STAFF . - Specinc redivihals le he

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Identified by Psecedure Q

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2.2 Augmentation of the Emergency Organization 2. Offsite Emergency Organization Augmentation of the American Electric Power Service Corporation Emergency Response Organization is initiated by telephone contact from the Donald C. Cook Nuclear Power Plant, Plant Manager (OSEC)

as described in Procedure PMP 2081 EPP.019. Contact is made to any one of five listed senior management individuals who makes an initial assessment of the situation by contacting members of the Initial Assessment Group (IAG) as needed to initiate support for DCCNP. Procedure PMP 2081 EPP.019 outlines action and responsibilities of the IAG. Augmentation may take up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> because the AEP staff is located in New York City, This lack of timely augmentation represents noncompliance with 10 CFR 50.47(b)(2). The goal of one hour stated in NUREG-0654 has been accepted by the Atomic Safety and Licensing Boar The IAG's primary function during the early phases of the event is to assess the situation and to provide assistance as requested by the plant and to decide how the AEPSC offices should be mobil-ized to provide support. In addition, dependent on the seriousness of the event, the IAG must decide upon further activation of the AEP Emergency Response Organization and whether or not to mobilize portions of, or the entire Emergency Response Organization to travel to DCCNP and become established onsite. The AEP-ERO would be established onsite in accordance with Procedure PMP 2081 EPP.019 and as shown on Figure 2.1. A primary and alternate line of succession exists for each AEP-ERO management position. The selection of personnel is based upon the normal working duties of the individua Supporting contractors and vendors are specified in the Emergency Plan as are State of Michigan, the Berrien County Sheriff and the Federal Government. The responsibilities and authorities of the County, State and Federal Government and their interrelationship with the DCCNP Emergency Plan are outlined in the Pla . Onsite Emergency Organization The Shift Supervisor is responsible for assuming the duties of the interim Onsite Emergency Coordinator until relieved by the

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Plant Manager or his alternate. The Onsite Emergency Coordinator is responsible for initiating the emergency call list and providing the requested information to the parties called in. Procedure

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PMP 2080 EPP.008 Emergency Call List and check lists for the i augmentation call sequence are also shown. The procedure lists,

" person to make call" and " person to be called" and an alternat If neither the " person to be called" nor the alternate is avail-able the next level is contacted. The individual listed to be called must notify the next one on the list who in turn calls the i

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next level and so on until the entire telephone chain is notifie The inspector interviewed members of the emergency organization on the call list. The were aware of these duties and responsi-bilities. The personnel identified on this list have all of the necessary expertise required Table B-1 of NUREG-0654, Revision The list has been prioritized to insure that those positions identified by Table B-1 are augmented within 30 to 60 minute The shift augmentation procedure has not been tested by the licensee. The licensee estimates that complete augmentation-could be accomplished within 30 to 60 minutes based on the distance most of the emergency response organization personnel have to travel to get to the site. However, augmentation drills have not been conducted to determine whether the call lists system can meet the goals of. Table B-1 of NUREG-0654, Revision Based on the above findings, the licensee's program is acceptable;

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however, the following item should be considered for improvement.

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. Conduct off-hours administrative shift augmentation drills to evaluate whether the call list system can meet the goals of Table B-1 of NUREG-0654, Revision 1. These drills should Le conducted semi-annually, documented, and used to identify and correct deficiencies in the call list procedure.

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DONALD C. COOK NUCLEAR PLANT PLANT ORGANIZATION PLANT MANAGER FIRE PROTECTION ITAFF COORDINATOR A5515 TANT A55T. PL ANT MANAGER 5 OPERATI0lt$ 8 NAINTEN ANCE I

I I I I I I OPERATION ADMINIST R ATIVE- QU ALIT Y . MAINTENANCE TECllNICAL CUTAGE/DE5!GN N

- SUPERINTENDENT SUPERVisdit'  ; ASSURANCE SUPERINTENDENT SUPERINTENDENT CHANGE $

' 5UPERV150R COORDINATOR y Q

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UNIT si $UP ENGINEER SUPERVISOR SUPERVl50R PROTECTION COORDIN A-

$UPERvl50R TOR PRODUCTION l I 5UPERV!50il 5HIF T' CONTR ACTOR 5ECURITy 5EN10R

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SECURITY ' SERVICE PERSONNEL ENGINEER UNIT #2 SUPERV!10R5 (NUCL E AR)

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. Emergency Plan Training / Retraining Program Established

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A review was made to determine if the licensee has an established Emergency Plan training / retraining progra Although Procedure PMP 2080 EPP.006 defines Emergency Plan training and retraining, it does not address retraining of Key Individuals (Senior Onsite Emergency Managers). Approved formal lessons plans, with cicarly stated student performance objectives-and the basis for a valid test of the individual's ability to perform, are not avail-abl A training program for Key Individuals is in the process of being raviewed. This program contains a list of Key Individuals which agrees with Key Individuals listed in the EPIP but both dis-agree with the individuals listed in the Emergency Plan. The plan does not include qualification criteria for Key Individuals. These individuals are chosen by their expertise and according to functional needs of the pla Hospital training is the only specific offsite personnel training documented in Procedure PMP 2082 EPP.006. The licensee stated that an offer to train emergency support personnel / agencies has been mad Although there are no provisions for training nonlicensee augmentation personnel, the licensee intends to use current standards as appropriat For case by case situations, training will be immediately developed and implemente Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for

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improvement:

. Reconcile the difference between the Key Individuals listed in the Plan against those listed in the EPIP and the licensee's Key Individual program under developmen . Develop a program for Key Individuals and offsite personnel /

agencie . Provide formal lesson plans with clearly stated performance objectives which provide the basis for student performance evaluatio . Address provisions for training of nonlicensee augmentation personne .2 Training / Retraining Implementation A review was made of training / retraining implementation to determine if this portion of the program has been complete ._ . .

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, Discussion with training personnel and a review of records indicate j that training provided to onsite personnel and supportive agencies is

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consistent with the elemen.ts of the Emergency Plan. Records are not

} available for all of the' supportive agencies although the licensee stated that training has been provided. Testing is performed for General Emergency Training and for specific training supplied for disciplines whose basic functions do not vary between normal and emergency condition Walk-through observations of individuals demonstrating basic skills and knowledge necessary to perform assigned tasks are covered in Section 7.0.

j Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

. Maintain training records for supportive agencies to include, but not be limited to attendance, subject matter, instructor, and dat .0 Emergency Facilities and Equipment Emergency Facilities 4. Assessment Facilities

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4.1. Control Room The inspectors reviewed the control room emergency preparednes The control room had updated copies of the Emergency Plan and Implementing Procedures. Emergency communication equipment con-sisted of a Gai-tronics intercom system, radios, plant telephone

. and dedicated telephones to the Technical Support Center (TSC).

The control room meets the habitability requirement of NUREG-0696 4 and contained sufficient instrumentation and equipment to permit evaluation of the magnitude and potential consequences'of an emergency situatio Based on the above findings, this portion of the licensees program is acceptabl .1.1. 2 Technical Support Center (TSC)

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The Licensee's Technical Support Center is located off the turbine floor in close proximity to the control roo During interim emergency conditions, the TSC will serve a four-fold

] purpose until all other emergency required response centers both on and offsite have been activated. The functions to be

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controlled at the TSC during the interim are:

4 Technical and Administrative Support for the Control Roo Accident Assessment and Dose Calculation Analysi !

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. Plant Condition Data Gatherin Communication Cente The TSC contains all the communication systems described in the guidance of NUREG-0696. The area has commercial telephones, plant telephones, portable radios, a base station I&MECo radio and a NRC Emergency Notification System (ENS) extension. The TSC does not have a NRC Health Physics Network (HPN) extensio The TSC has designed habitability systems to meet the guidance of NUREG-0696. Trend and alarm printers piggybacked from the control room process computer are displayed in the TSC. The TSC is inadequately sized to provide working space for about 25 people. Essentially no working space has been provided for five NRC personnel. Copies of the Donald C. Cook Nuclear Plant Emergency Plan and Procedures, plant records, abnormal and Emergency Procedures, Technical Specifications, FSAR, Flow Diagram, electrical diagram and system diagrams are located in the TS Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

. Provide a HPN extension in the TS The TSC is acceptable on an interim basis and is an open item

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pending approval by NRC Division of Emergency Preparedness relevant to its siz .1.1.3 Operations Staging Area (OSA)

The Operations Staging Area (0SA) is located in the basement area of the Plant Office Building. The OSA appears to be as described in the Donald C. Cook Nuclear Plant Emergency Plan, and Proce-dure PMP 2081 EPP.021 (Activation and Operation of the Operation and Support Area (0SA)). The facility does not appear large enough to accomodate all assigned personnel.since it is also the primary assembly area for onsite personne It is operated under the direction of the Maintenance Superintendent. All emergency equipment was found operable and calibrated and supplies were as described. Communications are provided to the Control Room and the Technical Support Cente The area provides shielding but does not have a filtered ventilation system nor other means of respiratory protection, e.g., respirator Although the staffing of the OSA is to assure availability of Operations Supnort Personnel to respond to the assistance re-i quests from the control room and the TSC, this facility is not activated in conjunction with the activation of the TSC. This

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is in disagreement with Licensee Actions ststed in Appendix 1 of NUREG-0654 for Alert and above classes of Emergency Action Levels and is therefore unacceptabl Based on the above findings, this portion of the licensee's program is unacceptable. Improvement in the following area is required to achieve an acceptable program:

. Activate the Operations. Support Center (Operations Staging Area) in conjunction with the Technical Support Cente In addition, the following items should be considered for improvement:

. The OSA should be reviewed to determine its adequacy to accomodate personnel assigned to it and also its function as an assembly are . Isolation of OSA ventilation system, installation of filtra-tion or another method of respiratory protection should be considere .1.1.4 Emergency Operations Facility (EOF)

The licensee's interim EOF is comprised of four separately func-tioning but interrelated centers. The centers are comprised of: Recovery Center (RC) located in the basement shelter area of the Plant Office Building. This facility is operated under the direction of the Recovery and Control Manager (Vice-Chairman Engineering and Construction, AEP) and is the command center for the direction of all recovery operation Emergency Control Center (ECC) is located in the training building. This facility is operated by the Radiation Control and Waste Handling Manager (Assistant Chief Nuclear Engineer, AEP). The ECC is to be used for evaluating and controlling emergency situations that affect the public; for example, the radiological dose projections and verifi-cations, information to local, State and Federal agencies needed for. implementation of offsite emergency plans and for receipt and analysis of all field monitoring dat Emergency News Source which is located in the Donald C. Cook Energy Information Center. This facility is operated by the Manager-Energy Information Center and functions as the area where information is disseminated to the news media imme-diately following an inciden .

. Joint Public Information Center (JPIC) is located at the Lake Michigan College Convention Center and described in Section 4. The latter two facilities are not considered by the NRC staff to be required functions of the EOF but necessary support facilities designed to provide information to the news medi The functions of the EOF prior to the arrival of the AEP and I&ME Co. Emergency Organization would be performed by the TS Dose assessment and communications with State and local govern-ment would be done from the TS The fragmentation of the EOF will not allow for effective man-agement direction and control of all of the licensee's activities during an emergency and will not provide for consultation and coordination between the licensee's senior management official and senior local, State and Federal emergency response managers in a central locatio The licensee does not intend to activate the EOF until the arrival of the AEP and I&ME Co., Emergency Organization, a period up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This is unacceptable because the EOF

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must be operational within about one hour after declaration of a Site Area or General Emergency. This NRC criterion has been confirmed by the Atomic Safety and Licensing Board Panel in previous board decisions including the restart of Three Mile Islan The Licensee's Emergency Plan, Revision 0, January 2, 1981, indicated that overall management shall be based in the EOF and once activated and staffed, the EOF shall function to evaluate the magnitude and effects of actual or potential radioactive releases from the plant and to recommend appropriate offsite protective measures. To accomplish these functions, facilities

! shall be provided in the appropriate areas of the EOF for the evaluation of all pertinent radiological, meteorological and plant system data. Further, EOF personnel shall also coordinate offsite radiological monitoring during nuclear emergencies and recovery operations with those of offsite response agencies.

Contrary to the licensee's Emergency Plan, the inspectors found I that the Recovery Center was a room located in the basement area of the onsite Administration Building which was woefully inade-quate and unequipped to perform the functions as stated in the Emergency Plan. The Recovery Center from which the licensee's

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Recovery Director was to manage the licensee's overall accident l

response had tables and chairs and only two telephones. No i other relevant emergency equipment was provided. The Recovery Center could not perform its functions because of inadequate communications capability; inadequate data acquisition capability to assess pertinent radiological, meteorological and plant system l

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data; inadequate radiological monitoring capability for habit-ability monitoring; inadequate emergency resource equipment to analyze data such as maps, status boards and administration equipment; and inadequate records availability and managemen The Recovery Center had no available records, plant technical specifications, offsite population distribution, environs radio-logical monitoring records, licensee employee radiation exposure histories, or up-to-date drawings, schematics and diagrams showing conditions of plant structures and systems down to the-component level and inplant locations of these system The Emergency Control Center was also found to be inadequately equipped to perform the functions. It appeared to have records and communications but lacked other essential equipment as noted for the Recovery Center. Its resources were those needed for its use in routine training functions and not those of a center designed for coping with an emergenc The inspectors concluded that there was an inadequate state of emergency preparedness because the licensee's EOF did not meet the regulations in 10 CFR 50 and Appendix Specifically, 10 CFR 50, Appendix E, Section IV, Part E (Emergency Facilities and Equipment) requires that adequate provisions shall be made and described for emergency facilities and equipment, including:

a licensee onsite technical support center and a licensee near-site emergency operations facility (EOF) from which effective direction and control can be exercised during an emergenc Further, the inspectors concluded that the Licensee's Emergency Plan did not meet the following standards relevant to a near-site EOF: 10 CFR 50.47(b)(3) states, in part, that arrangements to accommodate State and local staff at the licensee's near-site EOF have been made and 10 CFR 50.47(b)(8) states, in part, that adequate emergency facilities and equipment to support the emergency response are provided and maintaine As a result of the inspection and examination of the licensee's interim EOF, a special management enforcement meeting was held with the licensee on May 4, 1982. During that meeting, the licensee recognized the need to establish an near-site interim EOF at the Training Building. The licensee has agreed to equip and prepare this building to ensure that once activated within about one hour, the EOF will: Provide a senior DCCNP/AEP official to coordinate management of overall respons . Provide for coordination of I&ME Co. radiological and environmental assessmen . Determine recommended public protection action . Provide a location and facility for coordination of emergency response activities with Federal, State and local agencie .

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The new interim E0F will have adequate radiological habitability monitoring and adequate primary and backup communication The EOF will have ready access to up-to-date plant records, pro-cedures and emergency plans needed to exercise overall management of licensee emergency response resource The EOF will not be fragmented, but a central location for crisis management to-ensure adequate coordination with AEP management and offsite authorities. The EOF will be tested during an in-house drill in June 1982.

j As a result of the above stated noncompliance, the inspectors concluded that the licensee's Emergency Plan did not factually represent what was indeed discovered during the inspection. Had there been a Site Area or General Emergency at the D. C. Cook facility after issuance of the Emergency Plan dated January 1981, effective direction and control could not have been imple-mented at the interim EOF. The senior licensee official-would be totally uninformed and unprepared had he tried to control the emergency from the Recovery Center. The inspector. concluded that overall command and control would not have been transferred from the TSC to the EOF. Accordingly the TSC, during a Site Area or General Emergency, would have had to implement the functions of the EOF at all times, thus reducing its (TSC) primary design function which is to help mitigate the consequences of the emer-gency and assist the Control Room staff. Furthermore there would have been no effective communication between the licensee's Senior Onsite Manager and Senior State, Local and Federal officals-charged with the protection of the public. As a result, a degra-dation in the state of emergency preparedness would have resulted and similar problems experienced at Three Mile Island would have in all likelihood, occurre The inspectors noted that the licensee apparently recognized the need for an near-site EOF. This was so indicated in an April 16, 1981, letter to the Office of Nuclear Reactor Regulations. In spite of this, no timely effort was made to relocate the interim EOF to a near-site location nor did the licensee follow applicable NRC policies and practices pursuant to 10 CFR 50.12 (Specific Exemption), to ensure compliance with the regulatio Instead, the licensee indicated that a facility would be established on October 1, 1982. However, the licensee by letter dated June 19, 1981, submitted a conceptual design of a permanent EOF and failed to indicated where the EOF was to be located and failed

to describe its concept of operation. The omission of these critical data lead the inspectors to conclude that the licensee had not firmly established where the permanent EOF would be located or hcw it would functio i

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The inspector indicated to the licensee that their June 19, 1981, l submittal (Conceptual Design of TSC and EOF) was unacceptable and I i

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Inadequate and a new submittal must be prepared. The licensee agreed to prepare a draft and discuss it with the staf The licensee's interim EOF (Recovery Center and Emergency Control Center) were existing facilities prior to the accident at Three Mile Island. The inspectors concluded from observation of both areas of the EOF that no management attention was given to this area. Essentially, no preplanning or preparedness was given to establish a functional interim EOF as required by the regulatica This is a clear violation of the commission's regulations as indicated abov Based on the above, the licensee's permanent EOF is an Open Ite .1.1. 5 Post-accident Coolant Sampling and Analysis Equipment and Facilities 5.4. Primary Coolant Sampling Procedures 5.4. Primary Coolant Sampling Analysis Procedures Post-accident coolant sampling is presently accomplished with an interim system in the Auxiliary Building. The sample is taken by rerouting degassed coolant to an outlet behind a small heavily shielded area, it is collected in a small plastic bottle that is located inside a lead shield. The shield is on a track which places the bottle directly below the sampling outlet. The cap is placed on the bottle with the aid of an extension tool, which was not present at the sampling area, er in the post-accident equipment room located adjacent to the OSA. However, the post-accident equipment room did contain the remainder of the equipment outlined in the procedures for the Chemistry Technicians (CT). Bio packs were located in the OS Back-ground levels for the sampling area are not expected to be in excess of 100mR/hr. There are no area monitors present at the sampling locations, but survey meters are utilized to perform their function for this interim facility. Survey meters and a radio are obtained and operated by the Radiation Protection Technical (RPT) member of the sampling team. These items are obtained from the post-accident equipment room, which also contains the procedures. This room is locked when not in use, and an emergency key is located in a breakable glass case beside the~ door. The E-2 key, necessary for access to valves utilized in the procedure was not present, and a wrench needed to connect a U-tube to wash out the sampling line was also not in the equip-ment room. The laboratory utilized for analysis of the samples contains all necessary equipment and facilities including a hood to control airborne contamination from the sample. The radio-logical analysis is performed with a GeLi detection system and a Canberra hardware system. The procedures for the chemical analysis are posted on the lab work tables, and the lab equip-ment is set up on the lab tables. In addition to the lab, an alternate radiation counting facility consisting of a Na(TI)I gamma detector, is available onsite if the original lab should become uninhabitabl . _ . .

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The procedures for obtaining and analyzing post-accident coolant samples provide a detailed description which can be easily under-stood and performed by the ct However, the procedures omitted the operation of valve V-11 which is essential in obtaining the sample, and referenced valve SI-174 which has poor access for operatio In addition, the procedures do not address the proper route and method utilized in transporting the sample to the hot

, lab, and provide no provisions for diluting samples prior to transporting the sample to the la The procedure for obtaining a post-accident coolant sample was changed to include the operation of valve V-11 prior to the appraisal teams departure from the sit Based on the above findings, this portion of the licensee's program is unacceptable. Improvement in the following area is required to achieve an acceptable program:

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. The extension tool listed in the procedures shall be made availabl In addition, the following items should be considered for improvement:

. Provide more convenient operation and access to valve SI-17 . Modify the post-accident coolant sampling procedures to include the proper route and method of transferring the sample to the lab.

. . Modify the post-accident coolant sampling procedures to provide for the dilution of the sample, if necessary, prior to transporting the sample to the lab.

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. Supply the post-accident sampling cabinets with a wrench and an E-2 key necessary for access to certain sampling valves.

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Installation of a permanent post-accident coolant sampling system is an open ite The installation of a permanent primary coolant sampling system j is an open item.

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j 4.1. Containment Air Sampling and Analysis Facilities and Equipment 5.4. Containment Air Sampling Procedures ( 5.4. Containment Air Sampling Analysis Procedures l

Equipment necessary for Chemistry Technicians (cts) to obtain a post-accident containment air sample was located at the interim sampling location in the Auxiliary Building and in a locked post-accident equipment room adjacent to the OSA. A key was enclosed P

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in a breakable glass case at the door. Survey meters and radios were also contained in the post-accident sampling equipment room

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along with the procedures. A lead shield was prepositioned at the Unit 1 sampling area, and could be easily transported to the Unit 2 sampling area. The background radiation level is not expected to exceed 100 mR/hr in the worst post-accident situation. A stainless steel U tube was located in the shield to accept the sample, and was connected to the sampling line with quick disconnect fittings. There were no area radiation monitors at the interim sampling location, but the survey meters utilized by the Radiation Protection Technicians (RPTs) could satisfy this criterion on an interim basis. The new sampling system, currently being installed should prove to be an efficient method of obtaining both liquid and gaseous samples. Area radi-ation monitors are also being installed. The equipment necessary to perform the containment air analysis is located in the hot lab facility along with the necessary procedures. Two gas chromato-graphs are available for determining hydrogen content of the sample, and small sealed vials with a predetermined geometry are utilized to perform the radiological analysis. This analysis is performed with a GeLi detector and Canberra computer based syste An alternato NaI spectroscopy system is available in the Emer-gency Counting Facility (ECF) which can be used if the background in the hot lab presents counting interferenc The procedures provided for the sampling and analysis of con-tainment air were written in a concise and descriptive manne The procedures state that the sample should be transported to the hot lab and then the exposure rate determined. If these procedures were followed a highly radioactive sample could be brought to the hot lab without the chemist's knowledg Based on the above findings this portion of the licensee's program is unacceptabl Improvement in the following area is required to schieve an acceptable program:

. The sampling and analysis procedures shall be modified to provide for a determination of the exposure rate of the sample prior to transporting the sample to the hot la In addition, the following items should be considered for improvement:

. Modify the containment air sampling procedures to provide for dilution of the sample, if necessary, prior to trans-porting the sample to the hot lab.

I@ . Modify the containment air sample procedures to include the route and method of transporting the sample to the hot la The installation of a permanent Containment Air Monitoring System j

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4.1. Particulate, Gas and Iodine Effluent Sampling and Analysis Equipment and Facilities 5.4. Stack Effluent Sampling Procedures 5.4. Stack Effluent Sampling Analysis Procedures The vent particulate, radioiodine, and gas sampler is located on the 650 ft. level in the Auxiliary Building. The sampler utilizes glass or cotton fiber filters for particulates, silver zeolite cartridges for radioiodines, and a Marinelli beaker for gas samples. The area in which the Nuclear Measurements Cor-poration (NMC) vent sampling system is located is not expected to have excessively high radiation fields in a post-accident situation. New Eberline gaseous effluent systems are presently being installed and expected to be completed, and procedures will be provided in the near future. Equipment necessary for the sampling was located in the hot lab.and in the post-accident equipment room. There was presently no EPIP for obtaining the gaseous effluent samples from the NMC sampler. The procedures for analyzing the effluent samples were written in a precise,

! casily understood manner, and the necessary equipment was present in the hot lab and the counting room as described in

Section 4.1. Based on the above findings the particulate, gas and radioiodine sampling equipment and analysis procedures are acceptable; however, the Stack Effluent Sampling Procedure is not acceptabl Improve-ment in the following area is required to achieve an acceptable program:

. Procedures for sampling of stack effluent to prevent personnel overexposure shall be provided until the new Eberline systems are complete The permanent Stack Effluent Sampling System is an Open Ite .1. Liquid Effluent Sampling and Analysis Facilities and Equipment 5.4.2.10 Liquid Effluent Sampling Procedures 5.4.2.11 Liquid Effluent Sampling Analysis Procedures

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The liquid effluent sampling facilities consist of a secondary blowdown liquid sampling location in the nuclear sampling lab, and the holding tanks located in a small room across the hall from the interim coolant sampling station in the Auxiliary Building. Background radiation levels are not expected to exceed 100 mR/hr. The necessary equipment for the cts and i

RPTs to perform the sampling procedure was located in the post accident equipment room and the hot lab. The equipment for the analysis is the same as that described in Section 4.1.1.5. The

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procedures adequately describe the sampling process, and are presented in a concise and accurate manne Based on the above findings, this portion of the licensee's program is acceptabl .1.1.9 Offsite Laboratories A review was made of provisions for offsite laboratory capa-bilitie The licensee maintains a dedicated NaI counting system in the ECF, the former Guard Post. When an emergency is declared, a GoLi system will be moved from the normal counting lab to the EC In addition to this facility the licensee has arrangements with contractor laboratories to provide Emergency Analytical services as neede Based on the above findings, this portion of the licensee's program is acceptabl . Protective Facilities

) 4.1.2.1 Assembly / Reassembly Areas One primary assembly area is specified in the Plan although other areas may be designated by the Shift Superviso This area, the Operations Staging Area, provides shielding but does not have filtered ventilation or other respiratory protec-tion means i.e., respirator In the event that this area has to be evacuated or personnel reassembled, three evacuation routes are listed in the Plan. No provisions for movement of evacuated personnel once they arrive at the terminal points of routes 2 or 3 are provided or reference The Operations Staging Area was inspected and appears to be inadequate in size for the potential numbers of people who may be reporting there for accountability. Furthermore, the potential for personnel contamination may be increased proportionately to the amount of people in this area. No procedures are currently available which address personnel monitoring, segregation of contaminated personnel or prioritizing decontamination based on functions personnel are expected to perfor Based on the above findings, this program is acceptable; however, the following items should be considered for improvement:

. Provide a procedure which addresses transportation for plant personnel who evacuate along evacuation routes 2 or _

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. Determine where personnel may be relocated if not contaminated, to relieve the congestion in the OS . Develop a procedure for personnel monitoring to include segregation of contaminated personnel, and prioritizing decontamination based on functions personnel are expected to perfor .1.2.2 Medical Treatment Facilities Provisions for onsite treatment of injured personnel are con-sistent with the description in the plans and procedures except that there is no cot, litter or procedures in the first aid room as specified in the Plan. Facilities are readily accessable and are close to supplies and decontamination facilities. The first aid room is located on the first floor of the Administration Building and contains first aid equipment such as bandages, wraps, tape, gauze etc. This room is inventoried and restocked on a weekly basis by staff of the Personnel Section. The oxygen bottles in the room are inventoried and refilled as necessary, on a quarterly basis by Radiation Protection Technicians. A contaminated, injured worker could be treated in the first aid room and then transported downstairs to the decontamination facility in the Operations Staging Area. The main decontamination facility (in the OSA) is downstairs from the first aid room and some first aid supplies are immediately adjacent to the facilit The first aid room did not contain any survey instruments however there were instruments in the OSA. The first aid room contained phone communications. The first aid facilities at the OSA and access control facility had access to both phones and portable radio Procedures for decontamination and treatment were available at the OSA and access control facility. There were no emergency dosimetry capabilities available in the first. aid room; however, pencil dosimeters and TLD badges are available near other first aid supply locations. The licensee has made no provisions for the use of radioprotective drugs such as potassium iodide (KI) and is awaiting federal guidance before implementing a procedure. However, federal guidance currently

allows for the use of KI for emergency workers pursuant to NCRP

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No. 5 Based upon the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

. The licensee should include a cut, stretcher, and a copy of thu Emergency Plan Implementing Procedures in the first aid room as stated in the Pla (See Appendix D of the Emergency Plan).

. The licensee should provide an adequate supply of KI for use by onsite emergency worker .

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4.1.2.3 Decontamination Facilities The Operations Staging Area and access control facility have been designated as decontamination facilities. Radiation monitoring equipment including special probes for wound monitoring have been provided. The Interstate 94 and Stevensville alternate assembly area do not have decontamination capabilities although each site does have radiation monitoring equipment (GM, PIC-6, frisker).

Decontamination procedures are available at the OSA and access control facility and there was soap, water and decontamination aids at each sit The decontamination facility in the access control area has provision for disposal of solid and liquid wastes and access to replace clothing. The OSA drain is not controlled and thus does ,

not provide a means to properly dispose of liquid waste. Replace- l ment clothing is limited to 15 anticontamination suit Solid waste will be bagged and disposed of through normal method Based upon the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvemen ,

. Procedures should be written for decontamination of per- .

sonnel at the Interstate 94 and Stevensville alternate '

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assembly sit . The OSA should be modified to provide a means of controlling radioactive liquid waste and/or procedures ihould be written ,

detailing alternate methods of contt9 s s

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4. Expanded Support Facilities The basement of the office building and the~ training building will provide work space for corporate, contracting, or any other non-licensee personnel who may be present during an emergency.

l These areas were not supplied with adequate matecials and have l insufficient communications equipment. These , facilities are the same facilities described in Section 4.1.1.4 (EOF).

Based on the above findings, this portion of the licensee's program is unacceptable pending improvement in the licensen's EO ~

4. News Center (JPIC)

The licensco currently has contracted for Public Relations (PR)

offices and media briefing areas at the Lake Michigan College Community Center. The college is located in Burrien County, Michigan, about 11 miles northeast of the site. This facility provides for contacts with individual media people, a work area for PR releases by American Electric Power and a location for press gatherings, briefings, and press releases. Twenty tele-

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phone lines are installed,'and telephones are on hand to be used i

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when needed. Copy equipment, public address system and audio visual equipment will be transported to the JPIC from other company offices. A list of equipment and means to ensure its availability are provide The licensee han a document titled " Nuclear Emergency Response Plan" which describes the Public Re.ations function and the operation of the JPI Based on the above finding, this portion of the licenseo program is acceptabl .2 Emergency Equipment 4. Assessment 4.2. Emergency Kits and Emergency Survey Instrumentation The licensee reserves prepositioned supplies and kits for use in emergencies. The survey teams called for in the Plan and Imple-menting Procedures would have access to the necessary equipmen Equipment for use by rescue /re-entry (RRT) teams include provisions for monitoring dose to extremities (100 extremity TLD's) and botn/

gamma field Survey instruments with bota/ gamma distinguishing capabilities are also available in the basement assembly are However, additional survey =eters and dose rate meters should be transported to the assemble areas during an evacuatio Instrumentation for use in emergency environmental surveys has the capablility of measureing IX10 ' pCi/cc radiciodine and 1X10 ' pCi/cc Cs-137 (or equivalent) in the presence of noble gases and high background radiation. There is an inplant cap-

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ability for detecting airborne radiciodine in the presence of noble ga Instruments are routinely checked for operability and calibratio Standard operating procedures provide for calibration and replace-ment of defective unit Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

. Procedures should be developed to assure additional survey meters and dose rate meters are transported to assembly areas during an evacuation. These would supplement the

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prepositioned emergency equipment for use by RRT member .2. Area and Process Radiation Monitors

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4.2. Non-Radiation Process Monitors The pressure and temperature process monitors were verified to be present and operating. Effluent monitoring and area radiation

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monitors are properly located and are also operating. Two high rango containment dome monitors with a range of 10' R/hr have been installed in accordance with NUREG-0737. The plant has a seismic recording and monitoring system, and a failed fuel monito However, the failed fuel monitor is not operating at this tim Repair of this unit is currently in progress. Annunciators are located.in the control rooms, and audible and visual alarms are automatically actuated to indicate the failure of vital functions and their associated parameters. Emergency power related controls and annunciators are also located in the control room Based on the above findings, this portion of the licensee's program is acceptabl .2.1.4 Meteorological Instrumentation The bases for the inspectors review of the licensee's meteoro-logical measurements program included Regulatory Guides 1.23, 1.97 and 1.101 and the criteria set forth in NUREG-0696 and NUREG-073 The licensee outlined the characteristics of the meteorological measurements system in Esergency Plan Section 12.3.1 The integration of meteorological data into the licensee's dose projection scheme is summarized in Procedure PMP 2080 EPP.006, Inital Doso Assessments (Gaseous), Revision 1. The inspector alao tr<iewed the licensee's meteorological instrumentation and its associated preventive maintenance progra The current meteorological tower is located atop a sand dune east of the containment buildings and the meteorological instru-mentation on this tower provide the basic parameters (i.e, wind direction and speed and an estimator of atmospheric stability)

necessary to perform the dose assessment function. However, because of the complex terrain between the plant and site boundary, measurements from this tower location may not be representative of low-level plume transport from the plant release point to the site boundary. Use of wind direction information from this tower may be misleading with respect to plume location and may confuse environmental monitoring teams attempting to track the plum The use of data from the tower for licensing activities was adequate, but for a real time assessment of the plume, the tower may not be representative of the air flow around the site. For this reason, the siting of the meteorological tower at the time of the appraisal was determined to be questionable. To take into account the potential non-representativeness of the present meteorological monitoring systems, the licensee, in an emergency situation, will evacuate, if indicated, in all directions from the facility. This is acceptable on an interim basis until the representativeness of the present monitoring program can be verifie _ _ _ _ - _ _ - - _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - - _ - _ -

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Data from the meteorological measurements system were available in the control room via analog readout. The primary system is displayed unless a problem develope In that event a redundant system, located on the same tower could be accessed by turning a switch. If the primary and redundant systems were both rendered inoperable, data would be available from a separate system at the visitors center adjacent to the plant in the northeast directio The licensee has maintained a program for inspection and pre-ventive maintenancs. The instrumentation in the meteorological shed is checked each weekday as are the analog recorders in the control room. Data is also sent to the licensee's meteorological contractor, Pickard, Low and Garrick, in Washington, D.C., for visual examination each week day. All instruments are calibrated semi-annually, which is not in accordance with the guidance of NUREG-0737. The siting and exposure of the meteorological instrumentation on the towers at the time of the appraisal was

! acceptabl i The shift operations personnel will obtain acceptable National

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Weather Service information on severe weather warnings and watches

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in the site vicinity from the load dispatche ,

The inspector concluded that the licensee had the capab.11ty to

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appropriately integrate meteorological data into the radiological assessment / projection procedures with the exception of the deter-mination of G stability. Procedure PMP 2080 EPP.006 accounts for stability Classes A through F onl Based on the'above findings, this portion of the licensee's program

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is acceptable; however, the following items should be considered for l

improvement:

l . Procedure PMP 2080 EPP.006 should be revised to include a G stability class.

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. In accordance with NUREG-0737, the licensee should calibrate

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the meteorological measurements instruments at a frequency no less than quarterl . A comparative study based on additional meteorological information should ba undertaken to assess the representa-tiveness of wind data from the present tower location for predicting the real time flow of releases from the reactor building. The additional information should be obtained

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l from the installation of temporary supplemental meteoro-logical system (s) at a more representative location (s)

around the site and by comparing this wind data with simultaneous measurements on the present meteorological tower.

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4. Protective Equipment 4.2.2.1 Respiratory Protection Equipment and Facilities In addition to their main supply of respiratory equipment, the facility has equipment located in a number of places in both the auxiliary and the turbine building for emergency situation The respiratory equipment described in the procedures is in place and operational. There are three stations for recharging the supplied air units. Two are located at opposite ends of the turbine building and the third in the fire house. Air tanke for the recharging stations were provided by a contractor on a regular basi Based on the above findings, this portion of the licensee's program is acceptabl .2.2.2 Protective Clothing A review was made of the availability of protective clothing onsite, reserved for emergency us The licensee has an ample supply of protective clothing that would be available during an emergency. The clothing is maintained under the Assistant Plant Manager for Maintenanc Only a limited supply is available in other than the central storage and these are primarily in monitoring team kit Based on the above findings, this portion of the licensee's program is acceptabl . Communications Radio communications onsite utilize UHF systems with a number of antennas and repeater stations and are used daily. The range of the system is approximately five miles. However, radio contact cannot always be achieved beyond this distanc In addition, there are a number of dead spots when used in the Auxiliary Building and containment. Telephones and inplant P.A. connec-tions, located throughout the Auxiliary Building, and a control set with direct lines to the auxiliary repeater station, located at the containment access doors are used to compensate for these dead spots. There is a direct radio link between the plant and the Berrien County Sheriff's office as a backup for direct tele-phone communications and a low band transmitter is also available for direct communication with the State Police. In addition to these systems, the plant has a microwave telephone communications network which provides communication with Fort Wayne, Canton, the corporate office and the JPIC. Telephone communications are avail-able to all emergency organizations, and are checked regularly or used dail .

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The public warning system is controlled by the county Sheriff's office. The inplant emergency warning system is operated over the P. A. system, with additional speakers and strobe light systems in high level noise area Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

. Make provisions for reliable radio contact with offsite plant l survey teams up to a ten mile radius.

4.2.4 Corrective Action Maintenance Equipment and Supplies Emergency tool kits are spaced throughout the Auxiliary Building, 4 and a full machine shop is located in the turbine buildin '.

Additional emergency maintenance equipment and supplies can be obtained from existing contracts with Westinghouse, Power Systems

, and Comstock, i

l Based on the above findings, this portion of the licensee's program 1 is acceptabl I

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4.2.5 Reserve Emergency Supplies and Equipment

A review was made of the licensee's emergency supplies and equipmen The licensee maintains a complete inventory of supplies onsite j to support emergency operations. Only items subject to loss and therefore a reduction in the quantity available require a minimum stock level.

Supplies and equipment kept in emergency response facilities are inventoried according to prescribed frequencie Based on the above findings, this portion of the licensee's program is acceptabl .2.6 Transportation A review was made of the availability of transportation during j an emergenc A fire truck and an ambulance are set aside exclusively for emergency use. Other company vehicles are available during

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normal shift hours but are used by select management personnel t for transportation to and from the plant sit In the event of an emergency, these people, who are Key Individuals in the i Emergency Plan, would be required to report to the site and the vehicles made available. Personnel requiring vehicles (e.g.,

monitoring teams) who are onsite would be dispatched from the OSA where a complete set of vehicle keys are kept for emergency use, i

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Based on the above findings, this portion of the licensee's program is acceptable.

5.0 Emergency Plan Implementing Procedures i 5.1 General Content and Format Emergency Plan Implementing Procedures PMP 2080, PMP 2081 and PMP 2082 were reviewed. The procedures were developed in standard format con-sisting of objectives, responsibilities, applicability, instructions,

and. appropriate exhibits. The procedures specified the individual or j organizational element having the authority and responsibility to

perform the task. The procedures contain Emergency Action Levels

(EALs) to guide the user in performance of the required action '

Each procedure describes the conditions which must exist before the specified actions are performed. Standard operating procedures, j precautions and limitations to be observed are listed as necessary.

! Decisional aids are. supplied where necessary to assist the user in

the interpretation of EALs or applications of protective action levels

! or Protective Action Guides. Where appropriate, the Emergency Plan i Implementing Procedures refer to existing standard operating procedures.

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Emergency Implementing Procedures contain checklists, signoff and data j sheet Emergency Implementing Procedure groups (PMP 2080, PMP 2081, PMP 2082)

! are not completely cross referenced between groups. All procedures

! which refer a given topic (such as dose assessment PMP 2080 EPP.006, j .007; PMP 2081 EPP.016, .017, and PMP 2082 EPP.001) should be cross

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referenced. This was discussed with the Staff Assistant and he

Andicated these changes would be made. In addition, the inspector suggested that PMP 2080 EPP.001 be amended to include reference to

,' notification procedures PMP 2080 EPP.008 and PMP 2080 EPP.012 following j cmergency classification. This modification is now in progress.

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Based on the above findings, this portion of the licensee's program

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is acceptable; however, the following items should be considered for l improvement:

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The Emergency Plan Implementing Procedures should be amended to provide a cross index of other directly pertinent Emergency Plan Implementing Procedures.

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The licensee should complete the revision of PMP 2080 EPP.001 to include reference to PMP 2080 EPP.008 and PMP 2080 EPP.01 .2 Emergency Alarm and Abnormal Occurrence Frocedures i

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j Abnormal Operating Procedures (A0Ps) do not specifically instruct i personnel to evaluate abnormal conditions relative to Emergency Action

! Levels (EALs) in the the Emergency Plan and Implementing Procedures i

(EPIPs). However, the EPIPs contain steps to evaluate abnormal plant

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parameters and initiating conditions relative to Emergency Action

,' Levels. Emergency Plan Implementing Procedure PMP 2080 EPP.001 and

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other EPIPs are used by plant personnel to evaluate and classify abnormal occurrances with regard to emergency classification A recent gaseous release was not classified as an abnormal event based on Technical Specification levels. This same release did qualify as an Unusual Event based on the EALs. This discrepancy is being corrected and the remaining EAL's should be examined with the intent of eliminating future misclassification Based on the above findings, this portion of the licensee's program is acceptable; however the following items should be considered for improvement:

. Appropriate A0Ps should be revised to ensure the user is properly referenced to appropriate EPIPs for evaluation of the initiating conditions relative to emergency action level . Emergency Action Levels should be reviewed to assure agreement between Technical Specification levels and NUREG-0654, Appendix .3 Implementing Instructions The inspector reviewed current Emergency Plan Implementing Procedures and discussed aspects of the procedures with the Staff Assistant and Operations Engineer. Implementing instructions are written for use by the OSEC and contain delineation of responsibility, duties, and person-nel to be involved in each phase of the emergency organization. The procedures contain specific Emergency Action Levels and planned response actions to be considered and/or implemented. The procedures (particularly the PMP 2080 series) orchestrate the implementation of other specific procedures developed to support implementation of the Emergency Plan. However, emergency condition categories (Exhibit A of PMP 2080 EPP.001) are not listed in the Emergency Plan in accordance with 10 CFR 50, Appendix The implementation procedures do not clearly relate staffing and activ-ation of facilities and centers to emergency class as put forth in the Emergency Plan. The inspector discussed the possibility of constructing an abbreviated foria of Emergency Plan Tables 12.3.5.3 and 12.3. (Emergency Protective Action Guidelines for the Donald C. Cook Nuclear Plant) to include only Emergency class column and Donald C. Cook Plant Action column. This table would be referenced in PMP 2080 EPP.001 and placed in the PMP 2081 section. A revision to PMP 2080 EPP.001 is in progress which would insert a short explanatory paragraph relating emergency class to the degree of emergency organization activatio Based on the above findings, this section of the licensee's program is unacceptable. Improvement in the following area is required to achieve an acceptable progra . Incorporate Emergency Condition Categories 1-22 of PMP 2080 EPP.001 into the appropriate section of the Emergency Pla .

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In addition the following item should be considered for improvement:

. Construct an abbreviated form of Emergency Plan Tables 12.3. and 12.3.5.4, reference it in PMP 2080 EPP.001 and include it in the PMP 2081 sectio .4 Implementing Procedures 5. Notifications There are procedures to notify offsite personnel and organizations in response to emergency classificatio Immediate notifications that are the responsibility of the OSEC are delineated in the Procedures PMP 2080 EPP.001, PMP 2080 EPP.008 and PMP 2080 EPP.01 A pyramid phone call system is used so that the Shift Supervisor (as interim OSEC) is only required to make one call to the Plant Manager or the Operations Superintendent. The OSEC (Shift Supervisor) can delegate initial notifications to the Emergency Communications Director at his discretion. Action levels are specified for notification of the onsite and offsite emergency organization, and message content guidelines are contained in the appropriate procedures. However, actions to be taken for any General Emergency for which dose projections have not been calculated are not being recommended to appropriate offsite authoritie Implementation procedures contain a list of phone numbers for key personnel and agencies in Appendix A. Authenti-cation requests are specified in the calls to the Berrien County Sheriff and the Michigan State Polic Each technical section manager will be responsible for calling in necessary off duty personnel as neede The inspector suggested that PMP 2080 EPP.008 and .012 be referenced in the appropriate section of PMP 2080 EPP.00 <

This revision is now in progress. The inspector also discussed the possibility of reprioritizing PMP 2080 EPP.012 to assure notification of agencies responsible for public safety is not delayed due to other notifications. The inspector discussed the need for a feedback mechanism that would guard against an unnoticed termination of a portion of the call tree. A revision to PMP 2080 EPP.008 to expand the detail of the call tree and further delineate Shift Supervisor and Plant Manager responsi-bilities is now in progres Based on the above findings this portion of the licensee's program is adequate; however, the following items should be considered for improvement:

. Complete the revision to PMP 2080 EPP.008 to expand the detail of the call tree and further delineate Shift Supervisor and Plant Manager responsibilities, and reference PMP 2080 EPP.008 and .012 in PMP 2080 EPP.00 .

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. Repr d oritize the list of of fsite notification found in PMP 2080 EPP.012 to reficct notification of Berrien County Sheriff's Department and Michigan State Police before corporate personnel or Federal agencies in the event of an Alert or higher classificatio . Amend procedure PMP 2080 EPP.012 to indicate notification of offsite authorities within 15 minutes of an unusual event classification as per NUREG-0654, Appendix .4.2 Assessment Action Procedures The procedures for initial accident assessment have been writte They outline the proper sequence of actions and utilize a set of nomographs to provide a rapid and relatively easy prediction of the dose rate at the site boundary. In addition, the procedures describe the propar classification of the event as it relates to the site boundary dose rate. After the activation of the TSC, the RP supervisor becomes responsible for dose assessment. This task is performed with the aid of an online computer. A back up telephone connected time sharing computer system, and a programable calculator for calculating the site boundary dose rate from both effluent monitoring and offsite surveys are also availabl The finite cloud correction factors listed in PMP 2081 EPP.014 have not been incorporated into the computer software and therefore near-site dose assessments would overestimate the true dos Walk-throughs for determining initial rapid accident assessment were performed by eight Shift Supervisors and Assistant Shift Supervisors. Personnel in the walk-throughs were familiar with the procedures and should be able to provide accident assessment in an emergency situation. However, there are no provisions for determining an initial site boundary dose rate for the release of decayed (OLD) noble gases in the procedure The inspectors determined from the accident assessment procedures that protective measures for degrading reactor conditions have not been incorporated, specifically for those cases where offsite dose projections have not yet been calculated (e.g., loss of two out of three fission product barriers with a potential loss of the third, any core melt situation with a potential release, degraded core cooling or loss of coolable geometry leading to a potential significant release, etc.). For these significant reactor accidents, offsite dose projection may not be calculable and no release may be taking place. However, protective measures for the public would be warrante Based on the above findings, this portion of the licensee's program is unacceptable. Improvement in the following areas is required to achieve an acceptable program:

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. Revise procedures to provide for an initial rapid dose assessment for the release of decayed (old) noble gase . Incorporate finite cloud correction factors into the dose assessment computer software or modify procedure PMP 2081 EPP.014 to require that these factors be applied to the appropriate computer outpu . Recommend the following actions to appropriate offsite authorities for any General Emergency in which offsite dose projections have not been calculate activation of the public notification syste sheltering for two mile radius (not sectors) and five miles downwind in the affected sector placing cows (if appropriate) within ten miles on stored fee .4.2.1 Offsite Radiological Surveys 5.4.2.2 Onsite (out of plant) Radiological Surveys 5.4.2.3 Inplant Radiological Surveys The procedures describing onsite and offsite monitoring are well written, and present an easily understandable and accurate accounting of the necessary actions for performing the surve The equipment for performing the surveys is located in the post accident sampling room, with spars or extra backup equipment located at a distribution center or, the 633 ft. level. Special offsite survey kits have been made up and are also located in the post-accident sampling room. The kits were portable, contained all necessary equipment, and can save a great deal of time when organizing the offsite survey teams. One problem was noted in Procedure 12 THP SP.012. The procedures call for a PIC-6A survey meter as an interim monitor on a recirculation line for radioactive vent gases. However, the procedure for the setup does not provide

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an accurate description of how the survey meter should be positioned, and a walk-through of the procedure (See Section 7.2.2) illustrated this weakness.

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Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

l i . Procedure 12 THP SP.012 should be modified to provide a more accurate description of the placement of the PIC-6A survey meter, or training should be modified to insure that the RPTs understand the proper placement of the mete .

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5.4.2.12 Radiological and Environmental Monitoring The licensoe has a procedure (PMP 2081 EPP.013) for environmental analysis and monitoring. The procedure establishes routine sampling points and methods for evaluating the data obtained relative to projected dose. Elements of the sampling program include air, water, milk, precipitation and TLD's using standard RAD procedures. The sampling program does not include procedures for sampling various other elements such as sediments, food stuffs and fish. The bulk of the routine sampling program is performed by Eberline laboratories. No reference to Eberline or other con-tractor laboratories is found in the Emergency Plan Implementing Procedures (or the Standard Operating Procedures). There is no guidance as to when support laboratories and personnel will be activated in an emergency and what duties will be performed by site personnel versus contractor service Based on the findings above, this portion of the licensee's program is acceptable however the following items should be considered for improvemen . PMP 2081 EPP.013 should be expanded to include specific reference to standard operating procedures for the various types of samples including sediments, food stuffs, fish, et . Procedures should be written which describe the degree of involvement of various offsite contractors in the collection and analysis of environmental samples. Procedures should address activation of contractors with regard to emergency classification and criterion for continued us . Protective Actions 5.4. Radiation Protection During Emergencies The licensee has developed an overall emergency procedure (PMP 2081 EPP.004) governing the implementation of specific aspects of radiation protection by the Radiation Assessment Director (RAD) during emergencies. Elements of the program include personnel dosimetry, exposure records, access controls, instruction to emergency workers and dose assessment. A con-trolling procedure which describes how and by whom health physics functions will be performed and their priority during an emergency has been developed for use by the Radiation Protection Director (PMP 2081 EPP.009).

Based on the findings above, this portion of the licensee's program is acceptabl .4. Evacuation of Owner Controlled Area A review was made of the licensee's proposed evacuation of licensee and nonlicensee personne .

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Evacuation of specific areas within the site and from the site is the responsibility of the Onsite Emergency Coordinator and is determined by plant conditions and not tied to specific action levels. The protective Response Planning Standard which states that each licensee shall provide for the evacuation of onsite nonessential personnel in the event of a Site or General Emergency is not being implemented. Evacuation routes within the plant are marked, and evacuation routes from the site are shown on a drawing in the Emergency Plan and described in Procedure PMP 2081 EPP.00 Procedures for accountability, personnel monitoring and decontamination are available and adequat Based on the above finding, this portion of the licensee's program is unacceptabl Improvement in the following area is required to achieve an acceptable program:

. Activation of the site evacuation / assembly alarm (Nuclear Plant Emergency Alarm) for all Site Area or General Emer-gencies is required as well as for those radiological events judged necessary by the Shift Supervisor or Onsite Emergency Coordinato .4.3.3 Personnel Accountability A review was made of the area of personnel accountability, to determine if procedures are available for complete accountability and identification of missing individuals within about 30 minute Personnel accountability is performed using the Security Computer key card readers. Sub programs for the Computer can determine the last area in which a missing person was known to have bee In the event that the Computer is not operable, accountability will be completed using rosters and Security badges. Account-ability is the responsibility of the Operations Staging Area Manager (0 SAM).

Neither the OSAM nor Security personnel, who may have to assist in accountability, were aware of the design objective of completing accountability in 30 minute Based on the above findings, this portion of the licensee's program is acceptabl .4.3.4 Personnel Monitoring and Decontamination The inspectors reviewed EPIP PMP 2082 EPP.008, .009, .010 and .01 The procedures provide guidance to assure monitoring of individuals entering and leaving restricted and/or contaminated areas. Forms are provided to document survey and decontamination effort Action levels are specified with regard to airborne and surface contamination both to initiate and terminate decontamination efforts. Skin decontamination limits, addressing radiciodine

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only, are not specified. Forms are included to provide collected data to the RAD team superviso Based on the findings above, this portion of the licensee's program is acceptable; however the following items should be considered for improvement:

. A procedure and checklist of items (or prepositioned kits)

should be prepared to assist decontamination efforts at alternate assembly area .4.3.5 Onsite First-Aid / Rescue The inspectors reviewed EPIP PMP 2080 EPP.014 and PMP 2081 EPP.00 The procedures provide guidance for recovery, treatment, handling, and transportation of injured and/or contaminated persons. The procedures provide data to the OSEC to enable dispatching of appropriate personnel and, if contamination is present, to direct the Radiation Protection Director to form and dispatch a reentry and rescue team. Separate message forms are provided for com-munication with offsite medical facilities regarding injuries with or without radioactive contaminatio Based on the findings above, this portion of the licensee's program is acceptabl . Security During Emergencies A review was made of security measures to be placed into effect during an emergenc Site Security measures are in accordance with the requirements of 10 CFR 73, Appendix C. Security measures to be implemented have been developed. Security personnel have been trained in performing their functions during an emergency. Actions to be taken by Security personnel are specified in Security Emergency Implementing Procedures and Emergency Plan Implementing Procedure Based on the above findings, this portion of the licensee's program is acceptabl . , Repair / Corrective Actions Procedure Normal maintenance and Instrument and Control procedures are utilized in emergency situations in accordance with RP super-vision and general action procedures. The priority of the repair and corrective actions is determined by the TSC staf Based on the above findings, this portion of the licensee's program is acceptabl i

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5. Recovery Procedures There are no specific procedures for recovery after an accident; however, the licensee has stated that the classification criteria would be used for declassification and that other actions would be dictated by the circumstances of the even General Recovery / Reentry Procedures need to be prepared describing criteria to be used to determine when, following.an accident, reentry of the facility would be appropriate or when operation could be resumed. The procedures shall generally follow the recommendation of INP Based on the above, the licensee's lack of Recovery / Reentry EPIPs which follow the recommendations and standards of INP0 is an Open Ite . Public Information The AEPSC and the Indiana and Michigan Electric Company (I&ME Co.)

Public Relation Staff coordinates all press and media briefing, public information activities and Lccal, State and Federal infor-mation efforts. The I&ME Co. Public Af fairs Director supervises and participates in development, preparation, coordination, and dissemination of information to the news media and the publi The I&ME Co. " Nuclear Emergency Response Plan" manual adequately describes how the public information activities will be conducted in an emergency. The specific means for disseminating public information have been developed. An ongoing program for period-

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ically educating the public on key emergency preparedness and

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radiological concepts has been established. Rumor control methods have been establishe Based on the above finding, this portion of the licensee's program is acceptabl .5 Supplemental Procedures 5. Inventory, Operational Check and Calibration of Emergency Equipment Facilities and Supplies i

l The inspectors reviewed PMP 2082 EPP.007, .009 and standard Pro-

! cedures 12 THP 6010 RAD.222 and .224. The RAD procedures provide specific inventory listing and location of all equipment reserved for use during emergencies. The procedures specify quarterly inventory and operational checks. The interval between calibration checks is not specified in EPP or RAD procedures but the survey instruments are calibrated by the RP section semiannually.

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The radiation protection department is responsible for the inven-tory of most medical supplies, radiation protection / assessment-equipment, operational and calibration checks.of instrument The RP department does not inventory medical equipment in the first aid room except for the oxygen bottles and regulator Inventory and restocking the first aid room is performed on-a weekly basis by an employee in the personnel section. Procedure 12 THP 6010 RAD.222 does not contain instructions to check calibration stickers on the survey instruments. The procedures provide instructions for noting and replacing defective and/or missing equipmen Based on the findings above, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement:

. Procedure PMP 2082 EPP.007 should be amended to refer to a complete inventory of emergency equipment in the appendix of the Emergency Plan Implementing Procedures as per NUREG-0654, Section H.1 . The RP department should inventory the first aid roo Procedure 12 THP 6010 RAD.222 should be appropriately amended to reflect thi . The RP department should include an instruction to check calibration stickers in 12 THP 6010 RAD.22 . Calibration frequency of various survey instruments should be specifie . Drills and Exercises The inspector reviewed PMP 2082 EPP.005, and .00 Drills and exercises are administered by the Emergency Planning Coordinato Each drill / exercise is conducted in accordance with a prearranged scenario. Observers and participant comments are evaluated and records kept by the Emergency Planning Coordinator. Exercises, communication , fire and medical drills are conducted as specified in NUREG-0654. Radiological monitoring and health physics drills are not specifically listed in the Tests and Exercises Procedur Offsite agencies and groups participate in drills and exercises and simulated news releases are used.

j No provision has been made for backshift drills as outlined in i NUREG-0654, Section Nib. The procedure does not indicate if

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actual events can substitute for drills and exercises and, if so,

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to what extent. Radiological monitoring and health physics drills (in addition to the annual exercise) are not specified as per NUREG-0654, Section N2d.e.

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Based on the findings above, this section of the licensee's program is acceptable; however, the following items should be considered for improvement:

. Provision for backshift drills should be specified in the procedure as per NUREG-0654, Section Ni . Procedures for annual radiological monitoring and semi-annual health physics drills (in addition to annual exercise) should be written in accordance with NUREG-0654, Section N2 .5.3 Review, Revision and Distribution of Emergency Plan and Procedures Tha inspectors examined the licensee's program regarding review, revision and distribution of the Emergency Plan and Implementing Procedure The review and updating are the responsibility of the Plant Nuclear Safety and Design Review Committee and are performed on an annual basis. Specific personnel are assigned the responsi-bility for the review. The review and revision have been completed in accordance with Section 12.3.16 of the Emergency Pla Some discrepancies in a previous revision distribution were noted but have been correcte Based on the above findings, this portion of the licensee's program is acceptable, however, the following item should be considered for improvement:

. Telephone numbers should be reviewed and updated as necessary quarterl .5.4 Audit Procedure PMP 2082 EPP.009 states that the Emergency Plan shall be audited independently every 24 months and the Emergency Plan Procedures reviewed at least annually. Technical Specification 6.5.2.8 requires that the Plan and EPIPs are audited once per 24 months. The New York Service Corporation is responsible for the independent audit. The audit involves observations of procedure implementation and discussions with personne CFR 50.54(t) requires that an annual independent audit be conducted of the licensee's emergency preparedness progra Accordingly, the licensee should request a T/S change to ensure consistency with the new regulation Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

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. Change the procedure to require an annual audit of the Emergency Plan, Emergency Plan Procedures, Training, Drills and Exercises, Facilities and Equipment, and request a T/S chang .0 Coordination with Offsite Groups 6.1 Offsite Agencies Select offsite agencies were contacted to determine the support they would provide in the event they would be activate . Berrien County Sheriff The County Emergency Planning Coordinator was interviewed to determine the Sheriff's Emergency Preparedness capability in response to a nuclear emergency at the Donald C. Cook Plan The Coordinator was aware of his office's interface with the plant during an emergenc This office is responsible for prompt public notification (sirens).

Messages received from the plant which involve a recommendation for evacuation or sheltering are authenticated by a call back procedur The encoder which activates the sirens also can open channels with news medi This office also has a county Emergency Broadcast System available in their Emergency Operations Cente Based on the above findings, this portion of the licensee's program is acceptabl . Memorial Hospital, St. Joseph, Michigan The Vice President-operations was interviewed to determine the adequacy of the hospital to respond to an emergency involving contaminated injuries of plant personnel. The staff receives training annually by a licensee contractor and is involved annually, as a minimum, in plant initiated drill The hospital has set aside the autopsy / morgue room for handling contuminated patients. Adequate radiation protection supplies and containers for collection of contaminated solids and liquids are available as needed. Equipment and supplies are inventoried as require Based on the above findings, this portion of the licensee's program is acceptabl . Bridgman Fire Department The assistant Fire Chief was interviewed. He stated that the department consists of eighteen volunteers. The plant provides training in the form of tours and fighting of actual fires set

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ment also participates in drills conducted by the license ;

Based on the above findings, this portion of the licensee's program is acceptabl . Letters of Agreement A review of the licensee's file confirmed that the licensee has current letters of agreement signed by representatives of support agencies. These letters have not replaced outdated letters currently in an Appendix to the Plan, nor do they contain the elements of NUREG-0654, Section A.3. (see Appendix C of the Emergency Plan).

Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement and are discussed in Appendix D of this report:

. Assure that letters of agreement contain elements as stated in NUREG-0654, Section . Incorporate current letters of agreement in an Appendix to the Plan or describe these agreements and provide a signature page in the Plan in accordance with NUREG-0654, Section .2 General Public and Transient Population 6. Information Distribution An information brochure titled " Emergency Preparedness in Berrien County" has been published and distributed to all residents in the plume exposure pathway. The brochure is intended to provide residents near Donald C. Cook Plant with information on the plant, nuclear incidents, serious weather emergencies and emergency pre-paredness. Information on radiation, how they would be notified of an incident and specific evacuation and shelter advise has been included. Brochures have also been distributed to area hotels, motels, hospitals and other public building Special instructions and a special mailer to be filled out and returned to the Berrien County Sheriff's Department for those residents with hearing deficiency or who are severely handicapped are also include However, brochures or other means of pre-informing the transient population at the Warren Dunes State Park were not distributed or made available to this State Park. This is discussed in IE Reports No. 50-315/82-03; 50-316/82-0 Based on the above findings, this portion of the licensee's program is acceptabl __- _ _ _

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e 6. Prompt Public Notification System The licensee has installed an Early Warning Siren System (EWSS)

within the ten mile plume exposure pathway Emergency Planning Zon The EWSS consists of 14 strategically located sirens designed and placed to meet the criteria established in 10 CFR 50, Appendix The sirens were manufactured by Alerting Communication of America Corporation. The system was installed in August 1981. In addition to the sirens and siren activation radio receivers, special radio receiver recorders have been supplied to the major news media services in the general area of the Donald C. Jook Plant. The radio will alert the media operator to listen for a message transmitted by the Berrien County Sheriff's Department (BCSD). The BCSD has the responsibility for activating the Prompt Public Notification System. The sirens are tested on the first Saturday of every mont Based on the above findings, this portion of the licensee's program is acceptabl .3 News Media A program has been developed and implemented to train news media person-nel in nuclear power, terminology, concepts and emergency plan trainin Sessions have been provided for the media. The most recent training session was held on August 14, 1981. Annual retraining is schedule Based on the above findings, this portion of the licensee's program is acceptabl .0 Walk-throughs and Exercises Drills and Exercises Drills and exercises required by the Plan and procedure PMP 2082 EPP.005 have been conducted in accordance with established procedures. Observer comments and critiques of each drill are kept on file and individuals responsible for drill identified improvement items are identifie There is no formal procedure for tracking the completion of identified problems although that function is currently performed by the Onsite Emergency Coordinator. Offsite agencies participate in drills; how-ever, their comments are not included in the summary critiqu Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement:

. Develop a tracking system to insure timely completion of drill identified items pursuant to 10 CFR 50, Appendix . Solicit and include comments of offsite participants (including news agencies) in the drill critiqu e e

. 7.2 Walk-Throughs 7. Post-accident Sampling and Analysis Post-accident sampling and analysis walk-throughs were conducted by four different cts for liquid effluents, containment air, reactor coolant, and station vent effluents. All four technicians appeared to be familiar with the apparatus and procedures, with the exception of station vent effluent sampling for which a procedure is not availabl As a result of the lack of procedures, the vent sampling was not acceptable. There were numerous times when the necessary equipment was not available, when ALARA was not considered, and where con-tamination would probably have occured. The other sampling and analysis walk-throughs were acceptable; however, due to a problem in the procedures, the containment air sample would have been transported to the hot lab prior to checking the approximate dose rate of the sampl Based on the above, the containment air, coolant, and liquid effluent sampling and analysis is acceptable. The vent effluent sampling is not acceptable, and procedures were not availabl (See Section 5.4.2.8).

7. Radiological Survey Two Radiation Protection technicians were asked to perform an offsite radiation survey. The RP technicians showed a goo practical knowledge of the procedures and the equipment. The necessary equipment was readily available and is in good working orde Inplant surveys were conducted of the interim vent gas system by two RP technicians following Procedure 12 THP.SP.01 The technicians showed a good working knowledge of the principles

, and practices associated with the vent gas system by properly l performing the surveys. However, they were unable to place the l PIC-6A survey meter into the setup for generating the correct geometry. When they finally managed to fit the meter into the setup, it was obvious that the geometry was incorrect. Later, after discussing this with the RP Supervisor, it was learned that the setup is designed to use the meter without the sliding tray. The design is for use with an RM-16 meter and a compen-sated GM tube, as a more permanent interim syste Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvemen . Modify the procedure to provide a more precise placement of the PIC-6A survey meter, including the removal of the sliding tra (See Section 5.4.2.8).

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T.2.3 Dose Assessment Initial dose assessment walk-throughs were performed with eight Shift Supervisors and Assistant Shift Supervisors. The personnel performing the walk-throughs were familiar with the procedures and performed quick efficient assessments. The only problems arising during the walk-throughs resulted from a fault in the procedure The nomograph for determining dose rates due to old gas activity registering on the R-26 monitors was not present in the procedure In addition to the walk-through on initial dose assessments, the RP manager demonstrated the capability of his dose assessment computer models which can be accessed on two different computer systems and a TI-59 calculator. These models provide the facility with the capability to produce rapid and accurate dose assessmen Based on the above findings, this portion of the licensee's program is acceptabl .2.4 Emergency Classification The inspector conducted walk-throughs with most of the Shift Supervisors (SS) and the Assistant Shift Supervisors (ASS) to insure they understood Procedure PMP 2080 EPP.001, Emergency Plan Activation and Condition Classification. Scenarios were given to each Shift Supervisor and Assistant Shift Superviso As the postulated emergency event progressed, plant condition and instrument readings were provided. In each case the Shift Supervisors and the Assistant Shift Supervisors properly classi-fled the emergenc Based on the above findings, this portion of the licensee's program is acceptabl .2.5 Facilities and Kits

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Emergency equipment specified in the procedures was in place and inventory records were curren Spot checks showed equipment to be operable. The first aid room did not contain a set of pro-cedures, a cot, or a stretcher as specified in the Emergency Pla Personnel interviwed were familiar with the equipment and procedure Based on the above findings, this portion of the licensee's program is acceptabl .2.6 Radiological and Environmental Monitoring Program

! The intipector accompanied a radiation protection technician through a hypothetical sampling of well water. Enviroamental Monitoring Stations were visited and the technician outlined the steps required to take samples from a station. The tech-nician was familiar with the stations and sampling procedures.

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Based on the above findings, this portion of the licensee's program is acceptabl . Notification The inspector contacted an Operations Engineer, Staff Assistant Training Coordinator, Radiation Protection Supervisor, and Shift Supervisor who were cognizant of notification responsibilities and had ready access to the appropriate list of names and phone number Based on the above findings, this portion of the licensee's program is acceptabl .0 Licensee Actions on Previously Identified Items Related to Emergency Preparedness (Closed) 315/78-06-01: Air samplers were not located at Inter-state 94 Guardhouse and at the Stevensville substation. During the Emergency Preparedness Appraisal (315 and 316/82-05) the emergency equipment at these locations was examined and the air samplers were on han (Closed) 315 and 316/79-03-01: The licensee did not conduct a quarterly drill. All exercises and drills have been conducted in accordance with Procedures EPP.016 since 197 .0 Persons Contacted D. C. Cook Personnel

• W. G. Smith, Jr., Plant Manager

• E. Smarrella, Technical Superintendent

• V. Vanderburg, Production Supervisor Technical

• D. Nelson, Training Coordinator

• K. Baker, Operations Superintendent

• B. Svensson, Assistant Plant Manager

• E. Townley, Assistant Plant Manager

• R. Begor, Staff Assistant D. Palmer, Radiation Protection Supervisor T. Kriesel, Environmental Supervisor J. Dickson, Training Instructor I J. Wojcik, Plant Chemistry Manager B. Lentz, Shift Chemistry Supervisor J. Carlson, Senior Chemistry Technician C. Haglund, Chemistry Technician W. Nichols, Training Instructor I L. Correll, Training Clerk J. Cassidy, Training Clerk W. Brackett, Shift Security Supervisor G. Seifert, Facility Manager D. Weber, Assistant Training Clerk K. Vogel, Chemistry Technician

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O R. Dudding, Maintenance Superintendent J. Paris, Senior Radiation Protection Technician T. Gurn, Senior Radiation Protection Technician

• Denotes those present at the exit intervie . Exit Interview The inspectors and senior management from NRC Region III met with licensee representatives (denoted in Paragraph 9) at the conclusion of the appraisal on March 26 and 31, 1982, and by telephone on April 2, 1982. In addition, a special enforcement management meeting was held on May 4, 1982, to discuss the EPIA appraisal. The inspectors sum-marized the scope and findings of the appraisa NRC representatives at the enforcement meeting were: Messr J. Keppler, J. Hind, R. Knopp, D. Hayes, S. Ramos, W. Axelson, and the SRI. Representatives from AEP included Messrs. Hunter, Smith, and other AEP corporate personne As a result of that meeting, the licensee made acceptable verbal commitments to resolve some of the NRC concerns and agreed to respond, in writing, to the NRC regarding the inadequacy of the interim EO Also, they agreed to provide a draft conceptual design for a permanent EOF for NRC staff revie Specific enforcement action was not dis-cussed; however, the NRC staff clearly indicated to the licensee that their interim EOF was in noncompliance with NRC regulations and that an inadequate state of emergency preparedness existe e

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