IR 05000373/1986001

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Insp Rept 50-373/86-01 & 50-374/86-01 on 860407-10.No Violation Noted.Major Areas Inspected:Emergency Preparedness Exercise.Weaknesses Noted:Failure to Adequately Inform State & NRC Operations Ctr of Changes
ML20210L104
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 04/23/1986
From: Allen T, Ploski T, Matthew Smith, Snell W, Williamsen N
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20210L080 List:
References
50-373-86-01, 50-373-86-1, 50-374-86-01, 50-374-86-1, NUDOCS 8604290177
Download: ML20210L104 (12)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/86001(DRSS); 50 374/86001(DRSS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee:

Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name:

LaSalle Nuclear Generating Station, Units 1 and 2 Inspection At:

LaSalle Site, Marseilles, IL Inspection Conducted: April 7-10, 1986 LdG.M/k Inspectors:

T. Ploski

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.1/2 Me c, Team Leader Date'

{ (bA...

T. Allen

/#3/84 Date h)7.

nd M. Smith

? #4[f6 Date 6(_) Is N. Williamsen

.gn/To

Date w. c;.SJ'

Approved By:

W. G. Snell, Chief

.//n/.m Emergency Preparedness Date Section Inspection Summary Inspection on April 7-10, 1986 (Reports No. 50-373/86001(DRSS);

50-374/86001(ORSS))

Areas Inspected:

Routine inspection of the LaSalle Station emergency preparedness exercise, involving observations by eig. NRC representatives, four NRC inspectors and four consultants, of key fur t. ions and locations during the exercise.

Results:

No violations of NRC requirements were identified.

However, several weaknesses that will require corrective action are identified in the text of this report and are summarized in the appendix to the report's transmittal letter.

8604290177 860424 PDR ADOCK 0500

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GETAILS 1.

Persons Contacted NRC Observers and Areas Observed T. Ploski, Control Room, Technical Support Center (TSC), and Emergency Operations Facility (EOF)

F. McManus, Control Room D. Schultz, TSC G. Wehmann, Operational Support Center (OSC) and In plant Teams N. Williamsen, OSC and In plant Teams T. Allen, OSC and Offsite Environmental Monitoring Teams G. Martin, EOF M. Smith, E0F and Joint Public Information Center (JPIC)

Commonwealth Edison C. Reed, Vice President, CECO D. Galle, Assistant Vice President and General Manager, Ceco

  • G. Diederich, Station Manager, LaSalle Station
  • D. Scott, Station Manager, Dresden Station E. Fitzpatrick, Station Superintendent, Braidwood Station
  • K. Klotz, GSEP Coordinator, LaSalle Station
  • T. Blackmon, Lead Controller, E0F
  • F. Krowzack, Controller, E0F
  • T. Greene, Controller, EOF
  • L. Aldrich, Rad / Chem Supervisor, LaSalle Station
  • B. Cozzi, Controller, Control Room
  • T. Markwalter, Controller, TSC G. Swihart, Controller, Control Room D. Crowl, Controller, Control Room L. Literski, Controller, OSC A. Nykiel, Controller, OSC T. Chubb, Controller, High Range Sampling System J. Bowman, Controller, Environs Team K. Kenealy, Controller, EOF R. Moore, Controller, EOF, JPIC R. Thacker, Controller, EOF K. Licari, Controller, JPIC
  • Indicates those present of the April 9,1986 exit interview.

2.

Licensee Action on Previously Identified Items

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(Closed) Severity Level V Violation No. 373/85011-01, 374/85011-01:

The licensee failed to demonstrate that adequate corrective actions had been taken regarding two weaknesses identified during the October 1984 emergency preparedness exercise.

These weaknesses involved the overall performancec of licensee personnel who functioned as technical spokespersons in the

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JPIC and others who operated the dedicated GSEP Van as members of an offsite environmental monitoring tear...

As indicated in Sections 5f and 5g of this report, the overall performances of the JPIC spokespersons and persons assigned to the GSEP Van were adequate.

This item is closed.

3.

General An exercise of the licensee's Generating Stations Emergency Plan (GSEP)

was conducted at the LaSalle County Station on April 8, 1986.

The exercise tested the licensee's, NRC's, State's, and local government agencies' capabilities to respond to a hypothetical accident scenario resulting in a simulated major release of radioactive material.

This was a full-scale exercise for the State of Illinois and LaSalle County and a partial-scale exercise for Grundy County.

Attachments are the Exercise Scope of Participation, Exercise Objectives, and Scenario Narrative Summary.

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4.

General Observations a.

Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the GSEP, LaSalle Annex to the GSEP, and the onsite and offsite emergency organizations' emergency plan implementing procedures.

b.

Licensee Response The licensee's response was generally coordinated, orderly, and timely.

Had these events been real, the actions taken by the licensee would have been sufficient to allow State and local authcrities to take appropriate actions to protect public health and safety, c.

Observers Licensee observers monitored and critiqued this exercise along with eight NRC observers and a number of Federal Emergency Management Agency (FEMA) observers.

FEMA observations on the responses of State and local governmental agencies will be documented in a separate report.

d.

Exercise Critiques The licensee held a critique following the exercise on April 8, 1986.

The NRC critique was conducted on April 9 at the Emergency Operations Facility (EOF) located near Mazon, Illinois.

A joint public critique was held in Ottawt., Illinois on April 10, 1986, to present the preliminary onsite and offsite findings of the NRC and FEMA observers, respectively.

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5.

Specific Observations a.

Control Room The Shift Engineer (SE), Station Control Room Engineer (SCRE), and Nuclear Station Operator (NS0) functioned well as a team in recogniz-ing changing plant conditions and the consequences of these changes.

Appropriate emergency operating procedures were effectively utilized.

The SE and SCRE maintained adequately detailed, informal logs to permit later reconstruction of their actions.

The SCRE's notes also included trends of plant parameters relevant to the scenario.

The Unusual Event was promptly and correctly classified.

Initial notifications to the Illinois Department of Nuclear Safety (IDNS)

and Illinois Emergency Services and Disaster Agency (IESDA) were promptly completed using the dedicated Nuclear Accident Reporting System (NARS).

Initial notification of the NRC Operations Center was then accomplished using the Emergency Notification System (ENS).

Shortly after the Unusual Event declaration, the SCRE provided adequately detailed briefings on plant conditions to an Operating Engineer and the Senior Resident Inspector.

Within a 20 minute period Control Room personnel recognized two separate changes in plant conditions, each of which warranted Alert declarations per Alert Emergency Action Levels (EALs) No. 14 and 13.2, respectively.

The SE, as Acting Station Director (SD),

correctly declared an Alert for EAL No. 14 for the first change and instructed a communicator to begin transmitting an approved NARS message.

The Acting SD then returned his attention to activating the onsite emergency response facilities and to initiating several in plant investigative actions.

Several communicators then arrived to augment Control Room staff when the second major change in plant conditions, an Anticipated Transient Without a Scram (ATWS), occurred.

Although the Acting SD responded to the ATWS, he did not declare a second Alert for the ATWS per Alert EAL No. 13.2.

Consequently, no NARS message was prepared and transmitted for the ATWS occurrence.

By this time, a replacement communicator had begun an ENS notification to the NRC Duty Officer regarding the Alert actually declared per EAL No. 14. When asked by the Duty Officer what " Alert EAL No. 14" meant, the communicator mistakenly replied that No. 14 meant that an ATWS had taken place.

(The inspector noted that the communicator also did not refer to a readily available copy of the "NRC Duty Officer's Event Notification Worksheet" when calling the NRC.

Instead, he referred to a completed NARS form.)

The net result of these rapidly changing plant conditions and initial notification message errors was that the State agencies were only adequately informed of the first change of plant conditions that warranted an Alert declaration per EAL No. 14, while the NRC Operations Center was only adequately informed of the ATWS that also warranted an Alert declaration per EAL No. 13.2.

Fortunately, both

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State agencies and the NRC activated in response to an Alert declaration.

Nevertheless, the licensee's failure to adequately inform both State agencies and the NRC Operations Center of both changes in plant conditions that warranted Alert declarations is an Exercise Weakness.

(50-373/86001-01; 50-374/86001-01)

In addition to the Exercise Weakness, the following item should be considered for improvement:

When contacting the NRC Operations Center, Control Room

personnel should refer to the readily available copy of the "NRC Duty Officer's Event Notification Worksheet" to facilitate communication with the Duty Officer, b.

Technical Support Center The TSC was fully staffed in s timely manner.

An orderly transfer of command and control of emergency response activities to the iSC's SD was accomplished 45 minutes after the Alert declaration.

Adequate habitability monitoring within the TSC was then initiated.

Although a TSC communicator questioned whether the NRC Duty Officer had been adequately informed of both changes in plant conditions that satisfied Alert EALs, the SD incorrectly decided not to make an ENS call from the TSC, as he believed that the NRC was already sufficiently responding to an Alert declaration.

(The problems regarding initial notifications of both Alert Conditions has been addressed in Section Sa.) The SD classified a Site Area Emergency, per the appropriate EAL, about 20 minutes after changing plant parameters reached the EAL's setpoints.

The associated initial notifications to IESDA, IDNS, and the NRC Operations Center were completed in a timely manner.

However, the SD delegated the initial notification of the State agencies to the licensee's Corporate Command Center, while notification of the NRC Operations Center was delegated back to the Control Room. When questioned about the ENS call delegation at the exi; interview, the SD indicated that the Station's perception during several actual Alert situations had been that the NRC preferred to maintain communications with the Control Room even after the TSC was in command and cor. trol.

Undoubtedly a contributing factor to this situation is the poor placement of the ENS telephone in a far corner of the TSC, where the status boards are not readily visible to an ENS communicator, who would also not have easy access to TSC decisionmakers from the ENS telephone location.

The inspectors assured the licensee that the intent has always been for the Duty Officer to communicate with a knowledgeable person in the facility where command and control authority resides.

Also, that Regional staff and the licensee's corporate Emergency Planning staff are already assessing the adequacy of the numbers and locations of NRC communications devices at all of the licensee's nuclear stations.

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During the exercise the TSC staff made effective use of:

readily available procedures; hardcopy P& ids; large diagrams of plant electrical systems; plant drawings produced from microfiche cards maintained in the TSC; and various TSC status boards.

Status boards were generally well-maintained with relevant information.

In addition, large graphs of reactor vessel level, containment pressure and radiation level, and radioactive release rate were begun prior to the Site Area Emergency declaration and adequately maintained thereafter.

Appropriate graphs were also annotated with important setpoints such as top and bottom of the active fuel and radiation levels associated with specific EALs.

The Environmental Status Board was kept up to date with current and forecast meteorological information; however, it incorrectly indicated that a release had begun when, in fact, an initial slight increase in release rate remained within technical specification limits.

Logkeeping and use of internal message forms were adequately done by individual directors.

Administrative staff did a very good job in handling these messages and in generating typed summaries which were then dittributed to all key TSC staff.

Assembly and accountability of onsite exercise participants was initiated and completed in a timely hianner.

However, the Security Director was too hasty in informing the SD that accountability was complete, as he learned several minutes after making his report that a post-accident sampling team had been dispatched and was just accounted for.

Appropriate TSC directors interfaced in determining the proper direction for the simulated evacuation of nonessential personnel.

TSC directors were all informed of the plan to evacuate nonessentials and were given adequate time to reevaluate their staffing needs prior to the evacuation order.

Based on the above findings, this portion of the licensee's program was adequate; however, the following items should be considered for improvement:

Communications with the NRC Operations Center should be done by

knowledgeable persons located in the onsite emergency response facility where command and control authority is also located.

The Security Director should ensure that he has adequate

knowledge on the whereabouts of all in plant teams and their members' identities while accounting for all onsite personnel.

c.

Operational Support Center and In-Plant Teams The OSC was comprised of a lunchroom near the Shif t Engineer's office and a small room across the hallway which served as an assembly area for some OSC personnel awaiting assignment.

The OSC was adequately staffed within 20 minutes of its activation.

Status boards and a sign-up board had been set up; emergency supplies were inventoried; a repair team had been dispatched; and a frisking

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station had been established at the doorway to the lunchroom portion of the OSC. The location of this frisking station was awkward. On occasion technicians who simply wanted to travel across the hall between their assembly room into the lunchroom would unnecessarily frisk themselves.

At other times persons in either room would shout messages across the hallway rather than go through the frisking station.

The OSC Director maintained good control over his staff.

He delegated tasks effectively, such as the tracking of integrated doses supposedly received by in plant teams and the tracking of in plant teams'

progress and locations.

In plant teams were adequately briefed on assigned tasks and potential radiation hazards.

Persons within the OSC were kept sufficiently informed of in plant radiation survey results and significant changes in plant status through the use of status boards and verbal briefings.

However, an OSC status board did not indicate that a General Emergency had been declared roughly 90 minutes earlier, and some persons in the OSC's assembly area remained unaware of that classification change for at least another 15 minutes.

In plant teans adequately documented their surveys.

Survey results were posted in the OSC.

Ion chamber instruments were properly

" bagged" between usages to prevent interference by noble gases.

One examp'.e of good simulation by an in plant maintenance team was the actual use of a fork-lif t and four-wheel truck to demonstrate how large quantities of chemicals would be transported to an in plant location that was unaccessible to the fork-lift vehicle.

Several problems were observed regarding contamination control.

Some persons entering the OSC did not proper)> frisk themselves, allowing the probe to touch their clothing.

On another occasion, an in plant team went into a dressing station to don protective clothing; however, by that time in the scenario this location had become a high radiation area.

Based on the above findings, this portion of tne licensee's program was adequate; however, the following items should be considered for improvement:

The licensee should reevaluate the location of the OSC's frisking

station.

Changes in emergency classification should be promptly posted

in the OSC.

Assembled personnel should also be told of such changes.

Emergency workers should receive additional training on proper

frisking techniques and the precaution to survey normally clean areas for radioactivity before entering.

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d.

Post Accident Sampling Team Two sets of liquid and air samples were collected using the High Range Sampling System (HRSS).

Samples were then carried to an onsite laboratory for analysis.

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The overall performance of the sampling team was unsatisfactory.

Personnel operating the HRSS followed procedural guidance in LZP 1330-24 only in a perfunctory manner regarding a number of procedural steps that included very specifically worded time limits for performing required actions.

For example, Step F-64 stated that the operator must " wait for one minute" after opening a given valve. The operator in this instance waited for 90 seconds.

In general, persons collecting the samples paid little, if any, attention either to such specifically worded time limits given in the procedure or to a wall-mounted clock, with a sweep second hand, located in the HRSS room.

The second major aspect of the team's unsatisfactory performance was the failure to demonstrate good Health Physics practices.

For example, technicians handled several sample vials without wearing gloves.

On another occasion, a technician did not remove his gloves after handling a sample and then completing his log sheets. On one occasion a syringe needle was merely wiped dry after use and was then returned to its kit.

Little concern was demonstrated for simulated in plant radiological hazards on several occasions when a team member carried semples from the HRSS room to the analysis room.

The technician neitner carried a survey meter nor was accompanied by someone having a survey instrument.

Late in the-exercise, the team was directed to return to the OSC along a route that meant going through a 6 R/ hour simulated radiation field for a j-much lont,er distance that was necessary.

The post accident sampling

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team's failure to follow procedural guidance in LZP 1330-24, regarding specified time periods to perform procedure steps, and to adequately demonstrate good Health Physics practices when collecting, handling,

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and transporting samples in an Exercise Weakness.

(50-373/86001-02; 50-374/86001-02)

The inspector was also concerned about habitability of the HRSS room itself.

During sampling activities, the room's temperature rose to about 90*F, despite the fact that a pedestal fan was utilized to olow outside air into the HRSS room.

Such use of a fan during actual post accident sampling conditions could introduce radioactive contamination into the HRSS room.

In addition to the Exercise Weakness, the following item should be considered for improvement:

The licensee should evaluate methods of improving room

temperature control in the HRSS room.

e.

Emergency Operations Facility

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Shortly af ter an orderly and timely assumption of command and control, the E0F's Recovery Manager (RM) correctly declared a General Emergency.

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However, the Environmental Emergency Coordinator (EEC) misinterpreted procedural guidance when developing the initial offsite protective action recommendation. As a result, exercise controllers had to issue a contingency message so that State officials would receive the proper recommendation via the NARS.

The licensee's failure to follow adequate procedural guidance when formulating the initial offsite protective action recommendation is an Exercise Weakness.

(50-373/86001-03; 50-374/86001-03; The RM and several aids made frequent announcements to keep EOF

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personnel informed of significant changes in plant status and major decisions. With the exception of the Environmental Status Board, all status boards were kept up to date with accurate information.

Although the Environmental Status Board included provisions for current and forecast meteorology and dose projection results, only current meteorological conditions were posted.

A large status board, which matched the NARS form in appearance, was utilized to display the most recent NARS transmittal, including protective action recommendations.

However, no status board was effectively used to list what protective actions were being implemented by State officials and what was the completion status of such actions.

l-The RM and appropriate staff adequately briefed newly arrived NRC Site Team personnel on scenario chronology and actions initiated following the General Emergency that had been declared moments earlier.

During the exercise, the RM and his dose assessment sta "

kept appropriate NRC representatives adequately informed of dose assessments and potential changes to recommended offsite protective actions. A few of these discussions involved representatives of both State agencies present in the EOF and also available via conference

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call in their Springfield, Illinois, emergency response facilities.

However, as time passed, these discussions more often involved only the licensee, the NRC, and IDNS representatives, while the State agency responsible for implementing any recommendations (IESDA) was not always included.

Although there was some confusion and many

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assessments performed regarding a perceived need to expand the evacuation recommendation from a two to a five or even 10 mile radius, all changes to the initial offsite recommendation were appropriate, well-coordinated, and timely.

After a method of pumping water into the reactor vessel had become available, there was a delay of about 30 minutes in taking this important action.

While the licensee and its consultants had already evaluated the potential consequences of adding relative cold, unborated or borated water to the vessel now containing significantly

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degraded fuel, it was unclear to what extent the NRC Site Team was

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aware of the extent of and the results of these evaluations.

Later,

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when a valve was closed to terminate the release, the RM correctly l

requested verification of this closure and assurance that no other j

release path existed.

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E0F environmental staff maintained adequate records of environs teams' move nent.s and survey results.

However, it was not apparent that offsite radiation survey results from the licensee's and the State's field monitoring teams were shared by both organizations.

In addition to the Exercise Weakness, the following items should be considered for improvement:

The Environmental Status Board should be adeqLately maintained.

  • A status board should include information on what protective

actions are being implemented offsite and their implementation status.

Representatives of IDNS and IESDA should be invited to

participate in all discussions regarding offsite protective action recommendations.

Site Team personnel should be adequately informed of all major

technical evaluations performed by the licensee.

The licensee and State should promptly share survey results from

their field monitoring teams.

f.

Radiological Environmental Monitoring Teams Following thorough briefings in the OSC and TSC, two teams were dispatched prior to the release to conduct radiological environ-mental monitoring.

The teams performed radiation level surveys enroute to their vehicles and com Q ted field kit inventories, equipment checks, and dosimetry issue in a timely manner.

The team assigned to the dedicated GSEP Van adequately demonstrated the capability to locate and operate the vehicle's special equipment, to perform radiation surveys, and to collect environmental samples.

Team members frequently referred to applicable procedures, kept adequately detailed logs, and followed good ALARA practices to minimize their exposures.

Due to insufficient detail in Procedure EG-11 regarding the quantity of vegetation that constituted an adequate sample, the team experienced some delay in collecting the first vegetation sample.

The team also experienced brief delays in arriving at several predesignated sampling points since the identifying labels for these points were missing.

The teams were generally kept informed of changes in wind direction, emergency classification, and release status by their controllers in the various emergency response facilities.

However, while the teams were told of the initial protective actions being implemented offsite, they were not kept informed of subsequent changes to these actions.

The environs team leader did not always promptly infoam the team's controllers of arrivals at fixed sampling locations aid was occasionally slow to request clarification of seemingly contradictory instructions.

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Based on the above findings, this portion of the licensee's program was adequate; however, the following items should be considered for improvement:

Procedure EG-11 should include additional guidance regarding

the quantity of material that constitutes an adequate vegetation sample.

All fixed sampling points should be adequately labeled for easy

identification by environs teams.

Environs teams should be kept advised of all changes to

protective actions being implemented offsite.

Environs teams should promptly report their arrivals at sampling

locations, and should promptly request clarification to any instruction from their controllers that seem in error or unclear.

g.

Joint Public Information Center The licensee's JPIC staff was prepared to present their initial press briefing at the Mazon E0F/JPIC facility within one hour of the decision to activate this facility.

Several journalism students from Lewis University and exercise controllers functioned as media representatives.

They provided a good challenge to the licensee, NRC, and State agencies' spokespersons.

Nine press releases were made by the licensee during the exercise.

The first three were issued by corporate staff in Chicago, Illinois prior to the JPIC becoming operational.

The other p ess releases were issued by JPIC staff following approval by the RM or a designee, and after coordination with NRC and State spokespersons.

All press releases contained factual information, as was known at the times of their issuance.

One press release included an appropriate correct'on to an earlier press release.

Use of acronyms was avoided and technical jargon was explained where appropriate.

The overall performance of the licenspe's technical spokesperscns was adequate.

Items to be presented at press briefings were discussed with State and NRC spokespersons prior to these briefings.

Howaver, the spokespersons did not always confer behind closed doors.

Instead, they conferred partially inside a meeting room and into the hallway near the building's restrooms, where discussions could have been overheard by the media and others who were granted access to the building.

As an example of the demonstrated proper coordination between the licensee's and other spokespersons, all agreed that the licensee and NRC spokespersons could begin their statements regarding the General Emergency declaration while State spokespersons waited several additional minutes to learn what associated protective actions would be implemented offsite.

The media were correctly informed as to why all spokespersons were not present at the beginning of this briefing.

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Licensee spokespersons responded to media questions in an honest manner.

If answers were not immediately available, they were obtained and provided to the media within a reasonable time.

Spokespersons adequately attempted to provide information in a manner understandable to the media.

However, on several brief occasions, no licensee representative remained in the JPIC area to respond to media concerns in between press briefings.

The licensee's JPIC staff did not always coordinate adequately with

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' EOF technical staff.

Two notable breakdowns regarding insufficient coordination between the licensee's EOF and news center staffs were associated with press briefings dealing with the initiation and termination of the radioactive release.

While EOF technical staff was still evaluating the significance of a relatively slight increase in the readings from the plant's main stack monitor before transmitting a NARS message for release initiation, JPIC staff gathering information in the EOF mistakenly concluded that the release had begun and so informed the technical spokespersons.

Later, news center staff in the EOF learned that a valve had been closed to isolate one known release path.

However, while EOF technical staff were appropriately seeking to verify that report and to determine whether there might be another release path before sending a release termination NARS message, news center staff informed the spokespersons that the release had ended.

Consequently, media in the JPIC were told that a release had begun and had later ended roughly 30 minutes before EOF technical staff had satisfied themselves that these changes had occurred and had transmitted the associated NARS messages.

These examples of inadequate coordination between the licensee's news center and EOF technical staffs constitute an Exercise Weakness.

(50-373/86001-04; 50-374/86001-04)

In addition to the exercise weakness, the following items should be considered for improvement:

Technical spokespersons should discuss future press briefings

in an area where they have privacy.

A licensee representative should always remain in the JPIC to

respond to any media concerns in between press briefings.

6.

Exit Interview The inspectors met with those licensee representatives identified in Section 1 to discuss their preliminary findings.

The licensee agreed to consider the items discussed and indicated that none of the matters discussed were proprietary in nature.

Attachments:

1.

Exercise Scope of Participation 2.

ExerciseObjectives 3.

Scenario Narrative Summary

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