IR 05000373/1987002

Insp Repts 50-373/87-02 & 50-374/87-03 on 870209-13.No Violations,Deficiencies or Deviations Noted.Major Areas Inspected:Emergency Preparedness Program,Licensee Action on Previously Identified Items & Emergency Plan Activations

ML20211Q972
Person / Time
Site:	LaSalle
Issue date:	02/25/1987
From:	Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211Q946	List: IR 05000373/1987002 ML20211Q941
References
50-373-87-02, 50-373-87-2, 50-374-87-03, 50-374-87-3, NUDOCS 8703030232
Download: ML20211Q972 (16)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-373/87002(DRSS);50-374/87003(DRSS)

Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 Licensee: Comonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility: LaSalle County Nuclear Generating Station, Units 1 and 2 Inspection At: LaSalle Site, Seneca Illinois Inspection Conducted: February 9-13, 1987 Inspector: 2 f[~

DEte Approved By: tam S C Emergency repa edness Section bM~

Date Inspection Summary Inspection on February 9-13, 1987 (Reports No. 50-373/87002(DRSS);

No, f0-374/87003(DRSS) ?

Areas Inspected: Rout ne, unannounced inspection of the following aspects of the LaSalle Station's emergency preparedness program: licensee action on previ+usly identified items; emergency plan activations; and the operational status of the program. Portions of the program inspected with respect to their operational status included: emergency plan and implementing procedures; emergency response facilities, instrumentation and supplies; organization and management control; training; independent reviews and audits; emergency classification; protective action decisionmaking; emergency communications; changes to the program; staff augmentation provisions; and dose assessment capabilitie Results: No violations, deficiencies, or deviations were identifie ?$03030&'Rggg a m

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DETAILS 1. Persons Contacted

• Diederich, Station Manager

• Bishop, Services Superintendent

• Atchley, Operating Engineer

• Stobert, Quality Assurance Supervisor

• Novotney, Acting Training Supervisor

• Aldrich, Rad Chem Supervisor

• Klotz, GSEP Coordinator

• Gilman, Corporate Emergency Planning Supervisor

• T. Greene, Corporate Emergency Planner

• L. Blunk, GSEP Training Instructor

• Hentschel, Shift Engineer, (SE)

W. Sly, SE E. O'Connell Station Control Room Engineer, (SCRE)

S.Seaborn,$CRE R. Crawford, Training Supervisor A. Mosel, GSEP Training Instructor, Production Training Center E. Huerta-Pavia, ALARA Coordinator M. Friedmann, Health Physicist R. Klemp, Rad Chem Administration P. Wisniewski, AIR Coordinator

• Indicates those present at the February 13, 1987 exit intervie . Licensee Actions on Previously Identified Items (0 pen)ItemsNo. 373/84018-01 and No. 374/84024-01: There was a lack of procedural guidance regarding the formulation and documentation of adecuately detailed followup messages to offsite authorities, Jer the guicance in NUREG-0654, Revision 1, and Section 6.1 of the GSE).

Procedures No. LZP 1110-1, " Station Director (Acting Station Director)

Implementin Procedure," and No. LZP 1130-1 " Technical Director Implementin Procedure," had been revised in February 1986 to include provisions or providing and documenting periodic followup information to appropriate State agencies. Such messages would be transmitted once the TSC had been declared operational and until such time as command and control of emergency response efforts, including offsite notifications responsibility, had been transferred to either the Corporate Command Center or the Emergency Operations Facilit Since implementation of these revised procedures, the licensee has had only one occasion to demonstrate the Station's abilities to adequately provide and document periodic followup messages to State agencie That occasion was during the TSC activation associated with an Alert declaration on June 1, 1986. The ins)ector reviewed records of that event which were maintained by the GSEP Coordinator. Based on the log kept by the Technical Director, both State agencies were provided with followup information at an acceptable frequency. However, there was no

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documentation to prove that the Station Director had ever approved the followup messages prior to their transmittals. Only one followup message form was completed during the entire time that the TSC was fully operational (about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />), and that one form was not even properly filled out. Although the form had provisions for documenting who had prepared and a) proved the followup messages, the 3erson(s) who had accomplished t1ese tasks were not identified on t1e form. There were no entries on the form in the spaces measures" and "sup) ort requested."provided (Appropriatefor " recommended entires for both itemsemergency would have simply aeen "none" or "not applicable.") The followup message was updated only by revising the " prognosis of event" ')ortion of the form to include the latest value of reactor power level. T1e form did not contain provisions for documenting the persons contacted at either State acency. In summary, the inspector concluded that the licensee had not acequately demonstrated the capability to properly, prepare, approve, and l document periodic followup messages to State officials during the June 1-2, 1986 TSC activation. Therefore, as already indicated in Inspection Reports No. 50-373/86002 and No. 374/86002(DRSS), this Item will remain open pending an adequate demonstration (during an exercise or other TSC activation situation) of the Station's capabilities to prepare, transmit, and document a followup message to State official (Closed)ItemsNo. 373/86001-01 and No. 374/86001-01: During the 1986 exercise, the licensee failed to adequately inform the State and the NRC Operations Center of both changes in plant conditions that warranted Alert declarations. The inspector reviewed training attendance sheets and discussed the remedial training provided to the Station Directors and Acting Station Directors with the GSEP Training Coordinator. The training adequately addressed the concern expressed in this Open Item and was completed on schedule. This item is close (Closed)ItemsNo. 373/86001-02 and No. 374/86001-02: During the 1986 exercise, the post-accident sampling team failed to follow procedural guidance regarding specified time periods to perform procedure steps, and to adequately demonstrate good Health Physics 3ractices when handling, and transporting sample collectinglonaltrainingonrelevantproceduralguidancehadbeenT1e that addit inspector de completed on schedule by all Radiation Chemistry Technicians (RCTs) who could be members of a post-accident sampling team. This item is close (0 pen)ItemsNo. 373/86001-03 and No. 374/86001-03: During the 1986 exercise certain E0F staff failed to follow procedural guidance when formulatIngtheinitialoffsiteprotectiveactionrecommendation following the General Emergency declaration. The ins)ector determined that all Environmental Emergency Coordinators EECs) lad received additional training on protective action decis(ionmakin This training was in the form of a memorandum, supplemented by the NRC inspection team's findings. The licensee had also committed to revise the EEC's annual training program. While sufficient documentation was available to indicate that certain lesson plans had been revised, the revisions were not made available for review. This item remains open, pending review of the revised lesson plans to ensure that the concern expressed by this Open Item has been adequately addresse T '

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(Closed) Items No.-373/86001-04 and No. 374/86001-04: During the 1986 exercise, the licensee's E0F and JPIC staffs failed to adequately coordinatethetimingofmessagestoStateofficials(viatheNARS)with press briefings regarding the initiation and termination of the simulated release. The inspector determined that all aersons who could be assigned to Recovery Manager, Emergency News Center (ENC) Director, and ENC staff Jositions had received additional training during 1986 on the need to Jetter coordinate NARS messages with press briefings. This item is close (Closed) Items No. 373/86002-01 and No. 374/86002-01: The licensee must implement administrative measures to better ensure that dedicated GSEP Callers are provided with the current revision to LZP 1320-1 when it becomes effective, and that GSEP Callers and other key members of the onsite emergency organizations are promptly informed of changes to the personnel listin procedure revision in inspectors The LSP 1320-1 that maythat determined occur between quarterly administrative controls implemented by the GSEP Coordinator to assure that the GSEP Callers maintain current copies of Procedure No. LZP 1320-1 were adequate. The GSEP Coordinator maintained a file of signed cover sheets indicating receipt and filing of current copies of LZP 1320-1 by the designated GSEP Caller This item is considered close (Closed) Items No. 373/86002-02 and No. 374/86002-02: The licensee's Quality Assurance (QA) Department must develop and implement additional guidanceregardingappropriatesubjectmatterforsurveillancesofthe Station's emergency preparedness program, other than that contained in Checklist OP-40. The inspectors reviewed 1986 QA records, which indicated two surveillances were conducted. One onsite audit and one offsite audit were also conducted. The inspectors determined that the QA Department was developing additional checklists for performing multiple GSEP program surveillances scheduled throughout the yea This item is close . Emergency Plan Activations The inspector reviewed licensee and NRC records associated with all 1986 three emergency1987.plan activations which occurred All three situations werebetween January correctly classif1,ied and January w in accordance 31,ith the Station's Emergency Action Levels (EAls). All initial notifications to the NRC Operations Center and appropriate State agencies were completed in a timely manner following each emergency declaration. Records reviewed by the inspector included: the Station s EALs; all Licensee Event Reports (LERs) for the period in question; Shift Engineer's logs and NARS forms associated with each event; Technical Support Center (TSC) staff's records associated with the June 1986 Alert declaration; and summary records of each declaration available from the NRC Operations Cente r

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Tha folicwing table summarizes initial notification time informaticn for the three plan activations. Additional details regarding the staff's

, evaluation of the June 1986 Alert declaration are contained in Inspdction Report No. 50-374/86023(DRP).

GSlPActivatiens January 1936 through January 1987 '

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State Agencies NRC Declaration Emergencv Initially Initially Date Time ClassificatiorP' ' Jhotified Notified 2/19/86 1345 Unusuci Event 1350 1348 6/01/06 1830 - Alert 1840 1845 4 1/23/87 ' 1820 Unusual Event 1825 ' 1825'

Based on the above findings, this portion of the licensee's prograp is acceptabl . Operational Status of the Emergency Preparedness Program (82701) Emergency Plan and Imolementing Procedures By correspondence dated March 21, 1986, the staff approved Revision 4 to the LaSalle Annex to the Generating Stations Emergency Plan (GSEP). In October 1986, the licensee submitted prope.e1

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Revision 6 to the GSEP. By letter dated January 6 1987, the staff informedthelicenseethatRevision6wasacceptablewithone exceptio The staff did not accept the licensee's proposal to significantly eliminate the use of evacuation time estimate information during offsite protective action decisioimaking.. Based on subsequent discussions with the licensee's corporate emergency - ,

planning staff, it was agreed that the wording of the GSEP would not ~

ae changed from that found acceptable in Revision 5/5A regardinh th use of evacuation time estimates, pending further discussions and resolution of the NRC staff's concern. In the interim, the staff has informed the licensee that all other aspects of proposed Revision 6 to the GSEP can be implemented as schedule . The inspector spot checked the licensee'si lrovisions for preparing,

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reviewing, ap3 roving and distributing new or revised implementing procedures. T1e inspe,ctor determined that these provisions had been followed and had not changed since the previous routine inspectio Based on the above findings, this portion of the licensee's program is acceptabl .

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b. Emergency Facilities, Equipment, and Supplies

The inspector toured the Technical Support Center (TSC); Operational Support Center (0SC); and the onsite assembly area, which was the 710 and 734 foot elevations of the Radwaste Building. These facilities were located as described in the LaSalle Annex to the GSE The TSC was essentially a dedicated workspace that was occasionally used by plant staff as a meeting room. The room was configured and equipped as would be the case during a TSC activation, with the

. exception that a copyiryg machine would be brought into the TSC, if needed during a facility activatio Since the last inspection, the new Health Physics Network (HPN) telephones have been installed in the TSC. Both telephones were o)erable, as were other telephones and computer terminals checked by t1e inspector Central Files staff were responsible for updating the following controlled documents maintained in the TSC: various types of plant 3rocedures; Tech Specs; GSEP and LaSalle Annex; FSAR and Updated

SAR; Fire Pre-Plans; Offsite Dose Calculation Manual; Environmental and Environmental Director Emergency Procedures; Illinois Plan for Radiological Accidents (IPRA) and LaSalle Station supplement to the

IPRA; and the aperture cards containing various types of plant and plant systems drawing The OSC consisted of a lunchroom, meeting room, and a connecting hallwayalllocatedadjacenttotheShiftEngineer's(SE) office.

'J OSC telephones were in the lunchroom, while other OSC supplies were kept in several locked cabinets in the hallwa The licensee has conducted quarterly inventories of TSC and OSC supplies in accordance with Procedures No. LZP 1550-5 and No. 1550-6, respectively. Inventory records were maintained in the Health Physics office. The inventories were usually conducted by a RCT. A review of the 1986 inventory records indicated that procedural provisions had

, been adhered to regarding the timely replacement of missing or depleted supplies, a task usually assigned to the RCTs. However,

,.- the GSEP Coordinator was responsible for maintaining supplementary tele 3 hone directory information to that u) dated quarterly in both the LZP-1700 series procedures and the GSEP Telephone Directory that

. was filed with each copy of the GSEP. In the TSC, su)plementary telephone directories consisted of a local area and C11cago telephone directories, plus small binders for each director which contained the

" Joint Emergency Response Facilities (ERF) Telephone Directory."

Procedure No. LZP 1550-5 only indicated that one copy of a company

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telephone directory and one unspecified commercial telephone directory need be maintained in the TSC. While the TSC contained many more copies of various telephone directories than was required by procedure, the usefulness of the additional telephone directories was doubtfu All 14 commercial telephone directories stored in the Rad / Chem

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, ,. h "- Director's desk were dated 1984, while each director's " Joint ERF

', Telephone Directory" was dated March 198 (The last exercise was in April 1966.)a Smilarly, while OSC staff had easy access to current licensee and commerical telephone directory information in procedures- I kept in the OSC workspace and/or the SE'sroffice, commercial telephone directories stored in an OSC locker were vintage 1982 and 198 .,,. ,

The case of the telephone directories discussed in the preceding

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paragraph exemplifies a flaw in inventory requirements found in LZP 1550-5 and LZP 1550-6. Both procedures' inventory checklists specify minimum quantities of the listed items that must be maintained in the ERF However, the procedures do not address the need for periodic replacement of items such as batteries, potassium iodide tablets, or non-telephone directories. proceduralized licensee and commercialThe licens:

inventories of TSC and OSC supplies also address the need for  ;

periodic replacement of perishable items and non proceduralized

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telephone directories. ThisisanOpenitem(373/86002-01and

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374/86003-01).

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! The inspector examined the licensee's records of a November 1986 -

onsite assembly / accountability drill and toured the onsite assembly i

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area. One of the drill critique items was that the assembly area should be changed due to: changes in the use of works 710 and 734 foot elevations of the Radwaste Building (pace since on the the 1981 l- , EmergencyPreparednessImplementationAparaisal);theperceivedneed

to have multiple onsite assembl i

o building; and the need to have'y areas t1at are not in the samean assembly j Building for nonessentials working there. The Station Manager has agreed that additional assembly areas should be identified and has reviewed the Rad / Chem Supervisor's and GSEP Coordinator's proposed

< alternative The GSEP Coordinator has been told to prepare an Action Plan and to coordinate with the architect / engineer and d

t corporate staff as necessary to accomplish the change in the onsite assembly area. However, at this time, the licensee was unable to

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lgivetheinspectoranestimateofwhenthechangeinonsiteassembly areas would be complete ,

The inspectors toured both floors of the assembly area with the GSEP Coordinator. The assembly area had sufficient floor space for the

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numbers ~of non-essential onsite licensee personnel, plus contractors i

who may be onsite during an outage. However, the 734 foot elevation was being used as a temporary storage area for miscellaneous items

, that may be contaminated, such as small sections of pipe. A number

of adequately posted contamination areas were found on the 734 foot elevation. The current background radiation level on the 734 foot level was about 1 mR/ hour. The situation was less ideal on the 710

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foot elevation (ground level). This elevation of the building

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contained two truck bays, a loading dock, and some storage areas.

i Since the 1981 appraisal this portion of the assembly area has come to be used as a storage area for dry radwaste (pre- and post l

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compacting). Compacting o)erations also take place in this are The inspectors estimated tlat the 710 foot elevation of the building contained at least 75 drums of dry, compacted low-level radwaste and a similar number of bagged radwaste awaiting compacting. A rear area of the loading dock contained sufficient radwaste to be designated as a high radiation area, as evidence by its posting and its restricted access by way of a locked fence. All areas of radioactive waste storage were appropriately poste The current general radiation level for the 710 foot elevation, as provided by a RCT, was about 2 mR/ hour. The inspectors were also told that the truck bays were occasionally used as a temporary storage area for materials having, higher contact radiation levels than 10 R/ hou No such items were visible in either bay during the tou The inspectors concluded that the current onsite assembly area is far from ideal and multiple areas should be utilized as assembly. areas in lieu of, or in addition to the 734 foot level of the Radwaste Buildin The staff will monitor the licensee's progress to promptly identify and finalize additional onsite assembly areas for non-essential personne This is an Open Item (373/87002-02 and 374/87003-02).

The inspector reviewed the records of quarterly inventories of environs kits from January 1986. The kits have been maintained in an adequate state of readiness. Utilizing the latest inventory record, the inspector verified that one of kits contained all the materials specified on the inventory record. The kit's survey instruments had current calibration stickers and passed the battery check tests. The inspector also determined that, as had been suggested during the 1986 routine inspection, checks sources stored in the kit have been better separated from low range dosimetry and TLDs also found in the ki In addition to the Open Items, the following item should be considered for improvement:

• Until additional onsite assembly areas have been finalized and approved, the licensee should make provisions to utilize locations besides the Radwaste Building as interim assembly areas for non-essential onsite personne c. Organization and Management Control The GSEP Coordinator was a Station employee who reported to the Station Manager through the Rad / Chem Supervisor, Assistant Services Superintendent, and the Services Superintendent. The Coordinator also functionally reported to the corporate Emergency Planning Supervisor through a Supervisor of Emergency Planning located at the Mazon E0F. The GSEP Coordinator was a full-time position, with no assistant having been appointed. During 1986 the coordinator had been assigned the additional duty of ensuring that the weekly surveillance of the High Range Sampling System (HRSS) was conducte "

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The Coordinator was also responsible for conducting periodic tests-oftelephonesandradioslocatedintheonsiteERFs;updatingthe station s staff. augmentation procedure; maintaining records of emergency preparedness drills and exercises; assisting in the evaluation of related critigue items; reviewing records of periodic emergency supplies inventories; updating non proceduralized tele directories kept in the onsite ERFs; and evaluating the. Station' s phone responses to actual emergency plan activation Beginning in the first quarter of 1986, a member of the licensee's corporateemergencyplanningstaffhasbeenassignedtoperform

" quarterly followup visits" on activities of the Station s GSEP Coordinator. The Coordinator indicated that the same practice had been instituted at all the licensee's nuclear generating station These announced visits were not considered audits by the Coordinator

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or the corporate emergency planner. Instead, these one day visits were intended to better ensure that the Coordinator was performing all his duties in a timely manner, and was aware of progress being made by Station and corporate staffs on corrective actions on concerns identified by the NRC, Quality Assurance Department

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personnel, and INP0. A side benefit of these

- visits was an increased, mutual understanding' quarterly follow of the duties and responsibilities of the_ corporate and Station s emergency planning staff Based on discussions with the GSEP Coordinator and records reviews

.theCoordinatorhadnotaddedanyone'snametothestaffaugmentation procedure until after Training Department personnel had informed the Coordinator that such individuals had successfully completed all emergency preparedness training requirement The inspector reviewed copies of Letters of Agreement with offsite support organizations, which were maintained by the GSEP Coordinato All agreements for the LaSalle County Station had been updated during 198 Based ~on the above findings, this portion of the licensee's program is acceptabl Training The inspectors conducted interviews with two SEs, two SCREs, two Environs Directors, and an Administrative Director in order to assess their understandings of their emergency response role The SE/SCRE walkthroughs were conducted with two separate teams

. of personnel, each team consisting of a SE and a SCRE. inese

wal(throughs focused on emergency detection and classification; f

protective action decisionmaking; and initial offsite notification requirement The interviewees demonstrated an adequate familiarity

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with procedural guidance and their responsibilities relative to

implementation of the emergency plan. The Administrative Director

also exhibited an adequate understanding of his emergency duties.

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Both Environs Director interviews addressed the interviewees'

abilities to: acquire and interpret real time, onsite meteorological information; perform an offsite dose calculation; and to formulate protective action recommendations. Both directors were also asked questions relative to their roles as directors of field monitoring teams. The interviewees' performances were satisfactory, with the exception that both persons exhibited some hesitancy and uncertainty regarding such matters as: what ty)e of air sample cartridge shoulde be utilized in order to determine tie presence of radiciodines; or when must a field team withdraw from a radiation field based on their measurements of its strength. Both directors later admitted that they had never accompanied a field team during a drill or exercise situation in order to obtain a first-hand knowledge of survey techniques employed by the teams and a better understanding of the problems typically encountered by a field tea Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

• The LaSalle Station's Environs Directors should be given the opportunity to observe an offsite monitoring team during a drill or exercise situatio e. Independent Reviews / Audits (Also 82210)

The inspectors reviewed the records of Quality Assurance (QA)

Department audits and surveillances of the Station's emergency preparedness program ~ conducted during 1986. All records were complete readily available, and indicated that the QA staff had adequatelytrackedcorrectiveactionstakenonnegativefinding Onsite Audit QAA-01-86-26 in scope and depth a met the requirements of 10 CFR 50.54(t .and Offsite The QA audit matrix been revised to include a semi-annual QA audit of the emergency pre aredness program in February and August of 198 The QA department ha also added an additional surveillance checklist (0P-45) to the program. The QA Supervisor indicated that the department was continuing to evaluate the need for additional checklists for their GSEP surveillance progra The inspectors discussed QA department guidance regarding surveillance requirements with the QA Supervisor. The 1987 surveillance schedule was not yet completed and, therefore, the actual number of surveillances to be performed was not available. The QA Supervisor was cautious about committing to what topics would be included in the 1987 surveillance schedul __ -

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The inspector determined that all 1986 emergency preparedness drills and.the annual exercise had been critiqued by the licensee. The GSEP Coordinator and the Rad Chem Supervisor were responsible for reviewing the critiques and for determining which items should be acted upo Action Item Record (AIR) forms would then be initiated, usually by the GSEP Coordinator, with the persons being held responsible for completing the corrective action being either the coordinator, another member of the Station staff, or a member of the licensee's corporate organization. A spot check of AIR records indicated that the system had been pro)erly used to track corrective actions taken on items identified by tie NRC and/or the licensee during the 1986 exercise. The inspector determined that the drill records contained notes that either referred to specific AIRS or to the dates that corrective actions had been completed on specific critique item Based on the above findings, this portion of the licensee's program is acceptabl . Emergency Detection and Classification (82201)

By correspondence dated June 27, 1986, the licensee submitted to NRC RegionIIIaproposedrevisiontotheLaSalleCountyStation'sEALsand a supporting BWR EAL Philosophy" document. By letter dated December 19, 1986, the staff provided the licensee with comments on the proposed EALs and the supporting document. The staff concluded that the submittal was incomplete, and that some of the aro)osed EALs must be revise Based on subsequent conversations wit 1 t1e licensee's corporate emergency planning staff, the NRC staff understands that the licensee plans to submit the missing EALs and to provide additional information in response to the NRC's comments. Until such time as the NRC's concerns on the proposed EALs have been resolved, the licensee's emergency organization will continue using the current EAL The inspectors determined that one improvement had been made to the current LaSalle Station EALs since the last inspection. The General Emergency EAL for Condition No. 15 (Loss of Fission Product Barriers)

had been revised so that either 2000 R/ hour activity in containment loss of the third barrier" was sufficient to warrant declaration of a General Emergenc Based on the above findings, this portion of the licensee's program is acceptabl . Protective Action Decisionmaking (82202)

As Acting Station Director, the SE has been given the undelegatable authority and responsibility for issuing offsite protective action recommendations until properly relieve All SEs and SCREs interviewed during this inspection were well aware of this responsibility and of the requirement to issue a recommendation within about 15 minutes following

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any General Emergency declaratio Procedural guidance for formulating an offsite recommendation was identical to that found in the currently approved Revision 5/5A of the GSEP. Following the 1986 routine inspection, it was suggested that several procedures' reduced scale flowcharts, titled " Recommended Protective Actions - General Emergency,"

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be replaced with more legible, full-scale copies of the flowchart as were found in the generic GSEP. It was also suggested that full scale copies of protective action decisionmaking guidance be posted in the TSC. The inspections determined that the licensee had acted only on the latter suggestio Based on the above findings, this portion of the licensee's program is acceptabl . NotificationsandCommunications(82203)

The licensee's provisions for notifying, appropriate offsite organizations of emergency plan activations at the LaSalle Station are unchanged from the last routine inspection. Adequate copies of the NARS form used to document initial notifications to State agencies were readily available in the Control Room and TSC. The addition of commercial HPN telephones had been completed and tested in both the TSC and E0F. Procedures and checklists had been revised to reflect current HPN telephone number The discontinued HPN system telephones have been disconnected and remove The inspectors reviewed all communications drill records for 1986 and determined that all required equipment tests had been conducted and adequately documente Based on the above findings, this portion of the licensee's program is adequat . Changes to The Emergency Preparedness Program (82204)

Changes to the Station's program have already been described in Paragraphs 4a, 4b, 4c, 4e, and 5 of this repor Based on the above findings, this portion of the licensee's program is acceptabl . Shift Staffing and Augmentation (82205)

The licensee's provisions for the minimum shift staff and for augmenting this staff were reviewed and were found to meet the goals of Table B-1 of NUREG 0654, Revision 1. Provisions for onsite staff augmentation for each emergency class and each emergency response facility were adequately described in the GSEP, LZP-1110-1 and LZP 1320-1.

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Section 8.5 of the generic GSEP stated that names and telephone numbers of Station Group personnel shall be reviewed and updated quarterly as a minimum. Records of Revisions to LZP 1320-1 and LZP 1320-2 for 1986 indicated that these procedures were reviewed and updated approximately every 60 days, or more often than this quarterly requirement. The quarterly review of LZP 1320-1 was part of a computerized duty tracking system. The inspector discussed the quarterly review process with the GSEP Coordinato The actual changes of LZP 1310-1 and LZP 1320-1 have occurred when any change in station GSEP personnel has occurre Quarterly reviews were conducted along with such actual changes, as necessary to maintain a current working documen The licensee has implemented a method to better assure GSEP Augmentation Callers are )rovided with the current revision to LZP 1320-1. The GSEP Coordinator land carries changes with a cover sheet to each caller. The cover sheet contains a statement that the caller has received and will file the current copy of the procedure at the caller's home. The cover sheet is signed by the caller and returned to the GSEP Coordinator, who maintained a file of the signed cover sheet Revisions of LZP 1320-1 were conducted on an average of 60 days with the exception of January 1987. The quarterly review of the procedure was

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conducted by the GSEP Coordinator at the required frequency, at the sa:::e time three GSEP personnel changes were occurring. The three changes were of personnel already on the notification list and consisted of changes in their areas of responsibility. Training of these individuals was completed on January 22, 1987, and the revision was placed in the administrative review process. The revision became effective February 11, 1987. The quarterly review was actually performed twice during the time period, with only one actual distribution of a revised procedure being necessar The licensee had conducted semi-annual off-hours augmentation drills to demonstrate the capability to adequately augment onshift personnel following an emergency declaration. The inspector reviewed the records of both semi-annual drills conducted in 1986 and concluded they were successful, as was claimed in the licensee's drill critique Based on the above findings, this portion of the licensee's program is acceptabl . Knowledge and Performance of Duties (Training) (82206)

In addition to the walkthroughs described in Paragraph 4d of this report, the inspector reviewed a random sample of 1986 training records for about fifteen persons having key positions in the onsite emergency organization. Only one minor discrepancy was noted in the otherwise complete and readily available records. An Environs Director had received a portion of his annual training at the licensee's Production Training Center (PTC). However, a copy of the associated training completion record had not been forwarded to the individual's training file maintained at the Statio .-- , . --

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The inspector reviewed records of 1986 emergency preparedness drills and the April, 1986 exercise, which were all maintained by the GSEP Coordinator. All required drills and the exercise had been conducted and critiqued. Records were complete, and often contained references to the Action Item Record (AIR) system utilized at the Station to track various categories of work in progres The annual meeting for the LaSalle Station's offsite support agencies was held on October 16, 198 The agenda included: an overview of the Station's EALs; description of the emergency classes utilized by the licensee; a description of how an offsite agency representative could obtain a copy of internal audit items relevant to the licensee's interface with offsite support organizations; and the local location of the NRC Public Document Roo including Seneca and Marseille ambulance Medical support EMT personnel personnel,ining received tra from Radiation Management Corporation on June 11, 198 Selected personnel participated in a medical drill on June 12, 1986, thus meeting the annual training requirement of 10 CFR 50.47(b). Groups participating in the drill included licensee personnel and personnel from the Seneca Ambulance Service and St'. Mary's Hospita Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

• An individual's GSEP Training File should include records of any relevant training received at the PTC or at any other offsite location, to enhance the completeness and audibility of these record . DoseAssessmentandCalculation(82207)

The licensee's dose calculation and assessment methodologies were contained in Environmental Director (ED-series) procedures, controlled copies of which were found in the TSC. Topics addressed in these procedures included: cuantifying gaseous and liquid releases; estimating source terms from fielc measurements; obtaining current and forecast meteorological information; and formulating an offsite protective action recommendation. Methodologies ranged from rapid, conservative estimates based on gross activity source terms and worst-case meteorology to models accommodating nuclide-specific source terms and real-time meteorology, with options available for plume tracking. Computerized models could be run using the Station's computer or a remote computer located at the corporate offices. The licensee's dose calculations provisions will be reviewed in greater detail during a future appraisa The inspectors conducted walkthroughs with two of the three Environs Directors, and determined that the TSC's computer terminal utilized forgeneratingdoseprojectionswasoperable. Both individuals were i

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adequately familiar in. operating the terminal,-generating on offsite dose projection, and in using the results to formulate a protective

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action recommendation. Both knew how to acquire current onsite meteorological information using the termina the During inspectorthe Braidwood identified several Station's emergency human factors preparedness concerns associated w appraisal,ith u the computerized dose calculation methodologies. Several concerns involved a user having to hand-calculate an input value to~the program, as the units of measures required by the software did not always match the units of measure that would be reported to the Environs Directo The licensee has committed to perform a human factors evaluation of the computer software to enhance its " user friendliness," including reducing-the need for hand calculations to covert units of measure before inputting a value into the model. During the walkthroughs of the LaSalle Environs Directors,'the inspectors noted that these individuals still had to manually convert a release duration value from hours to seconds in order-toobtainacorrectdose. projection. One )erson did not recognize an error in the hand calculation, which was tien pointed out by the inspectors. -The staff will monitor the licensee's efforts to improve the " user friendliness" of its dose calculation softwar Ba:cd on the above findings, this portion of the licensee's program is acceptabl . LicenseeAudits(82210)

InadditiontothetopicsdescribedinParagraph4eofthisreport, the inspector reviewed the GSEP Coordinator s evaluations of records generated during actual emergency plan activations beginning in 198 The coordinator was required to compile these records and to determine whether or not the' Station's implementation of the plan was adequat The coordinator completed a checklist, which had been revised and improved since the January 1986 inspection, to document his evaluatio The inspector concluded that the coordinator had evaluated all plan activations since January 1986 and had compiled relevant Station records. Results of the evaluations were then reported to the Station Manager and to corporate emergency planning staf In general, the coordinator's evaluations of records associated with each GSEP event have improved in quality compared to those evaluations performed prior to January 1986. However, a lack of attention to detail was still evident in several of the coordinator's evaluations. As was indicated in Paragraph 2, the Station's documentation of periodic followup messages to the State during the June 1-2, 1986 event largely consisted of one incomplete message form, with no documentation as to which individuals had-)repared and approved the messages, and minimal information as to whici persons had received the messages. However, the coordinator concluded that all "GSEP procedures" had been followed satisfactorily, including the one dealing with preparation and documentation of followup messages to the Stat The inspector concluded

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l that this documentation was, at best, only marginally acceptabl The inspector also noted that " time of occurrence" and " time of classification" information contained on a NARS message form associated with the termination of the January 1987 Unusual Event was incorrec However, the coordinator's evaluation checklist did not indicate that this problem had been identifie Based on the above findings, this portion of the licensee's program is acceptable; however, the following item should be considered for improvement:

• The quality of the GSEP Coordinator's reviews of records associated with the actual GSEP events should be evaluated by the corporate emergency planner assigned to monitor the coordinator's activitie . Exit Interview On February 13, 1987, the inspectors met with those licensee representatives identified in Paragraph 1 to discuss the team's preliminary findings. The licensee agreed to consider the items discussed, and did not indicate that any of the items were proprietary in nature.

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