IR 05000397/1991002

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Insp Rept 50-397/91-02 on 910114-18.No Violations Noted. Major Areas Inspected:Previously Identified Items in Emergency Preparedness Program & Operational Status of Current Emergency Preparedness Program
ML17286A636
Person / Time
Site: Columbia Energy Northwest icon.png
Issue date: 02/21/1991
From: Good G, Mcqueen A, Reese J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML17286A634 List:
References
50-397-91-02, 50-397-91-2, NUDOCS 9103120143
Download: ML17286A636 (23)


Text

U.

S.

NUCLEAR REGULATORY COMMISSION

REGION V

Report No.

50-397/91-02 Docket No.

50-397 License No.

NPF-21 Licensee:

Washington Public Power Supply System P.O.

Box 968 3000 George Washington Way Richland, Washington 99352

,

Facility Name:

Washington Nuclear Project No.

2 (WNP-2)

Inspection at:

WNP-2 Site, Benton County, Washington Inspection Conducted:

January 14-18, 1991 Inspectors:

G.

M.

Goo E

rgency Pre aredness nalyst Approved by:

c ueen E

e gency Pre r

s Analyst SUMMARY:

J

. Rees, Chief Sa guards, Emergency Preparedness, and Non-Power Reactor Branch Ins ection on Januar 14-18 1991 Re ort No. 50-397/91-02 2 lie te Date Signed ate

>gne ZZIQ te signed

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d, 1.1

1

1

1

sdentlfled during previous emergency preparedness inspections and to address the Operational Status of the Emergency Preparedness Program.

Inspection procedures 92701 and 82701 were used as guidance.

910312oia3 9i022197 Q

t t,

"2" Results:

One-non-cited violation was identified for failure to submit an Emergency Plan change to the NRC within 30 days of implementation as required by 10 CFR 50..54(q)(see section 3.A. 1).

The violation was not cited, because the criteria specified in section V.A of the Enforcement Policy were satisfied.

The open items identified dur'ing previous inspections were closed.

Weaknesses were, identified in the following areas of the licensee's emergency preparedness program:

1) corrective action/root cause program implementation, 2) emergency response facility maintenance, and 3) Operational Support Center management training (see sections 2, 3.B, and 3.E, respectively).

The inspection staff acknowledged the licensee's effort to revise and improve its emergency classification procedure.

The results of this inspection indicated that the licensee was adequately maintaining its emergency preparedness progr a DETAILS Persons Contacted T. Albert, Supervisor, Instrument and Control (I8C)

~R. Chitwood, Manager, Emergency Planning (EP)

"S. Davison, Manager, Plant equality Assurance (gA)

"Y. Derrer, 'Supervisor, Emergency Training

"D. Feldman, Supervisor, Maintenance D. Gano, Contractor, Apollo Associates

"L. Harrold, Assistant Plant Manager

".A. Klauss, Supervisor, EP

  • D. Mannion, Emergency Planner

"S.

McKay, Manager, Operations

  • R. Mogle, Supervisor, EP G.

Ray, Emergency Planner

  • G. Sorensen, Manager, Regulatory Programs

"S. Washington, Supervisor, Compliance

" Denotes attendance at the January 18, 1991 exit interview 2.

Action on Previous Ins ection Findin s (Ins ection Procedure 92701 Closed)

0 en Item (88-25-01:

LoLo level emergency action level (EAL)

w)

be rev>ewed by NRC Headquarters and the licensee will be informed of the results.

By memorandum dated December 29, 1988, Region V requested the NRC Office of Nuclear Reactor Regulation (NRR) to determine the adequacy of the licensee's EAL involving LoLo reactor vessel water level.

Region Y Emergency Preparedness personnel had identified that the EAL was not totally consistent with NUREG-0654.

The response to the Region's request was issued in a memorandum dated March 29, 1990.

The NRR response recommended maintaining the "status quo" pending the NRC's final review of the Nuclear Management and Resource Council (NUMARC) EAL scheme.

The response stated that NRR was "inclined to disapprove isolated changes (such as the WNP-2 change)

on the grounds of the need for consistency and uniformity among licensees."

The NRR response also indicated that the licensee's EAL was similar to one proposed in the NUMARC EAL scheme.

The NRR response concluded that this was not a safety issue.

This item is considered closed.

Closed)

0 en Item (89-24-01):

Violation for failure to correct a weak area

> entlfled urging t e 1 88 annual emergency exercise.

This violation was issued because the licensee failed to correct demonstrated weaknesses in its ability to effectively notify plant personnel during exercises.

Follow-up on this open item was conducted in March 1990 (see section 2 of Inspection Report No. 50-397/90-06).

This open item involves two issues:

1) the capability to notify and protect plant personnel, and 2) the ability to correct problems when they are identified.

To address the first issue, the inspectors examined the prompting aids that had been placed in the Control Room (CR) and Technical Support Center (TSC) to help resolve the problems with the Public Address (PA) announcements.

The inspectors found that the prompting aids were in place, but that they appeared to have limited value, since the aids only mentioned the siren/PA.announcement sequence

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and the need to write down messages so the same information would be provided in the repeat PA announcement.

The prompting aids failed to provide any guidance regarding the need to include information about

'hazardous areas to avoid.

After the prompting aids were generated, the licensee developed a pre-scripted message form to help standardize the PA announcements and the information contained therein.

The form has been incorporated into emergency plan implementing procedure (EPIP) 13. 1.2,

"Plant Emergency Director Duties;"

however, the inspectors noted that the prompting aids had not been revised to include reference to the form, and blank copies "of the form had not been staged near the PA microphone in the CR.

The licensee's EP staff acknowledged this oversight and indicated that follow-up actions would be taken.

The capability to effectively notify plant personnel was satisfactorily demonstrated during the 1990 exercise.

To address the second issue, the inspectors reviewed the licensee's corrective action/root cause program (for EP), discussed the program's implementation, and examined several corrective action records (CARs).

The inspectors identified the following weaknesses in the program's implementation:

1) corrective actions did not,always address the results of the root cause analysis (e. g.,

one CAR stated that the root cause was less than adequate procedures, but the recommended corrective action did not require any modification of the applicable procedure);

and 2) root cause analyses were not being performed on NRC findings.

Based on these two weaknesses, the inspector's concluded that the adequacy of the

.

program was limited and that there was still a need to closely monitor the program's effectiveness.

This item is considered closed; however, implementation of the corrective action/root cause program will be closely monitored during future routine inspections and exercise evaluations.

(Closed 0 en Item (90-17-01):

Emergency classification procedure snadequacses.

he current revision (Rev.

11) of EPIP 13. 1. 1,

"Classifying the Emergency,"

was partially reviewed in conjunction with.

.the 1990 annual exercise (see section 5 of NRC Inspection Report No.

50-397/90-17).

A full review of 13. 1. 1 was conducted during this inspection.

The inadequacies identified in the exercise report were incorporated into this review and the results have been described in section 3.A.2. a of this report.

For tracking purposes, this item is considered closed.

0 erational Status of the Emer enc Pre aredness Pro ram Ins ection Procedure 82 Ol A.

Chan es to the Emer enc Plan and EPIPs 1. ~EP1 In accordance with 10 CFR 50.54(q),

changes to emergency plans are required to be submitted to the NRC within 30 days after the change is made.

Prior to this inspection, it was determined that the licensee's Emergency Plan had been changed on August 15, 1990, but the Plan was not submitted to NRC until December 27,1990.

This issue first surfaced during a" December

6, 1990, conference call with the licensee, during which the current Rev./date of the Emergency Plan was discussed.

The licensee pursued the issue and confirmed that the copies had not been sent.

The appropriate number of copies were subsequently submitted.

Additional foll'ow-up on this issue was conducted dur-ing this inspection.

According to the licensee, EP personnel reviewed the Emergency Plan distribution list and concluded that the number of Plans being distributed could be reduced.

In the process of paring down the list, the number of copies sent to the Licensing Department was reduced.

The licensee's EP staff was not aware that, the copies sent to licensing were the copies intended for the NRC.

Licensing personnel contacted Document Control, by memorandum, to obtain the additional copies, but the memorandum was not immediately acted upon.

The distribution list has been corrected to provide licensing with a sufficient number of copies to send to NRC.

The failure to submit an Emergency Plan change to NRC within 30 days of the change is an apparent violation of 10 CFR 50.54(q).

Based on the corrective actions taken by the licensee, the violation will not be cited, because the criteria specified in section V.A of the Enforcement Policy were met ((NCV) 50-397/91-02-01).

EPIPs The Region V Emergency Preparedness staff performs an annual review of changes to the licensee's EPIPs.

This review was accomplished during this inspection.

The following procedures were reviewed:

13. l. 1, Revs.

10 and ll, "Classifying the Emergency",

13.4. 1, Rev.

11, "Notifications" 13.5.3, Rev.

7, "Evacuation of Exclusion Area" 13.5.5, Rev.

6, "Personnel Accountability" 13.8.2, Rev. 8, "Manual Offsite Dose Calculations" 13. 10.9, Rev.

10, "Operations Support Center (OSC) Operations and OSC Director Duties" 13. 14. 1, Rev.

7,

"Emergency Exposure Levels/Protective Action Guides (PAGs)"

13. 14.5, Rev. 8,

"Emergency Organization" 13. 14.7, Rev.

12,

"Emergency Training" 13. 14.9, Rev.

6, "Emergency Program Maintenance" The questions/comments that were generated during this review

.

were discussed with EP personnel during this inspection.

The

following procedural issues were brought to the licensee's attention:

EPIP 13.1.1 The procedure does not include guidance on the loss of fission product barriers.

NUREG-0654 calls for a General Emergency (GE) in cases where any two barriers are lost and there. is a potential for loss of the third.

The fission product ba'rriers consist of the reactor coolant system, fuel cladding, and containment.

Response

- The licensee proposed to incorporate the safety barrier approach into Rev.

12 of 13. 1. 1.

Rev.

12 was in draft form at the time of this inspection.

This response was considered acceptable.

The procedure requires that a post-accident sampling system (PASS)

sample be analyzed to verify the existence of significant failed fuel (defined to mean 1X cladding failure or 0.3X fuel melt).

This could delay classification of a Site Area Emergency '(SAE)

or a GE by as much as three hours.

Response

- The licensee proposed to delete the prerequisite to analyze a

PASS sample in Rev.

12 of 13.1. 1.

This response was considered acceptable.

The situation based EAL for a fire at the Unusual Event (UE) classification appears to describe a

condition that is more significant than the corresponding example in NUREG-0654.

The EAL in Rev.

ll (first incorporated into Rev.

10) calls for a UE if there is a fire in the power block or protected area that lasts more than 10 minutes, and the fire is affecting plant equipment.

NUREG-0654 states that a

fire lasting more than 10 minutes warrants the declaration of a UE.

1v.

Response

- The licensee proposed to add the word

"potentially" before "affecting plant equipment."

This response was considered acceptable.

There is no EAL to correspond to the NUREG-0654, SAE example for a steam line break outside containment without isolation.

V.

Response

- The licensee proposed to incorporate this example SAE into Rev.

12.

This response was considered acceptable.

The situation based EAL at the SAE classification for a flood appears to describe a situation more severe

vl.

than 'the corresponding NUREG-0654 example.

The EAL'n Rev.

11 (first incorporated into Rev.

10) calls for an SAE declaration for a "flood that jeopardizes the plant safety systems to the point of inadequate control of the plant."

NUREG-0654 states that a

flood greater than design levels would warrant the declaration of an SAE.

Response

- The licensee proposed to modify the wording in Rev.

12 to eliminate use of the phrase

"inadequate control of the plant," and to substitute the phrase "... loosing the ability to mitigate a

release of radioactive materials."

This response was considered acceptable.

Declaration of an SAE based on hydrogen levels inside primary containment could be delayed because 13; 1. 1 requires an engineering analysis in accordance with Plant Procedures Manual (PPM) 9.3.25,

"Containment Hydrogen Assessment."

This analysis could delay the classification.

Response - The licensee proposed to eliminate this as a requirement in Rev.

12.

This response was considered acceptable.

The situation based EAL at the SAE classification, for situations involving sabotage, appears to describe a condition that is more severe than the corresponding NUREG-0654 example.

The EAL calls for an SAE declaration when there is "confirmed sabotage in the vital area that affects the ability to adequately shutdown the plant."

NUREG-0654 states that an ongoing security compromise warrants the declaration of an SAE.

Response

- The licensee proposed to modify the wording in Rev.

12 to bring the EAL more in-line with NUREG-0654.

The proposed wording and the response were considered acceptable.

viii.The situation based EAL at the GE classification, for a release of radioactive materials (on the situation based summary page, as opposed to the situation based example pages),

does not capture the anticipatory intent of NUREG-0654, or the intent of the fission product barrier scheme.

The 13. 1.1 EAL waits until radioactive material is being released, rather than a

situation where a release is imminent.

Response

- The licensee proposed to modify the wording in Rev.

12 to bring the EAL more in-line with NUREG-0654.

The proposed wording and the response were considered acceptabl t tl

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It should be noted that the draft of 13.1.1, Rev.

12, showed tha't the licensee was attempting to resolve some of the concerns previously identified by NRC.

For example, minor formatting changes were initiated to make the procedure easier to use, and the fission product barrier concept.was being incorporated.

The draft contained some internal inconsistencies; however, as indicated above, the licensee offered to initiate the changes necessary to bring the procedure in-line with NUREG-0654.

The licensee had also taken the initiative to add a new UE EAL for conditions where high energy is released.

Several other issues involving 13.1. 1 were also discussed during this inspection.

Those issues were either satisfactorily explained or did not require procedural modifications.

Until 13.1.1, Rev.

12 is.issued in final form, and reviewed, the Region intends to track the 13. 1.1 issues as Open Item 91-02-02.

EPIP 13.5.5 The previous revision of 13.5.5 stated that accountability.

would be initiated "upon activation of the OSC."

The OSC is activated at the Alert classification level.

The current revision of 13. 5. 5 states that protected area accountability

~ma (emphasis added)

be initiated upon activation of the OSC."

The current revision also states that accountability is required at the SAE and GE classifications, and that the 30 minute.requirement for*

completing accountability begins with the declaration of an,SAE or a GE, and "when the OSC is activated."

Since the previous revision required accountability at the Alert level, and the current revision makes accountability optional at the Alert level (mandatory at the SAE and GE),

the change constitutes a reduction from a previously approved procedure.

In addition, the prerequisite of OSC activation is not appropriate since the activation of the OSC could be delayed during off-normal hours, resulting in a potential delay in the decision to search for potentially injured individuals.

This change was evaluated against the criteria specified in NUREG-0654 (Planning Standards II.J.4 and 5) and discussed with the NRC Emergency Preparedness Branch.

Making accountability optional at the Alert level was considered to be acceptable.

The other changes were not considered to be acc'eptable.

Based on the discussions with NRC Headquarters, it was determined that the licensee should be reminded that changes that decrease the effectiveness of the Plan require prior NRC approval in accordance with

CFR 50.54(q).

Response

- The licensee proposed to modify the procedure to eliminate the requirement to activate the OSC before initiating accountability.

The licensee also proposed to modify the. procedure to extend the 30 minute

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accountability goal to the Alert level, if the process was initiated at that level.

This response was considered acceptable.

To follow the licensee's progress, this matter will be tracked as Open Item 91-02-03.

This part of the licensee's program was considered adequate; however, the results indicate a need for increased management oversight to ensure that the Emergency Plan and EPIPs are maintained.

No.deviations or cited violations were identified.

Emer enc Facilities E ui ment Instruments and Su lies This part of the inspection was conducted to determine whether the licensee was adequately maintaining its emergency response facilities (ERFs),

and to determine whether any changes to the ERFs adversely affected the licensee's ability to respond to an emergency.

The inspectors visited each of the ERFs to observe the state of readiness for activation.

No significant changes to the ERFs have occurred since the last time this area was inspected; however, the licensee stated that it had started to review ways to change the layout of the Emergency Operations Facility (EOF) to make interaction more effective and efficient.

The present layout has, on occasion, contributed to minor difficulties in emergency management, because the facility is spread-out and compartmentalized.

At the present time, the licensee is reviewing the possibility of relocating the Supply System Dec'ision Center (SSDC) to a more central location within the EOF.

During the tour of the TSC, the inspectors observed that most of-the office space and desks were being used on a day-to-day basis by plant operations personnel.

Desk tops were covered with papers, books, and office utility items, and the furniture in the Plant Emergency Director's (PED's) office had been re-arranged.

According to the licensee, the desks are cleared before drills; and the use of the office space has not affected the activation of the facility.

Since drills are pre-planned, and emergencies are not, the licensee was cautioned to closely monitor the the TSC (and all ERFs) to ensure that routine use does not degrade the emergency function of the facilities.

During the tour of the TSC, the inspectors also observed that there was a pool of standing water (about one gallon) at the base of an electrical panel in the Mechanical Equipment Room.

It appeared that the standing water had been there for some time since there was rust all along the base of the electrical cabinet where the pool was (and had been) in contact with the cabinet.

The inspectors questioned the potential safety significance of this condition.

In response, the licensee initiated steps to determine the source of the leak, and notified plant safety personnel to determine whether it presented a safety concern.

The licensee determined that the water resulted from a leaking relief valve on a hot water heater located in the room.

In addition, the licensee produced a Maintenance Work

H

Request (NWR) pertaining to the leaking rel,ief valve.

According to

'

the MMR, the leaking valve was first noted on Oecember 20, 1989.

The MMR was not initiated until August 10, 1990.

The licensee stated that the relief valve had not been replaced because the repair work was considered to be a low priority.

The licensee's review concluded that the condition was a safety concern and raised the priority of the repair work.

The pool of water was removed before the end of the inspection.

Subsequent to the inspection, licensee EP staff informed the inspector that the relief valve had been replaced.

The inspectors questioned the licensee about its program for inspection of ERFs.

In response, the licensee explained that there are three levels of facility surveillances; a quarterly walk-through by the center director, a quarterly walk-through by the plant area director, and a periodic inspection by the EP staff.

The'nspector's did not personally contact the center and area directors to determine whether they had noticed the condition during their walk-throughs.

The licensee's EP staff did not appear to have any prior knowledge of the problem..

No deficiencies or violations of NRC requirements were identified during this part of the inspection; however, the results indicate a

need for the licensee to devote more attention to this area to ensure that the ERFs are maintained in a state of operational readiness.

C.

Or anization and Mana ement Control D.

No significant changes to the site's emergency response organization (ERO) or EP program management control have occurred since the last inspection.

No deviations or violations of NRC requirements were identified during this part of the inspection.

Inde endent and Internal Reviews and Audits An annual audit of the EP program was conducted during the period April 2-13, 1990 (Audit Report No.90-510, dated June 8, 1990).

The periodicity and scope of the report were found to be in accordance with 10 CFR 50.54(t).

Eighteen equality Finding Reports (gFRs)

and five Observations were identified as a result of the audit.

Fifteen of the gFRs were classified as "Safety" and three were classified as

"Commercial."

"Safety",gFRs are categorized into three different levels; I, II, and III, where Level I is the most significant.

"Safety" gFRs are more significant than "Commercial" gFRs and require a more in-depth response.

Likewise, Level II "Safety" gFRs are more significant than Level III gFRs and require a more in-depth response.

Of the 18 gFRs identified, 5 were Level II and 10 were Level III.

The audit report transmittal memorandum stated that this was a "significant decrease in the number of gFRs,"

when compared to the previous audit.

Although the transmittal memorandum indicated that the findings identified were "considered minor and typically

ll 1"

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involve procedure problems," there was one area that was identified as requiring "further management attention."

The concern involved

'he

"repeated failure by EP to comply with the PPM procedure deviation process."

According to the audit report, a Level II (FR was issued during this audit and during the last audit, because the EP staff had circumvented the procedure deviation process".

The Programs and Audits Manager indicated in the transmittal memorandum that the "preventive actions taken to resolve the initial finding were not effective."

The response to each of the gFRs identified during this audit were reviewed to determine the adequacy of the planned/completed corrective actions.

In general, the corrective actions appeared to be adequate.

No deviations or violations of NRC requirements were identified during this part of the inspection.

~Trainin The inspectors discussed changes to the EP training program, verified that training was being conducted, and interviewed a small sample of selected individuals to determine whether they had been properly trained and understood their emergency responsibilities.

Mith respect to program changes, the EP Training Supervisor informed the inspectors that two new individuals had been hired to support the EP training program; one Senior Training Specialist and one Training Assistant.

The addition of the two individuals was clearly viewed as an improvement to the program.

The EP Training Supervisor also stated that a Job Task Analysis (JTA) had recently been completed and that the training program was being modified to implement the results of the JTA.

According to the EP Training Supervisor, the implementation of the JTA would elevate the EP training program to a level consistent with the Institute of Nuclear Power Operations (INPO) accreditation program.

To implement the JTA,.position specific training was being developed for members of the ERO.

The EP Training Supervisor indicated that the time devoted to training would be increased.

The training will consist of initial training and refresher training.

The refresher training will include a test to address the EP program overview, CARs identified during drills and exercises, NRC findings, industry events, changes to EPIPs, and a tabletop drill using a scenario as the basis for discussion.

These changes were viewed as an improvement to the program.

The EP Training Supervisor reported that changes to the drill program were also being implemented.

Instead of conducting four drills per year, the licensee now intends to conduct only three per year (one of the drills is the annual exercise).

According to the EP Training Supervisor, individual emergency center tabletop drills will be conducted in lieu of the fourth drill.

The impact of this change could not be determined at this time; however, the inspectors reminded the licensee that the number of drills conducted each year was increased several years ago to improve the performance during exercise I

The inspectors 'reviewed the records maintained by the EP Training Supervisor to verify that training was being conducted.

This review showed that the EP training program was being implemented in accordance with procedures.

To measure the effectiveness of the EP training program, the inspectors interviewed two relatively new OSC Directors to determine whether'hey were familiar with their emergency responsibilities and the functioning of the OSC.

The following observations were made during those interviews:

1.

Both of the individuals interviewed initially attempted to use an "uncontrolled" book that contained procedures for the OSC Director.

This book contained an out-of.-date copy of EPIP 13.10.9,

"OSC Operations and OSC Director Duties. 'ne of the individuals did not recognize that the procedure was not a

"controlled" copy, even though it was stamped "uncontrolled-verify prior to use."

This individual did not appear to be familiar with the term, "Level I" procedure (this is the licensee's own terminology).

One of the individuals indicated that he would use this book in an emergency.

The other individual said he would use the "controlled" EPIPs that are stored in the OSC.

2.

3.

5.

One of the individuals interviewed stated that he did not remember seeing or reading the new revision of EPIP 13. 10.9.

The other individual stated that he thought there was a

checklist for his position in'he OSC Director's.book (the

"uncontrolled" book mentioned above),

but not in 13. 10.9. It should be noted that the checklist is part of the EPIP.

When encouraged to use the EPIPs, one individual stated that he would not refer to the EPIPs unless he was asked a "detailed"

- question.

In response to a question about the minimum classification level for OSC activation, one individual said "the second level, an SAE."

The individual did not correct his response until he was asked'to name the other classification levels.

By procedure, the OSC is activated at the Alert level.

Both of the individuals correctly described how they would be notified of an emergency during normal and off-normal work hours.

6.

Both of the individuals appeared to be familiar with the process used to activate the OSC.

7.

One of the individuals did not have the emergency identification card issued to him as a member of the ERO.

The cards are used to bypass roadblocks.

8.

Both of the OSC Directors experienced difficulty when describing the process used to complete accountability.

The

.l H

9.

OSC has the responsibility to complete accountability during an emergency.

Neither of the two OSC Directors effectively responded to questions about the established methods to control contamination within the OSC.

Neither could explain how iodine concentration was measured in the the OSC.

10.

13.

Neither of the two OSC Directors knew the criteria for determining OSC habitability.

One of the individuals said that determining the habitability was his decision.

The other said that he would rely on his Health Physics (HP) lead.

When asked to provide the emergency exposure limits, one individual stated that the limit was (N-18)x25 to save a life, and a judgement call when repairing a piece of critical equipment.

The other OSC Director correctly answered thi.s question.

One of the OSC Directors did not appear to know how to gain access to the emergency lockers located within the OSC.

He'hought a seal needed to be broken, when in fact a key is used to gain access.

Independent of the interviews, the key was obtained from HP personnel at access control; however, when the inspector and one of the OSC Directors attempted to use the key, they found that it would not open the locker.

This issue was brought to the attention of the EP staff.

One of the OSC Directors thought there was a

CRASH telephone in the OSC.

14.

15.

16.

17.

Both of the OSC Directors were familiar with emergency repair team operations (e.g., task assignment, team composition, communications, tracking, and team briefing/debriefing).

When asked to describe the process for obtaining offsite fire or medical assistance, one of the OSC Directors stated that he would make the necessary calls himself, rather than notifying the Shift Manager (SM)/PED.

By procedure, these calls are required to be made by the SM/PED.

When asked to describe the method used to obtain additional support, one OSC Director stated that he would call the site support contractor.

By procedure, the Plant Administrative Manager in the TSC is supposed to be contacted.

When asked if they thought they had received enough training for the assigned position, one individual said "no" and the other said "yes."

No deviations or violations of NRC requirements were identified during this part of the inspection.

However, based on the results of the OSC Director interviews, the licensee should consider whether

corrective actions. are necessary to ensure that the OSC can be effectively managed during an emergency.

4.

Exit Interview An exit interview was held on January 18, 1991, to discuss the preliminary findings of the inspection.

The licensee personnel who attended the meeting are identified in section 1 of this report.

The NRC resident inspectors also attended the meeting.

During the exit interview the licensee was informed that one potential non-cited violation was identified.

Mith the exception of the open item involving the accountability procedure (EPIP 13. 5. 5) in section 3. A. 2. b, the findings described in sections 2 and 3 of this report were discussed.

The inspector acknowledged the licensee's effort to revise and improve its emergency classification procedur I t)

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