IR 05000416/1982027

IE Insp Rept 50-416/82-27 on 820412-16 & 28-29.No Noncompliance Noted.Major Area Inspected:Emergency Preparedness

ML20054H018
Person / Time
Site:	Grand Gulf
Issue date:	05/24/1982
From:	Andrews D, Cline W, Jenkins G, Marston R, Stansberry W NRC Office of Inspection & Enforcement (IE Region II)
To:
Shared Package
ML20054H011	List: IR 05000416/1982027 ML20054H010
References
50-416-82-27, NUDOCS 8206220499
Download: ML20054H018 (15)

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REPORT DETAILS Persons Contacted Licensee Employees

"J. McGaughy, Assistant Vice President - Nuclear Production

• • • C. K. McCoy, Plant Manager

• L. F. Dale, Manager of Nuclear Services

• L. R. McKay, Corporate Health Physicist

• J. D. Richardson, Manager, Nuclear Safety Licensing

• R. A. Ambrosino, Nuclear Support Manager

• M. E. Abbott, Manager, Security

• • • R. R. Weadon, Chem / Rad Control Supervisor

• • • P. B. Benedict, Corporate Emergency Planning Coordinator

• G. A. Ellis, Security Supervisor D. L. Hunt, Training Superintendent J. Raines, Test Supervisor J. Roberts, Startup Engineer M. J. Moon, Health Physicist T. G. Lee, Staff Health Physicist G. D. Lahmn, Shif t Supervisor

• A. R. Matura, QA Representative

• J. W. Yelverton, QA Supervisor

• R. D. Brown, Chemist

• M. A. Lacey, OA Representative

• P. Sulk, Training Instructor

• D. Ortz, Environmental Coordinator

• J. Vincelli, Radiological Control Supervisor

• J. Wallace, Radiation Protection Specialist

• * *C. Gulley, Site Emergency Planning Coordinator Other licensee employees contacted included construction craftsmen, technicians, operators, security force members, and office personnel .

Other Organizations E. Fuente, Director, State of Mississippi Radiological Health Program G. Dempsey, Health Physicist, Mississippi Radiological Health Program NRC

• J. P. Stohr, Director, Emergency Preparedness and Operational

• • D. Scott, Resident Inspector

• Attended exit interview on April 16, 1982

• • Attended exit interview on April 29, 1982

• • • Attended exit interviews on April 16 and April 29, 1982 8206220499 820526 PDR ADOCK 05000416 G PDR

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2. Exit Interview The inspection scope and findings were summarized on April 16 and April 29, 1982, with those persons indicated in paragraph 1 abov . Licensee Action on Previous Inspection Findings The inspector evaluated the licensee's actions on a previously identified unresolved item concerning a demonstration of emergency accountability (50-416/81-44-08; 50-417/81-19-08). The evaluation involved review of the licensees plans and procedures and observations of a test of the emergency accountability system. The accountability test was conducted on April 28, 1982 and involved the computerized accountability system. The sy stem provided the licensee with a computerized printout as to the last known location of an individual based on the individual's key card entry into that location. During the test, the licensee was able to show the location of approximately one-hundred individuals within the established plant account-ability zone This was accomplished by means of computerized printouts which listed individual names, badge numbers, and last known location for the individuals. According to licensee representative these reports would be made available to the operations superintendent for necessary followup actio During the test the licensee elected not to require all the personnel within the plant (plant accountability zones) to be processed through the accountability card readers, but limited the number of key card entries to less than fifteen. Although the system appeared to provide an initial accounting for a relatively large number of personnel within the plant accountability zones such factors as: minimal useage of the designated accountability card readers, lack of full site assembly involving participation by onsite (out-of plant) members to include onsite construc-tion and administrative personnel and the lack of testing communication of full assembly accountability results to the operations superintendent reveals that more thorough testing of the accountability system considering these factors is required before power ascensio This matter remains unresolved pending demonstration of a full site assembly and accountabilit . Unresolved Items New unresolved items were not identified during this inspectio . Organization This area was inspected with respect to the requirements of 10CFR50(b)(2),

10CFR50 Appendix E, Paragraph IV.A, and criteria in NUREG 0654 Section I and B. The review consisted of examination of the licensee's emergency plans and procedures relevant to the emergency organization, tour of work areas for emergency organization staff members, discussion with the licensee's teergency planning staff members, and interviews with selected key managers within the emergency organizatio During the review of the emergency plan and procedures, the inspector noted that the emergency organization chart depicted that key managers within the organization reported to the Emergency Communicator rather than to the Emergency Director. Licensee representatives stated that key managers reported to the Emergency Director rather than the Emergency Communicato Licensee representatives indicated that the roles and organizational relationships of the Emergency Communicator would be clarified. This will be reviewed during a subsequent inspection (50-416/82-27-01).

The inspector conducted interviews with five key management members of the emergency organization. All members interviewed appeared to understand:

the function of the emergency organization; their respective roles, responsibilities and authorities within the organization; reporting channels; and line of succession for leadership positions.

6. Radiological Emergency Response Training The emergency training program was inspected with respect to the require-ments of 10CFR50.47(b)(15) and (16); 10CFR50, Appendix E, Paragraph IV.F.;

and criteria in NUREG 0654,Section I Training for the emergency response organization was reviewed and discussed with licensee representatives. Training requirements have been established for key individuals in the emergency organization as well as for all employees of the station. These requirements are contained in Administra-tive Procedure 01-S-04-21, Rev. 1. A formal training program has been implemented based on these requirements, and includes examinations and practical exercises, where appropriat Examinations and quizzes are administered under the provisions of Administrative Procedure 14-S-01- Changes to procedures and the Emergency Plan which occur during the annual retraining cycle are promulgated to all emergency organization members through the provisions of a required reading list in accordance with Administrative Procedure 01-S-04-9. Training instructors are selected and qualified in accordance with Administrative Procedure 14-5-01- The selected lesson plans and outlines for emergency response training were reviewed and were considered to be adequate. Review of training records for key individuals in the emergency response organization indicated that sufficient numbers of personnel have been trained to adequately staff the emergency organization. The licensee's records also show that alternates for key positions have completed the required emergency response trainin The inspector noted that some individuals in the emergency organization had not received trainin The inspector pointed out that training and retraining programs would be reviewed during future inspections.

7. Emergency Response Facilities This area was inspected with respect to the requirements in 10CFR-50.47(b)(8); 10CFR50 Appendix E, Paragraph IV.E and criteria in NUREG 0654,

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Section II.H. The inspection involved review of licensee emergency plans and procedures, tour and physical inspection of the Control Room (CR),

Technical Support Center (TSC), and interim Emergency Operations Facility (EOF), and discussion with licensee representative During the tour of the CR the inspector was shown the signals, alarms, and instrumentation associated with the licensee liquid and airborne effluent control system. The inspector had no comments on this matter. It was noted that certain critical emergency supplies and equipment were on-hand and in place in the C The inspector conducted a tour and examined equipment and supplies v Ithin the TSC. It was noted that the TSC was within the CR design envelope, thus it apparently met the same habitability criteria as the CR. It appears that personnel can move quickly and safely between the CR and the TSC. Communi-cation systems (telephones and radios) were inplace and operable at the time of the inspection. Telephone systems included the HPN and ENS systems, dedicated voice links between the TSC and CR, and commercial phones. The inspector noted that provisions were made for keeping up-to-date records such as process and instrumentation diagrams, safety analysis reports, and emergency plans and procedures in the TSC. At the time of the inspection an equipment / supply cabinet was available within the TSC and was stocked with such items as protective clothing and survey meter An inspection was conducted at the interim E0F which is located south of the plant complex in the training buildin The licensee is planning to construct a permanent EOF at the site. During the inspection of the interim EOF the inspector observed work location, space availability and work area layout, communication systems, radiation control provisions, emergency supplies and equipment, management control provision within the EOF, and EOF recordkeeping programs. During the review cf communicaitons systems it was not apparent that a dedicated voice link existed between the interim EOF and TS Licensee representatives indicated that the internal plant " dimension telephone sytem" would suf fice as a communication linkage between the TSC and EO The inspector noted that this system was not truly a dedicated link between the TSC and EO The inspector pointed out the merits of dedicated communication links especially in situations involving heavy communications traffi The inspector also reviewed provisions for assessing airborne levels of radioactive material at the EOF. The licensee had air sampling equipment on hand at the EOF but apparently lacked necessary provisions for assessing levels of airborne radioiodine. This matter requires improvement and will be reviewed during a subsequent inspection (50-416/82-27-02).

Based on the inspectors observations and review of the licensees program for upgrade of emergency support facilities, TMI Action Plan requirement 111. A.1.2 related to interim facilities is close ~ -- - -- _-- .- -

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Emergency Assembly Areas i The assembly areas were reviewed with respect to the . requirements of 10CFR50.47(b)(8) and (10); 10CFR50, Appendix E, Paragraph IV.E; and criteria in NUREG 0654,Section II.J. Assembly areas are discussed in EPP-11, 15, 16 and 25; however, it appears that they are not addressed in the EP. Assembly

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areas are designated based upon the type of evacuation and if personnel are non-emergency or emergency personnel. During limited evacuation non-emergency and emergency personnel for the affected areas report to the HP 4 Laboratory for monitoring and accountabilit Unaffected area personnel

report as directed by their immediate supervisor or by the Emergency i Director over the site PA syste During -site accountability, non-

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emergency personnel report to the Site Access Point (SAP), emergency personnel report to their appropriate Emergency Response Facility (ERF).

Guidelines on control and operation of cne SAP are provided. The designated assembly areas are primarily used for accountability and radiological monitoring. According to licensee representatives alternate assembly' areas

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have been considered; however, it appears that they are not designated or identified in the EP or other appropriate EPP. This area will be reviewed during a subsequent inspection. (50-416/82-27-03) Emergency Medical Treatment Facilities This area was observed to determine that arrangements are made for medical

services for contaminated injured individuals as required by 10CFR50(b)(12),

10CFR, Appendix E, Paragraph IV.E. and criteria in NUREG 0654,Section I Two medical treatment facilities are provide The primary facility is F

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located at the 93 foot level of the Control Building in the Health Physics

Access Control Area. The room is located adjacent to the Health Physics Lab

and the Decontamination Area and is accessible to stretcher - carried patients. Communications are available in the Medical Treatment Room and in

. the HP Lab.

Treatment procedures are not yet availabl Frisking instruments and decontamination procedures will be available from the Decontamination or HP

rooms. Medical supplies and equipment are provided as listed in Appendix B

of the Emergency Plan and as listed on the appropriate forms (HP-1010 and

! HP-1011).

i Alternate treatment facilities are located in the Maintenance Shop which

{ serves as the Operational Support Center (OSC) in an emergency. Medical and decontamination equipment and supplies are provided. A shower is available near the opposite end of the building.

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Emergency dosimetry would be provided from the HP Lab in the Control Building and from the OSC Emergency Kit in the Maintenance Shop.

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Potassium Iodide supplies are maintained in the Emergency Kits and in locations specified in Emergency Plan Procedure 10-S-01-20, Administration of Thyroid Blocking Agent The inspector determined that the licensee's medical treatment facilities appeared to be adequat A licensee representative stated that some personnel will be trained as Emergency Medical Technician The inspector had no further questions in this are . Decontamination Facilities The facilities and equipment available for decontamination were inspected with respect to the requirements of 10CFR50.47(b)(8)(10) and (11); 10CFR50, Appendix E, Paragraph IV.E; and criteria in NUREG 0654,Section II, J. and The primary decontamination facility is located at the 93 foot level of the Control Building in the Health Physics Access Control Area. Partial monitors are in place and frisking instrumentation will be provided when necessary. Sinks and showers are available, including one shower which will accommodate a stretcher or gurney. Decontamination supplies are available, and procedures and Health Physics assistance will be provided as necessar Drains from the sink and showers run to the liquid radwaste system. Drums will be provided for solid waste. Replacement clothing is available in the decon roo Decontamination supplies are available in the Medical Treatment Room in the Maintenance Shop (OSC). A shower is also available in the building and drains to a holding tan Decontamination supplies are provided with the Site Access Point Emergency Kits. Provision is made for decontamination of personnel and vehicles at this point.

The inspector had no further questions in this are . Emergency Kits and Emergency Survey Instrumentation This area was inspected with respect to the requirements of 10CFR-50.47(b)(S)(9) and 10; 10CFR50, Appendix E, Paragraph IV.B and E and criteria in NUREG 0654,Section II, H. and The inspector reviewed the Emergency Plan and Emergency Plan Procedure EPP-24, reviewed kit inventories and inspected the onsite emergency kit All kits were found to be adequately and completely stocked. Contents were as specified in the Plan and Inventory Listing, but the inventory is not controlled under a procedur Instruments were checked and found to be in current calibration and operabl . .

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Ion chamber and GM instruments are provided in the kits for detection and measurement of radiation. TLDs are currently available only in the Hospital and Site Access Point (SAP) kits. A licensee representative stated that TLDs (including extremity TLDs) would be placed in the OSC and SA Dosimetry would also be available in the Dosimetry Office located in the Administration Buildin A review of the Corporate Offsite Monitoring Procedure (6.14) indicated that desired minimum detectable activities of iodines and particulates could be detected and measure Silver-impregnated silica gel cartridges are used by plant onsite and of f site monitoring teams to detect radioiodine The Corporate offsite monitoring team uses silver zeolite cartridge Calibration procedures are in use for all instruments stocked in the emergency kits. Emergency Plan Procedure EPP-24 assigns responsibilities and schedules for inspections and inventories of emergency equipment and facilitie The inspector had no further questions in this are . Area and Process Radiation Monitors This area was inspected with respect to the requirements of 10CFR50.47(b)(8)

and (9); 10CFR50, Appendix E, Paragraph IV, B. and E. , and criteria in NUREG 0654,Section I This inspection included those area and process radiation monitors related to the emergency plan with inspection emphasis on emergency radiological assessment rather than calibration and maintenance of the syste Potential release pathways are monitored for low range releases of radio-activity by standard effluent monitors. High range or post accident monitoring capability is in the process of being installed. In addition, high range area monitors are being installed in containment and the drywel These monitors will be used to provide an indication of radioactivity inventories in the atmosphere of both the drywell and containment. At the time of this inspection the high range monitors had not been turned over to the plant as operational and no correlation had been developed between high range monitor readings and containment or drywell activity concentratio The high range monitors will be reviewed during a subsequent inspection (50-416/82-27-04).

The high range or post accident effluent monitoring system is not expected to be operational at startup; consequently, graphs have been developed to relate low range monitor readings to noble gas source term information. No capability is available for low range iodine source term data from direct reading instrumentatio The post accident monitoring system will provide source term data as a direct readout in pCi/sec for both noble gases and

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iodine when it becomes operational. The inspector noted that the licensee had developed a procedure to obtain iodine source terms using the installed continuous sampling system, laboratory analysis and calculational method This procedure will be used by the licensee until such time as the high range system becomes availabl . Non-Radiation Process Monitors This area was inspected with respect to the requirements of 10CFR-50.47(b)(8); 10CFR50, Appendix E, Paragraph IV.E. , and criteria of NUREG 0654,Section I The seismic monitoring system has been installed and is operational. The system consists of several seismic triggers which actuate an event recorder in the CR to provide a means to evaluate the acceleration force of a seismic event occuring on or near site. There are five alarms associated with the equipment which provide the oporator with an alarm when the recorder is actuated plus alarms set for tr.e safe shutdown earthquake and operating basis earthquake for the drywell and containmen In addition, the control room panel has the capability to characterize an event by frequency spectrum analysis which can be compared to standard response code spectra. This will provide additional information to plant personnel on the exact nature of a seismic event. A second system consists of etch plate recorders which are placed at various key locations and can be analyzed on site for verifica-tion, or as a backup means of determining peak shock for a seismic even The EAL's and EPP 10-S-01-10 include operator actions to classify an emergency based on the above noted alarms; however, Procedure 10-5-01-10, Natural Occurrences, does not include actions to be taken on alarms occurring for the drywell operating basis or safe shutdown earthquakes. A licensee representative said that this procedure would be revised to include actions to be taken for both containment and drywell safe shutdown and operating basis earthquake alarms. This revision will be reviewed during a subsequent inspection (50-416/82-27-05).

14. Meteorology This area was inspected with respect to the requirements of 10CFR-50.47(b)(5), (8) and (9): 10CFR50, Appendix E. Paragraph IV, B and E; and criteria in NUREG 0654, Sectior II, E, H and The inspector discussed the meteorological program with licensee representa-tives. A computer system located in the CR is used to access meteorological information from the instrumention located at the onsite station meteoro-logical tower. The inspector inquired about the status of the revision to EPP 10-S-01-12 concerning stability classification based on the standard deviation of wind direction flucuation (50-416/82-03-16). Licensee representatives indicated that this procedural modification is still pending. This matter will be reviewed during a subsequent inspectio .

15. Respiratory Protection This area was inspected with respect to the requirements of 10CFR-50.47(b)(10) and (11): 10CFR50, Appendix E, Paragraph IV.E. and criteria in NUREG 0654, Section H and Provisions have been made to supply the CR and other ERFs with appropriate respiratory protective devices including self contained breathing apparatu An overall respiratory protection program has been initiated at the plant and training is being conducted in this area for all permanent plant employees. The inspector had no further questions in this are . Emergency Communications The area of emergency communication equipment was reviewed with respect to the requirement of 10CFR50.47(b)(6); 10CFR50, Appendix E, Paragraph IV.E; and criteria in NUREG-0654,Section I The licensee has discussed this item in Sections 5.7.1, 7.5, and 8.3.2 of the EP and EPP-16. The emergency communication equipment was inspected and found in place as indicated in the EP. There are provisions for primary and backup means of communication for the licensee, local, State and Federal emergency response organizations. Those links have redundancy of power source. There is communications between the applicant's near-site EOF and radiological monitoring team There is an alarm alerting system onsite for fire and site evacuations. The fixed and mobile medical support facilities have a communication link. The EP provides for monthly communication drills with the local and State emergency response organizations in the EPZ: quarterly drills with Federal and State emergency response organizations within the ingestion pathway; and annual communication drills between the licensee, State and local EOCs and field assessment team The inspector had no further questions in this are . Emergency Corrective Action Corrective action were reviewed with respect to the requirements of 10CFR50.47(b)(8); 10CFR50, Appendix E, Paragraph IV.E; and criteria in NUREG-0654,Section II . The licensee discusses Rescue and Damage Control Equipment, Maintenance and Inventory of Emergency Equipment and Supplies, and Corrective Action in Section 6.4, 7.9 and 8.6 of the EP and EPP-24. lhe EP indicated that these Rescue / Damage Control Equipment Kits are in specified areas; however, the EP and EPP does not indicate where these kits are located (50-416/82-27-06).

This will be reviewed during a subsequent inspectio .

18, Emergency Transportation Emergency Transportation was reviewed with respect to the requirements of 10CFR50.47(b)(8); 10CFR50, Appendix E, Paragraph IV.E, and criteria in NUREG-0654,Section II . The licensee discusses control of designated emergency vehicles in EPP-28; however, this emergency equipment is not addressed in the EP. Specifically emergency equipment discussed in Section 7.6.1 and Appendix B of the EP does not mention this designation (50-416/82-27-07). This item will be reviewed during a subsequent inspection. Primary, secondary and alternate emergency vehicles are designated in the EPP. The Shift Superintendent has adminis-trative control of the keys to these vehicle . Emergency, Alarm and Abnormal Occurrence Procedures This area was inspected with respect to the requirements of 10CFR-50.47(b)(4), (8) and (9); 10CFR50, Appendix E, Paragraph IV.B and E and criteria in NUREG 0654,Section II.D, H and During the appraisal of the emergency preparedness program in January 1982 it was noted that the emergency, alarm and abnormal occurrence procedures did not make specific reference to the EPPs. This matter was reviewed and no change found from the appraisal findings. This matter (50-416/82-03-23)

remains open and will be reviewed during a subsequent inspectic . Notifications The inspector reviewed emerge"scy notification procedures and discussed the notification program with 1.censee representative Licensee personnel interviewed appeared to understand the notification procedures and their respective roles / responsibilities in carrying out noti fication The inspector noted the licensee notification procedures contained appropriate telephone listings for local and contractor support agencies and a preplanned message for at for use with offiste agencie . Assessment Action This area was inspected with respect to the requirements of 10CFR-50.47(b)(9); 10CFR50, Appendix E, Paragraph IV.B; and the criteria of NUREG 0654,Section I Review of this area included training material presun to key members of the emergency response organization for both engineering assessment of accident conditions and radiological consequences of an acciden Engineering assessment actions includes training in mitigating core damage and plant desic.1 informatio . - .- __ _ .

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j Radiological assessment includes area and process radiation monitoring, potential release pathways and evaluation of dose equivalent assessment for offsite and site boundary doses. Procedure 10-S-01-12 was reviewed and the bases for assumed information in the procedure was discussed with licensee representatives. The dose assessment calculation is based on a straight line gaussian model using actual meteorological data and low and high range effluent monitor conversion graphs. Default and empirical data are provided in the event of instrument failure and there are provisions for incorpora-ting field monitoring data when available. High range atmospheric monitors in the drywell and containment have not been calibrated in terms of activity concentration conversions and the procedure does not currently employ dose calculations based on potential release A computerized method of dose calculation is under development (termed the I (ERFI's) which will meet class A model characteristics and will signifi-

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cantly improve calculation capabilit This system will utilize direct inputs and, using appropriate software, will provide a range of dose calculations which should meet all guidelines in this are The ERFI's system is planned to be operational by October 1982.

I The calculative procedure provided by Procedure 10-S-01-12 appears to be adequate for interin or backup use. The inspector noted that, when the high range monitors in the containment and drywell are calibrated and conversions to activity concentration have been completed, the procedure should be revised to include calculations of offsite doses based on potentials for

, release. This capability will be evaluated prior to exceeding 5% reactor power (50-416/82-27-08).

22. Offsite Radiological Surveys This area was inspected with respect to the requirements of 10CFR-50.47(b)(8), (9) and (11); 10CFR50, Appendix E, Paragraph IV.B and E; and criteria of NUREG 0654,Section II.H, I and The inspector reviewed the Emergency Plan and the Corporate and Plant Emergency Procedures for offsite monitoring, reviewed monitoring kit contents and discussed the program with licensee representative Offsite monitoring will be conducted initially by plant teams who will

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return samples to the Site Access Point for analysis. Its expected that the plant teams will be recalled when the corporate monitoring teams begin monitoring. The corporate teams have the capability to perform a field analysis of radioiodines and particulates. However, the plant teams appear not to have this same capability (50-416/82-27-09). This will be reviewed during a subsequent inspectio Offsite surveys are conducted at specific locations and are coordinated with surveys performed by the Stat Data sheets provide for recording all essential dat A licensee representative stated that preprinted labels

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will be provided to identify sample Primary communications and dis-position of samples are discussed in the EPP (10-S-01-14). Transportation is provided for in EPP 10-S-01-2 Radiation protection guidance is provided in Attachment I to EPP 10-S-01-14 and in Corporate EPP 6.1 Specific guidance will be provided to the monitoring teams in a briefing prior to dispatc There appears to be no provisions for backup communications for offsite monitoring teams (50-416/82-27-10) and no instructions for disposition of the offsite monitoring team's data sheets (50-416/82-27-11). These will be reviewed during a subsequent inspectio . Onsite (out-of plant) Radiological Surveys This area was inspected with respect to the requirements of 10CFR50.47(b)(8)

and (11); 10CFR50, Appendix E, Paragraph IV.B and E; and criteria of NUREG 0654,Section II.I and Discussion with licensee representatives indicated that onsite surveys within the Protected Area would be done by the In-Plant Survey team using their procedures and the onsite surveys outside the Protected Area would be conducted by the Offsite Teams using their equipment and procedures. The inspector had no further questions in this are . In Plant Radiological Surveys This area was inspected with respect to the requirements of 10CFR50.47(b)(8)

and (11); 10CFR50, Appendix E, Paragraph IV.E and criteria of NUREG 0654,Section I The inspector reviewed the EP, EPP-10-S-01-13, and Health Physics Procedures 08-S-02-50, 08-S-02-51, and 08-S-02-52; examined the monitoring kits; and discussed the program with licensee representative The procedures specified equipment and methods to be used in conducting the surve Data sheets are provided for recording essential informatio Radiation protection guidance is provided in the procedures and detailed guidance will be provided in the briefing given prior to dispatc A licensee representative stated that preprinted labels would be provided for labelling the sample A licensee representative stated that various telephone systems and a portable radio system would be used for communications. Samples are to be turned in at the HP Lab or OSC if the Lab is inaccessible. No provision is made for collection of data sheets (50-416/82-27-12). This matter will be reviewed during a subsequent inspectio __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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25. Post Accident Sampling and Analysis This area was inspected with respect to the requirements of 10CFR50.47(b)(8)

and (9); 10CFR50, Appendix E, Paragraph IV.E; and criteria in NUREG 0654,Section I The inspector discussed the post accident sampling and analysis program with licensee representatives and reviewed existing procedure An automatic system is being installed for post accident coolant sampling and analysis and post accident containment and drywell sampling and analysis. The equipment will also provide for taking grab samples. Vendor manuals are currently available to be used as a basis for training and procedure developmen The licensee has a procedure for routine sampling and analysis from gas and liquid pathways. In addition to developing procedures for post accident coolant and containment and drywell sampling and analysis, the current procedures for routine sampling and analysis need to be modified for post accident conditions, or new procedures should be written. Also, a procedure for handling high level samples and providing necessary precautions in obtaining sanples should be addressed (50-416/82-27-13). A license representative stated that such procedures would be developed. This matter will be reviewed during a subsequent inspectio . Emergency Protective Actions The area of emergency protective actions involves procedures required for radiation protection during emergencies, evacuation of owner controlled areas, personnel accountability, personnel monitoring and decontamination and onsite first aid / rescu The licensee's procedures for protective actions during emergencies were reviewed with respect to the requirements of 10CFR50.47(b)(10) and (11): 10CFR50, Appendix E, Paragraph IV.B; and criteria in NUREG-0654,Section II.J, K and The licensee discusses protective actions in Section 6.5, 6.6, 6.7 and of the EP, and EPP-11, 15, thru 19, 21 and 25; and RPI-20 and 2 The Emergency Director is responsible for implementing the appropriate EPPs when emergency conditions warrent protection of onsite personne The Shif t Security Supervisor is responsible for the appropriate personnel account-ability during Site Evacuation. The Shif t Security Supervisor also reports the personnel accountability directly to the Emergency Director within 30 minutes during an emergency. There are two kinds of evacuations onsite; Limited Evacuation and the Site Evacuation. The two different types of Protective Responses at the site are based upon the two kinds of onsite personnel: Emergency Personnel and Non-Emergency Personnel . Appropriate protective actions are announced on the site PA system when necessar Personnel are informed of the emergency condition, incident location, area to be evacuated, kind of evacuation, evacuation routes and assembly areas to

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report to for accountabilit The transportation for onsite individuals during Site Evacuation to some suitable offsite location appears not to have been provided for in the EP or EPPs (50-416/82-27-14). This item will be reviewed during a subsequent inspectio Card key emergency accountability boxes are used for accountability at the onsite ERFs. Onsite first aid is provided for in the First Aid Treatment Room on the 93 foot level in the HP Access Control Area. Primary and back-up medical services are provided for in the E Rescue and Search Teams are provided by the OSC Supervisor with personnel assembled at the OS Radiation exposure protection during emergencies appears to be provided for in the appropriate EPPs, RPPs and RPIs. Exposure guidelines, personnel dosimetry and permanent record devices and appropriate contamina-tion control is covered by appropriate EPPs, RPPs and RPIs. Decontamination capability is provided at or near the monitoring point Provisions for monitoring all personnel exiting from the controlled area are indicated in the EP. Appropriate personnel decontamination instructions are indicated in the RPIs. There appears to be no means established for radiological decontamination of supplies, instruments and equipment; and, there appears to be no specified action levels for determining the need for such decontamination (50-416/82-27-15). These items will be reviewed during a subsequent inspectio . Security During Emergencies The procedures involving security during emergencies were reviewed with respect to the requirements of 10CFR50.47(b)(10); 10CFR50, Appendix E, Paragraph IV.B; and criteria in NUREG-0654,Section II.J and The licensee discusses security during emergencies in Section 6.5.1.1, and Table 8.2 of the EP and EPP-11,16 and 2 Security is responsible for personnel accountability and traffic control once an evacuation has been initiated. During a site evacuation, the Shift Security Supervisor is also responsible for ensuring all GGNS MP&L property is evacuated. Security performs their normal functions during radiological emergencies except for the above mentioned item . Coordination with Offsite Agencies This area was inspected with respect to the requirements of 10CFR50.47(b)(3)

and (12); 10CFR50, Appendix E, Paragraph II.E and criteria in NUREG 0654,Section I . . .

The inspector reviewed letters of agreement from the various offsite agencies having a support role in radiological emergency response. The inspector also discussed coordination with offsite agencies with licensee representative During the inspection, the inspectors visited the M!ssissippi Radiological Health Branch and discussed items of mutual in'.erests in the area of radiological emergency respons The inspector had no further questions in this area.