IR 05000461/1985039
| ML20151L882 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 12/19/1985 |
| From: | Brown G, Meck R, Phillips M, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20151L872 | List: |
| References | |
| 50-461-85-39, NUDOCS 8601020415 | |
| Download: ML20151L882 (57) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-461/85039(DRSS)
Docket No. 50-461 Permit No. CPPR-137 Applicant: Illinois Power Company-500 South 27th Street Decai.ur, IL 62525~
Facility Name: Clinton Power Station
' Inspection At: Clinton site, Clinton, Illinois Inspection Conducted: November 12-21, 1985 Inspectors: n/if/tr'
Team Leader Date o /1-l/ flW
. 6a'te - . Meck lY/f/W EPB OIE Date Approved By:
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M. P. Phillips, Chief /2 //f/f Emergency Preparedness ~Section Date Inspection Summary Inspection on November 12-21, 1985 (Report No. 50-461/85039(DRSS))
Areas Inspected: Special announced preoperational appraisal of the state of onsite emergency preparedness at the Clintor. Power Station involving the following areas: Administration of the Emergency Preparedness Program; Emergency Organization; Training and Retraining; Emergency Facilities and Equipment; Emergency Plan and Implementing Procedures; Coordination with ,.
Offsite Groups; and, Drills, Exercises and Walkthroughs. The appraisal involved 685 inspector-hours by seven NRC inspectors and four consultant Results: No violations or deviations were identifie However, 47 Open Items were identified, s
1 4 8601020415 851220 PDR ADOCK 05000461 0 PDR
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1.0 ADMINISTRATION OF THE EMERGENCY PREPAREDNESS PROGRAM The _ inspectors reviewed the contents of Revision 4 of the applicant's Clinton Power. Station (CPS) Emergency Plan dated December 15, 1984 including Section 1.3, Applicability and Authority, and Chapter 5.0, Maintaining Emergency Preparedness. The inspectors also reviewed the contents of the applicant's Emergency Plan Implementing Procedures (EPIPs), especially AP-06, Revision 0, Review of' Emergency Preparedness Program and AP-02, Revision 1, Document Control, and Corporate Nuclear Procedure (CNP) 4.03, Revision 2, Emergency Preparedness Program. The inspectors also interviewed various members of the applicant's emergency planning organization to determine their duties, responsibilities, authorities, training, qualifications, etc., and reviewed other relevant documents including job descriptions, memoranda, policy' statements and organizational chart .1 Responsibility and Authority Assigned Sections ~1.3.and 5.1 of the applicant's Emergency' Plan and CNP 4.03 unambiguously defined the responsibilities and authorities of all persons assigned actions by the Plan, including those actions necessary to develop, implement and maintain the total emergency preparedness program for CP CNP 4.03 stated that the Vice-President monitors the effectiveness ~of the Emergency Preparedness Program and specifically the Manager - Nuclear Program Coordination has the overall responsibility for the progra CNP 4.03 established the Supervisor - Emergency Response (S-ER) as the individual at the site tith direct responsibility for emergency planning and preparednes Due to the fact that Clinton Power Station.was the only nuclear. power plant
- owned by the applicant, most corporate aspects related to the nuclear plant
were performed at the plant, and there was no counterpart to the S-ER located
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at the corporate offices. The duties of the S-ER were limited to emergency planning so that he was not diverted by other dutie CNP 4.03 also assigned various emergency planning and preparedness-duties to the Manager - Public Affairs, Manager - Nuclear Program Coordinator, Manager -
Clinton Power Station, Manager - Nuclear Station Engineering, Director -
Nuclear Training, Manager - Quality Assurance, the CPS Nuclear Review-and Audit Group, and other various CPS department managers and directors. These duties were explicitly defined by CNP 4.03, the Emergency Plan and its implementing procedures, and included provisions for' input to the emergency
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planning effort by site personnel through the review and approval processes for the various planning document '
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Management support to the S-ER was adequate and the S-ER reported directly to the Director - Nuclear Program Coordination who was equivalent to the Plant Managar in the CPS organizational structure.
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Based on the above findings,.this portion of the applicant's program is adequat (
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1.2 Planning Coordination-As~ mentioned above, most aspects associated with the operation of CPS were located at the site. This fact, coupled with senior management involvement with the emergency planning and preparedness program had resulted in a well coordinated and active program. The inspectors noted good coordination with offsite organizations and day-to-day contact and support by the various organizations at the site. While the S-ER was not a member of the site Facility Review Group, the S-ER did attend weekly management staff meetings which provided an adequate forum for senior management to focus on items needing their attentio The applicant had implemented a program to coordinate with offsite response organizations, the public and the news media. The applicant had conducted training and planning coordination with the offsite response organizations; instituted an extensive public information program, including monthly newsletters to all the public in the 10 mile EPZ; and was planning to provide training and familiarization meetings for the news medi Based on the above findings, this portion of the applicant's program is adequat .3 Selection and Qualification The inspectors reviewed the position description for various members of the applicant's emergency planning organizations and conducted interviews with selected individuals with emergency planning responsibilities. Each position description contained specific selection and qualification criteria. In order to. fill a position with an individual who did not meet all of the criteria a specific and formally documented process was required. A gener&1 training ~
program of site specific emergency planning items had been established for emergency planning personnel. Section 5,4.6 of the plan provided for profes-sional development training for emergency planners. Although some professional meetings and seminars have been attended in the past, no specific program had been established to ensure that the emergency planning personnel maintain a state-of-the-art knowledge of emergency planning and preparedness, pursuant to the requirements of 10 CFR 50.47 (b)(16) and the guidance contained in NUREG-0654, Revision 1, Criteria 0.1 and Based on the above findings, this portion of the applicant's program is adequate; however, the following item should be considered for improvement:
- A formal program for training should be developed and implemented for individuals who-are assigned Emergency-Planning responsibilities, which will enable them to attain and maintain a state-of-the-art knowledge in the. field of emergency planning and preparednes .0 EMERGENCY ORGANIZATION 2.1 Onsite Emergency Organization The inspectors' verified that an effective emergency organization was in place by a review of the emergency organization and assignments of duties and responsibilities described in the Clinton Power Station _ (CPS)' Emergency Plan,
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o the Emergency Plan Implementing Proce'dures (EPIPs), and the' Illinois Power Company (IPC) Nuclear Policy Statement dated March 29, 1984. The structure of the onsite emergency. organization was provided in Figures 2-6 and 2-7 from Revision 5 of the Emergency Plan (See Attachment). The Plan and EPIPs delineated the management structure for the emergency organization. Provisions had been established to ensure that'an Emergency Coordinator would be available and onsite at all times with the authority.and responsibility to initiate any emergency actions, including the exchange of information with offsite authori-ties responsible for implementing offsite emergency measures. The line of succession for the Emergency Coordinator position had been clearly defined in the plan and EPIPs. The position descriptions and duties for personnel responsible for key emergency response functions were contained in EPIP EC-01, Revision 0, CPS Emergency Response Organizations and Staffing. The candidates for each key position in the emergency response organization were listed in EPIP EC-01, Revision 0. The selection of individuals for positions in the emergency response organizations were made by the Manager - Nuclear Program Coordination who, among other things, evaluated the individuals' qualifications and performance in drills and exercises prior to selectio For the Technical Support Center (TSC), Operational Support Center (0SC), and Emergency Operations Facility (E0F), one to three persons were interviewed for each of the key emergency organization positions. These key personnel were found to be aware of their emergency responsibilities and authorit Each had a good working knowledge of the emergency plan and the implementation of the EPIPs, were aware of their counterparts in the other facilities, and were knowledgeable in how to implement their responsibilitie Based on the above findings, this portion of the applicant's program is adequat .2 Augmentation of the Emergency Organization Provisions had been made for the timely augmentation of key emergency personnel upon activation of the emergency organization. Personnel would be augmented to fill.the following functional areas in the TSC, OSC, E0F, and JPIC as appropriate: emergency response coordination; operational accident assessment; onsite radiological accident assessment; offsite radiological accident assessment; technical _ support; security and site access control; repair /
corrective actions; manpower and logistics support; public information; and governmental liaison. Key emergency personnel were assigned pagers that would be used to notify them of an emergency. . When the pager activated, personnel were to call the load dispatcher who would inform them of the plant emergency classification. There were three load dispatchers on duty at all times and five lines that these calls could be made on. These key personnel were then to report to their assigned areas as determined by the emergency classification and prior training. The personnel who would be initially paged depended on the level of the emergency classification. Personnel would be augmented to staff the TSC, OSC and the'E0F at the Alert or higher classification and JPIC at the Site Area Emergency or General Emergency classification Although the applicant had conducted a call-out drill, they had not yet conducted an actual drill of their notification scheme to demonstrate their capability to augment-the onsite staff based on the 30- and 60-minute goals of Table B-1 of NUREG-0654, Revision 1. This is an open item that must be completed prior to fuel load. (461/85039-01)
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Provisions have been established to provide continuous coverage of all ~ emergency positions based on a staff relief rotation; however, the second alternates had not been trained.- This is an oper, item that must be completed prior to fuel loa (461/85039-02)
Applicant personnel selected to augment the onsite emergency organization had work experience in the general types of duties of their assigned functional areas as described by the position descriptions. The applicant's plans provided for supplementing the health physics staff beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> under accident condition The applicant's Emergency Plan listed supporting contractors and organizations and the services they could provide. A Communications Directory with phone numbers for these supporting contractors and organizations was provided in each Key Position Nuclear Emergency Response Manua Based on the above findings, the following actions must be taken to achieve an adequate program:
- An actual drill-demonstrating the capability to implement staff augmentation in accordance with the CPS Emergency Plan must be performed prior to fuel loa * All primary and alternate personnel must be trained in their emergency functions prior to fuel loa .0 TRAINING AND RETRAINING 3.1 Program Establishment Emergency training / retraining was conducted by the Clinton Power Station (CPS)
Nuclear Training Department. The scope and content of the Emergency Plan training / retraining was addressed as part of the Nuclear Training Department Manual, dated October 18, 1985. The inspector examined the content of the training program for onsite' emergency response personnel which consisted of 23 module Training and retraining were required on an annual-basis and applied to all functional areas applicable to the CPS Emergency Plan. Categorization of '
training for the emergency organization was found to be consistent with the number and designation of the functional activities performed by that organization. However, the Emergency Plan did not state _that personnel would not fill a role in the Emergency Response Organization prior to the completion
.of all required trainin The applicant had developed.several unique training courses designed to familiarize personnel with its emergency program. Personnel assigned to perform in one facility were given specific overview training describing the-organization and function of other facilities with which they interface in ,.
the course of'an emergency. This was to give them a better understanding of their function within the overall progra .
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The inspector reviewed 10 of the 23 training modules for onsite training and found them to be satisfactory and relevant to the particular emergency
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functions. Classroom lectures, hands-on~ equipment, walkthroughs, drills and exercises were included as part of the training methods. The student performance objectives were clearly stated on each lesson pla The Emergency Plan (EP) provided that CPS shall maintain at least two first aid trained individuals on shift at all time The EP also stated that CPS
" intends" to establish an on-shift Emergency Medical Technician (EMT) program and train a substantial number of personnel in cardiopulmonary. resuscitation (CPR).
Training instructor selections were based on previous experience and educational background. In addition, final candidates for a position were given a topic within their area of expertise. They were then required to develop a lesson plan and give a demonstration before training department personnel under actual classroom conditions. Each candidate was then rated on this performanc Offsite training was the responsibility of the Director - Nuclear Training, and was conducted by contract to Impell Corporation. The inspector reviewed several lesson plans and attendance records for training of emergency workers, municipal executives, dispatchers, and table top drills. Training of offsite protective action decisionmakers included the relationship between plant conditions as described in the Emergency Action Levels (EALs) and protective measures recommended by the applicant, with additional considerations as needed by the State and County agencie Section 4.2 of EPIP AP-02, Document Control, described the method for making changes to controlled documents, including the flowpath for procedure approva The Training Department was not in the flowpath. The current method for the Training Department to keep abreast of procedure changes was to informally maintain close contact with the Emergency Preparedness Program Group. Since the procedure required that all proposed changes be reviewed by the Safety Evaluation Board, if the Training Department were represented on that board (either as voter or observer), it might ensure that the Training Department would be cognizant of all proposed changes to procedures well before final implementatio Section 5.4.3.2 of the Emergency Plan stated, " fire brigade members shall participate in four refresher training sessions a year. The content of these
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sessions will be established such that a session will not be repeated for at least two years." The wording of this statement did not clearly indicate the intent of the applicant to provide refresher training at least biannuall Section 5.4.2 of the Emergency Plan stated, "It is the responsibility of the Supervisor - Emergency Planning to concur in with Emergency Preparedness Program lesson plans..." However, the CPS position description for Supervisor -
Emergency Response assigned the same responsibility to that positio Based on the above findings, this portion of the applicant's program.is adequate; however, the following items should be considered for imnrovement:
- Section 5.4.3 of the Emergency Plan should be amended to provide that no one will be assigned a position in the Emergency Response Organization prior to satisfactorily completing all required trainin * The Training Department should be represented on the Safety Evaluation Review Board when proposed changes to the EPIPs are considere * Section 5.4.3.2 of the Emergency Plan should be revised so that it clearly indicates that fire brigade members will receive all required refresher training at least biannuall * The discrepancy between Section 5.4.2 of the Emergency Plan which indicates that lesson plan concurrence is a responsibility of the Supervisor - Emergency Planning and the CPS position description w :h assigns that responsibility to Supervisor - Emergency Response,.should be reconcile .2 Program Implementation A review of the training records revealed that all required training had been completed, although some of the lesson plans were based on procedures which had not been approve Six instructors on the emergency preparedness training staff were interviewed by the inspector. Only one of the instructors had previous experience in emergency preparedness training. Of the others, two had a background in education and two were from the Navy nuclear program. Even though a majority of the instructors lacked actual experience in emergency preparedness, they appeared capable of adequately supporting the emergency preparedness training progra CPS provided an " Emergency ' Plan Overview" course which all personnel in the emergency response organization were required to complete. This course provided a description of the emergency organization and its facilities, including their interface with each othe The inspector audited one course as it was being conducted. The material was well presented and the instructor closely followed his approved lesson pla In addition to drills and exercises, CPS conducted a number of individual group sessions to walkthrough and talkthrough emergency duties. Erroneous performances were corrected on-the-spot with additional training followed by a demonstration of the proper performance. Additional findings on the effectiveness of the applicant's training program are described in Section of this repor Based on the above findings, this portion of the applicant's program is adequat .. - _ .
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4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room A review was made of selected portions of the Emergency Plan, CPS FSAR, and operator walkthroughs were conducted of Main Control Room (MCR) personnel as discussed in Section 7.0 of this report. The MCR was located as described in the Emergency Plan. One set of EPIPs was located in the MCR, and the Shift Supervisor's Nuclear Emergency Response Manual (containing selected EPIPs and documents) in the Shift Supervisor's Office. Other items maintained in the Shift Supervisor's office included: Emergency Event Recorder (tape recorder),
clipboard with Command Authority Responsibilities, General Emergency Prompt Decision-Making Flow Chart, EPZ map, and site map.
i Final positioning of documents and MCR work stations had not been accomplished.
i Discussions were conducted with MCR personnel that indicated the planned
installation of procedures and equipment would support emergency response.
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Based on the above findings, this portion of the applicant's program is adequat .1. Technical Support Center (TSC)
The TSC was located between and immediately adjacent to the MCR and the Operational Support Center (OSC), and ori the same level. Two doors in the TSC (on opposite sides) exit to corridors which lead to both the MCR and the OSC. The uroximity of the TSC to the MCR permits face-to-face interaction between T!C and MCR personnel as may be neede The TSC and OSC were contained within the same shielding an'd ventilation envelope as the MCR, thus, no separate ventilation or shielding were required. HEPA and charcoal filters were included in the ventilation syste However, neither the Emergency Plan nor procedures addressed provisions for relocating the TSC or OSC in the event they become uninhabitable. For example, a fire in the MCR that could render the MCR uninhabitable, would also render the TSC and OSC uninhabitable since they shared the same ventilation system. . This is an open item that must be corrected prior to fuel loa (461/85039-03)
The TSC was located in a single room approximately 1038 sq.ft. in area, with several satellite offices-available within the same shielding and ventilation envelope. These rooms added an additional 487 sq.ft. for a total area of approximately 1529 sq.ft. EC-01, Revision 0, CPS Eme.gency Response Organization and Staffing, indicated that 22 applicant personnel were currently assigned to the TSC,-including two communicators and two status boardkeepers. Any fut growth must be carefully considered against space limitations. Data displays, records, and communications were all located in visible and readily accessible place .
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Although not yet operational, one ENS automatic ringdown telephone line would be available for TSC communications with NRC Headouarters and with the NRC Region III Office (See Section 4.2.3). The HPN circuit was being satisfied by an unrestricted comercial telephone. Emergency Automatic Ringdown (EAR)
telephone circuits were installed connecting the TSC to the following locations: MCR; OSC; EOF (four independent EAR circuits); Backup E0F; and, Control Room Sinclato Several single phone lines were installed ts unrestricted off-premise extensions of the IP Centrex PBX and the CPS FOCUS PBX systems. One CPS FOCUS telephone and one IP Centrex telephone were planned to be located in the NPC Consultation Room, designated "For NRC Personnel Use Only." However, because part of this space was in use as a Shift Supervisor's Office, the final telephone configura-tion of the NRC office was not set up and operational. This is an open item that must be completed prior to fuel load. (461/85039-04)
Padio comunications .were available from the TSC to mobile field monitoring teams via the Emergency Pemote Control Console (ERCC), and to operations perscnnel via the Operations Remote Control Console (ORCC). A dedicated Nuclear Accident Pepcrting System (NARS) line connected the TSC to the Illinois ESDA office in Springfield and to the DeWitt County ESDA office. An autodialer which used four independent telephone circuits was located in the Secondary Alann Station for-use in informing key plant. personnel of an emergency at the Clinton Power Station. All of the TSC. EAR (ringdown) instruments were colorcoded white and were equipped with headsets. Within the TSC one CENTREX unit and one FOCUS unit were shared by the NRC and by Illinois DNS, although NUREG-0696 specified NPC use onl Bookshelves were conveniently located and contained copies of Technical Specifit.ations, a full set of CPS procedures, the FSAR, the Energency Plan and Emergency Plan Implementing Procedures, the Nuclear Emergency Response Manual, various Illinois Emergency Preparedness publications, a Control Room Operator's Handbook, and a Core Damage Mitigation Handbook. Piping and Instrumentation Drawings (P&ID) were located in the adjacent OS The supply cabinet was inspected and found to contain, in general, a good cross-section of administrative and other support materials. However, no up-to-date inventory was available, and no official listing of supplies to be maintained was available. Without such a list, there was no way to conduct meaningful periodic inventories, nor was there any way to adequately control what.was, as well as what was not, to be kept in the locker. This is an open item that must be completed prior to fuel load. (461/85039-05)
Logs of periodic comunication checks were reviewed and found to be adequate and current. Status boards were located on the TSC walls and included personnel status, plant status, key events, emergency classification, OSC Team information, near area and 10-mile radius maps, plant . diagrams, trend plots, and protective action recomendation status. Status boards were located on the upper portion i of the walls and appeared to be readily readable.
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The Spectral Analysis, ALARA, and Recordskeeping System (SAARS).or (SR) was installed in the TSC and was operable. The Area Radiation Monitoring / Process Radiation Monitoring (ARM /PRM) (EBERLINE) System was installed but not operable (although it was in startup testing). The Performance Monitoring System / Display Control System (PMS/DCS).(which included SPDS) was installed but was not operable. The completion of training of personnel on these systems is an open item that must be completed prior to fuel load. (461/85039-06)
The power supply to TSC lighting and receptacles was from a class 1E source (essential bus power). The power supplies to the lighting and receptacles for the Results Records Room and.the NRC Consultation Room were powered from nonsafety power sources. Emergency lights were located in the TSC overhead drop ceilin Based on the above findings, the following actions must be taken to achieve an adequate program:
-* The Eme.rgency Plan and/or EPIPs must address relocating the TSC and OSC if they become uninhabitable. This must be completed prior to fuel loa * Installation of the telephones planned for the TSC's NRC Consultation Room must be completed prior to fuel loa * Develop and maintain an official controlled inventory list for the supply cabinet in the TSC containing administrative and support material; including a provision for periodic inventories. This must be completed prior to fuel loa * The Area Radiation Monitoring / Process Radiation Monitoring (ARM /PRM)
system and the Performance Monitoring System / Display (PMS/ DES) system (data acquisition systems) must be operable and operators trained in its use prior.to fuel loa t .1.1. 3 Operational Support Center (OSC)
A review was made of Section 3.1.3. of Revision 5 of the Emergency Plan, EPIP FE-02, Revision 0, OSC Activation, and EPIP FE-06, Revision 0, Emergency Communications Equipment. ' The OSC was not located as specified EPIP FE-0 This is an open item that must be completed prior to fuel loa (461/85039-07)
The OSC was located adjacent to both the Main Control Room (MCR) and the Technical Support Center, and was within the MCR HVAC envelope. The OSC was located in the area originally intended for the CPS Unit 2 Control Room and therefore pro'vided adequate protection from direct radiation and airborne contaminants. No provisions had been made to establish a backup OSC in the event the primary OSC becomes uninhabitabl This is discussed further in Section 4.1.1.2, and is an Open Item which must be corrected prior to fuel loa (461/85039-03)
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The general idea for activating the OSC was to require all Emergency Response Organization Personnel, not otherwise assigned, to report to the OSC. Those persons not naeded to respond to the emergency situation would be subsequently released. Discussions with the OSC supervisor and others, and experience from previous crills, led the inspectors to conclude that the OSC would be large enough to accommodate an early large influx of personnel (120-150 people).
The OSC was acceptably arranged from a functional basis, i
The OSC was equipped with a closed circuit, automatic ringdown telephone system with the MCR, the TSC and the EOF, denoted EARS. There was also the
- plant phone system, FOCUS, and both fixed and portable radios, as well as th Plant Gaitronics system. There were two EARS phones whose labels indicated that they were dedicated to Radiation Protection (RP) personnel. This was an error because there should have been only one. One Operations (MCR) EARS phone, one RP EARS phone, and one FOCUS phone were inoperable. This is an open item that must be completed prior to fuel load. (461/85039-08)
Based on the above findings, the following actions must be taken to achieve an adequate program:
- Revise EPIP FE-02, Operations Support Center Operations, to reflect the correct location of the OSC prior to fuel loa * Establish and maintain operability of telephone systems in the OSC prior to fuel loa .1.1.4 Emergency Operations Facility (EOF)
The E0F was located outside the station protected area fence approximately 1500 feet east of the Main Control Room (MCR) and the Technical Support Center (TSC). The location was as specified in the Emergency. Plan. The E0F was contained within a metal Butler tiuilding, the EOF area being further enclosed by a perimeter wall of eight inct thick reinforced concret The E0F was composed of a number of subareas, as follows: (1) personnel entrance /
monitoring / holding area (controlled by a guard when the EOF was activated);
(2) a Security Office, located at the EOF entrance (building security and fire protection systems were monitored from this office); (3) a personnel monitoring and decontamination room, with shower facilities, storage for contaminated clothing, and clean clothing; (4) a storage area for radiation monitoring equipment, kits, instruments, supplies and clothing; (5) a Radiation Protection Office provided space for administrative support of personnel _ monitoring, decontamination, and laboratory analysis; (6) Environmental Sampling Analysis i (ESA) Laboratory, used'to analyze samples collected by field monitoring teams; (7) a sample Counting room located adjacent to the ESA Laboratory; (8) a sample storage room provided storage for radioactive samples; (9) a document room adjacent to the central EOF Decisionmaking Area; (10) a 250 square foot office reserved for NRC personnel; (11) the Emergency Managers' Office; (12) EOF Conference Room; (13) Offsite Dose Calculation Room; and (14) Decisionmaking Area-(1770 sq.ft.).
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Total EOF working space was approximately 3350 sq.ft. , which appeared to be fully adequate for assigned personnel. No space was provided for News Media due to the proximity to the plant. However, appropriate space and facilities were provided for State / Local representatives and an owner's representativ .The EOF was equipped as stated in the Emergency Plan and the Implementing Procedures. Equipment and supplies were available as follows: E-120 or 520 GMs were provided in the Decon Kits and Field Team Kits. RM-20 or RM-14 Friskers were included in the Decon Kits. R0-2A lon Chambers were also included in the Field Monitoring Kits. High range gamma detection was met by an Area Radiation Monitor located in the Decisionmaking Area of the EOF, with an upper range of 10 R/HR. DC air samplers were provided for Field Teams, and a Constant Air Monitor (CAM) was located in the Decisionmaking Area, to sample for particulate, iodine, and noble gas activit Sample counting equipment was located in the Counting Room, with additional sample counting instruments (NaI) located in the Field Monitoring Kits. Personal dosimetry in the form of TLDs were available for issue, along with an E0F badge, on entering the Decisionmaking Area. There was no provision or plan for issuing low or high range direct reading dosimeters to EOF personnel other than to Field Teams (1.5R). Check sources were provided in the Field Team Kits and will be available in the Laboratory / Counting Room are The Emergency Plan, Implementing Procedures, State and county emergency plans, the Final Safety Analysis Report (FSAR), and the Environmental Report were available in the E0F, as was the CPS Evacuation Time Estimate Study. A 10-mile and a 3/4-mile site map were available in the Decisionmaking Area; a 3/4-mile and a 10-mile map with preselected sampling points were located in the Dose Calculation Room. Selected station drawings were included in the Document Room. There were no models, plant photos or layouts available in the EOF for use in job planning and training for reentry under accident condition Status boards were provided in the E0F as follows: (1) HVAC System Status; (2) Plant parameter trends; (3) Critical parameter status; (4) Problem board; (5) Radiological parameters; (6) 10-mile sector map; (7) 3/4-mile sector map; (8) Two boards combining radiological release, meteorological, and dose rate projection status; (9) Key event board, including event classification, command authority status, and protective action recommendations made; and a sign-in/ staffing boar Additional status boards were located in satellite offices as neede Administrative supplies and miscellaneous supplies were located in a cabine However, no official or controlled inventory list was available for the contents of the cabinet. This is an open item that must be completed prior to fuel load. (461/85039-09)
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First Aid and Decon Kits were kept in the E0F Decon area. Both 12-hour and 24-hour clocks were located at each end of the Decisionmaking Area. Other clocks were located in the satellite offices and spaces. Meteorology data was available via the CRT display in the Offsite Dose Calculation Roo Respirators, protective clothing, and other personnel protective equipment were availabl . _
t Although not yet operational, one ENS line will be available for communications to NRC Headquarters and to the NRC Region III Office. As a backup to the' ENS phone, an unrestricted commercial telephone network was available for us This is discussed further in Section 4.2.3 of this repor The HPN circuit was being satisfied by a commercial, unrestricted telephone. Emergency
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Automatic Ringdown (EAR) telephone circuits were installed connecting the E0F to the following locations: TSC (3 EAR circuits); JPIC-(2 EAR circuits); MCR; and, Control Room Simulato Additionally, an EAR circuit connected the E0F Offsite Dose Calculation Room to the TSC. Single phone lines were installed as unrestricted off premise extensions of the IP Centrex PBX and the CPS FOCUS PBX system Several Centrex and FOCUS telephone circuits were available in the EOF. An Emergency Remote Control Console (ERCC) located in the Offsite Dose Calculation Room
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provided communications with mobile field monitoring teams and with the TS The Maintenance and Operations Remote Control Consoles (MRCC/0RCC) located in the Decisionmaking Area provided communications with operations and maintenance personnel. A NARS circuit connected the E0F with Illinois ESDA, DeWitt County ESDA, and other governmental agencies. Two remote central office telephones were located in the EOF. One was in the NRC office, designated "For NRC Use Only," and the other was located in the Decisionmaking Are A total of six lines were available on four telephones for NRC us The Spectral Analysis, ALARA, and Recordskeeping System (SAARS or SR) was installed in the EOF and was operable. The Performance Monitoring System /
Display Control System (PMS/DCS) was installed but not operable. The PMS/DCS i must be completed and personnel trained in its use prior to fuel loa This open item is discussed also in section 4.1.1.2 of this report. (461/85039-06)
i E0F shielding was capable of attenuating 0.7 MEV gamma rays by at least a
- factor of five. An EOF HVAC system provided a filtered air flow to protect against airborne particulate radiation and maintained a posiuve pressure inside the EOF. Outside air was passed through a HEPA filter. Only the Personnel Holding Area was outside the described HVAC boundary. . Within the
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EOF, in the Document Control Room, was located an area ' radiation monitor (gamma) and a Constant Air Monitor (CAM) to sample ventilati'on air for radioactive airborne particulates, radiciodine, and. radioactive noble gase Electrical power to the EOF was provided from a 138 KV transmission line via the construction substation and 12 KV Construction Loop. Power supply reliability was estimated (by plant personnel) to be in excess of 99%.
A Backup Emergency Operations Facility (BEOF) was located in the city of Decatur, Illinois, approximately 20 miles from the plant site. The BEOF would perform the functions of the EOF in the event the E0F were unavailable. The BEOF~ occupied a 1000 square foot room, with an additional 1400 square feet of space available if needed. Because of the distance from CPS, no radiation protection or monitoring was needed. There also was no reasonable danger of flooding from streams or river ,
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The BE0F was inspected and found to be adequate with respect to power, communications, data receipt / display, and document availability. Additionally, 4 IPC Headquarters personnel in Decatur would be available to augment normal EOF staff personnel as neede '
Based on the above findings, the following action must be taken to achieve an j adequate program:
- Develop and maintain an official controlled inventory list for the EOF cabinet containing administrative and miscellaneous supplies, including a provision for periodic inventories, prior to fuel loa In addition, the following item should be considered for improvement:
- A set of selected models and/or color photographs and layouts of key areas within the plant should be prepared and maintained for use in job planning / training for re-entry under accident and/or accident recovery conditions.
4.1. Post-Accident Coolant Sampling and Analysis
! The applicant was in the processuof installing a Sentry System Model-B Reactor Coolant and Containment Atmosphere Sampling and Analysis syste The sampling panels and grab samplers were located in the Diesel Generator Building, within about 100 feet of the Chemistry Laboratory area, and on the same level (737').
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The PASS was evaluated and a formal report was. forwarded to the NRC Licensing Branch under cover letter dated April 19, 1985. Table 1 of the April 1985 i
report indicated that the maximum total time for sampling and analysis would be 165 minutes. Conversations with_ Chemistry personnel interviewed indicated that the 165 minute figure may be somewhat optimistic, but actual sampling and analysis cannot be determined until the system was fully operationa '
The Chemistry Laboratories were not supplied with emergency power, but such power should not be required because of the 3-line, continuous loop nature of outside power supplies to CP Based on the above findings, this portion of the applicant's program is adequat .1.1.6 Post-Accident Containment Air Sampling and Analysis
. The system described in Section 4.1.1.5. would also be used to provide diluted
or undiluted samples of containment air. The analysis of the sample, as explained in Section 4.1.1.5, could most likely be accomplished within three hours per the formal report submitted to the NRC Licensing Branch under the cover letter dated April 19, 198 Based on the above fin'ings, d this portion of the applicant's program is adequat .
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4.1. Post-Accident Gas, Particulate, and Radioiodine Effluent Sampling and Analysis The applicant was in the process of installing wide range gas monitoring systems to sample and monitor the HVAC vent (plant stack) and the Standby Gas Treatment Facility (SGTF) off gas system. These. monitoring systems, supplied by Eberline, were designed to allow the collection of grab samples, if neede The grab sample ports were in place, but the equipment needed to actually
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collect gas samples, such as connectors, sample containers, sample shielding, handling tools, and provisions to return the uncollected portions of sampled gas streams to the sampling lines, had not yet been developed. This is an open item that must be completed prior to fuel load. (461/85039-10)
The HVAC and SGTF grab sampling ports were located on the 762' level in the Diesel Generating Building, in an area which was rather congested with plant equipment, piping, ducts and structural supports. The ability to safely collect and transport high activity level samples from these areas had not been determined and tested. This is an open item that must be completed prior to fuel load. (461/85039-11)
There were no area Radiation Monitors in the immediate vicinity. The panels themselves were equipped with flashing light alarms which should indicate high activity levels in the sampling lines, but the ambient radiation levels were not monitored. The applicant intended to deal with this situation by making it a procedural requirement that chemistry technicians, when acquiring samples at these locations, were to be accompanied by Radiation Protection Personne Pre-established and approved "no go" radiation levels should also be establishe When the overall system becomes operational, sampling should be completed in less than one hour, unless access or sample transportation problems develo Concerning sampling and analysis procedures, as generally. spelled out in EPIPs, RA-09, Post-Accident Sampling, RA-04, Stack Effluent Sampling and RA-11, Stack Effluent Analysis, the general approach of the applicant was to
'use routine sampling and analysis procedures, modified to reflect emergency requirements and conditions. This would include personnel protection requirements. The normal operation procedures for sampling and analysis should be CPS 9954.01 for gas and tritium analyses, and CPS 9954.02 for particulate and iodine analyses. These two procedures were to be modified to reflect the emergency requirements and be produced as a separate procedure, CPS 1890.36. This procedure would deal with handling high levels of radioactivity. At the time of the appraisal, none of these procedures, normal operations or emergency, had been completed. This is an open item that must be completed prior to fuel load. (461/85039-12)
The Chemistry Laboratories were well equipped. Current permanent staff was very nearly at full complement. Training was underway and specific instrument procedures were availabl .-. . .
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Based on the above-findings, the following actions must be taken to achieve an adequate program:
- Equipment (sample containers, shielding, handling, and transport equipment)
needed.to enable sampling at existing grah sample ports for the HVAC vent and SGTF offgas system must be developed and tested prior.to fuel loa * Accessibility to and from the HVAC vent and SGTF offgas system sample ports, while using all necessary equipment, must be verified prior to-fuel loa * Procedure CPS 1890.36 must.be completed and approved prior to fuel loa .1.1. 8 Offsite Laboratory Facilities
.The applicant had established procedures to provide offsite (out-of plant)
laboratory facilities for offsite monitoring and analysis in the EOF located approximately 1500 feet east of.the Main Control Room. The E0F Environmental Sample Analysis Laboratory contained dedicated emergency instruments which included a high purity Germanium Detector and a Phoswich System. These
, instruments were in place, but the Germanium Crystal had not arrived and the Phoswich System power supply had been returned to the vendor for repair. The operability of this equipment is an open item that must be completed prior to fuel load. (461/85039-13)
As a backup, the applicant had initiated a contract with the U.S. Department of Energy at the Oak Ridge National Laboratory to provide Post-Accident
- Analytical Servic Based'on the above findings, the following action must be taken to achieve an
- . adequate program
- Complete the installation of the Germanium Detector and make necessary repairs to the Phoswich System located in the E0F Environmental Sample Analysis Laboratory. This equipment must be operational prior to fuel loa i
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4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas A review of-revision 5 of the Emergency Plan, Saction 4.3.1.3, established assembly areas at the parking lot outside the Gate House and at the " Change Shack" near the E0 This was a change in the assembly areas from those stated in Revision 4 of the . Emergency Plan and Revision 0 of EPIP EC-03,
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Non-Essential Personnel Evacuation. Although the plan had been revised to reflect these changes, EC-08 still referred to the use of the Permanent Warehouse and the Service Building as assembly areas._ This is discussed further in Section 5.4.3.1 of this repor Personnel evacuation reassembly areas were to be established at IPC Service Area Offices in Bloomington, Champaign and Decatu ;
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Nuclear Overview Training, prior to the time of the appraisal, had incorporated the old assembly area scheme. During the appraisal, such training made mention of the " Change Shack" assembly area, but not of the main gate parking lo This is an open item that must be completed prior to fuel load. (461/85039-14)
The inspectors were informed that no provisions had been made to equip or supply the assembly or reassembly areas with radiation protection instrumenta-tion or provisions for decontamination facilities, to provide plant evacuation route signs, or to identify the proposed assembly areas by signs. EPIP EC-10, Personnel Accountability, addressed obtaining the concurrence of Radiation Protection (RP) personnel in designating evacuation routes, and in having RP personnel assist in containment evacuation. However, no mention was made of monitoring / decontamination operations at the assembly areas, nor were there any personnel monitoring / decontamination procedures listed under EPIP EC-08, Section 5.0, " References." This is an open item that must be completed prior to fuel load.~ (461/85039-15)
Based on the above findings, the following actions must be taken to achieve an adequate program:
- Training lesson plans, for both Emergency Response and nonessential personnel, must be changed to reflect actual assembly and reassembly areas and evacuation routes, and all plant personnel retrained. This must be completed prior to fuel loa * The assembly and reassembly areas and evacuation routes must be identified and equipped with appropriate communication and protective equipment, including provisions for decontamination. This must be completed prior to fuel loa .1.2.2 Medical Treatment Facilities The applicant's onsite first-aid / medical treatment facility was examined by the inspectors. The facility was located in the Service Building on the 737' level, directly across from the Radiation Protection (RP) are The facility had access, through the Decontamination Area, to the mid-line corridor of the power bloc This access would accommodate a stretche The facility, although somewhat small, was fully operational. First Aid and minor medical matters responsibilities were shared with another onsite first-aid station operated by the plant construction contracto The builders' first-aid station will close down when construction is essentially complet The adjacent decontamination facility was. stocked and was equipped with an operable, calibrated personnel contamination survey instrument. Communications in the facility consisted of a Gaitronics phone, y1 ant telephones, and a portable radio on the operations frequency. Additional dosimetry capabilities and KI were available in the adjacent RP are *
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Procedures for medical first~ aid treatment were contained in EPIPs RA-08, Radiological Injuries; RA-04, Personnel Monitoring and Decontamination, and for normal first-aid in NP&S 4.01, First Aid Operation The EPIPs were approved, but the normal operations procedure was no Based on the above findings, this portion of the applicant's program is adequat .1.3 Expanded Support Facilities The applicant had designated work facilities / resources available for corporate, contractor and'nonapplicant augmentation personnel in the Emergency Operation Facility (EOF) located onsite. This building contained approximately 20,000 square feet of usable space in addition to the designated E0F area. Most corporate personnel required in the event of an energency had designated space in the EOF and a substantial number of contractor and nonapplicant augmentation personnel could be positimed in offices and classroom space adjacent to the EO An adequate number of telephones were located in the adjacent offices to the EOF and, in addition, there were telephone jacks located in the. classrooms which could be utilized in the event of an emergenc Based on the above findings, this portion of the applicant's program is adequat .1.4 Joint Public Information Center (JPIC)
The JPIC was located in Decatur, Illinois, approximately 20 miles from the CP The facility had ample office space for public information officers (PI0s) and their staffs and a general assembly room large enough to accommodate an estimated 200 media personnel. A minimum of 20 telephones were available for use by the media. The general assembly room was designed to facilitate video camera work and had a public address system. Provisions for security and the separation of the media from the'PI0s had been made. Informational materials available to the press included the following: public information brochures; press kits with' explanations on radiation, emergency planning, insurance, etc.; and schematic drawings of the plant and safety system Communications with the EOF were via voice activated telephone, company microwave telephones, and commercial telephones. Copy machines, a facsimile telecopier, and a word processor connected by modem to the E0F were availabl A closed circuit television monitor was available from the general assembly room to the PIO staff area. Audio from the general assembly room was trans-mitted to a remote corporate center where public broadcasts were monitore ,
The JPIC would be well staffed by approximately 72 Illinois Power personne The facility had a lunch room and parking space for 100 cars. No contingency, overflow plans had been made. The electric supply to the JPIC had no backu Based on the above findings, this portion of the applicant's program is adequat . _ - - _ _ _ - - _ . . -- - _ -
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4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2. Emergency Kits' and Emergency Survey Instrumentation
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The applicant maintained a total of 18 emergency kits with dedicated equipment and supplies for emergency conditions both onsite and offsite. The emergency kits were pre positioned in accordance with the Emergency Plan and EPIP FE-05, Emergency Kits, and were located in the OSC, E0F, Radiation Office in the Service Building, Craft Security Portal, Radiation Protection Storage Area in the E0F, Service Building First Aid Office, Gatehouse, Backup EOF and Emergency Room at the John Warner Hospital. The contents of the positioned emergency kits were checked against the kit, inventory sheets and found to be complete.
c The radiological instrumentation was operable, instrument calibration was
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current and instrument check sources were included in the kit The contents of the emergency kits were inspected, inventoried and operationally j checked at least once per calendar quarter and after each use, or when the seal
- was discovered broken. After each emergency kit was inventoried, a copy of the completed inventory sheet was placed in the emergency kit. Written procedures
. for the calibration of portable radiation detection instrumentation were i contained in Clinton Power Station Procedures 7911.10, 7911.12, 7911.13, 7911.15, 7911.18, 7911.21, 7911.23 and 7911.25. Instrumentation was available in the offsite kits capable of measuring Iodine concentrations of at least 1.0 E-7 uCi/cc under field conditions and particulate activities in air of
! 1.0 E-9 uCi/cc Cs-137 equivalent without regard to background radiation.
- Portable Ion Chamber instruments and GM survey instruments with Beta / Gamma
. distinguishing capability were contained in the offsite kits.
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The emergency kits located in the OSC and E0F contained sufficient numbers of instruments / supplies to equip.the number of team members projected to be needed during an Emergency. Included were high and low-range survey instruments, high and low-range personnel dosimeters, and TLDs and supplies to equip survey, re-entry and repair teams. The OSC and hospital kits did not include specific
, radiation monitoring dosimetry for extremity monitoring. This is an open item
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that must be completed prior to fuel loa (461/85039-16)
In plant capability for detecting airborne iodine in the presence of noble gases was accomplished by the Process Radiation Monitoring Constant Air i Monitors which provided ambient air monitoring for detecting airborne particulate radiation, iodine, and noble gases in selected station areas and
- cubicles. This monitoring system was not completely tested, calibrated an operational at the time of the inspection. This is discussed further in Section 4.2. c
. Based on the above firidings, the following action must be taken to achieve an [
adequate program:
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- Provide' extremity dosimetry for the OSC and hospital kits prior to fuel load.
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4.2.1.2 Area and Process Radiation Monitors The area and process monitoring systems described in the applicant's Emergency Plan were reviewed to determine if the monitoring systems were capable of providing the information required to support emergency response. The area and process monitoring instrumentation consisted of: Constant Air Monitors (CAM) which provided ambient air monitoring for detecting airborne particulate radiation, iodine and noble gases in station areas or cubicles; Area Radiation Monitoring (ARM) instruments which provided local visual and audible alarm if their high radiation set points were exceeded; Process Radiation Monitors (PRM) provided. monitoring of Station HVAC exhaust, standby gas treatment, pre- and post-treatment air ejector offgas, station service water, shutdown service water, liquid radwaste discharge effluent and component cooling water; and containment high range monitor Installation of all of the area and process monitors and the high range containment and drywell monitors was nearing completion; however, acceptance testing, calibration'and determining the operability of the monitoring systems had not been complete Internal correspondence provided by the applicant specified that all area and process radiation monitors would be completed and operable by five percent power with the containment and drywell high range radiation monitors completed and operable prior to fuel load. All of the area and process monitors and the high range containment and drywell monitors had readouts in the Main Control Room and all of the ARMS had integral battery power backup which provided eight hours of operation. Efficiencies had been determined for all detector The instrumentation provided was sufficient to determine appropriate EAL Based on the above findings, this portion of the applicant's program is adequat .2.1.3 Non-Radiation Process Monitors The non-radiation process monitors described in the applicant's plan and procedures as being relied upon for emergency detection, classification and assessment were incorporated in existing instrumentation located in the Main Control Roo The. process monitors inspected included: reactor temperature, pressure and core flow; reactor isolation cooling; feedwater flow; suppression pool level and bulk temperature; drywell level, pressure and bulk temperature; containment pressure and temperature; control room ventilation intake chlorine alarm; and seismic monitor The process monitor readouts listed above were located in the Main Control Room and were readily observable. The instrumentation provided was sufficient to determine appropriate EAL Based on the above findings, this portion of the applicant's program is adequat ,
4.2.1.4 Meteorological Instrumentation The applicant's onsite meteorological measurements system consisted of an instrumented tower located approximately 850 meters south-southeast of the containment building. This system provided the basic parameters (i.e., wind speed, wind direction, and an indicator of atmospheric stability) necessary to perform dose assessmen Specifically, wind speed and direction information was available from the 10- and 60-meter levels, and vertical temperature difference was computed through matched thermistors at the 10- and 60-meter levels. Additional meteorological measurements included dry bulb temperature at the 10- and 60-meter level, dew point temperature at the 10-meter level, and precipitation near the surface. The meteorolocical measurements prograr
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was modified in 1981 from the program used to provide data for the accident assessments included in the FSAR. The installation and calibration of this modified system was completed during November 1982, and its satisfactory operation was verified by IPQA surveillance in January 1983. This closes Unresolved Items 461/81-02-03 and 462/81-02-0 Because of some questions concerning accuracies of meteorological measurements and recent changes in the telemetry system for transferring data, there was no confirmation that the overall system accuracies for the basic parameters defined above met the specifications for both digital and analog measurements presented in ANSI /ANS 2.5-1984 and Regulatory Guide 1.9 For example, a report by Stone & Webster Engineering Corporation, " Evaluation of the Clinton Power Station Meteorological Monitoring and Assessment System," dated May 1983, gave the accuracy of the temperature difference between the 10- and 60-meter levels as + 0.36 degrees F. Regulatory Guide 1.97 requires this to be + 0.30 degrees F. This is an open item that must be completed prior to fueT load. (461/84039-17)
The applicant had assumed full responsibility for operating, maintaining and calibrating the meteorological measurements system. Operability checks of the data acquisition system were being made daily in accordance with the provisions of the plant technical specification However, no check on data reasonable-ness was performed, and no such checks were anticipated, although the computerized Eberline system could provide automatic data-checking protocol to flag suspect data. An inventory of spare parts was available at the site; however, equipment had remained inoperable for one week or more before being returned to service. Written procedures for calibrating the meteorological measurements system were availabl The meteorological measurements system was calibrated every six months. However, information was not available for data recovery since the system was verified operational in 1983. For the period of record included in the FSAR (4/14/72 - 4/30/77), data recovery exceeded 90 percen Considering the relatively long return-to-service times indicated in the maintenance records and the lack of-data recovery records since 1983, there was no assurance that data availability goals were being met. This is an open item that must be completed prior to fuel loa (461/85039-18)
The Eberline system will have 10-minute, 1-hour, and 24-hour averages of the following meteorological data available for display in the-Control Room, TSC,
.and EOF: wind speed and direction at the 10- and 60-meter levels; temperature difference between the 10- and 60-meter levels; dry bulb temperature at the
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10- and 60-meter levels; and, dew point temperature at the 10-meter leve Precipitation data will not be available through the Eberline system. Analog displays of all of the above parameters (including precipitation) were available in the Control Room, although 10-minute averages of parameters displayed on the multipoint recorder were somewhat difficult to determin No onsite backup or redundant measurements at the 10-meter level were availabl The National Weather Service (NWS) station at Springfield was identified by the applicant as a source of low-level backup meteorological data. However, the applicant had not demonstrated that data from the NWS station at Springfield adequately represented the Clinton site in real-time for use as backup information. This is- an open item that must be completed prior to fuel 1oa (461/85039-19)
Additionally, information available from the NWS, such as current observations,
forecast conditions, regional airflow and precipitation patterns, general weather, and severe weather was not reflected in the dose assessment procedures and considered in the development and implementation of protective action recommendations. This is an open item that must be completed prior.to fuel load. (461/85039-20)
Information on severe weather. occurrences in the vicinity of the site was currently available through the load dispatcher. When severe weather situations existed, the load dispatcher was required to notify the plant per Section 4. of IPC Power Production Procedure 2.1 The applicant's automated offsite dose calculation methodology to be available through the SR computer system will include a-relatively sophisticated plume-segment atmospheric dispersion model driven by data from the onsite meteorological measurements program. However, the model was not fully ~
operational at the time of the appraisal and the model was still being verified by the applican Complete documentation on this model should be made available for staff review. Also, the Emergency Plan and FSAR should be modified to reflect implementation of this model. Implementation of the model should be checked during drills and exercises to determine if model results will be available in'the appropriate time period for integration into the protective action decisionmaking proces The procedure should accurately reflect meteorological information available (e.g., sigma theta is not calculated), averaging period, and hierarchy'for substitution of missing informatio The manual offsite dose calculation procedure, EPIP RA-01, Manual Radiological Dose Assessment, was cumbersome and in places inaccurate with respect to input-of meteorological information. For example, the atmospheric stability indicator, vertical-temperature difference, was'to be determined by subtraction of two dry bulb temperatures which did not satisfy the accuracy specification
.for this. parameter. An error in the determination of atmospheric stability could result in significant errors in estimates of atmospheric stability with-corresponding errors introduced into the dose calculation. In addition, Attachment 7 of-EPIP RA-01 was incomplete in that no stability class was given for nighttime wind speeds less than 4.5 mph. As-with the procedure for automated dose. calculation, this procedure should accurately reflect meteorological information available, averaging period, and hierarchy for
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substitution of missing information. Also, uncertainties in meteorological data during either' variable conditions or through the use of off site information should be appropriately reflected in the protective action decisionmaking process. This is an open item that must be completed prior to fuel load. '(461/85039-21)
Based on the abcve findings, the following actions must be taken to achieve an adequate program:
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- Confirm that the operational meteorological measurements programs meet the system accuracy specifications stated in ANSI /ANS 2.5-1984 and
. Regulatory Guide 1.97.for wind speed, wind direction and vertical temperature difference. This must be completed prior to fuel loa * Confirm that.ieteorological data availability goals can be achieved during plant operation prior to fuel loa * DemonstrbtethatmeteorologicaldatafromtheNWSstationatSpringfield adequately represents the Clinton site in real-time for use as backup information. (Installation of onsite backup or redundant sensors at the 10-meter level would be an adequate alternative to the use of Springfield data). This must be completed prior to fuel loa '
- Incorpora$e the specific methodology and responsibility for acquisition of NWS forecast information and integration of this information into protectivefa,ction recommendations and dose assessment prior to fuel loa , . ,
- Correct inaccurate and incomplete references to meteorological information (i.e., determinatien of atmospheric stability) from EPIP RA-01, Manual Dose Assessment, and identify averaging periods that are to be used in the calculations. This must be completed prior to fuel loa In addition, the following items should be considered for improvement:
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- A routine quality control check, either manual or automated, should be implemented for meteorological dat * The return-to-service. times for replacement of inoperable meteorological equipment should be reduce * Procedures for obtaining and using backup or offsite meteorolegical data should be clarified and simplified to reflect the uncertainties in these data sources in the dose assessment and protective action decisionmaking proces * The plume-S$gment atmospheric dispe'i'i n/< il used for dose assessment should be documented and verified, t
- 4. Protective Clothing i
Stores of protective clothing reserved for emergency use were maintained by the applicant. The quantity of clothing maintained appeared to be adequat The protective clothing reserves were temporarily stored in a secured area in
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the Unit II Crossover Room. Prior to fuel loading the applicant planned to place the stored protective clothing in designated areas of the plant in accordance with Emergency ~ Plan, Chapter 3.2.10.1 and Table 3-8. This is an open item that must be completed prior to fuel load.- (461/85039-22)
Additional protective clothing was located in the OSC and E0F and in dedicated Emergency Decontamination Kits. The stores in each of the facilities would be accessible under emergency condition Based on the above findings, the following action must be taken to achieve an adequate program:
- Protective clothing supplies now stored in the Unit II Crossover Room must be placed in designated areas of the plant in accordance with Emergency Plan, Chapter 3.2.10.1 and Table 3-8 prior to fuel loa .2.3 Emergency Communications Equipment The applicant had five regular communications systems, besides the commercial telephone, which may be used as part of emergency communications equipmen Four additional systems were dedicated to emergency communication The following systems were part of regular communications which were also used in the event of an emergency:
(1) A fully operational pager system with 37 pagers assigned to key plant personnel and a. transmitter at the applicant's plant site was availabl Paging was effective for locations as far away as Champaign, Decatur and Bloomingto (2) A microwave system was incorporated into the plant telephone system. It had 40 microwave lines which provide station-to-IPC headquarters, and station-to-station interoffice communications. The system had a liquid petroleum generatcr, as weil as battery backup power. It was in full
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servic (3) A two-way radio system provided base-to portable routine communications over three frequencies. Two remote control stations were hardwired from
~the E0F and TSC to the transmitter, and thus also served as base stations. -The system was in full servic (4) The sound powered telephone system, which was not yet in service. It was described in the applicant's Emergency Plan as' consisting of telephone jacks hardwired to one of two panels. One panel.was located at the Radwaste Operations Center and the other at the Main Control Room. This system will be utilized for continuous communications over long periods during an emergenc (5) .The Public Address-System (Gaitronics) was not yet in service. This is an open item that must be completed prior to' fuel load. (461/85039-23)
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The following dedicated systems were part of emergency communications:
(1) The~ Nuclear Accident Reporting' System (NARS) telephones were in service and located in the Main Control Room (MCR), the Technical Support Center (TSC), the Emergency Operations. Facility (EOF) and the Backup E0F. The applicant had the option of direct contact with the State of Illinois-or
, direct simultaneous contact with both the State and county with this
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syste (2) The Emergency Automatic Ringdown directly connected the MCR-TSC, MCR-E0F, MCR-0SC, TSC-EOF and TSC-0S Provisions had been made to shift the power. source to the emergency 1E bus in the event normal power was interrupte This was to ensure uninterrupted service during an emergenc (3) The Emergency Radio System maintained dedicated emergency transmission frequencies which may be operated by the base station and remote control stations located at the MCR, TSC and EOF.
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(4) Specific station alarms for containment evacuation, plant evacuation, fire, etc. were not.yet in serv ~ ice. This included those alarms specifically designed for high noise areas and low visibility area This.is an open item that must be completed prior to fuel loa (461/85039-24)
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(5) The NRC Emergency Notification' System (ENS) was part of the emergency communications system but was not yet in service. General Telephone was installing lines at this time and expected to have the system in service by December 1, 198 In the interim, the licensee had an unrestricted commercial telephone dedicated to act as the interim EN Based on the above findings, the'following actions must be taken to achieve an
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adequate program:
- The public address system must be completely installed and operational prior to fuel loa * All emergency alarms must be completely installed and operational prior to fuel loa . Damage Control / Corrective Action and Maintenance Equipment and Supplies Equipment and supplies associated with damage control corrective action and maintenance were located in various areas, all' reasonably proximate to the OSC. Mechanical, maintenance material was kept in the 727' level Maintenance
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Shop, three levels below the OSC. The 762' level Radwaste area on the forth floor stored the electrical and C&I materia Fire Brigade equipment was located in the 737 level Radwaste and Turbine Building, and Health Physics and Chemistry material was kept in the Radwaste Storeroom. These spaces were used to store. ready service tools and material, consumables and the lik Large items and high-value/pilferable items were, as a rule, stored in'the 25-
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warehous Except for the warehouse, the storage areas described were within a maximum of three levels distant from the OSC and within the same building complex, i.e., within a five minute wal Not all equipment was yet in place because construction personnel had not completed the planned storage areas. A. general list of planned equipment to be located in the OSC was as follows: fire brigade equipment; radios; plugs; equipment to rack out breakers; band-it kits; flashlights; tool box and tools; and a multimeter, although no official list had been developed to specify precisely what emergency response equipment and material should be located in the OSC and/or other ready-service locations. The stocking of the equipment in the storage areas is an open item which must he completed prior to fuel load (461/85039-25).
An inventory list should be developed and officially controlled; and periodic inventories conducted using this lis Examples of additional items which were not included on the list provided, and which should be considered for inclusion were the following: fire suits; acid suits; steam suits; respiratory equipment (including ancillary support equipment); protective clothing; portable lighting; portable radiation monitors; Polaroid cameras and film; rubber mats; and, Wiggins voltage tester Based on the above findings, the following action must be taken to achieve an adcquate program:
- Complete the stocking, organization, and inventories of damage control /
corrective action equipment and supplies prior to fuel loa In addition, The following item should~be considered for improvement:
- The following items should be considered for inclusion in damage control /
maintenance kits: fire suits; acid suits, :: team suits; respiratory equipment (including ancillary support equipment); protective clothing; portable lighting; portable radiation monitors; Polaroid cameras and film; rubber mats; and, Wiggins voltage tester .2.5 Reserve Emergency Supplies and Equipment The inspector reviewed and inspected the applicant's emergency reserves and verified that an adequate inventory of emergency supplies and equipment including protective clothing, respiratory protective equipment, self-reading dosimeters, SCBAs and high and low range survey instruments were readily available in the emergency kits located in the OSC and E0F. Additional supplies and equipment which could be used to support emergency operations were located in the Radiation Protection storage area and in various plant locations such as the Laundry Facility and designated plant Decontamination /
Change Facilities. In addition, site warehouse supplies and equipment were controlled by a Computer Repeater System which tracked minimum and maximum'
order points and provided lead time so that sufficient quantities or supplies and equipment were readily available. It was the intent of the applicant to be self-sufficient as far as emergency supplies and equipment identified above were concerne Based on the above findings, this portion of tLe applicant's program is adequat .
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4.2.6 Transportation The applicant did not dedicate vehicles _specifically for emergency us Company vehicles were maintained onsite, and keys to those vehicles were maintained in the EOF Radiation Protection Storage Rou, in accordance with EPIP RA-07, Revision 0, Field Radiological Monitoring. During the appraisal the presence of the vehicles and the keys were verified by the inspector The immediately available vehicles were passenger sedans, and four-wheel drive vehicles and/or vans, if needed, were available from near the Security Building. The keys were kept in the same room as the offsite monitoring kit Portable radios, with booster systems, were also available in the same are Based on the above findings, this portion of the applicant's program is adequat .0 EMERGENCY PLAN AND IMPLEMENTING PROCEDURES 5.1 General Content and Format This area was reviewed with respect to the requirements of 10 CFR 50.47(b);
10 CFR Part 50, Appendix E; criteria in NUREG-0654,Section II.B; and criteria in Regulatory Guide 1.3 All CPS Emergency-Plan Implementing Procedures (EPIPs) were found to incorporate the following format: (1) Introduction; (2) Responsibility; (3) Definitions; (4) Instructions; (5) References; and (6) Attachment TPo Introduction section included subsections of Purpose, Scope and Applicabilit The Responsibility section included both the person, by title, responsible for implementing the procedure, and the person, by title,' responsible for mainten-ance and review of the procedure. Persons with subsequent responsibilities, once implemented, were included within the body of the procedure. Action steps of Section 4.0 to implement the procedure were supplemented by EC-15, Personnel Checklists. The Personnel Checklists were summaries of the procedure action items, with sign-off spaces, which were included with the respective Nuclear Emergency Response Manual for each member of the response organization and maintained at the emergency station. If appropriate, attachments provided worksheets and sign-offs. References listed in Section 5.0 were other CPS procedures that accomplished some of the action steps, or may be the reference material from which the~EPIP in question was developed. The references were-available in the TSC and E0 Based on the above findings, this portion of the applicant's program is adequat .2 Emergency, Alarm and Abnormal Occurrence Procedures CPS Station Manual Procedure 1005.02 established the Organization of Statiun Manual, with the 3000 series as the System / Plant Operating Procedures, the 4000 series as the Off-Normal Procedures, and the 5000 series as the Annunciator Procedures. The Annunciator Procedures were accessed through a coordinated alphanumeric numbering system corresponding to the annunciator tile number and panel number. The inspector reviewed several of the annunciator procedures to determine if adequate reference to Emergency Plan
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Implementing Procedures was available. The 5000 series (Annunciator Procedures) referenced other corrective action procedures such as the 3000 and 4000 series procedures, but there were no references to the Emergency Plan or Emergency Plan Implementing Procedures. This is an open item that must be completed prior to fuel load. (461/85039-26)
The inspector reviewed the 4000 series (Off-Normal' Procedures) to. determine if 4~
adequate correlation with the Emergency Plan and EPIPs existed and noted that no index of procedures.in the 4000 series was available, and thus operators
, must rely on memory to access procedures for use during emergencies. In addition, varying' degrees of reference to the CP.S Emergency Plan existed, for example:
(1) In CPS No. 4001.01, REACTOR C0OLANT LEAKAGE, step 3.8 stated " refer to Clinton Power Station Emergency Plan."
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(2) In CPS No. 4003.01, REMOTE SHUTDOWN, step 4.1.3 stated, " NOTE If reactor control cannot be established within 15 minutes after evacuating the Main Control Room, initiate a-Site Emergency per CPS 1890.03, Emergency Facilities Activation (EP)." However, CPS #1890.03 had been cancelle (3) In CPS No. 4200.01, LOSS OF AC POWER, no steps or notes refer the user to the Emergency Plan, although loss of onsite AC power and/or off-site power would be Emergency Action Levels (EAL's) classified by EPIP EC-02,
. Emergency Classifications. Although the 5000. series Annunciator Procedures
- existed for the loss of DC power, no 4000 series Off-Normal Procedures i existed for this emergency. A loss of DC was also an EAL under EPIP-02, but was not referenced by the Annunciator Procedure (4) In CPS No. 4301.01, EARTHQUAKE, step 3.2 stated, "IF An emergency condition exists as. determined by the Shift Supervisor THEN Activate the emergency plan using CPS No. 1890.09, Environmental Emergencies as the entrance point." However, the Procedure Detail Report (OMSR), which was the CPS Procedure Index, indicated that CPS No. 1890.09 had been cancelle In the 4400 Series of procedures, Plant Emergencies none of the following
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emergency procedures contained any references to the emergency plan, although their entry conditions fit EALs: (1) 4401.01 Level Control; (2) 4402.01
, Containment Control; (3) 4403.01 Cooldown; (4) 4404.01 Reactivity Control; (5) 4405.01 Combustible Gas Control (not issued, in review cycle); and (6) 4406.01 Secondary Contain~ ment / Radiation Release Control. Each of the five
" issued" procedures (4405.01 was not issued) had been developed from the GE Owner's Group Emergency Procedures Guidelines (EPG) and were symptomatic-based as opposed to event oriented. Procedures 4401.01, 4402.01 and 4404.01 were complete (i.e., no "later" remained to be entered), but contained no reference to the Emergency Plan, although several entry conditions (symptoms) were EAL CPS No. 4403.01 was complete and did not require reference to the Emergency Plan since its entry conditions were not EAl CPS No. 4406.01 had several entry conditions that were EALs but did not direct the operator to implement the Emergency Plan. All parameters / values of this procedure's tables (e.g., Table 3, MAXIMUM SAFE OPERATING VALUE, Table 4, EFFLUENTS INDICATIVE OF 0FFSITE RADI0 ACTIVITY RELEASE) were listed as "later,"
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which meant that they had not yet been included in the procedur Table 4 listed for each monitored point an ALARM LEVEL, ALERT LEVEL, and a GENERAL EMERGENCY LEVEL to be filled in ("later"), but no level was listed for SITE AREA EMERGENC In addition, the Table 4 monitored points were not consistent with the " Effluent" points listed in EPIP EC-02, Emergency Classif; cations, Attachment 2, p. 2 of 3, EAL Tsbl CPS 4900 Series RW/CH/RP Off-Normal Procedures such as 4979.01, HIGH AIRBORNE-RADI0 ACTIVITY contained no reference to Emergency Plan implementation, even though entry conditions (symptoms) were EALs. Action Step 4.1 of CPS 4979.17, PRETREATMENT AIR EJECTOR OFF GAS PRM (ADDRESS: 131) PROBLEM, stated " Prepare to take action per CPS No. 4979.18, POST TREATMENT AIR EJECTOR OFF GAS PRM...-
PROBLEM and exit this procedure." However, CPS No. 4979.18 had not been issue CPS No. 4979.04, ABNORMAL AIRBORNE RADI0 ACTIVE RELEASE, referenced incorrect procedures, e.g., step 4.6 stated " Complete the necessary forms, reports, etc., as required by CPS No. 0AP 1890.00N, EMERGENCY PLAN."
Temporary Changes were not entered into the body of the procedure, rather the
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CPS TEMPORARY CHANGE FORM was simply placed at the beginning of the affected procedure, necessitating reading of all change forms to implement the procedur As an example, temporary change 83-766 of 11-10-83 to CPS 4979.04, added a step after existing step 4.1 to read:
"IF The Offsite Radioactivity Release Rate reaches the Alert Level THEN Refer to CPS No. 10N4606.015, SEC CONT & RAD RELEASE CONT - EMERGENCY."
This step was not entered in the body of the procedure. These above discussed inadequacies in the 4000 series (Off-Normal) procedures are an open item that must be corrected prior to fuel loa (461/85039-26)
The inspector reviewed IP Quality Assurance Audit Report (Q38-85-21) of 10 July 1985 that addressed Emergency Preparedness Assessment and Notificatio Paragraph 4.2 of the report contained an observation that the Emergency Operating Procedures did not include the corresponding emerr;ency class when the initiating condition parameters were given. The capabilities of the monitoring instruments were not in the procedures. This was determined to be a program deficiency and was identified as audit finding number PD- Based on the above findings, the following action must be taken to achieve an adequate program:
- Where appropriate, System / Plant Operating Procedtres (3000 Series),
Off-Normal Procedures (4000 Series) and Annuncistor Procedures (5000 Series) must be completed and appropriately reference and implement EPIP EC-02, Emergency Classifications. This must be completed prior to fuel loa In addition, the following items should be considered f or improvement:
- Procedure indexes should be provided, where appropriate, to relieve operator memory task .
o e References to deleted procedures should be removed frcm the operating procedure * Emergency procedures should be prepared for loss of DC power and Combustible Gas Contro * Temporary changes should be included in the body of emergency procedures to reduce operator workloa .3 Implementing Instructions The CPS EPIPs were found to consist of seven sections as follows:
(1) Administrative Procedures (AP); (2) Emergency Control Procedures (EC);
(3) Facilities and Equipment Procedures (FE); (4) Radiological Assessment Procedures (RA); (5) Miscellaneous Procedures (MS); (6) Headquarters Procedures (HO); and (7) Public Relations Procedures (PR). Initial entry to the EPIPS was through the emergency classification procedure, EC-02, and the four classi-fication action procedures, EC-03 (Unusual Event) through EC-06 (General Emergency).
EC-02 was used.for classification purposes, then, having determined the classification, the user was routed to the particular EPIP to implement that classification. That particular EPIP then branched to others for specific activities (e.g., evacuation), but remained the governing procedure until reclassification occurre A review of the implementing procedures indicated that the responsibilities and authority of the Station Emergency Director and other key emergency personnel were adequately defined by Attachment 1 and others to EC-01, CPS Emergency Response Organizations and Staffin Command authority responsi-bilities vested in the Emergency Director were designated, as well as those duties which he could not delegat The following items were identified while reviewing the EPIPs: With regard to EC-02, Revision 0 paragraph 1.1, page 3 of 6 stated "The purpose of this procedure is to provide guidelines for classifying initiating off-normal events or incidents into one of four Emergency Action Level (EAL) Classifications..." This terminology was not consistent with the regulations. Differentiation between EALs (defined in 10 CFR 50, Appendix E, IV.B) and emergency classes (Appendix E, IV.C)
should be made in accordance with the regulations throughout the Emergency Plan and EPIP With regard to EC-02, Revision 0 - attachment 2, page 1 of The EAL for Pre-Treatment Offgas/ Fuel Damage was listed as "High Offgas at BWR air ejector monitor (greater than 500,000 uCi/sec. . .or an increase of 100,000 uCi/sec within a 30 minute time. . ." and ". . . greater than 5 Ci/sec. . ." The Pretreatment Air Ejector Offgas PRM (MON 131/ Channel 1)
had units of uCi/cc, thus necessitating reading Offgas flow in SCFM, and making a calculation after determining the proper conversion factor to move from uCi/cc via SCFM to Ci/sec. This is an open item that must be corrected prior to fuel loa (461/85039-27)
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C. With regard to EC-02, Revision 0 attachment 10, page 7 of 9. The EAL for a LOCA'is " loss of. coolant accident (LOCA) without evidence of fuel damage" l and maintaining reactor level with ECCS, was classified as a Site Area Emergency. A LOCA with ". . . evidence of major fuel damage" and use of
- ECCS System to maintain reactor level was classified as a General Emergenc The inspector noted that the classifications were not consistent with the fission product barrier status suggested by Appendix 1 to NUREG-0654, Revision 1, in that they were conservative.by one classification severity level. That is', if one barrier was challenged or failed, the classifica-tien would be Alert; if 2 barriers were challenged / failed, then the classification would be Site Area Emergency; and if 3, then General Emergenc Since the Site Area Emergency EAL indicated no evidence of fuel damage, and the General Emergency indicated ECCS was maintaining reactor level, the classifications should have been Alert and Site Area Emergency, respectivel Containment integrity should not have been
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challenged. On page 9 of 9 of this attachment, the EAL concerning " loss
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of 2 of 3 fission product barriers with a.p'otential loss of third barrier. . ." stated "MAY BE INDICATED BY: High activity on Drywell Fission Product Monitor, Containment Atmosphere Monitoring System, or Containment CAM's with reactor depressurization. . ." However, high activity was not quantified (other examples noted), and no quantified conditions were stated to assist operators in evaluating containment conditions for challenges such as temperature, pressure, or hydrogen content. This is an open item that must be completed prior to fuel loa (461/85039-27)
D. With regards to EC-06, Revision 0 paragraph 4.2.14, page 7 of 11, stated in part, "A recommendation for offsite protective measures should be made based on guidance provided in RA-01, MANUAL RADIOLOGICAL DOSE ASSESSMENT and RA-02, PROTECTIVE ACTION RECOMMENDATIONS." However, no guidance was
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included in RA-01 for formulating a protective action recommendation; the procedure was computational only. In addition, no reference was made to the Spectral Analysis,-ALARA, and Recordkeeping System (SAARS) computer, nor RA-16, Computerized Radiological Dose Assessment. Paragraph 4.12.14 should prioritize dose projection procedures and reference each as the
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Emergency Plan, paragraph 3.2.2, doe E. With regards to AP-01, Revision 1 - EPIP AP-01, Organization and Preparation of Controlled Documents, paragraph 4.3.2.3, stated, "The
, RESPONSIBILITY section identifies who is responsible for actions required under the Implementing Procedure." In practice, all EPIPs were found to also list the person responsible for preparation, review and maintenance of the procedure. This practice should be reflected in Paragraph 4.3. ~
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F. With regards to EC-01, CPS Emergency Response Organizations and Staffing identified and described members of the Emergency Response Organization (ERO) and their duties and responsibilities. No reference was made to subordinates " arriving" first assuming duties of seniors until relieved by the senior. For example, the On-duty Radiation Protection Shift Supervisor would report to the TSC for duties as Radiological Control
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Coordinator; with the Supervisor -' Radiation Protection becoming the Radiation Protection Supervisor. The Supervisor duties included dispatch and control of.onsite/offsite survey teams, not a duty of the Radiological Control Coordinato . .
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Based on the above findings, the following. action must be tak'en to achieve an i adequate program: I
- Ensure to the maximum extent possible that EALs are quantified and that criteria constituting EALs shall be as-read or as-observed, minimizing computations or calculation to determine if the EAL is exceeded. This must be completed prior to fuel loa In addition, the following items- should'be considered for improvement:
- Emergency Action L'evels (EALs) (defined in 10 CFR 50, Appendix E, IV.B)
and emergency classes (Appendix E, IV.C) should be differentiated and made in accordance with the regulations throughout the Emergency Plan and EPIP * The Emergency Classification scheme (and supporting EALs) should be structured .in a manner that establishes the following equivalencies of fission product barrier integrity and classifications as follows:
(a) Unusual Event - all barriers intact; (b) Alert - one barrier challenged
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or failed; (c) Site Area Emergency - two barriers challenged, failed, or combination thereof; and (d) General Emergency - all three barriers challenged, failed, or combination thereo * Internal references and requirements in the EPIPs and the Emergency Plan should be consisten * Assumption of duties in various disciplines should be provided by the first responder to the facilitie .4 Implementing Procedures 5.4.1 Notifications The inspector reviewed selected portions of the CPS Emergency Plan, Revision 4, and EPIP EC-07, Revision 0, Emergency ~ Plan Notification. Several subsections of the Instruction Section 4.0 of EC-07 were utilized including the following:
. types of notification; methods of notification; followup notification; and
' termination notificatio Sections 4.1 and 4.2 were redundant, occupying seven (7) pages of the EPI Much of the data.was informational, rathe.r than action steps. As listed in Section'4.1 and 4.2, the priority of notification was: (1) offsite agencies (e.g., ambulance); (2) Illinois Emergency Services and Disaster Agency (ESDA);
(3) USNRC; and (4) IPC Emergency Response Organization (ERO) Personne However attachment 6 of the procedure, which was used to perform the notifi-cation, listed the priorities as follows: (1) interim SER0-(on-shift)
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personnel; (2) key positions of SER0; information only persons (Public
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Affairs); (3) offsite support services; (4) Illinois ESDA; and (5) USNR These inconsistencies in:EC-07 are an open item that must be corrected prior
.to fuel load. (461/85039-28)
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A Communications Directory, with all emergency positions, phone numbers, support agency and contractor phone numbers, was provided in each Key Position Nuclear Emergency Response Manual. This Directory was maintained in accordance with Plan requirement Paragraph 4.1.1.3, page 4 of 11, stated, "The NRC shall be notified within one hour of any declaration of emergency classification. . ." Similar action statements existed in other areas of the EPIPs. This process was not
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cor.sistent with the requirement of 10 CFR 50.72(a)(3), which required the licensee to notify ". . .the NRC immediately after notification of the appropriate state or local agencies and not later than one hour af ter the time the licensee declared one of the Emergency Classes." This is an open item that must be corrected prior to fuel load. (461/85039-29)
Several administrative errors were found in EC-07, Emergency Plan Notificatio Examples included the following:
- Paragraph 4.2.2.1 stated that the Autodialer was located in the TSC, when, in fact, it was in the Secondary Alarm Statio * The NARS reporting form (Attachment 2) in the EPIP was different from the NARS form in use in the Control Room (Draft 1), which was different from the form that will be placed in use in December 1985 (Draft 2).
- Paragraph 4.2.1.2, EC-07 (Revision 0) reflected an incorrect NARS phone dial cod The inspector noted that EC-07, Revision 1, scheduled for issue did not list the dialing cod No provisions were made for authentication of notification messages which would be applicable if the NARS phone became inoperable, and notifications were required on a commercial line (backup method). A relatively simple solution such as a Main Control Room telephone number known only to ESDA watch personnel could be used to authenticate in the event of a failure of the NARS phon Based on the above findings, the following actions must be taken to achieve an adequate program:
- Revise EPIP EC-07. Emergency Plan Notification, prior to fuel load to be consistent with the methodologies actually employe * Revise the Emergency Plan and EPIPs prior to fuel load to conform with the requirements of 10 CFR 50.72(a)(3) concerning notification time limit In addition, the following item should be considered for improvement:
- An authentication scheme should be provided in the event of NARs failur .4.2 Assessment Actions A review was conducted of the applicant's facilities, equipment and procedures related to accident assessment. There was no specific single procedure which directly addressed accident assessment. Procedure EC-01, CPS Emergency
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Response Organizations and Staffing, described positions, response organizations and their mobilization, and the emergency facilities from which they would operate. Procedures EC-03 through EC-06 spelled out specific actions to be taken,-based on the classification of the emergencies for which definition guidelines (Emergency Action Levels) were presented in EC-02, Emergency Classification These procedures were supplemented with training under the
" Emergency Plan Over- iew," Lesson Plan 11001, which was required for all emergency response manager Overall direction of plant assessment actions was found to be the initial responsibility of the Interim Station Emergency Director (Shift Supervisor).
As the emergency organization was augmented through classification escalation or arrival of augmentation personnel, Emergency Director responsibility was
, transferred, along with command authority, to the Station Emergency Director (power Plant manager or alternate) and then to the Emergency Manager (Vice-President, Nuclear or alternate). The general responsibility, as passed from one emergency manager to the next, includei determining operational and radiological conditions, assessing trends, and taking actions as specified in the Emergency Plan and Implementing Procedure These actions included making decisions to classify the emergency condition, initiating corrective in plant
- actions, and making appropriate offsite protective action recommendations.
The initial assessment leading to an emergency classification level would be
made by the on-duty Shift Superviso Assessment actions would be initiated by following the procedure pertaining to i' the emergency classification declared, i.e., EP-03, Notice of Unusual Event; EP-04, Alert; EP-05, Site Area Emergency; or EP-06, General Emergency. Trend analysis of key plant parameters would be accomplished through the use of extensive computer systems in the Main Control Room (MCR) and Emergency Response Facilities (ERFs) and status boards in the ERF Plant status information (about 6000 analog, digital, and status points) was available through computer based data acquisition and display systems. At CPS, the following three major systems will be employed for emergency response purposes:
(1) the Display Control a'nd Performance Monitoring Systems (Plant Process Computer), which includes SPDS; (2) the Spectral Analysis, ALARA, and Recordskeeping System (SAARS); and (3) the AMR/PRM Radiation Monitoring Syste One display console in the MCR was dedicated to SPDS. The plant process computer system acquired data concerning several selected NSSS and BOP parameters and portrayed the current status of the Critical Safety Function The SPDS, along with other displays, would alarm when preestablished parameter limits have been exceeded. The SPDS display was not a control-type console, but strictly a display of safety-significant information which, when used in conjunction with the other Control Room instrumentation, would assist Control Room Personnel in performing their emergency response functions. SPDS displays were also located in the TSC and the E0F.
i Two Central Control Terminals (CCT) for operation of.the AR/PR RMS were located in the Radiation Protection Office and in the MCR. The CCTs provided an operator interface with the Radiological Monitoring System, which consisted of the Area Radiation Monitoring system (ARM /PRM). Selected information from the ARM /PRM' system was also input to the SPDS syste As a further aid in assessing plant conditions, plant chemistry data acquisition equipment and programs were being installe __-______ _-___ ___- _____- -_____ _ ____-_ _ _:
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a The SAARS was essentially a stand-alone system, a';chough it also acquired data from the ARM /PRM system and the meteorological system. This computer system had terminals in the TSC and the E0F; the SAARS was the primary tool for making dose projections discussed below. MCR personnel did not have access to automated dose projectio Eleven (11) attachments to EC-02, Emergency Classifications, were noted to specify the EALs to be used by assessment personnel in decisionmaking activities. These procedures identified priority systems and sources of information for making classification Step 4.2.14 of EC-06, General Emergency lead directly to the use of RA-02, Protective Action Recommendations. The Protective Action Guide (PAG) Logic Diagram permitted quick decisions concerning protective action recommendations to State authoritie Upon activation of Station emergency response personnel, the on-shift Radiation Protection Supervisor (RPS) would report to the TSC. The RPS would coordinate initial offsite radiological monitoring, dose assessment, and development of protective action recommendations until relieved by the Radiation Protection Supervisor in the TSC and subsequently by the Dose Assessment Supervisor upon activation of the EO As stated above, automated offsite dose calculations would be performed through use of the SAARS Computer. The operating proccdore for this function, CPS No. 7410.70, Computerized Emergency Dose Calculations, had been written but not approved at the time of the appraisal. Backup for the SAARS Computer dose calculations was contained in RA-01, Manual Radiological Dose Assessmen RA-01 was noted to be usable as long as normal instrumentation remained available. RA-15, Predictive Release Rates, orchestrated a procedure for estimating releases in gaseous effluents for a LOCA; RA-14 Dose Rate Determination Based on Environmental Samples, permitted estimating dose commitments from airborne contamination using environmental samples. The SAARS Computer and the manual system were demonstrated for the inspectors during the appraisal, using input data generated for that purpos The recommended protective action would be based on dose assessment values from either the SAARS Computer system or the manual system offsite dose calculations, projected or actual, for the site boundary, 2 , 5 , and 10-mile distances from the site. The most reliable projected doses would be determined from the radiation monitors in the effluent monitoring system, the high range containment monitors, or samples taken from these systems. The most reliable projected dose was the entry parameter to the PAG Logic Diagram of RA-02 and may'be based on either actual or potential releases. This whole body or thyroid dose projection could then be used to determine the appropriate action to take, such as no action, shelter, or evacuat The PAG Logic Diagram was organized into protective action recommendations based en system status; protective action recommendations based on dose or dose rates;' and means of " fine-tuning" the recommendations through taking into account evacuation times, weather conditions, time of day, and time of plume arriva Based on the above findings, this portion of the applicant's program is adequat _ -_ ___ . .
5.4. Offsite and Onsite Radiological Surveys The inspector reviewed EPIP RA-07, Revision 0, Field Radiological Surveys, and the Field Team Handbook and discussed radiological monitoring responsibilities and functions with the Radiation Protection Supervisor and observed the actions of monitoring team (s)'during a drill. The inspector concluded that the emergency team members were well trained and competent in their emergency function
', including radiation monitoring, plume tracking, and sampling. Methods and equipment used to perform emergency onsite and offsite radiological surveys were specified. A field team handbook was developed for use by persons performing actual surveys. Pre positioned survey points were established on field team maps and offsite maps were provided by the State Department of
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Nuclear Safety and were also used by the State field teams. Field team Handbook logs, for different survey media, included date, time, location and identified the surveyor. These logs also identified the survey instrument j used, the mode of use (open or closed window), duration of meter reading, air sampler flow rates, sample count times and ambient background radiation levels.
Environmental sample labels were included in the field team kits; collection 1'
methods were specified; data was transmitted by radio; and logs were forwarded to the Dose Assessment Supervisor. Environmental samples were delivered to the EOF Environmental Laboratory by the team (s) or by field team runners. Field teams had emergency phone numbers listed in the Field Team Handbook to j use as a backup to the Converta-Comm radio unit. Field team transportation
- included a selection of seven onsite vehicles and keys to the vehicles were
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located at the EOF. Each field team consisted of one radiation protection person and one qualified radiation worker. Radiation protection guidance was provided by the Field Team Coordinator and the Dose Assessment Superviso Based on the above findings, this portion of the applicant's program is adequate.
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5.4.2.2 Inplant Radiological Surveys The inspector reviewed Emergency Plan Implementing Procedures RA-05, Revision 0, Personnel Protection; RA-06, Revision 0,-Station Radiological Survey; EC-12, j Revision 0, Emergency Teams; FE-02, Revision 0, Operations Support Center .
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Operations; FE-06, Revision 0, Emergency Communications Equipment; and Clinton t Power Station procedures 7105.01, Radiological Surveys and 7105.02, Air Sample Assa Inplant was defined as all areas inside the Clinton Power Station (CPS) protected are Inplant emergency radiation monitoring was~ directed by the Radiation Protection Supervisor and performed by inplant radiological control teams. Emergency plan training was provided on equipment and methods to be used to perform emergency radiological surveys. Radiation protection training was provided by the Nuclear Training Department and emergency procedures were written from the viewpoint of the persons responsible for
- performing the surveys. Training had been provided to all radiation protection technicians on the use or instruments and documentation and use of survey
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- forms. The survey forms contained date,. time, location, name(s), instrument
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type', instrument serial number, reactor power, background, cpm, air flow rates, start and stop of samples and count time. Radioactive samples were uniquely labeled and data sheets were delivered to the Radiological Control Coordinator in the OSC whe:. the team (s) returned and all samples were delivered to the OSC for temporary storage. Portable radios were used as a primary means of communicatien, with Gaitronics and FOCUS telephones as a secondar Team briefing forms included radiation protective guidanc The inspector observed the emergency response functions of a number of onsite radiological survey team members during a drill and determined that they performed satisfactorily and demonstrated that they could perform their emergency function Based on the above findings, this portion of the applicant's program is adequat .4.2.3 Primary Coolant Sampling and Analysis The applicant had prepared a draft procedure, CPS 1890.34, for the operation of the PASS for collection of liquid and containment atmosphere sample (Analytical procedures for the analysis of high-level samples, as discussed in Section 4.1.1.7, were not developed). The draft PASS procedure was being revised at the time of the appraisal. This is an open item that must be completed prior to fuel load. (461/85039-30)
There was no intent to include keys to EALs in the procedure, as the applicant's approach to this matter was to assign that responsibility to the Chemist - Nuclear on the TSC's Emergency Response Organization staf Based on the above finding, the following action must be taken to achieve an adequate program:
- Procedure CPS 1890.34 for use of the PASS must be completed and approved prior to fuel loa .4.2.4 Fire Assessment and Classification EPIP EC-02, Emergency Classifications, Attachment 6, Fires Initiating Events; summarized the conditions, indications and setpoints which would cause the various emergency classifications to be implemented in a fire emergency. A fire lasting more than 10 minutes required a classification of Notification of Unusual Event; a fire potentially affecting safety systems required a classification of Alert; a fire causing severe damage to safe shutdown equipment required a classification of Site Area Emergency. The procedure adequately addressed Emergency Action Levels and classification relative to a fire emergenc Based on the above findings, this portion of the applicant's program is adequat i
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5.4.3 Protective Actions 5.4.3.1 Evacuation of Owner Controlled Areas The inspector reviewed the Emergency Plan, Revision 5, Section 4.3.1.4; EPIPs EC-08, Revision 0, Non-Essential Personnel Evacuation; EC-09, Revision 0, Security During Emergencies; EC-10, Revision 0, Personnel Accountability; and EC-12, Revision 0, Emergency Teams. Various levels of evacuation were described. These included single building or area, multiple buildings / areas, containment, protected area, and site evacuation. For single or multiple building or area evacuations due to fire, the fire alarm was sounded; otherwise, the Plant General Purpose alarm was sounded. For containment evacuation, the Containment Evacuation Alarm was sounded; and for protected area or site evacuation, the General Plant Evacuation Alarm was sounded. In each case a prepared announcement would be read over the public address system informing of the condition and location, the area to evacuate, the assembly point, and the route to be take All levels of evacuation were at the discretion of the individual with command authority and/or the Station Emergency Director, with site evacuation mandatory upon declaration of a Site Area Emergency or a General Emergenc While evacuation routes and assembly areas were specified in the PA announcement directing the evacuation, there were no posted signs, arrows or floor markings to clearly indicate primary and secondary evacuation routes, nor were either of the two designated assembly areas so marked. This is discussed further in Section 4.1.2.1. Actual locations of assembly areas were not consistent with the locations specified in EPIP EC-08, Revision 0. This was because the assembly areas had recently been changed as a result of drill lessons learned, but these changes had not yet been reflected in revisions to the EPIPs. This is an open item that must be corrected prior to fuel loa (461/85039-31)
EPIP EC-08 made appropriate reference to EPIP EC-10, Personnel Accountabilit EPIP EC-08 charged the individual with command authority (e.g., the Station Emergency Director) to direct a search of evacuated areas using Emergency Teams, EPIP EC-12. The Emergency Plan required Plant Protection personnel to ensure plant personnel and members of the public located outside the protected area but inside the CPS exclusion area boundary were properly assembled or departed. However, CPS personnel stated that while such persons outside of the protected area were notified by " routine notification," no means to verify receipt of notification in these areas was yet in place. This i an open item that must be completed prior to fuel load. (461/85039-32)
Based on the above findings, the followinc actions must be taken to achieve an adet,uate program:
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- Revise the EPIPs to correctly reflect the actual location of the assembly areas prior to fuel loa * Develop and implement a means for verifying that personnel outside the protected area but inside the CPS exclusion area have actually received the notification of the emergency condition and have followed the instructions provided prior to fuel loa . - .
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5.4.3.2 Personnel Accountability Procedures for personnel accountability were outlined in the Emergency Plan and implemented in procedure EC-10, Personnel Accountability. Personnel accountability may be implemented at any time, but was required following declaration of an Alert, Site Area Emergency, or General Emergency. The plan and procedures.provided for a full accountability of all individuals inside the CPS protected area boundary within 30 minutes of its implementatio EPIP EC-10 directed that the report of personnel accountability be transmitted to the Station Emergency Director or to the Shift Supervisor. The Emergency Plan directed the formation of search and rescue teams in the event that
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missing individuals were identified. Reference was provided to EPIP EC-12, Emergency Teams, which addressed search and rescu EPIP EC-10 charged the Supervisor - Plant Protection, to assist in the search for missing personnel if requested, and this procedure also referenced EPIP EC-12.
i The Emergency Plan required that accountability of personnel within the protected area, once established, be continuously maintained. This requirement was adequately implemented in EPIP EC-10.
) Accountability drills were held on October 16, 1985, and again on November 8, 1985. Although the first drill did not meet the 30 minute goal, the 8 November drill completed accountability satisfactorily within 28 minute Based on the above findings, this portion of the applicant's program is adequate.
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5.4.3.3 Onsite First Aid and Rescue Clinton Power Station procedure EPIP RA-08, Radiological Inquiries, described i the subject program. The prncedure adequately dealt with methods for receiving, recovering, transporting and handling injured persons who may be contaminated. In offsite medical treatment facility and an ambulance service
- prepared to. deal with contaminated injured persons, had been established as described in the Emergency Plan Sections 2.4.2.4. and 2.4.2.5. Communication protocols and contamination control methods were specified. The CPS medical i
supervisor was involved in the preparation of EPIP RA-0 Based on the above findings, this portion of the applicant's program is adequate.
- 5.4.4 Repair and Corrective Actions
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Repair and corrective actions were not the subject of specific CPS EPIP However, EPIP EC-12, Emergency Teams, provided guidance to emergency response parsonnel regarding Emergency Team formation and operations. The OSC Supervisor was responsible for organizing emergency teams as directed by the Station Emergency Director. The OSC Supervisor was also charged with preparing Emergency Team Data Sheets (in lieu of Radiation Work Permits),
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arranging for necessary Radiation Protection support, and providing necessary
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supplies snd equipment to the teams. Designated Team Leaders were responsible
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for ensuring that team members were authorized to receive radiation doses in excess of 10 CFR 20 limits, as necessary, and for briefing the team members on the assigned task. The OSC Supervisor was responsible for Emergency Team debriefing l The Emergency Team Data Sheet was reviewed and in general found to be '
' comprehensive and thorough. However, it was observed that emergency exposure authorization required only one verbal or authorization signature, rather than an individual authorization for each person involved. Further, there was no way for individuals authorized to exceed exposure limits to sign acknowledgement of the authorization, and to signify their awareness of the potential risks-and their acceptance of those risks. This is an open item that must be i
completed prior to fuel load. (461/85039-33)
CPS 1014.01, Safety Tagging Procedure, provided for special tagging methods during emergencies. CPS 1029.01, Preparation and Routing of Maintenance Work Requests, provided for emergency work to proceed in advance of required-documentatio EPIP EC-11, Reentry, provided guidance for reentering evacuated station or onsite areas. EPIP EC-14, Recovery, provided guidance in the form of general
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procedural steps to recover from an emergency, particularly a Site Area l- Emergency or a General Emergenc Based on the above findings, the following action must be taken to achieve an acceptable program:
- Revise the Emergency Team Data Sheet to provide for individual authorization signatures for each person who is authorized to exceed 10 CFR 20 limits. The data sheet should also provide for an acknowledge-ment signature by each authorized worker to signify his understanding of tie assignment, the potential risks, and his willingness to accept those risks. This must be completed prior to fuel loa .4.5 Recovery EPIP EC-14, Recovery, provided that when an emergency condition was terminated, l the Emergency Manager would declare a recovery phase and assume the role of the
, Recovery Manager. The procedure also provided for evaluating plant operating l conditions and in plant and out-of plant radiological conditions through the Facility Review Group and the Nuclear Review and Audit Group. These groups
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would be in session during the recovery phase. The Facility Review Group would be responsible for evaluating recovery action and approving recovery i procedures and the Nuclear Review and Audit Group would be responsible for an
! , independent review and audit of recovery procedures and activities. Key positions were well defined in Attachment 1 to the procedure and included the Station Emergency Response Organization, Emergency Support Organization,
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Headquarters Support Organization and the Nuclear Station Engineering Department. The Recovery Manager would determine which persons were needed to maintain the Recovery Organization. Appropriate notifications were addressed in Attachment 2 to the procedure.
! Based on the above findings, this portion of the applicant's program is adequate.
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5. Public Information The inspectors interviewed the Manager - Media Relations and reviewed the CPS Emergency Plan, Revision 4, and EPIPs PR-01 through 05 with respect to the mechanisms for disseminating media releases. The procedures did not identify the media organizations involved in news dissemination, nor did they identify how the media would be contacted if an emergency occurre There wer some provisions for coordinating the internal dissemination of information to the various locations and individuals; however, specificity was lacking, e.g.,
telephone numbers and exact routing. This is an open item that must be completed prior to fuel loa (461/85039-34)
The provisions for coordinating information among the various spokespersons of the various organizations and groups prior to activation of the JPIC were not specified. This is an open item that must be completed prior to fuel loa (461/85039-35)
There were provisions for rumor control; however, they were not found in the procedures. Based on interviews, the inspectors determined that the procedures did not reflect the mechanisms in the detail required to enable implementation from the procedures, although most of the necessary provisions had been mad The official spokesperson was the IPC Public Information Officer as described in EPIP PR-01, Revision 0, Attachment 2, and the sources of information to be used were clearly specified in EPIP PR-03, Revision Based on the above findings, the following actions must be taken to achieve an acceptable program:
- Revise the procedures to identify media organizations, media locations, and specific methods for contacting the media in the event of an emergency. This must be completed prior to fuel loa * The procedures should be revised to prescribe the means for coordinating information among spokespersons of various organizations and groups prior to the activation of the JPIC. This must be completed prior to fuel loa .5 Supplementary Procedures 5. Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies CPS procedures EPIP FE-05, Revisi a 0, cmergency Kits, and EPIP AP-09, Revision 0, Emergency Communication Surveillance, were reviewed. Procedure FE-05 dealt not only with Emergency Kits but also with emergency equipment stored in the Emergency Response Facilities (ERFs). Responsibility for ensuring that the kits were inventoried was specifically assigned to the Director - Plant Radiation Protection. However, the responsibility for ensuring that emergency equipment (other than the kits) located in the ERFs was inventoried was not assigned. This is an open item that must be completed prior to fuel loa (461/85039-36)
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s Specific inventory listings and locations of kits and equipment was specifie Calibration frequencies of portable emergency radiation instruments was included with all other plant portable instrument Provisions were made for noting and correcting deficiencie Emergency equipment, except for Radiation Protection instrumentation and some equipment at the OSC was not organized into cabinets and shelves. Emergency equipment inventories for the OSC were specified in EPIP FE-05, Emergency Kits, but responsibility for maintenance was not assigned. This is an open item that must be completed prior to fuel loa (461/85039-36)
Procedure AP-09 specifies ERF communication equipment and associated testing requirements, but did not include testing frequencies, as required by 10 CFR 50, Appendix E, Section 9. This is an open item that must be completed prior to fuel loa (461/85039-37)
Based on the above findings, the following actions must be taken to achieve an adequate program:
- Procedure EPIP FE-05, Emergency Kits, must be modified prior to fuel load to assign responsibility for inventory and maintenance of emergency equipment in the Control Room, TSC, OSC, E0F, and BE0 * Procedure EPIP AP-09, Emergency Communications Surveillances, must be modified prior to fuel load to specify the testing frequencies of emergency communications equipmen .5.2 Orills and Exercises The Supervisor - Emergency Planning had the responsibility for coordinating emergency drills and exercises as described in EPIP AP-04, Preparation and Conduct of Emergency Drills and Exercise Drills and exercises were conducted utilizing a scenario developed prior to the dril After review and approval, the basic idea for each drill would be developed into a Drill Scenario Package. The package would contain the drill objectives, scenario (complete with message and data forms), evaluator and controller instructions and any other supporting informatio Exercise scenarios were developed by a Scenario Package Working Grou This group consisted of a licensed Reactor Operator, a representative of the Nuclear Training Department, a representative of the Radiation Protection Department, a representative of Emergency Planning, and an engineer experienced in thermohydraulic and safety / risk analysis calculations. The purpose of this group was to ensure that the scenario package would contain an adequate number of events to exercise the various facets of the emergency response organizatio Neither the plan nor procedures specifically required that some drills be conducted on backshifts. This requirement should be included to ensure that all emergency response personnel would be afforded training under emergency drill condition .
Documentation of comments from controllers and evaluators were part of each drill and exercise. Findings were entered into the applicant's Computerized Commitment Tracking System and monitored until they were resolve Responsibility for maintaining the tracking was assigned to the Supervisor -
Emergency Plannin The required frequency specified in the plan for exercises, communications drills, fire drills, medical drills, radiological monitoring drills, and haalth physics was consistent with NUREG-065 Based on the above findings, this portion of the applicant's program is adequate; however, the following item should be considered for improvement:
- The Emergency Plan should specify that a certain percentage of the drills would be conducted on the backshift .5.3 Review, Revision and Distribution The inspectors verified that the Emergency Plan, EPIPs, and the Nuclear Emergency Response Manual were reviewed and updated at least annually in accordance with CNP 4.03, EPIP AP-06, and Section 5.2 of the plan. Critique items from drills and changes in the facility and environs were incorporated
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and tracked by the Supervisor - Emergency Planning. A computer-aided tracking system was used to assist the Supervisor - Emergency Planning in meeting his responsibility. Production and distribution of changes to emergency preparedness documents was the responsibility of the Supervisor - Nuclear Records. The inspectors found that the emergency planning documents had been reviewed, approved and updated as require Based on the above findings, this portion of the applicant's program is adequat .5.4 Audits 10 CFR 50.54(t) required an audit of the emergency preparedness program every 12 months by persons who have no direct responsibilities for implementing the Emergency Plan. This requirement was specified in Illinois Power Company Corporate Nuclear Procedure 4.03, Section 2.6, and was implemented in Section 5.2 of the Emergency Plan, which required the IPC Quality Assurance (QA) Department or a contractor to perform an annual review of the CPS Emergency Preparedness Program to verify compliance with IPC procedures, Federal regulations, State / local concerns, operating license provisions, and industry guidance. A list of 14 areas to be reviewed (as a minimum, but not limited to) was include The audit for the year 1985 was performed by the IPC QA Department over a period of about five months, from May through November, 1985. These audits were reported in QA38-85-15 through QA38-85-22 inclusive, and covered all but two of the areas listed in EP 5.2. Those two areas yet to be audited for year 1985 were dose assessment capability, and post-accident sampling capabilit An independent review by a contractor was also performed during the period May 13-17, 198 .
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The reports of the IPQA audit of the Emergency Preparedness Prograa conducted in 1985 were reviewed. The review supported the fact that in the course of the audit the assigned auditors utilized personnel interviews and discussions, and conducted facility and equipment inspections, as well as conducted a paper review. In this regard, the inspector discussed with the QA Audit Supervisor the governing directive for the QA Audit Program, QAP 118.0 This procedure was general in that it provided guidance for all audits, rather than being tailored to the Emergency Preparedness Program Audi As such, it lacked specifics which should be provided to the auditors, namely, the reference documents: 10 CFR 50.54(t); Wp a nt E::: agency Plan Section 5.2; previous audit and inspection reports; a reiteration of the review areas specified in Section 5.2 of the plan; and, additional guidance for the conduct of the audi %ch a requirement was at least partially satisfied by QAP 118.01, which required an audit checklist to be prepared, and further required a review of r the results of all previous audits and surveillances on this subject, including any other relevant document It was reported that QA personnel have, in the past, t'een involved in emergency drills as Controllers / Evaluators, but that this had not been an independent audit function. Discussions with key EP personnel revealed that independent participation by QA auditors was planned for 1986. Such participation, other than as Controllers / Evaluators, should be specified in the detailed audit requirements discussed in the preceding paragraph, and should be reiterated in the individual audit orde Based on the above findings, this portion of the applicant's program is adequate; however, the following items should be considered for improvement:
- The specific requirements for the annual Emergency Preparedness Program Audit should be defined in an expanded version of Section 5.2 of the plan or in the EPIPs and these requirements should be cited as a reference in the annual audit orde * The team conducting the annual audit of the Emergency Preparedness Program should observe an emergency drill other than as controllers or evaluator , COORDINATION WITH OFFSITE GROUPS 6.1 0,fsite Agencies G.1.1 DeWitt County Board An interview was conducted with the DeWitt County Board Chairman alternat The interviewee understood his responsibilities and authorit He demonstrated knowledge of the coordination of recommendations and protective actions among the county, state and applicant in the event of an emergency. The applicant was frequently in contact with the county and had contacted the county with regard to drills, exercises and trainin Most of the appropriate training was provided by the Illinois Emergency Services and Disaster Agency (ESDA);
however, the applicant had provided training in the areas of plant familiarit .
The_ County was satisfied with the coordination efforts of the applicant in relation to notifications, frequency and nature of training provided and routine planning information exchange. The county had participated in drills in conjunction with the applican Based on the above findings, this portion of the applicant's program is adequat .1. 2 Clinton Ambulance Service The inspector interviewed a member of the Clinton Ambulance Servic The ambulance service understood its role, authority and responsibilities relative to emergencies at the CPS. They were satisfied with the frequency and nature of the training provided, but stated that communications and notifications needed improvemen The high frequency of ambulance calls caused the ambulances to be out of their dispatch station ofte Radio contact between the CPS and the ambulances could improve ambulance response times and provide more ready access to medical information enroute to and from the plant. The applicant purchased a radio for the ambulance service, but inadequate coordination of the purchase with the ambulance service resulted in a less than satisfactory purchas Based on the above findings, this portion of the applicant's program is adequate; however, the following item should be considered for improvement:
- The applicant should consult and coordinate with the ambulance service to improve enroute communication . Illinois and DeWitt County /Clinton Emergency Services and Disaster Agency (ESDA)
F Through interviews, the inspectors found the Illinois Region 7 ESDA Coordinator and the DeWitt County /Clinton ESDA Coordinator to be knowledgeable of their emergency roles, authorities and responsibilities. They were satisfied with their notifications, training, routine planning information exchange and relationship to the applicant. They had controlled copies of plans and procedures readily at hand and were familiar with the contents. ESDA had participated in drills and training with the applicant. The applicant's protective action recommendations were consistent with ESDA's and had been reviewed by ESDA. The applicant had frequent contact and coordination with ESD Based on the above findings, this portion of the applicant's program is adequat .1. 4 Medical Service Arrangements The inspectors interviewed the Administrator of the Dr. John Warner Hospita This hospital was the local facility for receiving contaminated injured individuals designated by CPS. The hospital had readily available control copies of CPS emergency plans and procedures and had written copies of decontamination procedures. The physicians and nursing staff had received appropriate training from both the applicant and the applicant's medical
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contractor, Radiati:n Management Corporation (RMC). RMC provided the backup medical support for medical services arrangements. The inspectors reviewed the patiert facilities and equipment for decontamination ~and found them to be adequate. The hospital emergency kit is discussed in Section 4.2.1.1 of this report. Hospital personnel understood their emergency role and were satisfied with their notification, training and planning exchange with the applican Based on the above findings, this portion of the applicant's program is adequat .1.5 DeWitt County Sheriff The inspector interviewed the DeWitt County Sheriff. The Sheriff had emergency procedures available and was familiar with his emergency role. He had participated in drills related to the CPS and had received radiological I training for emergency workers. He was satisfied with his relationship to the I
applicant. There was, however, uncertainty with regard to why the siren system was being modified, who would notify his office of an emergency at the
! CPS, the operation of the siren system, and whether the public would know the I
appropriate response to siren activation. He felt that while a representative of the Sheriff's Department was needed in the Emergency Operation Center, decisionmaking authority would be better placed in the field. He stated that his staff could use more trainin Based on the above findings, this portion of the applicant's program is adequate; however, the following item should be considered for improvement.
l * The Sherif f Department's training should be improved to include l
information on siren activation, purpose of siren system modifications, and notification source .1. 6 Clinton Fire District The inspectors interviewed the Fire Chief and driver. The fire department relied heavily on volunteers and had approximately 19 people. They had received radiological emergency worker training from ESDA and had participated in several drills with the applican There was some confusion with regard to plant security requirements and the availability of dosimetry and respiratory equipment required before site entry. According to the applicant, approximately seven minutes were required to distribute dosimetry and for the firefighters to don appropriate respiratory equipment. An insufficient amount of respiratory e su'pment had been provided to fully equip properly manned fire trud Based on the above findings, this portion of the applicant's program is adequate; however, the following items should be considered for improvement:
- A sufficient amount of respiratory equipment should be provided to fully equip properly manned fire truck * Training should be sufficient to distinguish between security requirements and health physics practice .
S 6.1.7 Letters of Agreement Appendix C of the plan contained letters of agreement with governmental ~
agencies and other emergency support organizations. These organizations and the date of the letter of agreement were as follows: Illinois ESDA (10/29/79);
Illinois Department of Conservation (10/30/79); Illinois Department of Law Enforcement (12/5/79); Illinois Department of Nuclear Safety (10/24/79);
DeWitt County Sheriff's Department (10/31/79); DeWitt County ESDA (10/29/85);
Clinton Fire Department (12/4/79); U. S. Department of Energy (11/5/79); INP0 (7/6/81); General Electric (7/8/83); Sargent & Lundy (5/13/82); Clinton Ambulance Service (10/31/79); John Warner Hospital (10/31/79); Decatur Emergency Care Associates, Ltd. (6/22/83); and Radiation Management Corporation (RMC) (not dated).
Appendix C of the CPS Emergency Plan, Revision 4, stated that Illinois Power Company shall seek, prior to fuel load, new and/or revised letters of agree-ment from the above-listed originators with the exception of General Electric and Sargent & Lundy and additionally from the U.S. Nuclear Regulatory Commission, Region III, the National Weather Service and a rad waste haule Section 5.2 of the CPS Emergency Plan, Revision 4, dated December 14, 1984, stated that the annual review of the plan shall ensure letters of agreement with support organizations remain current. Section 2.4.3.4 of the plan reflected expectations of involvement and services from National Laboratories, but there were no letters of agreement to support the expectation Furthermore, the Decatur Emergency Care Associates, Ltd. letters of agreement implied services from Decatur Memorial Hospital, but there was no letter of agreement from the hospital. This is an open item that must be completed prior to fuel loa (461/85039-38)
Based on the above findings, the following action must be taken to achieve an adequate program:
- All Letters of agreement must be obtained and/or updated prior to fuel loa .2 General Public and Transient Population The inspector interviewed the Supervisor - Emergency Response, Manager - Media Relations, Supervisor - Nuclear Communications and reviewed the CPS Emergency Plan, Revision 4, Corporate Nuclear Procedure 4.03, Revision 2 and EPIP PR-05, Revision 0, with respect to the dissemination of emergency planning informatio The utility had made provisions for publication and dissemination of a public information brochure which will be mailed to consumers of electricity within the 10-mile EPZ. Completion of mailing the information brochures is an open item that must be completed prior to fuel load. (461/85039-39)
Publication of the brochure was coordinated by the staff at the CPS contrary to the description in Corporate Nuclear Procedure 4.03, Revision 2. In addition, the applicant had undertaken a program, which was initiated approximately two years ago, that entails personal representatives of IPC presenting themselves at each household in the 10-mile EPZ and availing themselves to answer questions concerning the CPS nuclear power plan '
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Emergency Information for the transient population was available at the Visitor's Center and from postings at various sites in recreation areas near the site. The emergency information was coordinated with the state and local governments. It is planned to update and disseminate the brochure at least annually. The brochure tells the public how they would be notified and what their actions should be in the event of an emergency. The information was accurate and contained information about radiation in language understandable by the lay public. The brochure did not contain a phone number to call regarding rumor control. The emergency information brochure was not yet available and observable in public areas such as motels and campgrounds. This is an open item that must be completed prior to fuel load. (461/85039-40)
The brochure provided a contact for additional information. In addition to the brochure, a monthly newsletter was distributed to all IPC employees at the CPS and to customers who bought electrical power within the 10-mile EPZ. This newsletter often contained information with regard to emergency plannin The alert and notification system consisted of approximately 20 sirens which were activated by encoded radio transmission from either the DeWitt County Sheriff's Office or the Clinton Fire District Statio The system was owned by the State of Illinois and maintained by IP The system was tested fully on the first Tuesday of each month. These monthly tests were used te train response personne The siren system was being reconfigured and augmented by the addition of approximately 40 sirens so that a coverage of at least 60 dB will be measurable within the 10-mile EPZ. Hence, the alert and notification system was incomplete and the system cannot be considered fully operationa This is an open item that must be completed prior to fuel loa (461/85039-41)
Based on the above findings, the following actions must be taken to achieve an adequate program:
- The public information brochure must be disseminated to the public prior to fuel loa * Emergency information must be made available to the transient population prior to fuel loa * The operability of the final siren system must be demonstrated prior to fuel loa In addition, the following items should be considered for improvement:
- IPC Corporate Nuclear Procedure 4-03, Revision 2 should be revised to accurately reflect who has responsibility for coordination of publication of the public information brochur * A rumor control number should be listed in the public information brochure's next update; in the interim, the rumor control number should be put in the monthly newsletter af ter fuel loa _
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J 6.3 News Media The inspector interviewed the Manager - Media Relations,- an Emergency Planning Coordinator and reviewed the CPS Emergency Plan, Revision 4, and EPIP PR-01 through PR-05 with regard to the applicant's planned relationship with the news media in the event of an emergenc The applicant had a program for familiarizing the news media with emergency plans, points of contact for the ralease of public information, space allocated for the media's use, information about radiation, normal plant operation versus accident operation and accident sequences. EPIP PR-05, Revision 0, Public Information and Radiation, provided for annual training for the media on the applicant's program; however, the program had not been implemented to date. This is an open item that must be completed prior to fuel load. (461/85039-42)
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Based on the above findings, the following action must be taken to achieve an adequate program:
- The news media must be' informed of the applicant's program for media familiarity with emergency plans, points of contact for release of public information, space allocated for the media's use, information about radiation, normal plant operation versus accident operation and accident
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sequences. This must be completed prior to fuel loa .0 DRILLS, EXERCISES AND WALKTHROUGHS 7.1 Orills and Exercises The applicant had conducted a total of 18 drills since February 21, 1985 testing various functions and facilities of the emergency progra Communications functions were drilled on six occasions, medical emergencies
, on three, radiological monitoring on four, health physics on five, technical
- on six and facilities on nine occasions. The'first annual exercise was scheduled for December 1985.
A Procedures for the development and conducting of these drills-and exercises were established in EPIP AP-04, Drills and Exercises.
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Based on the above findings, this portion of'the applicant's program is'
adequat . 2 Main Control Room Walkthrough Observations 7.2.1 Emergency Detection l - Walkthroughs were conducted for each of five (5) Shift Supervisors (SS) and their normal shift watch organizations. The watch organizations that the SSs had available to them consisted of one (or two) Assistant SS, the STA, two control room operators, and one Radiation Protection specialist,' The-interviews were conducted in the TSC where the crew had access to all documentation and references that would normally be available to them. The MCR could not be used due to construction work. No requirements were placed on the operators to perform from memory. Rather, they were provided with
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guidance that the interview was open book,-and that they should perform in a manner consistent with their normal standards and methods. A CPS observer sat in on several interview A hypothetical accident scenario was prepared by the inspector, with the assistance of the applicant to assure plant specific accuracy, containing degrading plant conditions that escalated an initial Alert declaration to a General Emergency. The watch organization was expected to evaluate the plant conditions presented, and to take action in response to the conditions /
indications by utilizing ~the proper procedures. The response in the area of detection was generally adequate. However, it was noteworthy that all watch organizations took different responses to the same set of accident condition For example, some watch organizations notified the load dispatcher on power change, others did not. Some crews shutdown immediately on high off gas; other conducted a slow, orderly' shutdown. Two crews failed to order the containment evacuated prior to reactor manual scram that may have lifted safety relief valves (SRVs) to the suppression pool. All watch organizations experienced difficulty using the Off-Normal Procedure Based on the above findings, this portion of the applicant's program is adequate; however, the following item should be considered for improvement:
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- Additional practical training for MCR personnel should be conducted to ensure adequate capability to implement plant emergency procedure .2.2 Emergency Classification
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Shift Supervisors and their watch organizations experienced difficulty in making timely classifications. For example, the declaration of Alert necessitated conversion from uCi/cc to Ci/sec which caused long delays in recognizing that an EAL had been exceeded. Two of four watch organizations were unable to properly classify the accident for multiple EALs exceeded, i.e., failed fuel, total loss of AC, and leak outside primary containmen This error was in a nonconservative direction, i.e., Site Area Emergency v General Emergenc None of the crews demonstrated a knowledge of the relationship between emergency classification, fission product barrier status, and radiological impact on the public. This is an open item that must be corrected prior to fuel loa (461/85039-43)
. Based on the above findings, the following action must be taken to achieve an adequate program:
- Control Room personnel must be provided with additional training ^regarding emergency classifications, especially related to the. relationship between emergency classifications and fission product barrier status. This must be corrected prior'to fuel-load.
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7.2.3 Notifications The watch organization was requested to perform the notification process that would be accomplished during an emergenc EPIP EC-07, Emergency Plan Notification, called for a shift member to contact the Security Liaison Officer to initiate staff augmentatio One shift failed to issue this order
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to the Security Liaison. Offsite agency notification was accomplished by transmission of a pre-formatted message form (NARS) over a special ring-down phone. One crew was unable to make a timely notifictsMn (i.e., greater than 15 minutes) for an Alert classification. All crews experienced difficulty in formulating Protective Action Recommendations (PAR) for the General Emergency classification (see Section 7.2.5) and were unable to classify, prepare a message, prepare the PAR for inclusion in the message, and transmit the notification message promptly and within the prescribed time limit. All communicators were generally unfamiliar with the NARS phone and its characteristics. Most Shift Technical Advisors (STA) completed the message form; one STA made the communication. This STA task appeared to be a waste of talent, a5d inconsistent with his assigned responsibilities of " Technical Support to reactor operations" (Table 3-1, Emergency Plan). None of the communicators. transmitted the information on the NARS form the same way; some communicators read the whole entry, some communicators read the alphanumeric entry, and some did both for the same message. This is an open item that must be corrected prior to fuel loa (461/85039-44)
Based on the above findings, the following action must be taken to achieve an adequate program:
- Conduct additional practical training prior to fuel load for Control Room personnel concerning notifications, message preparation, and communications to ensure uniform and timely accomplishment of notification requirement In addition, the following item should be considered for improvement:
- Additional training should be conducted for watch organizations to assure personnel assignments in the emergency organization make the most efficient use of the expertise of the various individuals to meet the needs of the existing situatio .2.4 Dose Calculations The inspectors observed the performance of dose calculations by the STA and Radiation Protection (RP) technician as part of the walkthroughs for Control Room personr.e1. Upon EP activation, the RP Shift Supervisor would report to the TSC, begin activation of the TSC because he would likely be a first responder, and perform radiological control duties in accordance with EC-01, CPS Emergency Response Organizations and Staffing, Attachment 14, and Table 3-1 of the Emergency Plan. These dutier would include " Radiological effluent and environs monitoring, assessment, and dose projections.' The priority of methods of dose assessment was as described in Section 5. above, i.e., SAARS backed up by manual procedure. Neither the STA nor RP personnel had been trained on the SAARS computer. This is an open item that must be completed prior to fuel load. (461/85039-45)
During walkthroughs the STA and RP technicians performed manual dose calculations in accordance with RA-01, Manual Radiological Dose Assessmen RA-01 was found to be lengthy, requiring more than ten (10) minutes (for all crews) to compute one point (2-mile radius) for whole body (noble gas) dose rate only. In general, the STA led the calculation effort; RP technicians were not able to demonstrate a high degree of facility with the procedur One crew did not obtain a " correct" answe a Based on the above findings, the following action must be taken to achieve an :
adequate program:
- Conduct training for appropriate personnel on the use of SAARS Emergency Dose Calculation Package and the utilization of computed data from SAARS !
prior to fuel loa j In addition, the following item should be considered for improvement:
- Additional. practical training should be conducted for appropriate personnel in performing EPIP RA-01, Manual Radiological Dose Assessment, and evaluation of computed dat .2.5 Protective Action Decisionmaking ,
The inspector presented a hypothetical accident scenario that resulted in a General Emergency classification without releases occurring outside the power block, followed by a release occurring that caused a whole body dose rate ;
offsite of >10 R/hr. Operators experienced extreme difficulty in implementing the Protective Action Guide (PAG) Logic Diagram, Attachment 1 to RA-02, >
Revision 0, Protective Action Recommendation. Many of the problems were directly related to the illegibility of the diagram. This is an open item that must be corrected prior to fuel loa (461/85039-46)
However, in many cases the watch organization failed to follow the diagram to its conclusion for the stated conditions. Operators also experienced confusion in trying to implement the not yet-issued General Emergency Prompt Decisionmaking Flow Diagram (Attachment 1, RA-02, Revision 1). This is an open item that must be corrected prior to fuel load. (461/85039-47)
In a similar fashion, operators experienced difficulty in determining a PAR for the situation of General Emergency, release occurring. The reasons for the difficulty were found to be the same, i.e., inability to read the chart and failure to follow the logi Operators demonstrated the capability to consider variables such as severe weather / icing, and time estimates to complete evacuation, in formul~ ting a PAR Based on the above findings, the following actions.must be taken to achieve an adequate program: i
- Revise RA-02, Protective Action Recommendations, to ensure functionality and compliance with regulatory requirements and guidance, prior to fuel-loa * Conduct practical training for emergency response organization personnel in formulating protective action recommendations based on varying plant conditions and status, dose assessment / projection, and environmental conditions prior to fuel loa ;
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7.3 Emergency Response Organization Walkthrough Observations Walkthroughs were conducted with 23 personnel assigned to key positions in the Emergency Response Organization to assess their level of training and knowledge. These personnel were examined for their familiarity with general emergency preparedness requirements and methods, as well as specific questions relative to their function in the emergency organizatio A walkthrough was conducted with a primary and/or alternate person for each of the following key Station Emergency Response Organization positions: Emergency Manager; EOF Director; EOF Emergency Advisor; Dose Assessment Supervisor; EOF Administrative Supervisor; Dose Assessor - Computer; Dose Assessor - Manual; Field Team Coordinator; Environmental Lab Coordinator; E0F Decontamination Coordinator; EAL Evaluator; Protective Action Evaluator; Station Emergency Director; TSC Radiological Supervisor; Radiological Controls Supervisor; Station Security Coordinator; Chemist - Nuclear; 0SC Supervisor; and, Radiological Controls Coordinato In all of the above walkthroughs, personnel were able to demonstrate a thorough knowledge of their emergency response functions and duties. Personnel were not only well trained in.their own positions, but had an excellent working knowledge of the positions that they in.terfaced with. Personnel demonstrated a good understanding of the overall emergency response organization and it's relationship to offsite organization Based on the above findings, this portion of the applicant's program is adequat .0 Persons Contacted 8.1 Illinois Power Personnel D. Hall, Vice-President P. Womeldorff, Vice-President
- S. Perry, Manager, Nuclear Programs Coordination
- F. Spangenberg, Manager, Licensing and Safety
- J. Wilson, Plant Manager _
R. Trotter, Manager, Engineering J. Miller, Director, Startup Programs
- R. Schaller, Director, Nuclear Training T. Taylor, Contract Purchases H. Lane, Director, Design Engineering A. Adams, Supervisor, Media Relationships R. Wyatt, Director, Nuclear Program Assessment Group
- K. Graf, Director, Operations-Monitorin *J. Greene, Manager, Startup. .
R. Begel, Supervisor, Medical
- J. Greenwood, Manager, Power Supply
. *J. Patten, Supervisor, Emergency Response
- D. Shelton, Manager, NESD
- R. Freeman, Program Manager ERCIP
- J. Palchak, Supervisor, Support Services
- Hillyer, Director, Radiation Protection-
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- Daniels, Jr. , Project Manager
- J. Brownell, Licensing Specialist T. Roe, Assistant Supervisor, Mechanical D. Antonelli, Supervisor, Plant Operations T. McKenrick, Supervisor, Asses'sment and support S. Foster, Emergency Planner T. Carder, Emergency Planner R. Lawrence, Security Shift Liaison M. Newby, Security Shift Liaison J. Hillman, Security Shift Liaison D. Smith, Security Shift Liaison G. Gregory, Supervisor, Control Room Instrumentation R. Snelson, Supervisor, Computer Engineering R. Thorn, Project Engineer J. Zwyner, Project Engineer C. Eichelkraut, Project Engineer R. Orthen, Radiological Staff Engineer T. Froelich, Supervisor, Radiological / Environmental R. Haight, Corporate Health Physicist R. Norville, Radiological Staff Engineer M. Stookey, Plant Test Engineer / Specialist-M. Ehalt, Staff Engineer J. O'Brien, Technical Advisor E. Harris, Startup Engineer M. Hedges, Chemistry Supervisor
'S. Giebel, Radiation Protection Technician W. Evans, Emergency Planner M. Helms, Radiation Protection Shift Supervisor W. Lones, Chemist, Nuclear F. Wolking, Supervisor, Plant Radiation Protection K. Robertson, Supervisor, Dosimetry D. Burke, Lead Instructor M. Meier, General Instructor J. Dodds, General Instructor R. Reno, General Instructor M. Hurshman, General Instructor P. Sefranek, General-Instructor B. Wier, Lead Electrical ~Startup D. Driskell, Auditor J. Friend, Supervisor, Audits F. Timmons, Supervisor,. Plant Protection J. Sipek, Fire Protection-M. Lyons, Lead Operations Instructor P. Ryan, Operations Development Specialist D. Brendley, Instructor, General
' J. Reed, Assistant Supervisor, Plant Operations F. Worrell, Shift Supervisor (SS)
W.. Sly, S J. Owens, Assistant Shift Supervisor (Assistant SS)~
J. 'Kouski, Assistant SS C. Holstein, Control Room Operator (CRO)
F. Mattsson, CR0 J. Hall, Shift Technical Advisor (STA)
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R. Campbell, Radiation Protection Specialist (RP Specialist)
j R. Reichert, Assistant SS R. Hayes, CR0-J. Carter,'CR0 C. Motsegood, STA-J... Helms, RP Specialist'
B.- Brehm, SS L P. Yocum, Assistant SS R. Price, Assistant SS D. Rumpel, CR0 D. Reeser, CR0
.L.' Rippy, STA'
. D. Noble, RP Specialist J. Hays, SS-J. Neuschwanger, Assistant SS
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K. Grooms, CR0 L. Anderson, CR0 C. Pond, STA
' Reandeau, RP Specialist
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K. Leffel, CR0 M. Needles, CR0
. M. Holliden, STA M.' Dodds,- RP Specialist
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8.2 Non-Illinois Power Personnel
- V.- Everett, Emergency Planning Advisor,. Consultant'from Impell N. Waddock, Dewitt' County' Board Chairman alternate
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P.-Danison, Clinton Ambulance Service
! '.P. Keane, Region'7 ESDA Coordinator
! M.. Strain,.Dewitt County /Clinton City.ESDA Coordinator
- H. Bohn, Chief, Clinton Fire Department
~ Taylor, Driver, Clinton Fire Department
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D.-Tucker, Nuclear Data Consultant
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M. Hein, R.N., Hospital Administrator, John' Warner Hospital D. Massey, DeWitt County Sheriff .
Z. McCamon, DeWitt County Sheriff's Dispatcher-
- Denotes those attending the exit meeting on November 21,:1985 held at the l Clinton Power Statio .0 EXIT INTERVIE The inspectors, the. Chief of.the Emergency Preparedness Section and.the~ Chief.-
of the Emergency Preparedness and Radiological Protection' Branch from the NR Region III office met ~with applicant representatives (denoted in Section 8.0)
at the conclusion of the appraisal on November 21, 1985. -The inspectors
! -summarized the scope and' findings of the: appraisal, including the open item 'The inspectors also discussed the content of the report to determine if the
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applicant. thought any of the information was proprietary. The applicant responded that.none of=the information was proprietary.;
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ILLIN0IS POWER COMPANY
CLINTON POWER STATION EMERGENCY PLAN FIGURE 2-7
, EMERGENCY SUPPORT ORGANIZATION !
EMERGENCY MANAGER
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COOPERATIVE EXECUTIVE EOF MANAGEMENT ADMINISTRATIVE TECHNICAL REPRESENTATIVE SUPPORT ADVISOR EOF DIRECTOR v i i i i i EMERGENCY LICENSING EOF EMERGENCY _ PROTECTIVE' SECURITY NUCLEAR ADVISOR EMERGENCY ACTION ACTIONS SUPERVISOR INFORMATION ADVISOR LEVELE EVALUATOR COORDINATOR , EVALUATOR R
TECHNICAL INFORMATION LIAISON i l
_ RADIATION EOF EOF 4 PROTECTIO!3 ADMINISTRATIVE ENGI!1EERING -
SUPERVISOR SUPERVISOR SUPERVISOR DOSE EOF i
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EOF l ASSESSMENT _ COMMUNICATORS RECORDS EOF ADMINISTRATIVE - -
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- CONTROLS . - ADVISOR TO COORDINATOR STATE EO STATUS BOARD KEEPERS ENVIRONMENTAL LABORATORY . TECHNICAL
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COORDINATO ADVISOR TO ICRD ~
STATE REAC FROCESSORS
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NEMRK DECONTAMINATION . TECHNICAL COORDINATOR
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ADVISOR TO DEWITT I ( COUNTY EOC Q- /
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t FIGURE 2-6 STATION EMERCENCY RESPONSE GRGANIZATIOlj STATION EMERGENCY DIRECTOR
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EMERGENCY CSC E. RGENCY ADMINISTRATIVE ASSEfSME!!T OPERATIONS
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SUPERVISOR ADVISOR SUPERVISOR SUPERVISOR SUPERVISO SUPERVISCR
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MECHAt3ICAL -
COORDIt1ATOR -
E!1GINEEuMC .-
E!4ERGENCY COORDINATOR ENGIt!EER SPECIALTST TEAMS J
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NUCLEAR , COMPUTER - OPERATOR _ RADIOLOGICAL E!!GINEER -
OPERATOR / (RP) CO!!TROLS !.
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