ML17335A568

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Confirms Plans to Conduct Meeting with American Electric Power & DC Cook Plant Mgt to Discuss Status of Case Specific Checklist Items,Rev to Restart Plan,Operations Dept Readiness for Restart & Performance Assurance Audit Status
ML17335A568
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 10/19/1999
From: Anton Vegel
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Powers R
AMERICAN ELECTRIC POWER CO., INC.
References
NUDOCS 9910270125
Download: ML17335A568 (53)


Text

October 19, 1999 Mr. R. P. Powers Senior Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395

Dear Mr. Powers:

This letter confirms our plans to conduct a meeting with American Electric Power and D. C. Cook Plant management to discuss the status of Case Specific Checklist items, the revision to the Restart Plan, Operations Department readiness for restart, and Performance Assurance audit status and findings. Th'e meeting is scheduled for 1:00 p.m. (EST) on October 28, 1999, and willbe held at the Training Building onsite at the D. C. Cook facility. The meeting willbe open to the public.

Sincerely,

/s/A. Vegel A. Vegel, Chief Reactor'rojects Branch 6 Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 cc:

A. C. Bakken III, Site Vice President T. Noonan, Plant Manager M. Rencheck, Vice President, Nuclear Engineering R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division MI Department of State Police D. Lochbaum, Union of Concerned Scientists DOCUMENT NAME: G:>Cook<10-28 mtg Itr.wpd To receive a co of this document, indicate In the box "C" = Co w/o att/encl "E" = Co w/ati/encl "N"= No co OFFICE NAME DATE Rill Passehl:dp 10/I9/99 Rill Vegel 10$ /99 OFFICIALRECORD COPY 99i0270i25 9910i9 PDR ADQCK 050003i5 P

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JFS2 (Project Mgr.) (E-Mail)

J. Caldwell, Rill B. Clayton, Rill SRI D. C. Cook DRP DRS RIII PRR PUBLIMC-St~~+3 Docket File GREENS

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Item; ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003679242

Subject:

REVISION OF DONALDC. COOK RESTART INSPECTION SCHEDULE Page 1

Body:

Distri21.txt Docket: 05000315, Notes: N/A Docket: 05000316, Notes: NIA Page 2

January 25, 2000 Mr. R. P. Powers Senior Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395

SUBJECT:

REVISION OF DONALDC. COOK RESTART INSPECTION SCHEDULE

Dear Mr. Powers:

The purpose of this letter is to notify you of revisions to the Donald C. Cook (D. C. Cook)

Restart Inspection Schedule necessitated by your recent announcement of a delay in the restart dates for D. C. Cook Unit 2 and the need to conduct three followup inspections.

The followup inspections are necessary because actions to be reviewed had not been completed by your staff at the time of the previous inspections.

It is our understanding that the current Unit 2 restart schedule shows:

Fuel Load - March 5, 2000 Mode 4 - March 18, 2000 Mode 2 - March 31, 2000 Full Power - April 11, 2000.

As indicated, three followup inspections have been added to the schedule.

An Engineering Followup Team Inspection, an Emergency Operating Procedure Inspection and a Foilowup Surveillance Testing Inspection have been added.

The enclosure to this letter contains a revised restart inspection schedule for your information and identifies the new and revised inspection dates for the remaining inspections.

Ifyou have any questions regarding the NRC actions discussed above, please contact me at 630/829-9700.

R. Powers In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure willbe placed in the NRC Public Document Room.

Sincerely, ohn A. Grobe, Director Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosure:

As stated cc w/encl:

A. C. Bakken III, Site Vice President J. Pollack, Plant Manager M. Rencheck, Vice President, Nuclear Engineering R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division Ml Department of State Police D. Lochbaum, Union of Concerned Scientists Distribution:,

RRB1 (E-Mail)

WES (E-Mail)

JFS2 (Project Mgr.) (E-Mail)

J. Caldwell, Rill w/encl B. Clayton, Rill w/encl SRI D. C, Cook w/encl DRP w/encl DRS w/encl Rill PRR w/encl PUBLIC IE-01 w/encl Docket File w/encl GREENS DOCUMENT NAME: G:DRS'tDCC01& O.WPD To tecelvo a co ot this document, Indicate In the hotu 'C' without atlachmentlenctosure

'E' with attachmenUenctosure

'N ~ tto OFFICE NAME DATE Rill GShear:sd ts 01/ 4'00 Rill AVe el 01/z /00 Rill JGro 01/

OFFICIALRECORD COPY

Inspection Case Specific Checklist Items NRC Scheduled Ins ection Dates Team Size Corrective Action Program Team inspection Inspection Procedure (IP)

IP 40500 "Effectiveness of Licensee Controls in identifying, Resolving, and Preventing Problems" Design Control Team Inspection IP37550 "Engineering" IP 37700 "Design Changes and Modifications" IP 37001 10 CFR 50.59 Safety Evaluation Program" IP 92903 "Followup - Engineering" 2A (Failure to promptly identify and evaluate conditions adverse to quality) 4A (Failure to perform safety evaluation screenings) 4B (Inadequate safety evaluations).

08/30/99 through 09/23/99 COMPLETE 09/13/99 through 10/01/99 COMPLETE 4 Inspectors-TL-A.Dunlop 5 Inspectors-TL-Z.Falevits Ice Condenser Inspection IP 37550 "Engineering" IP 37700 "Design Changes and Modifications" IP 40500 "Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems" IP 92903 "Follow up - Engineering" 6 (Resolution of ice condenser issues) 12 (Resolution of containment liner pitting).

09/14/99 through 12/31/99 (intermittent)

COMPLETE 2 Inspectors-TL-M.Holmberg TL - Team Leader ATL-Assistant Team Leader

Inspection Instrument Uncertainty Inspection (IR99032)

IP 92903 "Follow up - Engineering" IP 93807 "Systems Sased Instrumentation and Control Inspection Case Specific Checklist Items 3C (Failure to consider instrument uncertainties, setpoints and/or instrument bias) 7 (Resolution of Non-Safety Related Cables Going to Shunt Trip Coils)

CAL item 9 (Instrument uncertainties incorporated into procedures and analysis).

NRC Scheduled Ins ection Dates 11/15/99 through 11/19/99 COMPLETE Team Size 2 Inspectors-TL-Z.Falevits TL - Team Leader ATL-Assistant Team Leader

PI

Inspection Case Specific Checklist Items NRC Scheduled Ins ection Dates Team Size Engineering Corrective Action Team Inspection (IR 99029)

IP 37550 "Engineering" IP 37700 "Design Changes and Modifications" IP 40500 "Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems" IP 92903 "Follow up - Engineering" 2B (Inadequate corrective actions for previously identified conditions adverse to quality) unintended changes in the plant design) 3B Failure to update the Updated Final Safety Analysis Report 3D (Inadequate consideration for system/component failure modes) 10 (Resolution of containment spray system operability issues) 8 (Resolution of hydrogen recombiner operability issues) 9 (Resolution of distributed ignition Technical Specification issues)

GALitems 1,2,3,5,6,7,8 11/29/99 through 12/17/99 COMPLETE 10 Inspectors TL-M.Farber ATL-J. Gavula TL - Team Leader ATL-Assistant Team Leader

Inspection Case Specific Checklist Items NRC Scheduled Ins ection Dates Team Size Surveillance Testing Inspection and Emergency Operating Procedure Program Inspection (IR 99033) 61726 "Surveillance Observations" 61725 "Surveillance Testing and Calibration Control Program" IP 42001 "Emergency Operation Procedures 1A (Inadequate instructions in surveillance tests) 18 (Acceptance criterion lack sufficient margin to analysis limit) 1C (Failure to meet technical specification requirements) 1D (Preconditioning of equipment prior to surveillance testing) 1E (Failure to assess and control the quality of contractors performing surveillance testing) 14D (Emergency operating procedures program ready for restart)

CALitem 4 (ES-1.3 Switchover to Recirculation Sump Procedure) 12/6/99 through 12/1 7/99 COMPLETE 4 Inspectors-TL - G.Hausman TL - Team Leader ATL-Assistant Team Leader

Inspection Case Specific CheckIist Items NRC Scheduled Ins ection Dates Team Size Programmatic Readiness Inspection (IR 99034)

Contractor Control Preventative Maintenance Electrical Coordination Operability Determinations Inspection IP 40500 "Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems" 14B (Contractor control program readiness for restart) 14C (Preventative maintenance program readiness for restart) 14F (Operability determination program-readiness for restart)

December 13-17, 1999 COMPLETE 4 Inspectors-TL - C.Lipa Engineering Followup Team Inspection (IR 200007)

IP 37550 "Engineering" IP 37700 "Design Changes and Modifications" IP 40500 "Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems" IP 92903 "Follow up - Engineering" 3A (Inadequate design control pertaining to uncontrolled and/or 11 (Resolution of hydrogen mitigation system operability and material condition issues) 14E (Electrical protection coordination including fuse/breaker control program readiness for restart) 01/24/00 - 02/25/00 6 Inspectors-TL-M.Holmberg TL - Team Leader ATL-Assistant Team Leader

Inspection Motor-Operated Valve Inspection (IR 200002)

Tl 2515/109 Safety-Related Motor-Operated Valve (MOV)Testing and Surveillance Case Specific Checklist Items CSC Item 16 (Resolution of operability of motor operated valves in the generic letter 89-10 program)

NRC ScheduIed Ins ection Dates 03/06/00 through 03/10/00 Team Size 3 Inspectors-TL - A.Dunlop Emergency Operating Procedures Followup Inspection (IR 2000010)

IP 42001 Emergency Operation Procedures Followup Surveillance Testing Inspection (IR 200008)

IP 61726 'Surveillance Observations IP 61725 "Surveillance Testing and Calibration Control Program CSC Item 14D (Emergency Operating Procedures program ready for restart) 1A (Inadequate instructions in surveillance tests) 1B (Acceptance criterion lack sufficient margin to analysis limit) 1C (Failure to meet technical specification requirements) 1D (Preconditioning of equipment prior to surveillance testing) 1E (Failure to assess and control the quality of contractors performing surveillance testing) 02/07/00 through 02/11/00 02/28/00 through 03/10/00 1 Inspector-R.Langstaff 2-inspectors-TL-G.Hausman CSC Item 14D (Emergency Operating Procedures program ready for restart)

TL - Team Leader ATL-Assistant Team Leader

Inspection Case Specific Checklist Items NRC Scheduled Ins ection Dates Team Size Restart Readiness Assessment Team Inspection (IR 20003)

IP 71707 "Plant Operations IP 93802 "Operational Safety Team Inspection IP 61726 Surveillance Observations IP 62707 Maintenance Observation IP 37550 "Engineering" Post-Restart Backlog Inspection (IR 20004)

CSC item 13B (System and containment final readiness review) 14G ( Programmatic final readiness reviews) 15B (Functional area final readiness reviews).

N/A 03/20/00 through 03/31/00 03/06/00 - 03/10/00 10 Inspectors-TL-J.Lara ATL-P.Lougheed 2 Senior Reactor Analysts-TL - S.Burgess TL - Team Leader ATL-Assistant Team Leader

S F

Distribution Sheet Distri96.txt Priority: Normal From: Stefanie Fountain Action Recipients:

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Item: ADAMS Document Library: ML ADAMS"HQNTAD01 ID: 003677166

Subject:

Predecisional Enforcement Conference (NRC OFFICE OF INVESTIGATIONCASE NO. 3-1998-041)

Body:

Docket: 05000315, Notes: N/A Docket: 05000316, Notes: N/A Page 1

,lt

January 14, 2000 EA 99-329 Mr. R. P. Powers Senior Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395

SUBJECT:

PREDECISIONAL ENFORCEMENT CONFERENCE (NRC OFFICE OF INVESTIGATIONSCASE NO. 3-1998-041)

Dear Mr. Powers:

This letter is in reference to an apparent violation of a U.S. Nuclear Regulatory Commission (NRC) requirement prohibiting discrimination against employees who engage in protected activities (i.e., 10 CFR 50.7, "Employee Protection" ). The apparent violation involved a Duke Engineering Services Inc. (DES) employee, who was fillingan American Electric Power (AEP) management position at the Buchanan engineering offices, terminating a Cataract contract engineer's employment.

Although the management individual was not a permanent American Electric Power employee, the NRC holds American Electric Power, as the licensee, responsible for ensuring compliance with NRC requirements by contract personnel.

On October 1, 1998, a Cataract engineer reported to work at the Buchanan facility. Following the individual reporting, the acting Nuclear Engineering Structural Design Manager, to whom the individual reported, learned that the engineer had been "trouble" at another NRC-regulated facilityand had "testified". On October 7, 1998, the acting manager terminated the individual's contract, purportedly because of a lack of "synergy". The NRC Office of Investigations conducted an investigation and the synopsis of their report and a summary of relevant facts are enclosed.

R. Powers Based on the results of the OI investigation, an apparent violation of 10 CFR 50.7 was identified and is being considered for escalated enforcement action in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy),

NUREG-1600, Revision 1. The NRC is not issuing a Notice of Violation at this time; AEP will be advised by separate correspondence of the results of our deliberations on this matter. Also, please be aware that the characterization of the apparent violation described in this letter may change as a result of further NRC review.

As requested by Mr. R. Gaston, D. C. Cook Regulatory Affairs Manager, on January 6, 2000, we willcontact your staff within five days of the date of this letter to schedule a transcribed predecisional enforcement conference with AEP to discuss this apparent violation. The conference will be held at the NRC Region III Office in Lisle, Illinois. Since the performance of certain AEP employees or personnel contracted to AEP will be discussed during the conference, the conference will be closed to public observation.

However, the former acting Nuclear Engineering Structural Design Manager willbe invited to attend.

In addition, Duke Engineering Services, Inc., and Cataract, Inc., as interested parties, have been invited to send representatives.

Also, as discussed between Ms. Patricia Lougheed of my staff and Mr. R.

Gaston on January 12, 2000, AEP is requested to bring a specified employee to the enforcement conference.

The NRC's Enforcement Policy permits the individual who was the subject of the alleged discrimination to participate in the conference.

Accordingly, the complainant will be invited to attend the conference.

He may participate by observing the conference and ifdesired, following the presentation by AEP,'s well as any presentations by either Duke Engineering Services, Inc., or Cataract, Inc., should either party choose to make one, the individual may make a presentation to address his view on why he believes discrimination occurred and his views on the AEP presentation.

American Electric Power Company willthen be afforded an opportunity to respond, and the NRC may ask some clarifying questions.

In no case willthe NRC staff permit AEP or the complainant to cross-examine or question each other.

The decision to hold an enforcement conference does not mean that the NRC has determined that a violation has occurred or that enforcement actions will be taken. This conference is being held to ensure a common understanding of the facts, root causes, significance of the issue and, ifnecessary, plans for lasting and effective corrective action. Only then will NRC make its enforcement decision.

In addition, this is an opportunity for you to point out any errors in our investigation findings and for you to provide any information concerning your perspectives on: (1) the severity of the violation; (2) the application of the factors that the NRC considers when it determines the amount of a civil penalty that may be assessed in accordance with Section VI.B.2 of the Enforcement Policy; and (3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.

Finally, a violation of 10 CFR 50.7, ifit occurred, could have a chilling effect on other employees in that it might deter them from identifying any nuclear safety related concerns they may have.

Therefore, we request that at the conference you address the actions taken or planned to correct any perceived chilling effect upon other employees.

ENCLOSURE 1 SYNOPSIS This investigation was initiated by the U.S. Nuclear Regulatory Commission, Office of Investigations (Ol), Region III (Rill), on November 16, 1998, to determine whether a contract engineer employed by Cataract, Inc., assigned to D. C. Cook Nuclear Power Plant, American Electric Power, in Buchanan, Michigan, was discriminated against because of his previous whistle blowing activities.

Based on the evidence developed during this investigation, Ol:Rillsubstantiated the allegation that a contract engineer employed by Cataract, Inc., assigned to D. C. Cook Nuclear Power Plant, American Electric Power was discriminated against by a contract engineering manager because of his previous whistle blowing activities.

Case No. 3-1998-041

R. Powers In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter without will be placed in the NRC Public Document Room (PDR). The NRC willdelay deciding whether to place a copy of Enclosure 2 in the PDR until a final enforcement decision has been made.

Sincerely, John A. Grobe, Director Division of Reactor Safety Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74

Enclosures:

1. Ol Report Synopsis
2. Summary of Ol Report cc w/encl 1:

A. C. Bakken lll, Site Vice President J. Pollock, Plant Manager M. Rencheck, Vice President, Nuclear Engineering R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division Ml Department of State Police D. Lochbaum, Union of Concerned Scientists DOCUMENT NAME: G:DRSiE99-329.WPD To receive s co of this document the botu "t

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R. Powers ENCLOSURE 2 IS NOT FOR PUBLIC RELEASE WITHOUTTHE APPROVAL OF THE DIRECTOR NRC OFFICE OF ENFORCEMENT Distribution with Enclosures 1 arid 2:

Office of Enforcement M. Stein, OE D. Dambly, OGC S. Chidakel, OGC J. L. Caldwell, Rill OE:EA(2)

Distribution with Enclosure 1 ONLY:

Public Docket ile IEO (e-mail)

DOCDESK (e-mail)

Resident Inspector, D. C. Cook J. Stang, NRR S. Bajwa, NRR SLO:RIII PAO.RIII OAC:RIII PRR:RIII DRP:RIII DRS:RIII

Distri60.txt Distribution Sheet Priority: Normal From:

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Item:

ADAMS Package Library: HL ADAMS"HQNTAD01 ID: 993440494

Subject:

Emergency Preparedness-Appraisal/Confirmatory Action Ltr/Exercise Rept

/Etc.

Body:

PDR ADOCK 05000315 F

Docket:

05000315, Notes:

N/A Docket:

05000316, Notes:

N/A Page 1

December 3, 1999 Mr. R. P. Powers Senior Vice President Nuclear Generation Group American Electric Power Company 500 Circle Drive Buchanan, Ml 49107-1395

SUBJECT:

NRC D. C. COOK EMERGENCY PREPAREDNESS EXERCISE INSPECTION REPORT 50-315/99030(DRS); 50-316/99030(DRS)

Dear Mr. Powers:

On October 28, 1999, the NRC completed an inspection of an emergency preparedness exercise at your D. C. Cook Nuclear Power Plant. The purpose of this inspection was to evaluate the performance of your emergency response organization during the exercise.

No violations were identified during the inspection.

However, two Exercise Weaknesses were identified. The enclosed report presents the results of the inspection.

Areas examined during the emergency preparedness exercise are identified in the report.

Within those areas, the inspection consisted of a selective examination of procedures and representative records, observation of performance, and interviews with staff. The objective of the inspection was to determine whether the D. C. Cook Nuclear Power Plant Emergency Plan was adequate and ifstation personnel properly implemented the Emergency Plan in accordance with NRC requirements during the exercise.

Overall licensee performance during the 1999 exercise was adequate.

The exercise was considered a successful demonstration of implementation of the Emergency Plan. Staff performance in the various evaluated emergency response facilities was generally effective.

Two Exercise Weaknesses were identified concerning the failure to effectively communicate the status of implant repair activities to the control room and the failure to timely relieve control room personnel of the responsibility to transmit notification forms to the State of Michigan. An Exercise Weakness is a finding that could have precluded effective implementation of the Emergency Plan in the event of an actual emergency.

The Weaknesses are summarized in the Appendix to this letter. As required by 10 CFR 50, Appendix E (IV.F), any Weaknesses that are identified must be corrected.

Facility critiques following termination of the exercise were self-critical and detailed and the consolidated critique meeting provided an excellent discussion of exercise strengths, weaknesses, and concerns.

R. Powers In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Sincerely, Original Signed By John A. Grobe Docket Nos. 50-315; 50-316 License Nos. DPR-58; DPR-74 John A. Grobe, Director Division of Reactor Safety

Enclosures:

1. Exercise Weaknesses
2. Inspection Report 50-315/9930(DRS); 50-316/99030(DRS) cc w/encls:

A. C. Bakken III, Site Vice President T. Noonan, Plant Manager M. Rencheck, Vice President, Nuclear Engineering R. Whale, Michigan Public Service Commission Michigan Department of Environmental Quality Emergency Management Division Ml Department of State Police D. Lochbaum, Union of Concerned Scientists W. Curtis, FEMAV Distribution:

RRB1 (E-Mail)

RPC (E-Mail)

JFS2 (Project Mgr.) (E-Mail)

J. Caldwell, Rill w/encls B. Clayton, Rill w/encls SRI D. C. Cook w/encls DRP w/encls DRS w/encls Rill PRR w/encls PUBLIC IE-35 w/encis Docket File w/encls GREENS IEO (E-Mail)

DOCDESK (E-Mail)

DOCUMENT NAME: G:DRSttDCC99030.WPD To receive s co of this document, Indicate In the botu C'

without attachment/endostNe

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with sttschmcnVenctosure N'

No OFFICE RIII NAME J Foster:uf/

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~>O/99 Rill GShear cW 12/I /99 Rill JGr OFFICIALRECORD COPY

EXERCISE WEAKNESS During the evaluated exercise conducted on October 26, 1999, the following Exercise Weaknesses were identified. As required by 10 CFR 50, Appendix E (IV.F), any Weaknesses that are identified must be corrected.

Operations Staging Area personnel failed to communicate the status of assigned actions to the Technical Support Center and Control Room Simulator in an effective manner.

Because of delays in obtaining repair team status reports, the control room staff vented nitrogen to the containment atmosphere.

This unnecessary venting of additional non-condensible gases to the containment could have exacerbated control of containment pressure during an event. The inspectors identified the failure of Operations Staging Area personnel to effectively communicate the status of repair teams as an Exercise Weakness.

This item was tracked as an Inspection Followup Item (IFI 50-315-99030-01; 50-316/99030-01).

There was a delay in restoring an Emergency Operations Facility dose projection computer to service and accepting responsibility for state notification form transmittal utilizing that computer.

As a result, AuxiliaryEquipment Operators (AEOs) in the Control Room Simulator continued generating and transmitting forms to offsite officials for approximately 40 minutes after Emergency Operations Facility personnel assumed overall command of event response.

The inspectors identified the failure to timely relieve the Simulator Control Room shift staff of the responsibility to transmit notification forms to the State of Michigan as an Exercise Weakness.

This item was tracked as an Inspection Followup Item (IFI 50-315/99030-04; 50-316/99030-04).

U.S. NUCLEAR REGULATORYCOMMISSION REGION III Docket Nos:

License Nos:

50-315; 50-316 DPR-58; DPR-74 Report No:

50-315/99030(DRS); 50-316/99030(DRS)

Licensee:

Indiana & Michigan Power Company (American Electric Power)

Facility:

D. C. Cook Nuclear Power Plant Location:

1 Cook Place Bridgman, Ml 49106 Dates:

October 25-28, 1999 Inspectors:

J. Foster, Sr. Emergency Preparedness Analyst R. Jickling, Emergency Preparedness Analyst D. Funk, Emergency Preparedness Analyst T. Ploski, Emergency Response Coordinator B. Bartlett, Senior Resident Inspector K. Coyne, Resident Inspector Approved by:

Gary L. Shear, Chief, Plant Support Branch Division of Reactor Safety

EXECUTIVE

SUMMARY

D. C. Cook, Units 1 and 2 NRC Inspection Report 50-315/99030(DRS); 50-316/99030(DRS)

This inspection consisted of evaluating the licensee's performance during an exercise of the Emergency Plan, The inspection was conducted by four regional inspectors, a Senior Resident Inspector, and a Resident Inspector.

No violations of NRC requirements were identified.

Overall licensee performance during the 1999 exercise was adequate.

The exercise was considered a successful demonstration of implementation of the Emergency Plan.

(Section P4.1.c)

Performance of shift personnel in the Control Room Simulator was effective. The shift manager and unit supervisor consistently displayed effective command and control of the operators.

(Section P4.1.c)

The Technical Support Center (TSC) staffs overall performance was effective. The TSC personnel demonstrated effective communications and teamwork.

(Section P4.1.c)

Overall performance of Operations Staging Area (OSA) management and staff was competent.

Personnel were focused on the emergency and their duties, and teamwork was evident.

(Section P4.1.c)

An Inspection followup item was identified in the OSA concerning the slow dispatch of some inplant repair teams.

(Section P4.1.c)

Performance in the Emergency Operations Facility (EOF) was good. The EOF management successfully overcame several staffing and equipment problems.

An inspection followup item was identified in the EOF relative to the proficiency of dose assessment personnel in utilizing the dose assessment program.

(Section P4.1.c)

An Exercise Weakness was identified concerning the failure of OSA staff to effectively communicate the status of inplant repair teams.

(Section P4.1.c)

An Exercise Weakness was identified concerning untimely relief of the Control Room Simulator staff of the responsibility to transmit notification forms to the State of Michigan. (Section P4.1.c)

The participants and controllers initial facilitycritiques following termination of the exercise were self-critical and detailed.

An excellent consolidated critique meeting with participants provided a detailed discussion of strengths, weaknesses, and concerns.

The critiques included inputs from controllers and exercise participants.

Overall licensee critique findings were consistent with the NRC evaluation team's findings. (Section P4.1.c)

Re ort Details IV. Plant Su ort P3 Emergency Preparedness Procedures and Documentation P3.1 Review of Exercise Ob'ectives and Scenario 82302 The inspectors reviewed the 1999 exercise's objectives and scenario and determined that the exercise would acceptably test major elements of the licensee's emergency plan. The scenario provided a sufficiently challenging framework to support demonstration of the licensee's capabilities to implement its emergency plan. The scenario included several equipment failures and a large radiological release.

P4 Staff Knowledge and Performance in Emergency Preparedness P4.1 1999 Evaluated BiennialEmer enc Pre aredness Exercise Ins ection Sco e 82301 Appendix E to 10 Code of Federal Regulations (CFR) Part 50 requires that power reactor licensees conduct biennial exercises that involve participation by offsite authorities.

On October 26, 1999, the licensee conducted a biennial exercise involving partial participation by the State of Michigan, and full participation by Berrien County responders.

This exercise was conducted to test major portions of the licensee's onsite and offsite emergency response capabilities.

Onsite and offsite emergency response organizations and emergency response facilities were activated.

The inspectors evaluated performance in the following emergency response facilities:

~

Control Room Simulator (CRS)

~

Technical Support Center (TSC)

~

Operations Staging Area (OSA)

~

Emergency Operations Facility (EOF)

The inspectors assessed the licensee's recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command-and-control, the transfer of emergency responsibilities between facilities, communications, and the overall implementation of the emergency plan.

In addition, the inspectors attended the post-exercise critiques in each of the above facilities to evaluate the licensee's initial self-assessment of exercise performance.

b.

Emer enc Res onse Facili Observations and Findin s b.1 Control Room Simulator Exercise staff performance in the Control Room Simulator (CRS) was effective. The shift manager and unit supervisor consistently displayed effective command and control of the operators.

Operators consistently used three-way communications.

Periodic shift management briefings kept personnel aware of current conditions, priorities and desired goals.

Operator statements and actions indicated a detailed understanding of developing plant conditions.

In general, significant changes in plant status were immediately reported to shift management.

The inspectors noted one occasion when a reactor operator delayed informing the shift management of a problem involving the operation of the hydrogen recombiners.

Following the receipt of a recombiner high temperature alarm, the inspectors observed the indicated recombiner temperature exceeding the 1400'F maximum operating temperature specified in Annunciator Response Procedure (ARP) 02 Operations Head Procedure (OHP) 4024.203, "Annunciator 0203 Response:

Ventilation," Revision 5. Despite repeated recombiner power reductions by the reactor operator, the indicated recombiner temperature continued to exceed 1400'F. The operator did not promptly report the high temperature condition or the difficultyin controlling recombiner temperature to the unit supervisor or shift manager.

During discussions with the simulator controllers, the inspectors learned that the simulator did not accurately model the expected behavior of the hydrogen recombiners.

The licensee critique additionally indicated that some of the recombiner switches in the simulator have malfunctioned, and replacements were on order. The licensee had previously documented the need to upgrade the simulator hydrogen recombiner temperature indication in simulator change request number 98091, dated September 21, 1998.

Operators proficiently utilized their procedures, including emergency operating procedures and emergency plan implementing procedures.

CRS personnel properly diagnosed reactor events at the Alert and Site Area Emergency levels, and correct emergency classifications were made in a timely manner.

Event notification message forms and verbal communications to State of Michigan and the NRC personnel were completed in a detailed and timely manner.

Transfer of command and control of emergency responsibilities from the Acting Site Emergency Coordinator (Shift Manager) to the TSC's Site Emergency Coordinator (as the TSC was ready for assumption of command and control of response efforts) was orderly and timely. Communications between the CRS and TSC staffs were maintained throughout the exercise, but information and status reports were sometimes delayed.

The inspectors noted that information concerning reactor plant and repair team status was not consistently communicated between the CRS and other emergency response facilities in a timely manner.

Examples of communications problems included the following:

The TSC staff continued to prioritize a repair team activity involving the opening of a failed reactor trip breaker after the activity was no longer required to support plant operation.

CRS management requested a repair team to open the failed trip breaker to support reset of a safety injection signal and subsequent switchover to cold leg recirculation. At 9:15 a.m., per the scenario, the exercise controllers opened the trip breaker, which then allowed the reactor operators to successfully reset the safety injection signal. The TSC staff continued to track the dispatch of the trip breaker repair team for an additional twenty minutes after the trip breaker was opened.

Because of delays in obtaining repair team reports from the OSA, the control room staff was unsure ifthe accumulators would be isolated in a timely manner.

The CRS Assistant Shift Manager requested a repair team to energize the accumulator discharge motor operated valves in order to isolate the safety injection accumulators in accordance with procedure 02-OHP 4023.E-1, "Loss of Reactor or Secondary Coolant," Revision 8, Change 1, step 16.

In order to prevent entry of nitrogen from the accumulators into the reactor coolant system, the operators vented nitrogen to the containment atmosphere in accordance with the emergency operating procedure.

The unnecessary venting of additional non-condensible gases to the containment could have exacerbated control of elevated containment pressure during an event.

However, at the time of the venting, containment pressure was less than 5 psig. The licensee initiated Condition Report (CR) P-99-26485 to address the failure of the OSA staff to communicate the status of assigned actions to the TSC and CRS. The inspectors identified the failure of OSA staff to effectively communicate the status of repair teams as an Exercise Weakness.

This item was tracked as an Inspection Followup Item (IFI 50-315/99030-01; 50-316/99030-01).

Initial dose projections were made in the CRS utilizing the Dose Assessment Program.

However, due to significant delays in the transfer of state facsimile communications from the CRS to the EOF, the non-licensed AuxiliaryEquipment Operators (AEOs), who were providing communications, were prevented from being reassigned to other response activities. This is discussed further in the EOF observations and findings section (b.4).

b.2 Technical Su ort Center The Technical Support Center (TSC) staff's overall performance was effective.

Activation of the facilitywas rapid and efficient. Minimum staffing was achieved within ten minutes of the Site Area Emergency declaration.

The TSC's Site Emergency Coordinator (SEC) accepted command and control of accident response within twenty-six minutes of the Site Area Emergency declaration.

Command and control of the facility by the SEC was good. The initial briefing defined plant status and provided guidance to the TSC staff. Subsequent, periodic briefings were concise and informed the staff of current status, priorities, and issues.

Significant changes in plant conditions were promptly announced as they occurred, instead of waiting for the next briefing.

Status boards were effectively maintained and updated, with one exception of the Emergency Status Board. Conversely, the Tasks and Priorities status board continuously tracked the OSA repair teams'riorities and status.

Transfers of emergency responsibility from the CRS to the TSC and to the'EOF were crisp and occurred in a seamless manner.

The SEC ensured the staff was aware of the current status of communications and which facilitywas responsible for the next notifications.

TSC personnel demonstrated effective communications and teamwork. The SEC maintained headset communications with CRS and EOF staffs, to provide and receive current emergency conditions.

Noise levels were maintained appropriately low. When necessary, the SEC emphasized the need for reduced noise levels.

Relative priorities assigned by TSC management did not seem to have any impact on the OSA's emergency response teams dispatch times. The SEC did not emphasize to the OSA manager the need to dispatch teams more expeditiously.

The Radiation Assessment Coordinator (RAC) maintained appropriate awareness of plant and offsite radiological conditions.

For example, security officers were told early in the exercise to put on electronic dosimeters which aided in determining onsite radiation levels. The RAC also requested the TSC managers to expedite evacuation of non-essential personnel before radiation levels affected the primary evacuation route.

The Emergency Response Data System was rapidly activated.

The system experienced some technical difficulties that caused the system to disconnect twice. The system responded as designed, and automatically reconnected to the NRC system.

Plant personnel accountability was not accomplished within the goal specified in'rocedure PMP 2081 EPP.103, revision 3, dated May 11, 1999, "Assembly, Accountability, and Evacuation of Plant Personnel."

Section 5.6.2 specified that accountability be accomplished within thirty (30) minutes of the start of an emergency.

A simulated accountability was reported as being completed approximately'57 minutes after declaration of the Site Area Emergency.

b.3 0 erational Sta in Area OSA and Emer enc Res onse Teams The overall staff performance in the OSA was competent.

Personnel were focused on the emergency and their duties.

Teamwork among the staff in the facilitywas evident.

Setup and activation of the facilitywas rapid, with personnel arriving within six minutes of the Site Area Emergency declaration.

Facility staff appropriately signed in on the facilitysign in status board as they arrived at the OSA. The facilitywas staffed and effectively activated within 31 minutes of the emergency declaration, well within the one hour requirement.

Upon arrival, the Radiation Protection Director (RPD) proactively coordinated staff activation activities, verified that radiation protection technicians, chemistry technicians, and maintenance personnel were prepared for response, and then initiated access control at both ends of the facility.

Offsite Monitoring Teams efficiently prepared their equipment, obtained briefings from the RPD, and were dispatched within 39 minutes of the Site Area Emergency declaration.

Control of the offsite teams wa~ accomplished by a radio operator, who performed his responsibilities well. The RPD and Skills Supervisor provided detailed briefings to all monitoring teams dispatched from the OSA.

Facility command and control by the OSA Manager (OSAM) was generally good.

Periodic briefings were concise; however, not all staff were attentive, as they continued their phone communications and discussions.

The OSAM and Assistant OSAM effectively communicated with the TSC regarding response team requests and team priorities. Facility status boards were well maintained and continuously updated.

This became important when TSC management directed the OSA management to change numerous response teams priorities prior to the teams'ispatch.

Frequent habitability surveys were conducted in the OSA.

Dispatch of some response teams was untimely. Examples included response team number three, assigned to open a reactor trip breaker, which was initiallyidentified as a priority three team, was later changed to a priority two team, and changed again to a priority one team.

Response

team number three was then placed on standby due to high radiation levels and was never dispatched from the OSA. Response teams took between 26-58 minutes to dispatch from the time they were requested by the TSC. The licensee's evaluation and corrective actions for the untimely dispatch of OSA teams will be tracked as an Inspection Followup Item (IFI 50-315/99030-02; 50-316/99030-02).

Priorities assigned to response teams had no apparent impact on the timeliness of team dispatch.

Independent of the team's priority, team selection, donning of protective clothing, obtaining a detailed briefing, and obtaining appropriate tools or equipment took a certain amount of time. This amount of time was not affected by the priorities assigned to the OSA response team as indicated by the above dispatch times. As an example, response team number five, identified as the "highest priority"took 40 minutes to dispatch after being requested by TSC management.

The inspector accompanied response team number five from selection to briefing, dispatch, completion of task, return to the OSA, and debriefing. The briefing was comprehensive, including task specifics, location and route to the equipment involved,

~

requested communications frequency, turnback dose/dose rates, wind direction, dose rates expected, plant conditions, and protective clothing. Good radiological practices were used as the approach to the area was continuously monitored by a radiation protection technician (RPT). When the team concluded their observations and communicated back to the OSA, they were advised that a radiological release had been reported.

The area dose rates were checked and the team discovered they were in a radiation field of 84 rem per hour. They immediately proceeded to a low dose area where they reestablished communications with the OSA for additional directions.

Upon the team's request to return to the facility, the RPT reported that they had been downwind of the release and may have been contaminated.

An OSA manager indicated an appropriate return route through the plant, where they were to remove their protective clothing and respirators and obtain contamination surveys.

r Good decontamination discussions by the RPD and the response team were noted by the inspector when the team was found to be contaminated.

A thorough debriefing was conducted for the returning team, which included the team's observations, doses received, dose rates observed in the field, and status of team members'ontamination.

b.4 Emer enc 0 erations Facilit EOF The EOF had been relocated to the licensee's offices in Buchanen, Michigan since the last (1997) NRC-evaluated exercise.

The EOF's layout facilitated information sharing among response team members, and included work space for more private telecommunications with senior State officials and discussions between senior EOF responders.

During the first two hours of the exercise, EOF management successfully overcame several, EOF staffing and equipment problems.

For example, the Recovery and Control Manager (RCM), EOF Manager, and Communications Director monitored ongoing EOF staffing by pre-selected personnel and determined that the senior of three key protective measures staff would not be reporting for duty due to (actual) illness.

Faced with a decision of whether to delay declaring the EOF fullyoperational and allowing EOF staff to reduce the burdens on onsite responders, the RCM correctly conferred with available protective measures staff and decisively appointed one of them to lead the group until another qualified, senior staff member could report to the EOF.

The RCM became concerned with the operability problems of two desk top computers used to perform offsite dose projections.

Associated software provided the capability of printing offsite dose projection data directly on the form used to transmit updated event-related information to State officials at 15 minute intervals. The RCM had to encourage a computer specialist and protective measures staff to increase their efforts to restore at least one of,these computers to more than intermittent service.

Dose assessment personnel initiallydid not appear to be proficient in the use of the Dose Assessment Program (DAP). The proficiency of dose assessment personnel in use of the dose assessment program will be tracked as an Inspection Followup Item (IFI 50-315/99030-03; 50-316/99030-03).

A negative impact resulting from the delay in EOF staff restoring a dose projection computer to continuous service was that AuxiliaryEquipment Operators (AEOs) in the CRS were told to continue generating and transmitting the 15 minute message forms to offsite officials for about 40 minutes after the EOF's RCM assumed overall command of the licensee's event response.

Apparently, TSC staff were unable to relieve the AEOs

of this notification task so that the AEOs could be assigned to other duties. The inspectors identified the failure to relieve the CRS shift staff, in a timely fashion, of the responsibility to transmit notification forms to the State of Michigan as an Exercise Weakness.

This item is tracked as an Inspection Followup Item (IFI 50-315/99030-04; 50-316/99030-04).

Coordination of the shift of notification form transmission was ineffective. As a result, between 9:50 a.m. and 10:30 a.m., offsite officials received three update message forms from CRS staff and three update message forms from EOF staff. The transmittal of update message forms from two response facilities resulted in offsite officials being given conflicting wind speed and direction information. The CRS staff's three message forms included incorrect wind directions from 282 to 286 degrees and incorrect wind speeds of 7.6 to 8.1 miles per hour, while EOF's staff's corresponding message forms included the correct 315 degrees wind direction and correct wind speed of 9 miles per hour. This was an "exercise artifact," as the meteorological information transmitted by CRS staff represented actual conditions, while the information transmitted by EOF staff represented conditions postulated in the exercise's scenario.

The RCM demonstrated effective command and control of the EOF staff and was decisive when correctly making major decisions.

He clearly communicated his expectations to EOF staff and promptly informed them of significant changes in plant status, major decisions, and higher response priorities. The RCM closely monitored emergency classification criteria related to the status of the three fission product barriers.

The RCM correctly declared a General Emergency within 15 minutes of the existence of the related degrades in plant conditions and quickly selected a procedurally correct offsite Protective Action Recommendation (PAR).

Telephone communications with State officials following major changes in plant status and major decisions were timely and accurate.

The RCM personally informed his State counterpart of the General Emergency declaration, its bases, the related PAR, and the correct wind direction. The RCM also communicated changes to the release's status and top priorities to his State counterpart and correctly responded to questions.

When a county official requested guidance on a radiological exposure control concern, several EOF staff promptly interfaced and correctly forwarded this concern to State, Emergency Operations Center counterparts for resolution.

The use of status boards within the EOF varied in quality. Status board writers were relatively slow to post information on the Emergency Action Level associated with the Shift Manager's Site Area Emergency declaration.

Several status boards were effectively used to depict the licensee's PAR versus protective actions chosen for implementation by State officials. In contrast, chronological event information posted on an electronic copy board was less valuable.

Relevant times were not always posted with information printed on this copy board.

Although information about inplant damage control teams was occasionally posted on this status board, the information did not always indicate whether an inplant team's mission was successful or whether a listed team had yet been dispatched.

Although a meteorological forecast was obtained, it was not posted on an EOF status board.

After the simulated release was terminated, the RCM assigned select EOF staff to an initial onsiterecoveryplanning team. Therelevantprocedurewasreviewed.

The recovery planning staff and the senior State official were correctly advised that the situation should remain classified as a General Emergency and that no relaxation to the current offsite PAR was prudent.

The recovery planning staff acceptably discussed higher priority action items, including assessing the extent of fuel damage and options for reducing radiation levels within the containment building. It was correctly concluded that any decision to initiate a controlled release of radioactive gas from containment must first be discussed with State, local, and Federal officials.

b.6 Scenario and Exercise Control The exercise scenario was challenging and exercised the majority of the licensee's emergency response capabilities.

The scenario included several equipment failures, and a major radiological release.

No instances of controller prompting were observed.

b.7 Licensee Criti ues The inspectors attended the licensee's self-critiques in the CRS, TSC, OSA, and EOF which occurred immediately after the exercise.

Exercise controllers solicited verbal and written inputs from the participants in addition to providing the participants with the controllers'nitial assessments of personnel performance.

The inspectors concluded that these initial critiques were self-critical, thorough and in close agreement with the majority of the inspectors'bservations.

A common theme among the critiques was that some of the pagers did not work during emergency response organization activation and the pager codes were unfamiliar.

Summa of Conclusions Evaluation of the license's exercise performance was as follows:

Overall licensee performance during the 1999 exercise was adequate.

The exercise was considered a successful demonstration of implementation of the Emergency Plan.

Performance of shift personnel in the Control Room Simulator was effective.

The shift manager and unit supervisor consistently displayed effective command and control of the operators.

The Technical Support Center staff's overall performance was effective. TSC personnel demonstrated effective communications and teamwork.

Overall performance of OSA management and staff was competent.

Personnel were focused on the emergency and their duties. Teamwork was evident. An Inspection followup item was identified relative to the slow dispatch of some inplant repair teams.

Performance in the Emergency Operations Facility was good.

EOF management successfully overcame several EOF staffing and equipment 10

problems.

An inspection followup item was identified relative to the proficiency of dose assessment personnel in utilizing the dose assessment program.

Two Exercise Weaknesses were identified relating to (1) communicating to the CRS shift staff the status of completion of inplant repair team assigned tasks, and (2) untimely relief of the Simulator Control Room shift staff of the responsibility to transmit notification forms to the State of Michigan.

The participants'nd controllers'nitial facilitycritiques following termination of the exercise were self-critical and detailed.

An excellent consolidated critique meeting with participants provided a detailed discussion of strengths, weaknesses, and concerns.

The critiques included inputs from controllers and exercise participants.

Overall licensee critique findings were consistent with the NRC evaluation team's findings.

P8 Miscellaneous EP Issues P8.1 Closed Ins ection Followu Item No. 50-315/97013-02 50-316/97013-02:

During the 1997 exercise, the licensee identified that a controller had to intervene during PAR development when containment radiation levels exceeded 25,000 Rem/hour in the containment building. Exercise participants were aware that a revised PAR was required, but an attachment to the procedure proved confusing.

During this exercise, procedurally correct PARs were determined in a timely manner.

This item is closed.

P8.2 Closed Ins ection Followu Item No. 50-315/97013-03 50-316/97013-03:

During the 1997 exercise, there were several instances where the licensee's exercise controllers simulated the response teams to fixneeded equipment to keep the exercise timeline on track. Controllers injected this information without informing other participants.

During

. this exercise, controllers properly controlled the progression of the scenario.

This item is closed.

V. Mana ement Meetin s X1 Exit Meetin Summa The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on October 28, 1999. The inspection team leader stated that overall exercise performance was good, two Exercise Weaknesses (Inspection Followup Items) had been identified, and the licensee critiques were effective. The licensee acknowledged the preliminary findings presented.

The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

No proprietary information was identified.

11

PARTIALLIST OF PERSONS CONTACTED Licensee C. Bakken, Site Vice President S. Chambers, Radiation Protection R. Cook, Regulatory Affairs Compliance Engineer R. Gaston, Compliance Manager R. Krieger, SPS W. Kropp, Performance Assurance D. Kunsemiller, Technical Assistant to Senior Vice President D. Loope, SPS M. Marano, Director Business Affairs W. McRae, RA T. Noonan, Plant Manager J. Pollock, Director, Performance Assurance M. Rencheck, Vice President, Engineering J. Smith, SPS C. Vanderniet, Performance Assurance G. Vaughn, Vice-President, Central and Southwest Utilities L. Weber, Operations Manager L. Wolf, Radiochemist D. Wood, Radiation Protection Superintendent Those listed were present at the October 28, 1999, exit meeting.

NRC J. Grobe, Director, Division of Reactor Safety, Region III INSPECTION PROCEDURES USED IP 82301:

Evaluation of Exercises for Power Reactors IP 82302:

Review of Exercise Objectives and Scenarios for Power Reactors 12

~oened 50-315/316/99030-01 50-315/316/99030-02 50-315/316/99030-03 50-315/316/99030-04 Closed 50-315/316/97013-02 50-315/316/97013-03 Discussed ITEMS OPENED, CLOSED, AND DISCUSSED IFI Exercise Weakness, the failure of the OSA staff to effectively communicate the status of repair teams.

IFI The untimely dispatch of OSA teams.

IFI The proficiency of dose assessment personnel in use of the DAP.

IFI Exercise Weakness, the failure to relieve the CRS shift staff, in a timely fashion, of the responsibility to transmit notification forms to the State of Michigan.

IFI During the 1997 exercise, a controller had to intervene during PAR development; a revised PAR was required, but an attachment to the procedure proved confusing.

IFI During the 1997 exercise, there were several instances where exercise controllers injected information without informing other participants.

None.

13

LIST OF ACRONYMS USED AEO ARP CFR CR CRS DAP DPR DRS EOF FEMA IFI NRC NRR OHP OSA OSAM PAR

'DR PRR PSIG RAC RCM RPD RPT SEC SRI TSC AuxiliaryEquipment Operator Annunciator Response Procedure Code of Federal Regulations Condition Report Control Room Simulator Dose Assessment Program.

Demonstration Power'eactor Division of Reactor Safety Emergency Operations Facility Federal Emergency Management Agency Inspection Follow up Item Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Operations Head Procedure Operations Staging Area

'perations Staging Area Manager Protective Action Recommendation NRC Public Document Room Public Reading Room Pounds per square inch, gage Radiation Assessment Coordinator Recovery and Control Manager Radiation Protection Director Radiation Protection Technician Site Emergency Coordinator Senior Resident Inspector Technical Support Center