IR 05000305/1985009

Insp Rept 50-305/85-09 on 850729-0802.Violation Noted: Failure to Evaluate All Required Areas During Annual Review of Emergency Preparedness Program.Unresolved Item Re Independence of Reviewers Performing Review Noted

ML20137D957
Person / Time
Site:	Kewaunee
Issue date:	08/15/1985
From:	Brown G, Phillips M, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137D908	List: IR 05000305/1985009 IR 05000729/2008002 ML20137D903 ML20137D928
References
50-305-85-09, 50-305-85-9, NUDOCS 8508230096
Download: ML20137D957 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/85009(DRSS)

Docket No. 50-305 License No. OPR-43 Licensee: Wisconsin Public Service Corporation Post Office Box 19002 Green Bay, WI 54307-9002 Facility Name: Kewaunee Nuclear Power Plant Inspection At: Kewaunee Site, Two Creeks, WI Inspection Conducted: July 29 through August 2, 1985 Inspectors: W eh S/er/ar Team Leader ' Date br Sbf/ar Date Approved By: bh , Chef Emergency Preparedness Section WIf/af Date Inspection Summary Inspection on July 29 through August 2, 1985 (Report No. 50-305/85009(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the emergency preparedness program: emergency detection and classification; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); licensee audits; maintaining emergency preparedness; and, licensee actions on previously itentified items. The inspection involved 126 inspector-hours onsite by two NRC inspectors and two consultant Results: One violation was identified for the failure to evaluate all the required areas during the annual review of the emergency preparedness program (licensee audits); an Unresolved Item was i@ itified concerning the independence of the reviewers performing the annual review of the emergency preparedness program (licensee audits); and, a Deviation from a Commitment was identified for falling to complete a task by the committed time (changes to the emergency preparedness program). No violations or deviations were identified in the remaining areas inspecte PDH ADOCK 05000305 O PDR

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DETAILS l 1. Persons Contacted D. Hintz, Manager Nuclear Power l *C. Steinhardt, Plant Manager

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• J. Morrison, Assistant to the Manager Nuclear Power

• M. Marchi, Assistant Manager Plant Technical and Services

• K. Evers, Assistant Manager Plant Operations

• Seebart, Nuclear Emergency Preparedness Coordir.ator

• Pulec, Plant Technical Supervisor

• Nalepka, Nuclear Licensing Projects Supervisor

• Zube, Nuclear Simulator Supervisor

) * Molzahn, Nuclear Systems Supervisor

• T. Moore, Security and Administrative Supervisor

• Bartelme, Emergency Planning Specialist D. Dow, Plant Security Supervisor R. Ledvina, Shift Supervisor J. Peterson, Shift Supervisor

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D. Mielke, Shift Supervisor

R. Hanson, Shift Supervisor G. Holmes, Shift Technical Assistant J. Giesler, Shift Technical Assistant S. Gunn, Shift Technical Assistant G. French, Control Room Supervisor T. Gencius, Control Rnom Supervisor T. Keneklis, Nuclear Training Supervisor S. Meyer, Plant Officer Supervisor

• Denotes those present at the exit interview on August 2, 198 . Licensee Action on Previously Identified Notice of Violation (Closed) Open Item No. 305/84-07-03, Monthly Communications Tests: A review was made of all monthly communications tests for the ENS, NAWAS and HPN phones between July 1984 and July 1985. All tests were adequately performed on a monthly basis. The inclusion of a reference to 10 CFR Part 50, Appendix E, IV.E.9.a to procedure TSP 44-2, Emergency Communica-tions Systems Check, to emphasize the importance of carrying out these tests, and the existing computerized planning and scheduling system for tracking these tasks should be sufficient to avoid a repeat violatio This item is close . Licensee Action on Previously Identified Emergency Preparedness Weaknesses (Closed) Open Item No. 305/83-13-05, Ensure 15-Minute Notifications:

EP-AD-7, Notification of Unusual Event, EP-AD-8, Notification of Alert, EP-AD-9, Notification of Site Emergency and EP-AD-10, Notification of General Emergency, all dated April 23, 1985 have been revised to specify that the emergency notifications must be completed withir 15 minutes. This item is close !

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b. (Closed) Open Item No. 305/84-07-01, Shift Augmentation Drills:

l Revision 5 of the Emergency Plan dated February 25, 1985 specifies that unannounced quarterly radio pager response drills will be conducted. This was added to the plan to provide a means to continually ensure the licensee has the ability to augment the onshift staff in a timely manne This item is close c. (Closed) Open Item No. 305/84-07-02, Time Averaged Meteorological Parameters: A review of procedures EP-ENV-3C (Revision F), EP-ENV-3E (Revision H), EP-RET-5A (Revision G), and EP-TSC-3 (Revision F) all specified where appropriate that 15-minute averaged meteorological data is to be used for X/Q calculations. In addition, the computer display printout specifies the meteorological data as being 15-minute average This item is closed, d. (Closed) Open Item No. 305/84-14-01, Establish Routine Testing Program for TSC and RAF Atmospheric Filter Cleanup Systems:

Procedure TSP 67-1, TSC Ventilation HEPA Filter D0P Test, and TSP 67-2, TSC Ventilation Charcoal, were issued on September 27, 1984 to verify the assumed removal efficiencies of the TSC and RAF atmospheric cleanup systems. Testing was performed on October 2-3, 1984. Testing of the TSC/RAF filters is now scheduled to be performed on a biennial basis. This item is close e. (Closed) Open Item No. 305/84-14-02, Quantitative Auxiliary Building Vent Stack Flow Rate Information Should Be Made Available for Dose Assessment Calculations: A matrix of fan combinations available for dose assessment calculations has been completed and was incorporated in EP-ENV-3C Rcvision E. This item is closed, f. (0 pen) Open Item No. 305/54-14-03, Quantitative Resctor Building Vent Flow Rate Information Shauld Be Made Available for Dose Assessment Calculations: The licensee has replied by letter to NRC Region III concerning this open item on February 1, 1985 and August 1, 198 The containment purge and vent system is not a credible post accident release path. The shitld building ventilation system is a credible release path which is not addressed in the current dose projection program. The dose projection program is in the process of being revised to include this potential release pathway. The licensee has committed to completing this item by December 1, 198 g. (Closed) Open Item No. 305/84-14-04, An Additional Release Pathway Should Be added to the Dose Assessment Model that Could Represent Any Pathway Not Already Addressed: The licensee has modified the dose projection program such that any flow rate can be manually entered. This item is close h. (Closed) Oper. Item No. 305/84-14-05, EP-TSC-6 Incorrectly Estimates Cladding Oxidation from Hydrogen Production: The licensee committed to correct this by January 1985. This item was corrected with a revision to EP-TSC-6 Assessment of Reactor Core Damage, dated December 28, 198 This item is close __- __ _ _ _ _

. . (0 pen) Open Item No. 305/84-17-01, Initial Notifications: A review of procedures EP-AD-7 through EP-AD-10 determined that the procedures have been revised so that notifications to offsite agencies is performed prior to the shift augmentation notifications. This should ensure that initial notifications will be completed within 15 minute This item will be examined during the 1985 annual exercise to verify the changed procedures result in timely notifications.

, (Closed) Open Item No. 305/84-17-03, Revise PASS Procedure EP-REI-3C:

Procedure EP-RET-3C, issued on April 2, 1985, was revised to include a method to ensure the vacuum in the sample bottle is not lost before the sample and dilution volumes are injected into the bottle; and to include a method to obtain different dilution factors for the sample as desired or required. This item is close . Emergency Detection and Classification Emergency Plan Implementing Procedures (EPIPs) were reviewed with emphasis on classifications, notifications, protective action recommendations, and the duties, including those not delegatable, of the Emergency Directo The EPIP's clearly require the Emergency Director to promptly (within 15 minutes) initiate appropriate offsite notifications following declaration of an emergency, and any subsequent upgrad The procedures provide for consideration of various protective action recommendations corresponding to various plant conditions, including, as a minimum, to shelter within a 2-mile radius and within 5 miles in the three downwind sectors for a General Emergency recommendatio The procedures prescribe assembly and accountability for all declarations of ALERT and highe Additionally, EP-AD-3, UNUSUAL EVENT, requires the Emergency Director to consider and determine if personnel assembly is necessary for that classificatio Discussions with the licensee indicated that the requirement of 10 CFR 50, Appendix E, Part IV.B, to provide State and local agencies an annual opportunity to review and concur in the EALs has been marginally adequat The licensee presents selected EALs to the State and local agencies during annual training, but this provides only a partial EAL exposure annually, i Additionally, no documentation of concurrence by those agencies is obtaine Emergency classification procedures and charts were reviewed for

! impediments or errors which might lead to incorrect or untimely l classifications. Several items were noted that should be considered

[ for improvement.

l A number of the Emergency Classification Charts, under the column

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"KNPP Indication," contain references to Technical Specification This requires the user to refer to yet another document to determine a classification, rather than the chart being sufficient itsel This is cumbersome, time-consuming, and offers additional opportunity for error. Inclusion of technical specifications into the classification charts would speed up the classification process and is recommended by the inspection team.

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b .' The classification charts are oriented such that the user enters at the lowest level of classification, and proceeds toward the highest level until he reaches a classification criteria corresponding to the plant conditions. As such, there is a possibility that he would

< find a criteria which seemed to apply and stop there, when in fact,

! a higher classification might also apply. Inverting the order so as l to have the operator enter at the General Emergency level and work down towards the Unusual Event would have the advantage of ruling out the most serious conditions first, rather than the other way i

aroun In a number of areas of the EPIP's there is considerable redundancy causing them to be voluminous, which results in a significant amount of refering back and forth between procedures. For example, there is a procedure for each of the emergency classifications, and also a corresponding procedure for notifications associated with each classification. Consideration should be given to incorporating the notifications into the corresponding, emergency classification procedur Interviews and walkthroughs of four Shift Supervisors, three Shift Technical Assistants, and two Control Room Supervisors resulted in the following observations and recommendations: In general, and to varying degrees, they were slow in their use of the EPIP's, particularly the classification charts. This reflected a lack of practice with the EPIP's. Consideration should be given to more frequent Emergency Plan and EPIP training (e.g., quarterly)

in order to maintain a higher retention level across the yea Several Shift Supervisors (SS) were unfamiliar with the general provisions of EP-SEC-2, " Security Force Response to Emergencies,"

even though each classification procedure requires the Shift Supervisor as the Emergency Director to ensure that the Security Force is implementing that procedure for the existing emergency classificatio One SS shifted classification charts between his correct classification of an unusual Event, and a subsequent effort to classify an ALERT. Another SS made an incorrect classificatio Both SS's quickly recognized their errors with only minor coaching, and got back on trac One SS and one STA, in a primary leak to LOCA scenario, did not reach a classification of Unusual Event, but correctly classified at ALERT when the scenario reached that level. A second SS, in the same scenario, classified an Unusual Event and then the ALERT, as the leak rate increased. This discrepancy was directly related to an interpretation of the Technical Specification wording regarding reactor shutdown at specified leak rate . .

The Technical Specification calls for a reactor shutdown to hot standby within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> when an unidentified leak rate exceeds 1 gp The first two interviewees interpreted this to mean they had 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before being required to shutdown. The third interviewee interpreted it to mean the reactor is to be shutdown, with 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to reach hot standby. This situation should be reviewed and any ambiguities corrected. (See Chart C, Table AD-2.1 of EP-AD-2.) At the very least, action should be taken to insure all affected operators have the correct understanding of the intent of the procedure and the Technical Specificatio All persons interviewed were clear on the fifteen minute time limit to complete notifications to State and local agencies, and of the one hour limit for notification of NRC Headquarter Interviews reflected that the licensee can effectively use post-TMI indicators for core and containment status. A minor weakness was noted in that several operators did not have a " feel" for the readings which they might expect under various accident condition However, they indicated familiarity with where that information was availabl Based on the above review, no violations or deviations were identifie . Protective Action Decisionmaking Walkthroughs and interviews with Shift Supervisors, Shift Technical Assistants and Control Room Supervisors determined that personnel understood the various considerations of and recipients of protective action recommendations, as well as the authority, functions, responsibilities, and transfer of authority for protective action recommendations. The delegatable and non-delegatabla duties of the Emergency Director were understoo ,

.A review of the EPIP's determined that they contain provision for a minimum recommendation to shelter in a 2-mile radius and 5 miles downwind within 15 minutes of a classification of a General Emergency, with additional protective actions recommended as require Personnel interviewed reflected a clear understanding regarding the requirement for protective action recommendations based on plant, core and containment conditions, even though no release may have occurred, as well as an understanding of the considerations for sheltering and evacuation.

l l Based on the above review, no violations or deviations were identifie . Notifications and Communications A review was made of the licensee's procedures for notification of offsite agencies and licensee personnel during an emergency. Notification vocedures EP-AD-7 through EP-AD-10 were consistent with emergency

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classification and emergency action level schemes. Each of the above notification procedures specified that State and local governmental authorities must be notified within 15 minutes of the emergency declara-tio A verification call-back system is in use by State and local governments, and the licensee's procedures have a place to document the times that they receive the verification calls.

l The licensee uses the NAWAS as the primary means of notifications to State and local governmental agencies. Appendix A of the EPIP's describes the communication systems to be used to notify onsite pqrsonnel; emergency response organization personnel; Federal, State and local authorities; and, private support agencies. Appendix A also contains the telephone numbers of the above personnel and organizations. These telephone numbers are updated quarterly per Technical Support Procedure (TSP) 44-1, Telephone Number Quarterly Review. A review of records showed that these reviews were being implemented quarterly as require A review was made of procedures EP-AD-7 through EP-AD-10 and Appendix A to the EPIP's to ensure that for alerting, notifying and activating emergency response personnel, these procedures addressed the appropriate personnel and organizations. These procedures were determined to be current and complete.

l The Kewaunee County Government is responsible for the testing of the

siren system in Kewaunee Courty. The county performs monthly " growl" l tests and complete cycle tests twice per year. The licensee observes the

! monthly tests on a quarterly basis and observes the complete cycle tests.

l Discussions with licensee personnel identified a satisfactory performance of the sirens. Sirens in Manitowac County are tested by the Manitowac County Government and their performance is coordinated with the Point Beach Nuclear Plant.

l lhe inspectors reviewed the results of the monthly tests of the National i Warning System (NAWAS), Emergency Notification System (ENS), Health

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Physics Network (HPN), and dial select phone system and the quarterly

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checks with the Coast Guard. With the exception of January 1985 during

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which minor delays occurred, all checks were determined to be adequat ,

l During January 1985, a delay was introduced in conducting the tests due *

l to the unavailability of support from one of the Counties. It is i recommended that in the future, it would be better to proceed with the

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rest of the checks so only a few of them are delayed, rather than al Based on the above review, no violations or deviations were identifie . Changes to the Emergency Preparedness Program Interviews were conducted with licensee management personnel

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Correspondence between the licensee and the NRC as well as minutes of Plant Operating and Review Committee meetings were reviewed. From these, a

it was concluded that changes to the emergency plan and implementing

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procedures are routinely being reviewed by licensee management to ensure compliance with 10 CFR 50.54(q) as required.

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A number of changes to emergency facilities were noted which will enhance the emergency preparedness program. For instance, the remodeling of the Technical Support Center to provide for the consolidation of key personnel into one central area, the expansion of the Radiation Protection Office (RPO) and laundry facilities, the acquiring of a new ND 6700 sample counter which can serve as a backup for the counter in the RPO, and the construc-tion of a new Site Access Facilit In a letter to the NRC from Mr. O C. Hintz dated December 14, 1984 the licensee made a commitment to include a method in Procedure EP-RET-3C for preventing the loss of vacuum in the sample bottle when collecting a post accident sample. The change was committed to be implemented by February 28, 1985. The change was not actually implemented until April 2, 1985. This is a Deviation from a Commitmen The system for distribution of revisions to the emergency preparedness implementing procedures (EPIPs) is inadequate. A review of records of distribution of changes to the EPIPs during August 1, 1984, September 26, 1985 and December 28, 1984 indicate that receipt of these changes has not been verified for five outside agencies, one personal manual, seven reference manuals and 27 working manuals. Additionally, one working manual was reviewed and revealed six outdated procedures, one outdated and previously deleted procedure, and one procedure was missing. This is an Open Item No. 305/85009-0 Based on the above review, one deviation was identifie . Shift Staffing The inspector reviewed the physical and administrative aspects of the shift staffing and augmentation procedures. During a July 9-13, 1984 inspection (Report No. 50-305/84-07) concerns were raised over the acceptability of the minimum shift staffing level At that time NRC concerns revolved around the fact that a communicator position was being eliminated subsequent to the addition of a Control Room Supervisor to the onshift staff. Since the July 1984 inspection the licensee has reevaluated their minimum shift staffing levels and have assigned a member of the security force to be an initial communicator (Notifier) in the event of an emergenc Thirteen security personnel have been trained to fill this position of Notifier which includes making the initial notifications to the State and local governmental agencies and licensee emergency response personnel. The Notifier will be relieved of all communications responsi-bilities by a Control Room Communicator upon arrival. These Communicators all live close to the Kewaunee Plant and shift augmentation drills have demonstrated they can respond within 30 minutes as the licensee has committed. The initial notification to the NRC will be made on the ENS phone by the ST These above changes have resolved the NRC concerns over the minimum shift staffing leve The NRC has allowed the licensee to deviate from the minimum shift staffing guidance in NUREG-0654, Revision 1 in that the Chemistry Technologist is on shift only 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> per week. This is based on the licensee's commitment to provide two or more chemistry personnel within 30 minutes of the declaration of an emergency. Examination of the

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l l quarterly shift augmentation tests per TSP 44-3, Tone-Voice Radio Pager Test, showed that the licensee has continued to meet this commitmen Examination of other aspects of the augmentation drills identified only one instance where a significant number of personnel failed to meet the augmentation goals of 30 and 60 minutes. This was determined to be the result of a problem in the communications equipment, and a repeat. test after the equipment was repaired provided satisfactory results. These augmentation tests included one between 5 and 6 a.m. in the morning which was an improvement over past practice of only conducting drills in the evenin Based on the above review, no violations or deviations were identifie . Knowledge and Performance of Outies (Training)

The inspectors examined the licensee's program for emergency preparedness training and retraining by means of walkthroughs and reviews of training records maintained by the licensee. The emergency preparedness training program was described in Section 8.0 of the Kewaunee Emergency Pla This section of the plan described the training program's major component These included initial training and retraining, refresher training, proficiency training, team proficiency training, indoctrination training, offsito agency training, drills, and exercise The Training Department, individual supervisors, or team leaders determine which staff members require specific emergency preparedress training and to what exten The training section conducted training for both nuclear and non-nuclear activitie Emergency preparedness training was conducted by the Nuclear Emergency Training Section. This section conducted training involving the individuals involved in plant operations and emergency response activitie The training department had developed a computerized data based system which listed all personnel requiring emergency response training, the dates which training would be provided and documentation when the actual training was provided. Training records were reviewed which revealed that all refresher training for Shift Supervisors had been conducte During the previous year a commitment was made by the Kewaunee Plant to add an additional Control Room Communicator to the control room staff to make the initial notifications to local governmental aathoritie These communicators were drawn from the onshift security staff personnel. As of April 26, 1985 all security staff members who might be delegated this function had receited this training. Training records of the Control Room Communicators / Notifier Response Training were reviewed for verifica-tion that this training had been provrde ;

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Training records of offsite emergency response organizations were i reviewed and found satisfactory. Kewaunee and Point Beach entered into ~

an agreement whereby alternate year training for emergency preparedness was conducted by each plant for common emergency response organization Offsite agency training for 1985 was planned for September 1985 by l Kewaune Previous year's training was conducted by the Point Beach Nuclear Plant,

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The emergency preparedness drill and exercise schedule met the requirements of 10 CFR Part 50 Appendix E. The first aid training program for an injured contaminated patient transported to Two Rivers Hospital was conducted by Point Beach in 1984 and will be conducted in September 1985 by Kewaunee prior to the 1985 exercis Walkthroughs were conducted to determine the working level knowledge of the Control Room Staff with the Emergency Plan and Implementing Procedure The walkthroughs consisted of plant accident scenarios which were presented for emergency classification purposes. Four Shift Supervisors, three Shift Technical Advisors, and two Control Room Supervisors were interviewed. The scenario and plant instrumentation data provided presented a progression from Unusual Event to General Emergency classifications. The individuals

} were requested to utilize all normally available tools and procedures and request additional information or data from the inspectors if necessary in order to classify the incident. Special emphasis was placed on post-TMI information learned, protective action recommendations, and EAL recognition !

and classificatio The walkthroughs were generally well received and most interviewees i displayed an adequate knowledge of the Plan and Procedures. However, !

on several occasions individuals were incorrect in classification of scenario incidents. It was also noted that due to infrequency of practice most individuals were very tentative in the use the classifica-tion scheme and hesitant in maHr.;; ;:rotective action recommendation This item was also addressed in the previous routine inspection conducted on August 6, 1984 which indicated that this should be stressed in the annual refresher training for Shift Supervisors. In view of the fact that tentativeness in procedural use and hesitancy on the part of control room staff in making protective action recommendations it is recommended that training in this area be increased from yearly to quarterl Based on the above review, no violations or deviations were identifie . Licensee Audits The inspector examined the licensee's audit and technical review reports issued in the past 18 months. One Quality Assurance Audit (Report No.83-003) and one In_ dependent Technical Review Report (Review No. 84-04)

was issued during that perio Deficiencies, weaknesses, and recommenda-tions were identified in both reports, and it was noted that the licensee had developed an adequate method for reporting them to corporate management for consideration and tracking the progress of any corrective action During 1984, the licensee implemented a new method of performing an annual review and biannual audit of the emergency preparedness program. The annual review is conducted by the Nuclear Services Group as a " technical" annual review of the emergency plan and its implementing procedures while the Quality Assurance Group performs an " audit" of the emergency pre-paredness program every two years. This is done in an effort to provide more knowledgeable and technical reviews of the emergency preparedness program. However, a review of the Independent Technical Review Report dated November 1, 1984 raised concern over the independence of the reviewers for implementation of the emergency preparedness progra _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

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It was determined that nine out of ten reviewers conducting the November 1, 1984 Independent Technical Review (Review No. 84-04) are assigned positions in the emergency response organization. Even though in most cases the reviewers examined areas that were not related to their emergency organi-zation positions, 10 CFR 50.54(t) states that the review will be carried out "by persons who have no direct responsibility for implementation of the emergency preparedness program." It was noted that none of the reviewers had review / approval responsibilities for changes to the Emergency Plan and only the possibility of initial review / approval for EPIP's is a cognizant supervisor, with two levels of further review and approval beyond their revie Because the above concerns revolve around the interpretation of the 10 CFR 50.54(t) phrase, "by persons who have no direct responsibility for implementation of the emergency preparedness program," this will be an Unresolved Item pending further guidance from NRC Headquarters. This will be tracked as Item No. 305/85009-0 In addition, an examination of the Independent Technical Review dated November 1, 1984 (Review No. 84-04) determined that the review failed to evaluate for adequacy the interfaces with State and local government This is a violation of NRC requirements based on 10 CFR 50.54(t) which

, states, "the review shall include an evaluation for adequacy of interfaces l with State and local governments...." This will be tracked as Item I No. 305/85009-0 Based on the above review, one violation and one unresolved item were identified.

L 11. Maintaining Emergency Preparedness The inspectors verified that the licensee coordinated with offsite support agencies as specified in the Emergency Plan. Letters of agreement with I all offsite agencies were contained in the Emergency Plan, Appendix D and were determined to be current. The inspector determined that all drills specified in the emergency preparedness training program were conducted and that records were maintained and available for revie The inspectors verified that the health physics, environmental monitoring, i

and medical drills had been conducted as specified in the emergency pla During this inspection the inspectors observed the Emergency Operations Facility Dose Assessment Drill on July 30, 1985. During this time communications with offsite teams, the plant, and offsite agencies were tested. Estimated offsite dose estimates were plotted, and offsite protective action recommendations were mad Based on the above review, no violations or deviations were identifie . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, weaknesses, items of violation, or deviation An unresolved item disclosed during this inspection is discussed in Section 1 _ _ _ _ _ _ _

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13. Exit Meeting The inspectors met with the-licensee representatives (denoted in Section 1)

at the conclusion of the inspection on August 2, 1985. The inspectors summarized the scope and findings of the inspection including the Violation, Deviation from Commitment, Unresolved Item, and Open Ite The inspectors also discussed the contents of the report to determine if the applicant thought any of the information was proprietary. The applicant responded that none of the information should be proprietary.

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