IR 05000354/1985040
| ML20138Q447 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 12/05/1985 |
| From: | Amato C, Cohen I, Craig Gordon, Harpster T, Hawxaurst J, Hawxhurst J, Perotti D, Rich Smith, Viid D, Vitd D, Vito D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20138Q441 | List: |
| References | |
| 50-354-85-40, NUDOCS 8512270227 | |
| Download: ML20138Q447 (29) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-354/85-40 Docket No.
50-354 License No.
CPPR-120 Priority Category C
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Licensee:
Public Service Electric and Gas Company P. O. Box 236 Hancocks Bridge, New Jersey Facility Name:
Hope Creek Generating Station Inspection At:
Hancocks Bridge, New Jersey _
Inspection Conducted:
August 12-16, 1985 Inspectors:
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to, Sr. EP Specialist
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G C. G.'Amat6, EP Specialist
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C. Z. Gordon P Specialist
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5 M Approved by:
Y. L.,tfaybsth~f
date EmergencyPreparednessSection Inspection Summary:
Inspection on August 12-16, 1985 (Inspection Report No. 50-354/85-40)
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Areas Inspected: Appraisal of the Emergency Preparedness Program at the Hope Creek Generating Station including a review of the plan and procedures, program administration, organization and staffing, training and emergency facilities.
The inspection involved 283 inspector-hours by six region-based inspectors and one NRC/HQ inspector.
Results:
The inspection resulted in the identification of a number of program areas, which are incomplete or inadequate, particularly the Emergency Response Facilities.
Completion of many of these areas is needed prior to the authori-zation of a full power license.
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OETAILS 1.
Persons Contacted PSE&G and Contractors
- C. Adams, Planning Engineer
"K L. Anderson, Principal Engineer - Preparedness (Training)
R. Bennett, Control Room Operator D. Burgin, Associate Engineer, Emergency Planning S. Bravar, Public Information Manager R. Campanella, Hope Creek Licensing J. Clancy, Senior Health Physicist
- S. Colon, Emergency Preparedness, Facilities and Equipment Engineer C. Conner, Operations Manager G. Daves, Senior Engineer, Operations
- J. D. Driscoll, Assistant General Manager, External J. Estes, Security Supervisor
- J. E. Forde, Jr., Emergency Preparedness, Facilities and Equipment Engineer D. Gairvors, Shift Supervisor R. Gary, Health Physics Technician R. Harrington, Senior Supervisor, Radiation Management and Control J. Healy, Meteorological Technician S. F. Hilditch, Jr., Hope Creek Quality Assurance M. Idell, Site Engineering
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M. Ivanick, Nuclear Security Coordinator C. Johnson, General Manager, Quality Assurance
J. R. Lovell, Radiation Protection / Chemistry, Manager
- D. P. McCloskey, Emergency Preparedness Manager S. McGinnis, Site Engineering I. Mermeistein, Hope Creek Licensing D. Noce, Health Physicist P. O'Donnell, I&C Supervisor W. O'Malley, Shift Technical Advisor B. Preston, Manager - Hope Creek Licensing J. Russell, Health Physics Technician W. Ryder, Engineering and Operations Staff L. Salamon, Public Information Coordinator
- R. Salvesen, General Manager - Hope Creek Operations
- J. Schaffer, Emergency Preparedness - Facilities and Equipment Manager J. Simiele, Staff Engineer G. Suey, Chemist C. Vondra, 0; o
1 Engineer G. Winner, S'c f '
..g i nee r M. Wolowsky,l aputer Engineer B. Yewdall, Staff Engineer (Corporate)
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Offsite Agencies E. Bradford, Cumberland Country Disaster Preparedness Communications W. Brown, Deputy Director, Delaware State Department of Emergency Planning and Operations (DEPO)
Dr. J. Castiglioni, Director, Emergency Medical Services, Salem County Memorial Hospital (SCMH)
M. Davidson, Head Nurse, Oncology Inpatient Unit, University of Pennsylvania Hospital D. Evans, Radiological Department - SCMH J. M. Galvin, Administrator - SCMH D. B. Hollinger, Kent County Emergency Planning and Operations Director R. Kendall, New Castle County Emergency Planning Coordinator T. Linnemann, General Manager, Emergency Medical Services, Radiation Management Corporation (RMC)
Dr. McGhee, Bioassay Laboratory Director - RMC D. Petrilli, Radiological Assessment Coordinator - DEPO J. Sever, Cumberland County Disaster Preparedness Coordinator M. Simpson, Radiation Protection Services - DEPO D. Yates, Cumberland County Disaster Preparedness Deputy Coordinator J. Zarebicki, Chief Planner - DEPO USNRC A. R. Blough, Senior Resident Inspector - Hope Creek
- J. J. Lyash, Resident Inspector - Hope Creek
- Denotes those present at exit meeting on August 16, 1985.
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Emergency Preparedness Appraisal Summary During the period of August 12-16, 1985, the NRC conducted an appraisal of the state of emergency preparedness for the Hope Creek Generating Station. Areas examined during this appraisal are described in this report.
The objective * of the appraisal were to evaluate the overall adequacy and effectivenes of emergency preparedness and to identify areas of weakness that need to be strengthened.
The findings from this appraisal will be used as a basis for findings against the provisions of 10 CFR 50.47(a)(2)
and for requesting individual licensee action to correct deficiencies and effect improvements.
The appraisal of the state of onsite emergency preparedness at the Hope Creek Generating Station involved six general areas:
Administration of the Emergency Preparedness Program Development; Er.ergency Organization;
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I Emergency Training; Emergency Facilities and Equipment; Procedures W,1ch Implement the Emergency Plan; and l
Coordination with Offsite Agencies.
The inspectors interviewed onsite and offsite emergency response personnel
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as to their duties and responsibilities with regard to Emergency Plan implementation during the review of each of these areas.
The findings of this emergency preparedness appraisal at the Hope Creek Generating Station indicate that the framework for the EP program (admints-tration and organizational setup, training, procedures, facility locations)
is established and appears to be adequate.
However, several critical
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program areas were found to be incomplete (organization, communications training and facilities). Therefore, the NRC appraisal team was unable to make a determination as to the adequacy of the program.
Specific areas i
of concern have been identified as open items in the context of this i
report.
l The appitcant was notified of these open items in an exit meeting held on I
August 16, 1985.
The appraisal team indicated that a followup inspection would be necessary in order to review the applicant's progress in resolving or completing these open items.
The inspectors stated that the timing for the followup inspection would be determined by the applicant's progress in addressing and resolving the
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open items. The applicant committed to periodically notifying NRC Region I I
of the status of the incomplete areas noted durtog the exit meeting to facilitate the decision as to when the appraisal followup inspection would l
be appropriate.
Those deficient or incomplete areas are:
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Installation and testing of the Nuclear Emergency Telecommunications System (NETS) and related training 2.
Implementation of the EP training program 3.
Changes in the EP organization and in other plant organizations which may effect emergency preparedness 4.
Transfer of EP training responsibilities to the Nuclear Training Center (NRC)
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Implementation of the Radiation Monitoring System
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Implementation of the Control Room Instrumentation Display System (CRIDS), including the Safety Paraneter Displays System (SPDS), in the TSC and EOF.
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Installation / testing of the onsite radiation alert and evacuation alarms and the page system.
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Installation and operability of the Artificial Island security access point (for accountability evaluation)
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Assimilation of the Salem and Hope Creek Emergency Plans (schedules, licensing considerations)
10. Physical completion of the onsite emergency response facilities.
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Emergency equipment and supplies.
The inspectors noted that the items of additional concern are those which may be adversely affected by ongoing changes in the onsite organization (Items 2, 3, 4 and 9).
The applicant acknowledged that every attempt will be made to assure continuity in the development and completion of the Hope Creek Emergency Preparedness program and that NRC Region I would be kept abreast of program changes and status of completion.
During the course of this appraisal, all of the Emergency Plan Procedures were reviewed by the inspectors as they related to the particular program areas to which each inspector was assigned.
These procedures along with other documents were reviewed for consistency with the r m irements and guidelines in the Hope Creek Emergency Plan, 10 CFR 50.47 and 10 CFR 50, Appendix E, and NUREG-0654.
To preclude repetition throughout this report, the Emergency Plan Procedures, the Hope Creek Emergency Plan, 10 CFR 50.47, 10 CFR 50 Appendix E, and NUREG-0654 will not be listed under each specific area of this report as reference documents.
3.0 Administration _of_the Emergency Preparedness Progry The inspectors reviewed the contents of Revision 8 to the appitcant's Hope Creek Generating Station (HCGS) Emergency Plan effective June 30, 1985, including:
Section 1.0, Introduction;
Section 2.0, Assignment of Responsibility;
Section 17.0, Emergency Plan Administration; and
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i Figures 17.1 of the Plan, t
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l The inspectors also reviewed other relevant documents, including job i
descriptions and organizational charts, and held discussions with site l
management, site supervisory personnel, and facility employees.
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done in order to determine the applicant's normal site organizational
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l structure, emergency duty assignments, and the characteristics of those
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personnel within the applicant's organization who are responsible for the
development and administration of the emergency preparedness program.
3.1 Responsibility Assigned Section 1.0 of the Plan summarizes the purpose and scope of the emergency preparedness program. Section 2.0 of the Plan delineates i
the responsibilities of the applicant, offsite support groups and the
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principal governments within the emergency planning zone for HCGS.
Section 17.0 of the plan specifies that the Vice President - Nuclear has the overall responsibility for the development and updating of emergency planning and coordination of the plans with other response organizations.
The Plan identifies the Manager - Nuclear Site Protec-tion as the individual responsible for ensuring that the plan and
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procedures are appropriately interfaced with the corresponding plans,
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i procedures and training of offsite si;pport agencies as required to l
maintain suitable timely notifications and development of protective action recommendations. The plan further assigns the responsibility for preparing, reviewing and revising the plan and for maintaining and l
updating emergency plan procedures to the Nuclear Emergency Prepared-i ness Manager (NEPM).
The NEPM's responsibilities are delineated in Section 17.0 of the Plan.
From discussions with the applicant, however, the inspectors were informed that due to a recent reorganization, the responsibilities
formerly assigned to the Manager - Nuclear Site Protection regarding i
the overall administration of the HCGS emergency preparedness program
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are now assigned to the NEPM.
In addition, the inspectors were provided documentation that describes an Emergency Planning and Pre-paredness Group (EPP Group) that is further subdivided into three
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functions:
1) Planning, 2) Preparedness, and 3) Emergency Facili-
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ties. Although the EPP Group and its responsibilities are not described i
in the Plan, the applicant agreed to incorporate this information
in Section 17.0 of the Plan.
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The inspectors noted that individuals at both management and pro-fossional levels were aware of the various individuals involved in
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planning and preparedness.
The inspectors were assured that the current arranctment of onsite and offsite responsibilities, under the ove.rall dire.cton and coordination of the NEPM, has been working satisfactorily and would be maintained in the same manner in the future.
l Based on the above finding, the following must be corrected to achieve an acceptable program:
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The Emergency Plan requires the following revisions: Section 17.0 of the Plan should describe the overall responsibility and authority of the NEPM for emergency planning and preparedness.
Figure 17.1 of the Plan requires clarification with regard to the current chain of command for the NEPM.
In addition, the plan should describe the l
planning, preparedness and facilities responsibilities of the three I
sub groups of the EPP Group. This is an Open Item (50-354/85-40-01)
wnich must be addressed in a future revision to the plan.
3.2 Authority Assigned As noted in Section 3.1 above, the inspectors determined that the NEPM has been delegated the authority for overall program administra-tion.
Provided the Plan is changed as discussed with the applicant, this portion of the applicant's program is acceptable.
The EPP Group is not defined in the Plan, and while this group appears to have been assigned appropriate functional responsibilities with regard to planning, preparedness, and facilities, there are no commensurate authorities delegated to the assigned individuals to allow them to perform their emergency tasks.
From discussions with the applicant's supervisory personnel, there appears to be an implied authority by nature of the individual's position within the normal operating organization. Clarifications of these authorities should
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be considered by the applicant so as to provide for a clearer per-ception of managerial responsibilities.
I During the appraisal, the inspectors were informed of a proposed HCGS organizational change. The applicant presented a chart i
l entitled " Nuclear Department", which showed the NEPM reporting to i
the Assistant General Manager for External Affairs, who in turn
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reports to the Assistant Vice President for Operations Support who is on the same level as the General Manager - Hope Creek Operations.
From discussion with the site managers and professional staff, the inspectors determined that the NEPM position has high visibility and is receiving a high level of support from plant management.
Based on the above findings, this portion of the applicant's program is acceptable.
3.3 Planning Coordination The HCGS Nuclear Department, including the EPP Group, is located at the site. As such, there appears ta be effective coordination between and among the EPP Group and the various plant departments, and state and local agencies.
Section 17.1 of the plan specifies that, "the Station Operations Review Committee (SORC) reviews emer-l gency plans and procedures as they relate to nuclear safety in
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L accordance with Technical Specifications.
The General Manager - Hope Creek Operations approves plans and procedures." Thus, key depart-ment heads have a sign-off responsibility with regard to the plan and procedures. Also, the NEPM has been given authority to coordinate directly with department heads for emergency planning purposes.
In addition, from discussions with the Public Information Manager (also located at the site), it cppeared that this portion of the emergency organization was adequately integrated into the overall emergency response organization.
Based on the above findings, this portion of the applicant's program is acceptable.
3.4 Personnel Selection and Qualification Based on discussion with individuals responsible for the emergency planning effort, the inspectors determined that the individuals pussessed a general understanding of the principles involved in developing emergency plans and procedures.
The inspectors reviewed personnel requisition forms which specified selection criteria in-cluding education, experience, and spt.cial skills required.
The form also includes a brief outline of the individual's major duties.
From discussion with key individuals in the EPp Group, the inspectors determined that the individuals either meet the selection criteria or are provided an opportunity for attending professional development courses.
Personnel have participated in and observed emergency exer-cises, attended workshops and courses on emergency planning and pre-paredness, and have established, along with other nuclear utility planners, the PJA Interconnect, a group of emergency planners from power reactors in Pennsylvania, New Jersey and Maryland.
This group meets semi-annually to discuss mutual concerns.
It appears at the current time that emergency planning personnel are being provided appropriate opportunities for professional develop-
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However, a formal training program for emergency planners is not provided and should be considered by the applicant.
Based on the above findings, this portion of the appItcant's program is acceptable.
4.0 Emergeg y A anization
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4.1 Onsito Organization The inspectors reviewed the Hope Creek Generating Station Emergency Plan and implementing procedures and held discussions with personnel to evaluate the adequacy of the onsite emergency organization and the assignment of emergency duties and responsibilities.
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response personnel to determine their familiarity with their role in i
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Interviews were held with persons whose emergency response functions were part of the following
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functional areas:
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Emergency Duty Officer Shift Organization and Management Operating Department Management Shift Technical Advisor
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Shift Operators and Technical l
Shift Operators and Technical Support Personnel
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Emergency Radiation Survey Teams Onsite Technical Suppcrt The inspectors found the emergency organization to be in place with
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adequate numbers of site personnel designated to fill the required emergency response positions.
Personnel interviewed were aware of d
their emergency response organization assignment and the responsibil-ities associated with that assignment. The inspector noted this to be rather commendable as most of those interviewed had not received
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the full compliment of training specified for their respective emer-
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gency response positions. Most stated that they were familiar with l
their EP responsibilities from previous experience with PSE&G emer-
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gency response under the Salem Generating Station Emergency Plan.
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The inspectors found the onsite organization to be inclusive of the
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Plan.
It was also determined that when initial training is complete, adequate numbers of personnel will be available for all emergency response organization positions required to satisfy NUREG-0654,
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Table 8-1 criteria during each phase of emergency response.
4.2 Offsite Organizations
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and other energency response organizations were not looked'at in
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detail as a part of this inspection.
Since 1980, agreements have
been formulated between PSE&G and these organizations as part of the Salem Generating Station Emergency Plan.
The inspectors did visit a
i number of offsite organizations during this inspection to determine i
i whether changes in the PSE&G emergency response program relating specifically to Hope Creek had been communicated to them.
These findings are discussed in Section 8.0 of this report.
i 5.0 Emergency Preparedness Training j
5.1 Scope of Review l
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The inspectors reviewed the applicants Emergency Preparedness Train-
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ing program to determine its effectiveness and degree of implementa-tion. This was accomplished by review of lesson plans and proce-dures, review of train!ng records, interviews with the trainers and EP managers, inspection of the training facilities and training session audits.
5.2 Findings
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The EP training program is documented in Section 16 of the Hope Creek Emergency Plan.
Initial emergency response training and requalifi-cation are required annually for station employees. The States of New Jersey and Delaware both conduct training independently of PSE&G.
However, all PSE&G EP training courses offered are open to State employees and the States are liven schedules and encouraged to partic-ipate. There is no provision in the Hope Creek Emergency Plan for PSE&G Corporate (Newark, New Jersey) involvement in the EP training program except for Public Information Officers.
Provisions should be made for the appropriate training of PSE&G Corporate personnel other than Public Information Officers who may play a role in the response to an emergency situation.
This is an Open Item (50-354/85-40-02).
A review of the lesson plans, practical instructions, and the train-ing matrix indicate that required subjects are covered in the training progree,. Formal lesson plans were available for each func-tional area and are of good quality. All contain statements of pur-pose and performance objectives which provide a basis for a valid examination of student activity.
The lessons plans offered have
, generally been developed by the instructor. Also, one backup instruc-tor has been developed for each course.
EP group managers review procedure changes for possible lesson plan changes and relate this information to their staff.
Instruction in changes would also be addressed in the requalification courses.
Home study assignment sheets are distributed as needed to update the staff immediately.
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The training matrix (Table 16-1, Rev. 7 of the HC Emergency Plan)
was reviewed against the planning standards of NUREG-0654, Appendix E to 10 CFR 50.47(b)(1) through 50.47(b)(16). While correspondence is~not direct, the inspectors concluded that all requirements, with'the exception of an open item relating to the Hope Creek Visitors Guide noted in a letter of July 17, 1985 from W. R. Butler NRC/NRR to R. L. Mitti, PSE&G (Confirmatory Item 13.3.2.15) have been addressed.
This Confirmatory item remains open and for this report shall be designated as an Open Item (50-354/85-40-03) pending apolicant resolution.
There are also a fe4 of the proposed lesson plans which have yet to be developed (HLP,005, 0080A, B, C, D, E) and a number of corrections which remain to be made to existing lesson plans and associated Emergency Plan Procedures.
This is an Open Item (50-354/85-40-04)
pending resolution by the applicant.
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l Personnel are, as required, trained in equipment use, data interpre-
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tation, access control, and protective action decision making and implementation.
Applicant first aid team members are trained via Red Cross Standard
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Multimedia training. Non-applicant medical services and public emer-l gency response organization personnel are trained by Radiation Management Corporation (RMC). Training for local service support organizations are not included in the Plan, but are found in the Fire Protection Plan and Security Procedures. Training of offsite decision makers i. available and includes the relationships between plant conditions and protective measures. As previously noted, the States train their emergency response personnel independently of the applicant and supplement this training with attendance at select PSE&G EP training courses.
Three hundred and fifty (350) Hope Creek staff personnel are to be
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trained in their emergency response functions by the end of 1985.
Training will encompass classroom instruction, practical instruction and participation in drills and exercises. As of the end of this inspection, approximately 17% of the staff had received training.
No senior level manager had been officially trained for the position of Emergency Response Manager. However, discussions, record checks and course audits by the inspectors indicate that a limited amount of
training for other emergency response functions has taken place and l
1s indeed effective. As such, the inspectors concluded that although the Hope Creek EP Training Program is adequate in content and effec-l tiveness,'it has yet to be implemented for an adequate number and for certain key members of the Hope Creek staff.
This is an Open Item l
(50-354/85-40-05) pending further_ implementation of the training program.
The Artificial Island (Hope Creek and Salem Units 1 & 2 combined) EP Training Program will be transferred to the Salem Nuclear Training Center (NTC) in the beginning of 1986.
Interviews with the NTC Director and four staff members indicate that guidelines for accom-plishing this changeover are not in place and a determination of needed resources is yet to be made. At this time, one NTC staff member has been assigned to bridge the transfer.
The inspectors expressed a concern for maintaining continuity and effectiveness of the EP training program until the transfer is completed. This is an Open Item (59-354/85-40-06) pending applicant development of guide-
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lines to effect a smooth changeover to the new training program with adequate resources.
The applicant is also considering the implementation of computer assisted instruction based on the Control Data PLATO training system as used at San Onofre. Details are not yet available. As this con-sideration develops, NRC will be evaluating it for its impact on the training program.
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5.3 Emergency Preparedness Training Staff and Qualification-Emergency Preparedness training is accomplished by a staff of ten instructors. Two are PSE&G employees (the manager and one technical paraprofessional). These two staff members have five years of experience and have been in the groug from one to three months. The contract employees include two nuclear engineers, one certified Health Physicist, two former civilian' reactor operators and one nuclear navy reactor operator. Two are ANSI 3.1 qualified. All have
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experience at other civilian nuclear powe'r reactors with expertence ranging from four to thirteen years. All had prior EP training experience before coming to PSE&C,
It was noted by the inspectors that the technical strength of the EP training department rests primarily with conf.ract personnel.
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. the event that contractor involvement may be reduced, the Emergency Preparedness Manager and NTC Director have indicated orally that adequate training resources as well as program continuity will be maintained.
ANSI 3.1 and Table 1 of INPO 82-026 (Technical Instructor Training and Qualification) were consulted for guidance in determining staff-qualification. Based on the. information gathered du' ring personnel interviews and presented above, the ir.spectors concluded that the staff is qualified to administer the required instruction. This determination is based on the following considerations:
> The. diversity and depth of experience
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Description of training techniques
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Audit of-performance (critique by students and grade trend analysis)
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Assignment of former R0s to prepare the Event Classification Guide and provide course instruction.
(generally, those who prepare the lesson plans for a course teach the course)
Inspectorauditofasmallsampleoftrakningsessions
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Qualification criteria, however, have not been formally documented.
This is an Open Item (50-35.4/85-40-07) pending applicant development of qualification criteria for EP instructors and recommendations for continuing education.
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6.0 Emergency Facilities and Equipment 6.1 Control Room Facilities 6.1.1 Scope of Review The Control Room and its facilities were examined by the inspector to determine compliance with Emergency Plan requirements.
6.1.2 Findings The inspector found that the Control Room, when completed, will con-tain the monitoring equipment, communications equipment, emergency equipment, and decisional aids required to cope with an emergency.
At this time however, the bulk of this equipment has yet to be installed.
Those items most notably absent are the telephone com-munications system and the Radiation Monitoring System (RMS).
The telephone communications system is to be installed and tested by October 1, 1985. Due to contractural problems, the licensee is experiencing difficulty in the implementation of a fully functional Radiation Monitoring System i.e.,
a system which will feed auto-matically to a radiological dose assessment calculation system.
Present plans are to approach the implementation of the RMS in a graded fashion.
Initial efforts are to install vital bus fed RMS monitors in the control room which will be indicated by strip chart recorders.
In ar emergency, this information would have to be man-ually recoraed and then distributed to the other emergency facilities.
By the conclusion of the inspection, the licensee had not formally presented the deferral request for the full implementation of the RMS system to the NRR Division of Licensing.
The inspector suggested that this be considered as a priority item as it may have a substan-tial effect on the NRC decision to issue a license.
The licensee acknowledged this and stated that submittal of a package to NRC/NRR was imminent.
The completion of the control room facilities required for emergency plan implementation is designated as an Open Item (50-354/85-40-08)
and will be reviewed during the appraisal followup inspection.
6.2 Technical Support Center (TSC) F,gc;11 ties 6.2.1 Scope of Review The TSC and its facilities were examined by the inspector to determine compliance with emergency plan requirements.
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6.2.2 Findings The inspector found the TSC to be a hardened, spacious, well lit facility with suitable accessibility to the control room.
Like the control room however, the TSC is only partially equipped with the facilities required for an adequate emergency response. At the time of the appraisal, the following discrepancies were noted in the TSC:
The telephone communications system has yet to be installed.
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The proposed system will be sufficient to support an emergency response situation, including hookups between the TSC and state local government response agencies, the NRC, the E0F, and the Hope Creek and Salem 1 and 2 control rooms.
The telephone communications system is to be installed and operational by October 1, 1985. The NRC ENS line will not be installed until October 29, 1985 due to scheduling problems.
The ventilation system has not been put into operation.
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proposed system is separate from the control room ventilation system and is provided with filters for habitability conditions similar to that of the control room. The proposed system when activated, will provide for adequate habitability conditions in the TSC.
The computerized data display and analysis systems have yet to
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be installed. The fully operational RMS data monitoring system will not be installed until early to mid-1986. The licensee is developing a contingency plan for transfer of RMS data from the control room to the TSC until the computerized system is in-stalled and coerational.
The MIDAS dose assessment computer system has yet to be installed. The applicant stated the software for the MIDAS system is available for input to the computer when installed in the TSC.
Data would be input manually to the MIDAS dose assess-ment program until the RMS system is fully automated.
The applicant also plans to install in the TSC a plant display computer system (CRIDS), an exposure history computer system (PREMS), and a Compaq portable computer for initial and backup dose calculations for an accident related radiation release.
These computer systems have yet to be installed in the TSC.
A radio communications system (between the TSC and field moni-
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toring teams) has yet to be installed.
The initial installment of RMS instrumentation does not include
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a radiation monitor for the TSC ventilation system.
The licensee has stated that the TSC ventilation system ductwork is
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in close proximity to the control room ventilation system duct-work which will be monitored. The adequacy of this arrangement should be documented by the licensee.
The TSC Emergency Kit is incomplete. A number of items listed
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in Table 9-2 of the Hope Creek Emergency Plan are missing.
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The proposed status boards are adequate but have yet to be installed.
The completion of the TSC facilities required for emergency plan implementation is designated as an Open Item (50-354/85-40-09) and will be reviewed during the appraisal followup inspection.
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Also, the inspector noted a degree of confusion when inquiring as to where the drawings to be used in the TSC would be provided from.
Hope Creek Engineering and Construction Document control personnel stated that they are only responsible for providing drawings and aperture cards to the EOF. This is an Open Item (50-354/85-40-10)
pending clarification of the responsibilities for providing and maintaining these documents.
6.3 Operations Support Center The inspectors reviewed Section 9.1 of the Emergency Plan, "Onsite Emergency Facilities and Equipment; EPI-18, "0SC Activation," and EPI-19 "0SC Notification and Administration," toured the room identified as the Operations Support Center and determined that the 05C is located as stated in the Emergency Plan. The cesignated room is strategically located adjacent to the control room and in close proximity to the Technical Support Center. The area appears adequate in size to assemble and stage OSC support team members prior to dis-patch for repair and corrective actions. The OSC Coordinator's desk is also located inside the OSC where briefings are provided to team members. The licensee stated that due to OSC space limitations, large numbers of personnel (chemistry, I&C, electricians, mainten-ance) normally assigned for emergency operations support would report to the locker room immediately next to the OSC until called upon.
The locker room has more than adequate space to accommodate large numbers of personnel. The OSC was not arranged as an emergency response facility as identified in Figure 9-3 of the Emergency Plan.
Communication links between the OSC and other emergency response facilities (CR, TSC, E0F) have been identified, but telephones and other communications equipment (except for plant page) were not avail-able.
Four NETS telephones and two (2)' dimension 2000 extensions are expected to be available in the OSC as the primary and backup sources for notifications prior to licensing. The callout lists (Procedure EP I-19 attachments) were also incomplete. Section 9.1 of the Emergency Plan indicates that an alternate OSC facility is used but does not identify the location or description of this alternate are.
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However, discussions with licensee personnel indicated that the OSC was engineered with a differential pressure design for maintaining habitability and that the Hope Creek Unit 2 Control Room (unfinished)
could be used as the hardened area for support personnel.
For per-sonnel entering or exiting the radiation control areas, two emergency control points have been established at the 124 ft. and 137 ft. ele-vations. Additional emergency equipment is located at the 137 ft, main centrol point.
Based upon the above findings, this portion of the applicant's program appears acceptable but the following areas need to be evaluated for corrective action:
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Provide all logistical arrangements for the OSC as described in the Emergency Plan and Emergency Plan Implementing Procedures including furniture, communication equipment, radiation protection equipment, and any additional supplies necessary for emergency use.
Describe the facility and identify the specific location for
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the alternate OSC and revise the Emergency Plan and EPP's accordingly.
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Complete installation, testing, and callout procedures used in operation of the primary and backup OSC communication system.
These concerns are colleceively designated as an Open Item (50-354/85-40-11) pending physical completion of the OSC and
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_ documentation thereof in the Emergency Plan and procedures.
6.4 Assessment Equipment The inspectors reviewed Tables 9-1 through 9-6 of.the Emergency Plan and inspected kits used by OSC support members which are located outside the Control Room and OSC areas, in the TSC, and at the radiation control point. The inspectors determined that the Emer-gency Plan inventory description of emergency equipment and supplies appears adequate.
Equipment is stored in emergency lockers.
Inspec-tion of emergency equipment revealed that the locker inventories were either incomplete or not as described in EP inventory lists. All lockers were missing the following essential emergency equipment:
respirators and SCBA's, silver zeolite cartridges, KI tablets, SAM II instruments, and extremity (ring) dosimetry badges. Some lockers also did not have step off pads, complete sets of protective clothing, or radiation work permits.
Equipment designated for assignment to the dedicated cnsite emergency vehicle was available but had not been placed inside the vehicle.
Respirators and other emergency equipment was found in the supply storage room but not assigned to lockers and kits. The facility where testing of respirator cartridge integrity will be performed was also incomplete.
Licensee representatives
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stated that provisions were being made to complete stocking of lockers.
Keys to lockers are kept by senior response personnel.
Radiation monitoring instruments have beta and gamma detection cap-ability for measurement of whole body dose rates and plume exposure rates. Air sampling instruments were portable but could not be used with battery power. Air sampling devices appear to have the capabil-ity to detect radiciodine at levels below 10 7pCi/cc under field conditions. A procedure for conducting inventories of lockers on a regular frequency has not been developed. Of those survey instru-ments contained in lockers, all were found to be functional and have current calibrations. However, check source buttons to ensure reli-able instrument operation prior to use were missing. Calibration of all radiation detection instruments and air samplers are performed as part of the routine health physics program.
Based upon the above findings, this portion of the applicant's l
program will be deemed acceptable pending performance of the follow-
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ing corrective actions:
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Ensure that contents of all emergency lockers are as described in the Emergency Plan and EPP's.
Inventories should be i
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consistent with the description of equipment and supplies outlined in Tables 9-1 through 9-6 of the Emergency Plan.
These inventories should be performed at specified frequencies (
and documented.
Store environmental monitoring equipment in vehicles designated
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for near site surveys.
These concerns are collectively designated as an Open Item (50-354/
85-40-12) pending the completion of stccking of all emergency lockers f
and documentation of the inventory procedures to be used for emer-gency equipment storage areas and vehicles.
6.5 Emergency Communications Equipment The inspectors reviewed a draft copy of Section 7 " Emergency Communi-cations", Rev. 5 to the Emergency Plan provided by the applicant at the time of the appraisal. This section describes the provisions and means which are expected for prompt communications among principal response or anizations, to emergency personnel, and to the public.
Neither of tne primary or secondary communication systems at Hope Creek have been completely installed.
Procedures for use and testing also have not been developed. Communication lines, telephones, and power sources for the control room, TSC, and OSC were not established but a plant page was available. The primary communication system for providing information to New Jersey and Delaware from Hope Creek is an independent offsite premise extension linked to Nuclear Emergency Telecommunication System (NETS) telephones.
The backup means for State communication is a private corporate (PSE&G) microwave system
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(ESSX I) supplemented by the onsite Dimension 2000 telephone system.
The backup systems are commercial telephone lines with independent power systems.
Emergency response facility communication links are
' identified in Emergency Plan Section 7 and provide adequate communi-cations for key licensee responders. When completed and functional, it appears that the primary and secondary systems will have adequate capability to ensure reliable onsite and offsite communications.
However, all emergency telecommunications should be carefully evalu-ated by NRC as soon as each system and respective equipment is in place and testing completed.
Other emergency communication equipment such as alarms were also found not to be functional or surveillance tested. alarms with specific meanings such as radiation emergency alarms, evacuation alarm, sound alarms in high noise areas, and visual alarms in limited sight areas are primarily included as part of the radiation monitoring system (RMS).
Since the RMS is still in the design and review phase, communication alarms should be installed and completed concurrently with RMS installation.
Based upon the above findings, the following areas require corrective action:
Complete installation and testing of the primary and backup
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telecommunication systems and formal incorporation into the Emergency Plan and EPIP's of a description of all details of the emergency telecommunication's systems.
y This is an Open Item (50-354/85-40-13).
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Ensure operation of all emergency related alarm devices
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including radiation, fire, audio, visual, evacuation, etc.
This is an Open Item (50-354/85-40-14) pending installation and testing of all emergency related alarm devices.
6.6 Protective Facilities
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16.6.1 Assembly / Reassembly Areas 6.6.1.1 Review The inspectors reviewed sections 3, 7, and 11 of the Emergency Plan, Emergency Plan Procedures, held discussions with applicant represen-tatives, and observed locations and equipment related to Account-ability and Evacuation. There were six assembly areas observed within the protected area and each was described by procedure. The
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areas appeared to have sufficient ; pace to accommodate expected numbers of personnel. There were also designated assembly areas if required for a site evacuation
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Emergency kits for performing surveys will be available at the Control Point assembly area which is for Chemistry and Radiation Protection personnel.
Surveys will be conducted as required.
The procedures for accountability were reviewed and applicant repre-sentatives stated,that when the system was installed and operational for performing accountability, it would be similar to that in use for the Salem Generating Station. The inspectors also determined that the Radiation Alert Alarms; Evacuation Alarms; and the Station PA system had not been completely installed.
This def-iciency was noted previously in this report.
6.6.i.2 Findings A definitive finding as to the acceptability of the personnel accountability system for the Hope Creek Generating Station cannot be made until the site access facility and related equipment is fully installed and operational. This is an Open Item (50-354/85-40-15).
The applicant's actions in addressing this item will be reviewed in a subsequent inspection after the personnel accountability system is installed and operational.
6.6.2 Medical Treatment Facilities Review
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The inspectors reviewed sections 3 and 13 of the Emergency Plan,
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Emergency Plan Procedures, and held discussions with applicant representatives.
During an inspection of the 137' Control Point, the inspectors determined that the first aid facility had not been established but was scheduled to be located near the Control Point.
A site and ambulance with equipment was also described in the plan but was not in place for the Hope Creek site.
The procedures also describe the use of an off-site ambulance service.
Treatment for contaminated injured personnel has been arranged with Salem Memorial Hospital. The procedures regarding Medical Services and transport of injured personnel _ are similar to those presently in effect for the Salem Generating Station.
6.6.2.1 Findings The following area was identified as an Open Item (50-354/85-40-16)
requiring applicant attention:
The first aid facility has not been established. The applicant's
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action in addressing this item will be reviewed in a subsequent inspection after the first aid facility is installed, equipped, and operational.
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6.6.3 Decontamination Facilities 6.6.3.1 Rev?ew The inspectors reviewed Section 12 of the Emergency plan, Emergency Plan Procedures, and held discussions with applicant representatives and observed the personnel decontamination station established at the 137' Control Point Area.
The station is equipped with showers and sinks but no decontamination supplies have been provided. The site decontamination procedures for personnel and vehicles are des-cribed in the Radiation Protection Manual and the offsite decontami-nation of personnel and vehicles are described in the EPIP's. The offsite facilities are located at the Emergency Operating Facility which has been established for the Salem Nuclear Generating Station.
6.6.3.2 Findings The following area was ider.tified as an Open Item (50-354/85-40-17)
requiring applicant attention:
The decontamination facility on site had not been provided with
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procedures and decontamination supplies.
The applicant's action in addressing this item will be reviewed in a subsequent inspection after the facility is supplied and
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6.7 Meteorological Instrumentation
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6.7.1-Review The inspectors reviewed the applicant's meteorological measurements program against the guidance and criteria listed in Section 6.7.3 of this report to determine if:
.The monitoring program is adequately described and readouts are
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available; all instruments, required by technical specifications, are
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operable and calibrated;
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a surveillance program is established and maintained;
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provisions are established for continuously obtaining representative real-time meteorological information for dose projections and protective action decision making, and;
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meteorological instruments provide reliable indication of the basic parameters required by the emergency plan.
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6.7.2 Findings The applicant outlined the characteristics of the meteorological monitoring program and provided the inspector with the ' Artificial Island Environmental Meteorological Monitoring Manual', Rev. 5. A description and outline of the instrumentation, monitoring location and data acquisition system were also included in HCGS FSAR Section 2.3.3, and the HCGS Emergency Plan Section 9.0 respectively.
The licensee indicated that the system was not fully operational and had recently been modified to include a hard disk drive as part of the data logging and acquisition equipment.
The Salem / Hope Creek meteorological tower and instrument shelter was visited by the inspectors. The inspectors found that the instruments were adequately maintained in accordance with Technical Specification - 3.3.3.4 for Salem Unit 1.
However, the surveillance and calibration program does not include the entire monitoring system; the primary and back-up data acquisition system (DAS) and back-up tower are not included in the periodic (monthly and quarterly) calibrations.
In addition, the CRIDS and RMS meteorological data di: play, which will-provide essential meteorological parameters to the control room, are not currently part of the calibration procedure. The inspector also found that no meteorological data is available on a continuous basis in the control room, the licensee has indicated that an interim method is planned.
The inspector noted that the meteorological monitoring and instru-mentation on the primary and back-up towers meets the intent of R.G. 1.23 and ANS 2.5 for siting and evaluation of routine environ-mental impacts.
However, the meteorological monitoring system must also provide representative meteorological conditions in the site vicinity (up to about 10 miles) of the plant site for accidental radioactive releases in support of protective action decision making.
The inspector verified that real-time meteorological data was available at the met tower and Salem Unit I control room and could be obtained directly from the DAS computer through remote interrog-ation.
The inspector confirmed the reliability of the analog system, which was found to be adequate based on the percent annual data recovery for the essential parameters (wind speed, wind direction and a measure of atmospheric stability) and expedient corrective action following major loss of capability (i.e. ice storms).
Based on the discussion above, the following are identified as open items requiring resolution by the applican.
23 Open Item 50-354/85-40-18: The meteorological monitoring program's current calibration (monthly and quarterly) procedure does not include the entire system. The primary and back-up data acquisition system (DAS) and back-up tower instrumentation should be included in the. periodic calibrations.
In addition, the CRIDS and RMS meteoro-logical data display should also be verified during calibrations.
Open Item 50-384/85-40-19: The meteorological monitoring system must provide representative meteorological conditions in the vicinity (up to about 10 miles) of the plant site.
Open Item 50-384/85-40-20: Provide continuous m'eteorological parameters to the Control Room (HCNGS) prior to fuel load.
6.8 Transportation The applicant has ten vehicles specifically dedicated to emergency response operations. These included one dedicated emergency survey van for offsite monitoring purposes. Two ambulances are available on site.
Fire vehicles are available at the EOF. Most of these vehicles are equipped with both radio and radio telephone communications systems.
Based on the above findings, this portion of the applicant program appears to be acceptable.
7.0 Emergency Procedures 7.1. Scope of Review
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The inspectors reviewed the Emergency Plan Procedures (EPPs) and other associated procedures (Radiation Protection Procedures, Administrative Procedures,...) for general format and content,' for compliance with the Emergency Plan, and for ease of application.
The. inspectors also reviewed the Emergency Action Levels with the
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attendant Event Classification Guide to determine agreement with the EAL guidelines of NUREG-0654.
7.2-Findings 7.2.1 General
.The inspectors found the EPPs to be of good format and content. The
. procedures are logically written and the text is understandable to the user. Several of the EPPs however, are incomplete or are being revised at this time. The applicant has stated that these changes will be made shortly so that the completed procedures may be incorporated into the Emergency Plan and the EP Training Program.
Also, the applicant has acknowledged the need for minor procedural changes as suggested by various inspection team members during the
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course of the inspection and is treating them accordingly. The need for the aforementioned procedural changes and additions will be collectively considered as an Open Item (50-354/85-40-21) pending procedural revisions and implementation into the Emergency Plan and the EP Training Program.
7.2.2 Emergency _ Action Levels 7.2.2.1 Scope of Review The inspector reviewed the Emergency Action Levels (EAL) in Section 5 of the Hope Creek Emergency Plan and the Event Classification Guide (ECG) to determine agreement with the EAL guidelines in NUREG-0654.
The inspector also inquired as to how the control room operators will be triggered into the ECG to effect event classification.
7.2.2.2 Findings There is agreement between the EALs/ECG and NUREG-0654 with one exception.
Initiating Conditions 78 (Alert) and 7C (Site Area Emer-gency) call for event declaration in situations when all annunciators are lost. NUREG-0654 refers to situations when most or all of the annunciators are lost. The inspector determined that situations could indeed exist in which a significant amount, but not all, of the
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control room annunciators could be lost. Such situations snould be considered for event declaration, depending on the amount of annun-ciators-lost and the systems involved. This is an Open Item (50-354/85-40-22) pending applicant consideration and subsequent NRC:RI review.
The inspector also found that the control room operators are to be directed into the Event Classification Guide from the Emergency Operating Procedures (EOPs).
The first drafts of the E0Ps do not include the needed procedural steps to effect this direction.
This is an Open Item (50-354/85-40-23) pending revision of the Hope Creek Emergency Operating Procedures.
7.2.3 Assessment Actions (Dose Projections)
7.2.3.1 Review The inspectors reviewed the licensee's dose assessment procedures, held discussions with licensee personnel and evaluated this area against the guidance and criteria listed in Section 7.2.3.3 of this report to determine if that provisions for making offsite dose projections are complete, adequate, ava G able and personnel have been traine,
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7.2.3.2 Findings The-inspector reviewed HCGS Emergency Plan, Section 10, Rev. 4,
"- Accident Assessment" and held discussions with the license: L3 the primary systems utilized to support emergency planning activities.
The Radiological Monitoring System (RMS) which will provide a major portion of the accident assessment capability has not been completed.
An interim system is planned. The licensee was currently working on the proposal for a " mini" or " interim" RMS system, to be installed and operational by fuel load.
This area is unresolved.
The inspector verified that procedures, lesson plans and training were developed.
However, the associated training was not complete.
The interim RMS system design planned for fuel load till fuel power, will effect the completion of training and modification of proce-dures. This is an Open Item (50-354/85-40-24) pending installation and incorporation of both the " interim" and/or " final" RMS System into the Emergency Plan, procedures, training, and other related documentation.
7.3 Audit The Hope Creek Emergency Plan states that the plan and its imple-menting procedures will be reviewed on an annual basis. The inspec-
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tors held discussions with QA and safety review personnel, reviewed Sections 17.4, 17.5 and 17.6 (Audits) of the Hope Creek Emergency Plan, and examined Emergency Plan Procedure VI-5, Annual Quality Assurance Review of Emergency Preparedness, to determine the validity and comprehensiveness of the EP-audit program at Hope Crem,.
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The proposed audit program appears to be adequate to monitor the overall EP program and to provide a means for tracking deficiencies and subsequent corrective actions taken. The effectiveness of the audit program could not be reviewed at this time as the first audit of the Hope Creek Emergency Response Program has yet to be performed.
8.0 Coordination with Offsite Groups 8.1 Offsite Agencies The inspectors reviewed the Attachments to the Emergency Plan, letters of agreement with offsite governmental agencies and support personnel, and met with representatives of the fnllowing offsite agencies: Salem County Memorial Hospital, Cumberland County (New Jersey) Office of Emergency Management, New Castle County (Delaware)
Department of Public Safety, Kent County (Delaware) Department of
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Emergency Planning and Operations (DEPO), Delaware State DEPO, and Radiation Management Corporation. All representatives expressed a clear understanding of their agency's role and responsibility in
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response to Hope Creek emergencies. The inspectors found that arrangement for technical and administrative support at each facility was consistent with the language specified in letters of agrooment. Agreements or contracts between the licensee and each offsite group were current with the exceptions of New Castle County (which had been drafted and was under review) and the physicians identified in the plan who will provide medical advice to the applicant. The representatives interviewed expressed satisfaction with the efforts made by the applicant to coordinate notifications and communications, emergency response training, and routine exchange of information functions.
In most cases, close working relationships have been established with each offsite entity since 1980 as a result of the continuous interface by PSE&G in dealing with emergency planning issues for the Salem Nuclear Generating Station.
Each group-had the opportunity to participate in at least two (2) exercises at Salem and all expect to play active roles in the first Hope Creek exercise (scheduled for late October 1985).
Additional training of offsite groups is an ongoing effort and the epplicant has provided training sessiors on review of the Emergency Flan and its concepts, EPP's, radiation protection, and the ECG.
However, offsite training has not been completely implemented since all offsite representatives did not have a chance to visit or attend Hope Creek site specific training.
Controlled copies of the Hope Creek EP and EPP's were distributed to and are maintained by all offsite groups except for Salem County Memorial Hospital.
Delaware representatives appearai to be familiar with the applicant EPP's affecting State response, i.e.,
notifica-tions, communications, and recommendations for protective measures.
State personnel explained that their protective action recommenda-tions would be consistent with those made by the applicant.
County representatives indicated that recommendations for protective measures which were agreed on by the State and the applicant would bt:
supported at the local level.
Those individuals who were interviewed by the inspectors were identi-fied as top level representatives of their respective organizations.
In general, satisfaction was found on their part with the applicant coordination and cooperation and all stated that they were prepared to honor all language identified in agreements.
Based upon the above findings, this portion of the applicant's program will be deemed acceptable, pending resolution of the follow-ing Open Items:
Open Item (50-354/85-40-25) Ensure that all letters of
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27 Open Item (50-354/85-40-26) Complete the orientation and
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training program for New Jersey and Delaware State and county representatives.
Open Item (50-354/85-40-27) Ensure that controlled copies of
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the Emergency Plan, Emergency Plan Implementing Procedures, and other emergency planning documentation are maintained by offsite authorities and emergency response support groups.
8.2 General Public and Transient Information According to Section 8.1 of the plan, emergency planning information is provided to the transient and permanent residents of the Plume Exposure Emergency Planning Zone (EPZ) using bill inserts, pamphlets, advertisements in locally distributed newspapers or telephone books, and placards and/or postings at recreational facilities as appropriate. This information is either updated and redistributed or verified to be in place at appropriate locations annually.
During interviews with the applicant's public information and emergency preparedness representatives, the inspector was informed of the status of the issuance and distribution of the applicant's public information program. As the licensee of Salem Generating Station, Public Service Electric and Gas Company (PSE&G) has estab-lished a public information program, including a map / brochure on emergency information, a rumor control phone line at Artificial Island, a siren fact placard, a farmer and special needs (handicapped)
mail-in card, and emergency information placed in local newspapers.
However, the inspector was informed that the siren fact placard and special needs mail-in post card have not been effective.
The placards have been torn down by vandals or other persons and the handicapped are reluctant to make public knowledge of their special needs by virtue of the non-confidentiality of the post card. The applicant plans to provide a questionnaire for special needs persons which is to be completed by the individual, placed within an envelope and mailed to the respective county emergency management office. With regard to the placard, the applicant plans to update the placard with more useful information and distribute them via state and county agencies in time for the initial Hope Creek exercise to be held on October 29, 1985.
In addition, the applicant has obtained telephone book subscriptions for inserting emergency in forma tion. However, the new phone book books will not be issued until January 1986 (Delaware) and April 1986 (New Jersey).
PSE&G has had an ongoing public information program in support of its Salem Generating Station.
However, an updated map / brochure, updated siren fact placard, new special needs questionnaire and telephone book inserts have not been distributed.
In addition, the HCGS plan needs to be revised with regard to the applicant's commitment to
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place emergency information in utility bill mailings.
Since the 10-mile EPZ lies within other electric company service areas, this method of disseminating emergency information is not feasible, and according to emergency preparedness representatives will probably not be used.
Based on the above findings, the following items must be corrected to achieve an acceptable program:
The plan requires revision with respect to placing emergency
planning information in utility bill mailings. This is an Open Item which must be addressed in Revision 9 to the plan.
(50-354/85-40-28)
Update and distribute the emergency information map / brochure
and the new special needs questionnaire to residents in the 10-mile EPZ. This is an Open Item (50-354/85-40-29)
Ensure distribution of emergency information via telephone book
inserts. This is an Open Item (50-354/85-40-30).
8.3 News Media The inspectors evaluated the applicant's program for familiarizing the news media with aspects of emergency preparedness through inter-views with the Public Information Manager and emergency preparedness representatives.
Familiarization for the news media was conducted on April 3, 1985, and included two local radio stations and two local newspapers.
Expansion of the public information department is underway.
Two public affairs representatives will operate out of the appliant's EOF, one for Salem (PWR) and one for Hope Creek (BWR). A staff of approximately 34 public affairs personnel (including cor-porate personnel) are currently undergoing training at this time.
The applicant plans to move the Emergency News Center (ENC) from the
. EOF locale to the Salem YMCA. A selected pool of media representa-tives will be allowed limited access to the EOF during an emergency situation at Artificial Island. The ENC will have 54 dedicated media telephone lines as well as 50 other phone lines for utility, state, Federal and offsite support group use. A training walk-through will be completed at the new location of the ENC in preparation for the Hope Creek exercise in October 1985.
Based on the above information, this portion of the applicant's program is acceptable.
9.0 Exit Meeting An exit meeting was held on August 16, 1985 to discuss the findings of the l
appraisal team as denoted in this inspection report. The inspectors summarized the inspection findings (open items) and presented a general conclusion that a definitive statement as to the applicant's readiness i
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i to respond to an emergency situation could not be made due to the incomple-teness of a number of critical emergency response program areas (facili-ties, training program, RMS,...).
The inspectors also requested that the applicant periodically report to NRC Region I the progress of selected Emergency Plan areas to facilitate the decision as to when the appraisal followup inspection will be performed.
At no time during the inspection was written material provided to the licensee by the inspectors.