ML20199D167

Insp Rept 50-312/86-14 on 860402-11 & 21-25.Violations Noted:Failure to Ensure That Emergency Plan Training Available to Appropriate Personnel & Maintain Current Emergency Plan Implementing Procedures

ML20199D167
Person / Time
Site:	Rancho Seco
Issue date:	06/06/1986
From:	Fish R, Martin G, Prendergast K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20199D165	List: ML20199D160 ML20199D167
References
50-312-86-14, NUDOCS 8606200079
Download: ML20199D167 (11)

See also: IR 05000312/1986014

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U. S. NUCLEAR REGULATORY COMMISSION

. REGION V

Report No. 50-312/86-14

Docket No. 50-312

License No. DPR-54

Licensee: Sacramento Municipal Utility District

P. O. Box 15830

Sacramento, California 95813

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Facility Name: Rancho Seco Nuclear Generating Station

Inspection at: Clay Station, California

Inspection Conducted: April 2-11 and 21-25, 1986

Inspectors: Ih2 MM M 6,19tif:>

1 K. Prendergast, Emerd4ncy Preparedness Analyst Date Signed

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Greg Martin,(Realth Physicist Dat'e signed

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Paci c Northw st Labor tories

Approved By: -

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R. Fidh, Chief Datn Signed

Emergency Preparedness Section

Summary:

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Inspection on Ap-11 2-11 and 21-25, 1986 (Report No. 50-312/86-14)

Areas Inspected: Unannounced routine inspection of the licensee's emergency

preparedness program including

knowledge and performance of duties,' licensee

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audits, protective action decision making, emergency detection and

classification, changes to the emergency preparedness program, notification

and communication, and followup on open items identified during previous NRC

inspections. Inspection procedures 82201, 82202, 82203,:82204, 82206, 82207,

82210, and 92701 were addressed.

Results: Of the 7 areas evaluated, 3 apparent violations (with multiple .

examples) of NRC requirements were identified. The violations concerned:

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(1) l

The licensee's failure to insure emergency plan training is provided to all

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appropriate personnel required by Technical Specification 6.8.1.; (2) The

licensee's failure to maintain their emergency implementing procedures j

-current, as required by Technical Specification 6.8.1.; (3) The licensee's

failure to follow some of the requirements contained in 10 CFR 50.54(q) and l

Appendix E. l

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DETAILS

1. Persons Contacted

SMUD PERSONNEL:

• J. McColligan, Nuclear Operations Assistant Manager

• S. Redeker, Operations Manager

• B Dieterich, Manager, Nuclear Licensing Department

S. Woods, Shift Supervisor

D. Dickey, Senior Control Operator

R. Macias, Shift Supervisor

C. Crumpler, Senior Control Operator

• R. Myers, Emergency Preparedness Coordinator

R. Le Neave, Emergency Planner

• D. Finley, Emergency Planner

• W. Hellums, Emergency Planner

• R. Tobin, Emergency Planner

F. Kellie. Health Physics Manager

E. Bradley, Supervising Health Physicist

J. Reese, Plant Health Physicist

B. Mc Donald, Associate Nuclear Engineer

D. Elliot, Quality Assurance

CONTRACTORS:

M. Borter, IMPELL, Emergency Planning

R. Bass REALOGIC, Software Coordinator

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• Indicates those attending the exit interview.

2. FOLLOW-UP ON OPEN ITEMS

(Open) 85-26-03, Review the responsibility to make PARS in the Emergency

Plan and procedures. Section 6 of the Emergency Plan was reviewed and

noted to have been changed to clarify the licensee's responsibility to

formulate and make a protective action recommendation (PAR) to offsite

authorities when conditions warrant. The emergency procedures were

reviewed and noted to contain provisions for protective action

recommendations.- However, the notification form used to notify the

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offsite authorities referenced AP 528 (Protective Action Guides) which

provided no guidance on PARS associated with detericrating plant

conditions, rather it offered guidance only for PARS based upon the

results of dose projection. The procedure was determined to be

inadequate to be used as a tool for the formulation of PARS based upon

plant conditions. This matter is discussed further in paragraph 4B.

(Closed) IN 85-44, Monthly testing of the ENS _and HPN. The licensee had

reviewed this Information Notice and their procedures for the. monthly

checks and changed them to include a check of the Emergency Notification

System from the Control Room and the TSC. Records of monthly checks

were reviewed for 1985 and noted to be adequate.

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(Closed) IN-85-62, Backup telephone numbers for'the NRC Operations

Center. The-licensee has followed the guidance in this notice and placed

backup numbers for the NRC Operations Center on the ENS phones in the

Control Room (CR), Technical Support Center ( TSC), and the Emergency

I Operations Facility (EOF). A physical inspection of the ENS phones inL

l the CR and TSC demonstrated that the labels had'been placed on the phones

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and the correct numbers were in place.

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. (Closed) IN-85-77. Possible Loss of ENS Due to Loss of AC Power.

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According to the licensee's file on this issue, the information notice'

i had been reviewed and an evaluation of the wiring for the ENS system was

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made. .The licensee determined that the system was adequately wired and

4 would remain operable if there was a loss of AC power.

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3. KNOWLEDGE AND PERFORMANCE'0F DUTIES (TRAINING)

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The Emergency Plan, emergency implementing procedures,and records of

4 training were reviewed and interviews with plant personnel, Emergency.

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j Planning Personnel and the Training Manager were held. The following are

! the findings and observations.

A review of the licensee's emergency preparedness training program

revealed the-licensee's contracted training program and related training

i procedure (Temporary Change AP 580) for emergency preparedness training,-

. had expired on 12-31-85 and had,not been replaced by the beginning of

i this inspection. When.the-temporary procedure was allowed to expire

! without being replaced by another procedure', an outdated 1983 procedure,

which was not being implemented, became effective. The. licensee .

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currently plans to use the site training organization to accomplish.EP

training. On April 14, 1986, ie licensee acquired'an additional

individual to help reestablish he emergency preparedness training

i program, and to update AP 580 (Training).

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The EP, Section 8.1.3.(a), states in part, "It is.the responsibility of

the Emergency Preparedness Coordinator to' assure appropriate personnel

receive Emergency Preparedness' Training."' In addition Section 8.1.3(c)

also states " Records of the District's Onsite Emergency Response '

l Organization training will be maintained by the Emergency Preparedness

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Coordinator (EPC) with a copy to be forwarded to the Nuclear Training

Superintendent." The intent of Section 8 was to insure'that someone.in

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the emergency organization was tracking EP training to assure personnel

maintained their required training. The review of training. performed.

indicated the EPC was'not maintaining training records or tracking

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required training. ~The EPC was in possession of a box of records from

, the former contracted training organization. However, the EPC.wa's unable

to produce selected records of the onsite organization, which included

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Control Room staff, and'did not. appear to have'a method to track required

training. The discussions revealed the EPC was not cognizant of the

status of EP training implementation. .In~ addition, the licensee did not

appear to be maintaining a tracking' system to assure appropriate

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individuals receive timely training. The licensee committed to the NRC in

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a letter dated August'31, 1984, to establish a tracking system to assure

that training is maintained.' This review determined that the licensee

had initiated a Nuclear Tracking list, but failed to maintain it,'in that

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the: list did not include all members of the' control room staff and those

individuals who would be designated for the Emergency Team. There was no

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indication that the licensee was attempting to use the list for-its

intended purpose.

In order to ascertain the status of eme'rgency preparedness training, the

inspector examined individual training records maintained by.the Site

Training Department. The examination revealed that eight individuals-on

the Control Room staff had not received their annual. emergency

preparedness. retraining during periods that varied between 15.7.and'17

months. _Four of these individuals were Shift Supervisors, the

individuals who would be the Emergency Coordicator at the beginning of an ,

emergency. In addition 24 members of the District's Emergency Response

Organization, according to records, did not receive retraining including ,

personnel who would fill positions of the EOF Manager, Radiation

Assessment Coordinator, Technical Support Coordinator and'other essential ,

positions. Training for the above individuals varied between 16 and 20

months. AP 580, " Training" states th'at, " Training will be conducted

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annually, and whenever necessitated by significant~ revisions to'the

Emergency Plan, Emergency Plan Procedures, equipment or when changes

occur to emergency assignments" and further references attachment.7.1'to

describe the specific training. Failure to conduct the required training

is an apparent violation of Technical Specification'6.8.1.e which-

requires implementation of procedures governing the EP.

In addition to the finding: 'dentified above, the matter of first1 aid

training was noted to be deficient. First aid training is described in

Section 6 of the Emergency Plan ~. Section'6.2.7 states " Health Physics

personnel and the Emergency Team are provided Advanced First Aid,

Standard Multi-Media and Cardio-Pulminary Resuscitation.(CPR) Training at

Ra'ncho Seco." Section 6.2.7(d)(1) states, " Retraining of personnel

qualified in Advanced First Aid or Standard Multi-Media is conducted

every three years," and paragraph'3 states "At least one member of;the

Emergency Team will have Advanced First Aid training."

Based upon discussions with the site nurse.it' appears-that.the training

for advanced first aid was discontinued approximately 5 years ago, and

that multi-media first: aid was discontinued 3-years ago. Failure-to

conduct the required training'is an apparent violation of 50.54(q), that

requires the' licensee to follow and maintain in effect Emergency Plans

which meet the standards in 50.47(b).and the requirements of' Appendix E.

-The inspector further noted there'were no records to support that the-

licensee had conducted training that would_have been necessitated by.

changes in the Emergency Preparedness Program. . Discussions with licensee

personnel further supported that' training has not been provided in'

all cases. Examples of changes in the emergency preparedness program and

the subsequent lack of training are described in Paragraph 4 and 5 of.

this report,

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Two apparent violations for failure to-implement training pursuant to 10

CFR 50.54(q)~and. Technical Spec,1fication 6.8.1.e-were identified. :The. ,

Technical Specification violation is a repeat violation.- A similar

violation ~was~ issued August.2, 1984. Apparently the licensee's 1

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corrective actions contained in their, August 31,;1984 reply to the;

Notice of. Violation have been ineffective _(86-14-01).

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4. CHANGES TO THE EMERGENCY PREPAREDNESS PROGRAM

h Records of changes to the EP and implementing procedures were reviewed,

i interviews with licensee personnel were performed, and changes in the

i licensee's Emergency Response Organization.(ERO).were examined to

determine that the EP and implementing procedures are being adequately

maintained, and changes to the Plan and procedures do not degrade the

effectiveness;of.the.EP. As a result of.this review the inspector

identified a number'of instances where the EP and implementing procedures

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were not maintained current. The following are the inspector's findings:

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j- a) Prior to July:1955 The Herald Fire Department and,Ione Fire Academy

!. were designated as offsite. relocation points'and provisions were

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made to store emergency equipment and supplies at these facilities.

s During July 1985 the licensee elected to remove emergency. equipment

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from these 2 facilities, although they:still remain offsite

i relocation points.> AP 519, " Site' Evacuation" was revised to reflect

the changes made to the Herald and Ione facilities. The revised-

, procedure states in 5.2.2, " Radiation monitoring and decontamination

equipment must be brought from. Rancho Seco to the offsite relocation

i point." The following procedures were not maintained in that

i emergency equipment and'aupplies are still listed as available at

j these facilities..

1) Section 7 of the EP'still'11sts the Herald Fire Department & j

- Ione Fire Academy as a place where-dedicated emergency

! equipment and' supplies are stored. Emergency' lockers -

] ambulance kits, and decontamination-(decon) kits are

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j specifically mentioned. .

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t 2) AP 516, " Personnel Decontamination," Section 4 refers to >

l- decontamination kits which are maintained at the Herald Fire '

Station and the Ion Fire Academy.

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3) AP 552, "Activ'ation And O Nration Of The Offsite Relocation

! Points',". Sections 1 and 5 also reference emergency equipment,

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protective clothing, curvey instruments, decontamination kits

and respiratory equipment, etc.

j 4)~ AP.305-9D,'" Personnel Decontamination," Sec' tion 3, still lists

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Herald & Ione'as,an area where decontamination kits are stored.

It should be noted'that during a walkthrough'with an individual who

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. would fill the position of the Radiation Assessment Coordinator the' '

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individual was not aware of the removal of the emergency equipment

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formerly stored at the offsite relocation areas. The individual- -

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also stated he had not' received'energency plan training in over a

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year...The matter of training necessitated by changes to the

i' Emergency Preparedness Program was previously discussed in.ParagraphL

3 of this report.

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f b) AP 528, " Protective Action Guides" Revision 1,. dated 9/27/85, added

a requirement'that Plant conditions or trends will be considered

when promulgating. protective actions to recommend to offsite

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1 authoritiesa A review of this procedure identified that the

. procedure only' addressed protective actions based upon dose

projection. - The ' statement " plant' conditions and trends" was merely

added.to the instruction portion of the procedure and not the body ~

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l of the. procedure. -The procedure and attachments do not offer-

~ guidance as to what plant condition or trend must be present to

. - recommend shelter or evacustion.

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ic) Th'e -EP, Section 7.1.2, Technical Support Center, states, "The

l Technical Support Center (TSC) is located adjacent to the Control

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i Room and incorporates the Nuclear Operating Superintendents' office

j area and the computer-room as shown'in figures 7.2 and 7.3. This '

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procedure and attachments 7.2 and 7.3 have not been maintained

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current, in that prior to' September 10', 1985 th'e licensee '

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established a new TSC separate from the Control Room. .The new

facility is located down the hallway from the Control Room.

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Section 7.1.5 of the Emergency Plan describes the First Aid Room as ,

- being adjacent to the Auxiliary Building and next to the Safety

Office. In addition Figure 7.8 shows this location as being in.the

building housing-the Tool-Room. The_First_ Aid Room was moved in the

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fall of-1984. The new location of the First Aid room is in the T&R

Building next to the cafeteria.

Additional examples of noncurrent procedures are discussed in Section 5

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of this report.

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Based upon the~ findings of this inspection, the licensee has not

implemented an effective method to assure,that when changes to the.EP,

j emergency implementing procedures, or emergency facilities occur, other ,

impacted procedures are identified and training is accomplished .for those; i

j individuals who may be affected by the changes.- .

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The. failure to. maintain the Emergency Plan ~and implementing procedures

1 current is an apparent violation of-10 CFR 50.54(q) and Technical

, Specification 6.8.1.e, respectively (86-14-02). .

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5. DOSE ASSESSMENT

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'The inspector reviewed the following dose assessment related

documentation to ascertain that adequate methods and procedures exist for

the licensee to formulate emergency action levels (EALS) and-to ,

. continually assess the impact of a release to'the environment.

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i. The Emergency Plan

, Control Room Dose Calculation, AP 509

! . Technical Support Center' Dose Calculation, AP.511

l Emergency Operations Facility. Dose Calculation, AP 512

Activation of the Unified-Dose Assessment Center, AP~554

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Recognition and Classification of. Emergencies, AP 501 .

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Protective Action Guides, AP 528

Dose Assessment Codes (Racode, Jade, and Specter)

Interviews with key personnel responsible for dose assessment in the

Control Room (CR), Technical Support Center (TSC) and the Unified Dose

Assessment Center (UDAC) were held. The interviews with plant and

contractor personnel and procedural reviews identified several problems

as discussed below.

Radiation monitors R150044 and R150045 are the high range effluent

monitors for the reactor and auxiliary building vents. These monitors

were installed pursuant to item II.F.1 of NUREG 0737 and provide the

capability to measure gaseous effluents that might be expected during an

accident. The licensee's procedures that utilize source term for dose

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assessment are contained in AP 509, " Control Room Dose Calculation," AP

511. "TSC Dose Calculation," and AP 512,." EOF Dose Assessment". None of

these procedures contain reference to nor incorporate any methodology to

convert high range instrument response to a source term. The importance

of being able to utilize data from the high range. effluent monitors is

partially illustrated by a careful review of AP-509, " Control Room Dose

Calculation". This procedure addresses release pathways from the

auxiliary building stack. If a calculation is performed using the

maximum reading from the normal range monitors (R15001 and R15002) and

default values (most conservative) for vent flow rate and X/Q, the

projected doses obtained are below the lowest range of Protective Action

Guide values listed in AP 528. Consequently, the procedure as written is

of limited value in assessing the dose consequences from a severe event

with a release rate greater than the capabilities of the normal range

monitors. From a previous NRC inspection (Report No. 50-312/86-06), it

is noted that AP-501, " Recognition and Classification of Emergencies"

also makes no reference to the high range monitors for purposes of

classifying an event. The failure to update and incorporate instructions

for use of the high' range effluent monitors (R150044 and R150045) in

procedures AP 501, AP 509, AP 511 and AP 512 represents an apparent

violation of Technical Specification 6.8.1.e which requires that written

procedures covering the emergency plan to be maintained.

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Additional deficiencies were noted in procedures AP 509, 511 and 512 and

are discussed below,

a) procedures AP 509 and 511 only provide a methodology for determining

the release rate from the auxiliary building. No methodology is

provided for the containment (reactor building) vent.

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b) procedure AP 512 states, "obtain the release rate from Attachment

7.1." Attachment 7.1 has a place for recording release rates (noble

gas and iodine) but provides no methodology _on determining what the

release rate is from instrumentation readings.

Paragraphs (a) & (b) above are additional examples of failure to maintain

procedures.

Interviews with licensee personnel established that computer based dose

assessment is the principal method expected to be used by the licensee in

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the TSC and EOF. Manual calculations would be performed by control room

personnel early in an event and as backup methodology for TSC and EOF

calculations. As discussed above, AP 511 and AP 512, "TSC Dose

Calculation" and " EOF Dose Calculation", respectively, are the licensee's

procedures governing dose. calculations. It is noted that in both of

these procedures the primary emphasis is on manual calculational

techniques. AP 511, under paragraph 5.0, " Instructions" has a note which

states, " NOTE: These calculations may be performed.using Apple II Code

> "RAC0DE". No further instructions are given.regarding how to use the

code, a description of the code, or its limitations and capabilities. AP

512 has a similar note that states." NOTE: These calculations may be

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performed using Apple.II Code "UDACODE". (See AP 554', Attachment 7.7)"..

The inspector noted that " JADE" has replaced "UDACODE" and Attachment 7.6

l is the correct reference in AP 554. Otherwise the referenced

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instructions (Attachment 7.6) appeared adequate for setting up and;

i running the code. However, as is the situation with "RAC0DE", no further

, instructions on code description, limitations and capabilities were

provided. Failure of AP 511 to provide instructions on use of computer

based dose calculations represents an apparent violation of Technical

Specification 6.8.1.e for failure to maintain a procedure.

Further examination of the: licensees use of computer codes for dose

assessment. disclosed the following.

The licensee has three separate codes available for use in the TSC,

" JADE", " SPECTER" and "RACODE".~

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Various changes to the codes occurred in 1985.

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l The Unified Dose Assessment Center'in the EOF only uses the " JADE"

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Only the " SPECTER" code provides a capabil'ity to calculate doses

j based on a primary to secondary release source tera.. It is-also

noted that none of the licensees procedures for manual dose

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calculation (AP 509, 511 and 512) contain methodology for

i calculating doses from a primary'to secondary source term. Since

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control room personnel would rely on the manual calculations, and

the EOF does not.use " SPECTER" it is apparent that the licensee's

capability for assessing the consequences of a primary to secondary

source term is limited.

The licensee was unable to produce documentation such as user guides

that would describe the codes methodologies, assumptions,.

capabilities and limitations.

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Several key individuals (those expected to use the codes,.i.e. a

Radiological Assessment Coordinator and a UDAC Dose Assessment

I Coordinator) interviewed were not aware of all the capabilities .

contained in the codes. The lack of awareness of-computer code

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capabilities or existence indicates that training has not been given

) in all cases when codes were'added or revised.

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The licensee's failure to provide procedures to calculate doses from a

primary to secondary system-source term (except for the TSC) represents

an apparent violation of Technical Specification 6.8.1.e for failure to

maintain procedures.

One apparent violation for failure to maintain procedures pursuant to

Technical Specification 6.8.1.e (with multiple examples) was identified

in this program area.

6. NO"IFICATIONS AND COMMUNICATIONS

Yhe inspector reviewed AP 506, " Notification /Co munication" to determine

that adequate provisions exist for notifying both offsite agencies and

District personnel of an emergency event. This included a review of AP

506.01, " Activation of the TSC", and AP 506.02, " Activation of the EOF".

In addition, the inspector had discussions with one individual from

security. This individual would be tasked with making notifications to

activate the TSC during the evening and backshift hours.

The inspector determined that the licensee has the capability, by

procedure, to notify all appropriate personnel and agencies. However the

discussion with the individual from security further substantiated

weaknesses in the area of training. The individual indicated that it had

been more than a year since emergency plan training had been provided,

and he was unable to locate the proper procedure for notifying District

personnel to activate the TSC. The individual was also unaware of proper

record keeping procedures. AP 506.01 requires records of names of

individuals contacted and the time of contact for planning purposes.

No violations were identified in this program area.

7. LICENSEE AUDITS

10 CFR 50.54(t) requires licensees to provide for a review of the

emergency preparedness program by persons who have no direct

responsibility for implementation of the emergency preparedness program.

A review of the 1986 annual EP audit was performed. From this review the

audit appears to satisfy the regulatory requirements contained in 10 CFR

50.54(t). An examination of the 1985 annual EP audit (audit 0-692) was

also performed to ascertain the status of items identified as deficient

during 1985. Emergency Preparedness Audit number 0-692, the 1985 annual

EP audit, identified deficiencies in the Training Program, maintenance of

the Emergency Plan and implementing procedures, and the licensee's system

for maintaining required records (Plaza 50 Files). The findings of audit

0-692 were transmitted to Corporate and Plant management by letter dated

March 22, 1985. The findings of this inspection and the licensee's 1986

annual EP audit indicate that major deficiencies exist in the Training

Program, maintenance of the Emergency Plan and implementing procedures,

and the licensee's record system. It appears that the licensee has been

ineffective in correcting identified deficiencies (86-14-03).

There were no violations observed in this area.

8. EMERGENCY DETECTION AND CLASSIFICATION

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This program area was inspected to determine whether the licensee used

and understood the standard emergency classification and action level

scheme. Selected emergency action levels (EALs) specified in the

classification procedures were reviewed. The reviewed EALs appeared to

be consistent with the initiating events specified in Appendix 1 of

NUREG-0654. The inspector noted that some of the EALs were based on

parameters obtainable from Control Room instrumentation.

Interviews were held with two Shift Supervisors and two Senior Control

Room Operators to verify that they understood their responsibility and

authority in relation to accident classification, notification, and

protective action recommendations. Walk-through evaluations involving

accident classification problems were conducted vilu,these personnel.

The following weaknesses were identified:

(1) All personnel exhibited difficulty in using the EPIPs to classify

the hypothetical accident situation presented to them. It was

necessary for them to search several times through the procedures to

locate desired information.

(2) The individuals were unable to locate in the procedures the person

responsible for assembly / accountability at the assembly area.

The inspector attributed the above weaknesses to the poor quality of the

licensee's training program as discussed in paragraph 3 above and in NRC

Inspection Report 50-312/86-06, paragraph 4.b.

To insure that the licensee's EALs are consistent with those of the state

and local agencies, discussions with those agencies were held. 10 CFR

50, Appendix E Section IV.B states in part, "That emergency action levels

shall be based on in plant conditions and instrumentation in addition to

onsite and offsite monitoring. These emergency action levels shall be

discussed and agreed on by the applicant and State and local governmental

authorities and approved by NRC. They shall also be reviewed with State

and local governmental authorities on an annual basis."

The discussions with state and local agencies indicated that a review of

the EALs had not taken place in 1985. In addition, the licensee was

unsure if such a review had taken place and was unable to provide

documentation that such a review had been accomplished.

One apparent violation of 10 CFR 50, Appendix E Section IV.B was

identified in this program area for failure to provide for state and

local governmental review of EAL's (86-14-04).

9. PROTECTIVE ACTION DECISION-MAKING

This area was inspected to determine whether the licensee had a

24-hour-per-day capability to assess and analyze emergency conditions and

make recommendations to protect the public and onsite workers.

Essentially, inspection findings affecting protective action decision

making are discussed in previous sections of this report. Problems were

identified in:

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(a) Lack of guidance in the procedures for a protective action

recommendation based upon plant conditions.

(b) General impediments in the dose assessment area.

(c) Training deficiencies affecting the performance of key individuals.

The capability of offsite officials to make protective action decisions

and to promptly notify the public was discussed with licensee

representatives. Licensee procedures made provisions for contacting

responsible offsite authorities on a 24-hour basis. Backup

communications links with offsite authorities were available.

There were no violations identified in this program area.

) 10. EXIT INTERVIEW

An exit interview was held on April 25, 1985, for the purpose of

discussing the praliminary findings of this inspection. Licensee

personnel present have been previously identified in paragraph 1 above.

G. Perez, acting Senior Resident Inspector was also present. The

licensee was informed that violations were identified in a number of

program areas, and that NRC Management would determine the specific

course of action to be taken. The following observations were made by

the inspector:

1. Training was deficient for numerous personnel in the onsite

organization, and the licensee's EP training program and

implementing procedure for training were not current.

2. The Emergency Plan and implementing procedures were not being

maintained. District Personnel were also aware of this fact, This

may have an adverse effect on their effectiveness during an

emergency.

3. The dose assessment program appeared marginal in several areas.

4. The licensee had been ineffective in correcting problems previously

identified by the NRC and their own audit program of the emergency

preparedness program.

5. The licensee does not have the capability to use their procedures to

determine a protective action recommendation based on plant

conditions.