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| issue date = 07/17/2009
| issue date = 07/17/2009
| title = IR 05000271-09-502; 06/08/2009-06/12/2009; Vermont Yankee Nuclear Power Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators
| title = IR 05000271-09-502; 06/08/2009-06/12/2009; Vermont Yankee Nuclear Power Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators
| author name = Trapp J A
| author name = Trapp J
| author affiliation = NRC/RGN-I/DNMS
| author affiliation = NRC/RGN-I/DNMS
| addressee name = Colomb M
| addressee name = Colomb M
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=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:uly 17, 2009
[[Issue date::July 17, 2009]]


Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station Vernon, VT 05354
==SUBJECT:==
VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.


SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO. 05000271/2009502
05000271/2009502


==Dear Mr. Colomb:==
==Dear Mr. Colomb:==
On June 12, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the June 10, 2009, evaluated emergency preparedness exercise at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on June 12, 2009, with Mr. Chris Wamser and other members of your staff.
On June 12, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the June 10, 2009, evaluated emergency preparedness exercise at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on June 12, 2009, with Mr. Chris Wamser and other members of your staff.


The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
 
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.


Based on the results of this inspection, no findings of significance were identified.
Based on the results of this inspection, no findings of significance were identified.


In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).


Sincerely,/RA/ James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-271 License No. DPR-28  
Sincerely,
/RA/
James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-271 License No. DPR-28 Enclosure: NRC Inspection Report 05000271/2009502


===Enclosure:===
July 17, 2009 Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc.
NRC Inspection Report 05000271/2009502 July 17, 2009 Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc. Vermont Yankee Nuclear Power Station Vernon, VT 05354


SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO. 05000271/2009502 Dear M
Vermont Yankee Nuclear Power Station Vernon, VT 05354 SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.
 
05000271/2009502 Dear M


=SUMMARY OF FINDINGS=
=SUMMARY OF FINDINGS=
IR 05000271/2009502; 06/08/2009-06/12/2009;
IR 05000271/2009502; 06/08/2009-06/12/2009; Vermont Yankee Nuclear Power Station;


Vermont Yankee Nuclear Power Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators.
Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators.


This was an announced inspection conducted by two region-based inspectors, and two resident inspectors. No findings of significance were identified. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.
This was an announced inspection conducted by two region-based inspectors, and two resident inspectors. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.


===Cornerstone: Emergency Preparedness===
===Cornerstone: Emergency Preparedness===


===A. NRC-Identified and Self-Revealing Findings===
===NRC-Identified and Self-Revealing Findings===


No findings of significance were identified.
No findings of significance were identified.


B. Licensee-Identified Findings None.
B. Licensee-Identified Findings None.
ii


=REPORT DETAILS=
=REPORT DETAILS=
Line 60: Line 67:
==REACTOR SAFETY==
==REACTOR SAFETY==


===Cornerstone:===
===Cornerstone: Emergency Preparedness (EP)===
Emergency Preparedness (EP)1EP1 Exercise Evaluation (71114.01 - 1 Sample)
 
1EP1 Exercise Evaluation (71114.01 - 1 Sample)


====a. Inspection Scope====
====a. Inspection Scope====
Prior to the June 10, 2009, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Entergy had submitted to the NRC, to determine if the exercise would test major elements of the Vermont Yankee Emergency Plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle. The exercise evaluation consisted of the following review and assessment:
Prior to the June 10, 2009, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Entergy had submitted to the NRC, to determine if the exercise would test major elements of the Vermont Yankee Emergency Plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle.
* The adequacy of Entergy's performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS) described in 10 CFR 50.47(b)(4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and protective action recommendations, respectively.
 
* The overall adequacy of Entergy's Vermont Yankee emergency response facilities with regard to NUREG-0696, "Functional Criteria for Emergency Response Facilities," and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Operations Support Center (OSC), Technical Support Center (TSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC).
The exercise evaluation consisted of the following review and assessment:
* A review of other performance areas, such as: the Vermont Yankee emergency response organization's (ERO's) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies; staffing and procedure adequacy; and the overall implementation of the emergency plan and its implementing procedures.
* The adequacy of Entergys performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(b)(4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and protective action recommendations, respectively.
* A review of past performance issues from the last NRC Vermont Yankee exercise inspection report and Entergy's Vermont Yankee EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50.47(b)(14).
* The overall adequacy of Entergys Vermont Yankee emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Operations Support Center (OSC), Technical Support Center (TSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC).
* The licensee's post-exercise critiques, to evaluate Entergy's self-assessment of its ERO performance during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50, Appendix E, Section IV.F.2.g.
* A review of other performance areas, such as: the Vermont Yankee emergency response organizations (EROs) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies; staffing and procedure adequacy; and the overall implementation of the emergency plan and its implementing procedures.
* A review of past performance issues from the last NRC Vermont Yankee exercise inspection report and Entergys Vermont Yankee EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50.47(b)(14).
* The licensees post-exercise critiques, to evaluate Entergys self-assessment of its ERO performance during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50, Appendix E, Section IV.F.2.g.


The inspectors reviewed the documents listed in the attachment to this report.
The inspectors reviewed the documents listed in the attachment to this report.
Line 75: Line 85:
====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 Sample)
1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 Sample)


====a. Inspection Scope====
====a. Inspection Scope====
Since the last NRC inspection of this program area, in October 2008, Entergy implemented various revisions of the different sections of the Entergy Vermont Yankee Emergency Plan. Entergy had determined that, in accordance with 10 CFR 50.54(q), any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50.
Since the last NRC inspection of this program area, in October 2008, Entergy implemented various revisions of the different sections of the Entergy Vermont Yankee Emergency Plan. Entergy had determined that, in accordance with 10 CFR 50.54(q),any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50.


The inspectors confirmed no EAL changes had been made since October 2008, and conducted a sampling review of other Emergency Plan changes, including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
The inspectors confirmed no EAL changes had been made since October 2008, and conducted a sampling review of other Emergency Plan changes, including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.
Line 94: Line 103:
: (1) Drill and Exercise Performance (DEP);
: (1) Drill and Exercise Performance (DEP);
: (2) Emergency Response Organization (ERO) Drill Participation; and,
: (2) Emergency Response Organization (ERO) Drill Participation; and,
: (3) Alert and Notification System (ANS) Reliability. The last NRC EP inspection at Vermont Yankee was conducted in the fourth quarter of 2008, so the inspectors reviewed supporting documentation from EP drills, training records, and equipment tests from the fourth calendar quarter of 2008 and the first quarter of 2009, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, "Regulatory Assessment Performance Indicator Guidelines,"
: (3) Alert and Notification System (ANS) Reliability. The last NRC EP inspection at Vermont Yankee was conducted in the fourth quarter of 2008, so the inspectors reviewed supporting documentation from EP drills, training records, and equipment tests from the fourth calendar quarter of 2008 and the first quarter of 2009, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 5.
Revision 5.


This inspection activity represented the completion of three samples on an annual cycle.
This inspection activity represented the completion of three samples on an annual cycle.
Line 101: Line 109:
====b. Findings====
====b. Findings====
No findings of significance were identified.
No findings of significance were identified.
{{a|4OA6}}
==4OA6 Meetings, Including Exit==


{{a|4OA6}}
On June 12, 2009, the inspectors presented the results of this inspection to Mr. C.
==4OA6 Meetings, Including Exit==


On June 12, 2009, the inspectors presented the results of this inspection to Mr. C. Wamser, the General Manager of Plant Operations, and other members of the Entergy staff. No proprietary information was provided to the inspectors during this inspection.
Wamser, the General Manager of Plant Operations, and other members of the Entergy staff. No proprietary information was provided to the inspectors during this inspection.


A-ATTACHMENT  
ATTACHMENT


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=
Line 114: Line 123:


===Licensee Personnel===
===Licensee Personnel===
: [[contact::C. Wamser]], General Manager of Plant Operations  
: [[contact::C. Wamser]], General Manager of Plant Operations
: [[contact::M. McKenney]], Emergency Planning Manager  
: [[contact::M. McKenney]], Emergency Planning Manager


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==


None
None
 
==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
==Section 1EP1: Exercise Evaluation==
: Entergy Vermont Yankee Emergency Plan (Revision 46) Vermont Yankee Emergency Plan Implementing Procedures Vermont Yankee June 10, 2009, Emergency Exercise Scenario Package Vermont Yankee Emergency Preparedness Drill Reports, January 2008 - May 2009 
===Condition Reports===
generated as a result of the June 10, 2009, exercise (As documented in the Emergency Response Organization Team "D" After Exercise Report, dated July 13, 2009)
==Section 1EP4: Emergency Action Level and Emergency Plan Changes==
: Entergy Vermont Yankee Emergency Plan (Revision 46)
: EN-LI-100, Process Applicability Determination (Revision 6)
: EN-EP-305, Emergency Planning 10CFR50.54(q) Review Program (Revision 1) Various Emergency Plan and related procedure and equipment 10CFR50.54(q) screenings and evaluations, dated between October 2008 and May 2009


==Section 4OA1: Performance Indicator Verification==
: EN-EP-201, Performance Indicators (Revision 8)
: ERO Drill Participation PI data, October 2008 - March 2009 Alert Notification System PI data, October 2008 - March 2009 DEP PI data, October 2008 - March 2009
: A-
==LIST OF ACRONYMS==
: [[ANS]] [[Alert Notification System]]
: [[CR]] [[Condition Report]]
: [[DEP]] [[Drill and Exercise Performance]]
: [[EAL]] [[Emergency Action Level]]
: [[EOF]] [[Emergency Operations Facility]]
: [[EP]] [[Emergency Preparedness]]
: [[ERO]] [[Emergency Response Organization]]
: [[JIC]] [[Joint Information Center]]
: [[NEI]] [[Nuclear Energy Institute]]
: [[NRC]] [[Nuclear Regulatory Commission]]
: [[OSC]] [[Operations Support Center]]
: [[PI]] [[Performance Indicator]]
: [[RSPS]] [[Risk Significant Planning Standard]]
: [[TSC]] [[Technical Support Center]]
}}
}}

Latest revision as of 22:58, 21 December 2019

IR 05000271-09-502; 06/08/2009-06/12/2009; Vermont Yankee Nuclear Power Station; Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators
ML092010469
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 07/17/2009
From: James Trapp
Division of Nuclear Materials Safety I
To: Michael Colomb
Entergy Nuclear Operations
References
IR-09-502
Download: ML092010469 (11)


Text

uly 17, 2009

SUBJECT:

VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.

05000271/2009502

Dear Mr. Colomb:

On June 12, 2009, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection of the June 10, 2009, evaluated emergency preparedness exercise at your Vermont Yankee Nuclear Power Station. The enclosed inspection report documents the inspection results, which were discussed on June 12, 2009, with Mr. Chris Wamser and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based on the results of this inspection, no findings of significance were identified.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter and its enclosure and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

James A. Trapp, Chief Plant Support Branch 1 Division of Reactor Safety Docket No. 50-271 License No. DPR-28 Enclosure: NRC Inspection Report 05000271/2009502

July 17, 2009 Mr. Michael Colomb Site Vice President Entergy Nuclear Operations, Inc.

Vermont Yankee Nuclear Power Station Vernon, VT 05354 SUBJECT: VERMONT YANKEE NUCLEAR POWER STATION - NRC EVALUATED EMERGENCY PREPAREDNESS EXERCISE - INSPECTION REPORT NO.

05000271/2009502 Dear M

SUMMARY OF FINDINGS

IR 05000271/2009502; 06/08/2009-06/12/2009; Vermont Yankee Nuclear Power Station;

Exercise Evaluation; Emergency Action Level and Emergency Plan Changes; Emergency Preparedness Performance Indicators.

This was an announced inspection conducted by two region-based inspectors, and two resident inspectors. No findings of significance were identified. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Emergency Preparedness

NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee-Identified Findings None.

ii

REPORT DETAILS

REACTOR SAFETY

Cornerstone: Emergency Preparedness (EP)

1EP1 Exercise Evaluation (71114.01 - 1 Sample)

a. Inspection Scope

Prior to the June 10, 2009, emergency preparedness exercise, the NRC inspectors conducted an in-office review of the exercise objectives and scenario, which Entergy had submitted to the NRC, to determine if the exercise would test major elements of the Vermont Yankee Emergency Plan as required by 10 CFR 50.47(b)(14). This overall exercise inspection activity represented the completion of one sample on a biennial cycle.

The exercise evaluation consisted of the following review and assessment:

  • The adequacy of Entergys performance in the biennial full-participation exercise regarding the implementation of the risk-significant planning standards (RSPS)described in 10 CFR 50.47(b)(4), (5), (9), and (10), which are: emergency classification; offsite notification; radiological assessment; and protective action recommendations, respectively.
  • The overall adequacy of Entergys Vermont Yankee emergency response facilities with regard to NUREG-0696, Functional Criteria for Emergency Response Facilities, and Emergency Plan commitments. The facilities assessed were the Control Room Simulator, Operations Support Center (OSC), Technical Support Center (TSC), Emergency Operations Facility (EOF), and Joint Information Center (JIC).
  • A review of other performance areas, such as: the Vermont Yankee emergency response organizations (EROs) recognition of abnormal plant conditions; command and control; intra- and inter-facility communications; prioritization of mitigating activities; utilization of repair and field monitoring teams; interface with offsite agencies; staffing and procedure adequacy; and the overall implementation of the emergency plan and its implementing procedures.
  • A review of past performance issues from the last NRC Vermont Yankee exercise inspection report and Entergys Vermont Yankee EP drill reports, to determine the effectiveness of licensee corrective actions as demonstrated during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50.47(b)(14).
  • The licensees post-exercise critiques, to evaluate Entergys self-assessment of its ERO performance during the June 10, 2009, exercise and to ensure compliance with 10 CFR 50, Appendix E, Section IV.F.2.g.

The inspectors reviewed the documents listed in the attachment to this report.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level (EAL) and Emergency Plan Changes (71114.04 - 1 Sample)

a. Inspection Scope

Since the last NRC inspection of this program area, in October 2008, Entergy implemented various revisions of the different sections of the Entergy Vermont Yankee Emergency Plan. Entergy had determined that, in accordance with 10 CFR 50.54(q),any change made to the Plan, and its lower-tier implementing procedures, had not resulted in any decrease in effectiveness of the Plan, and that the revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR 50.

The inspectors confirmed no EAL changes had been made since October 2008, and conducted a sampling review of other Emergency Plan changes, including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential decreases in effectiveness of the Emergency Plan. However, this review was not documented in an NRC Safety Evaluation Report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES (OA)

4OA1 Performance Indicator (PI) Verification (71151 - 3 Samples)

a. Inspection Scope

The inspectors reviewed data for the Vermont Yankee EP PIs, which are:

(1) Drill and Exercise Performance (DEP);
(2) Emergency Response Organization (ERO) Drill Participation; and,
(3) Alert and Notification System (ANS) Reliability. The last NRC EP inspection at Vermont Yankee was conducted in the fourth quarter of 2008, so the inspectors reviewed supporting documentation from EP drills, training records, and equipment tests from the fourth calendar quarter of 2008 and the first quarter of 2009, to verify the accuracy of the reported PI data. The review of these PIs was conducted in accordance with NRC Inspection Procedure 71151, using the acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 5.

This inspection activity represented the completion of three samples on an annual cycle.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

On June 12, 2009, the inspectors presented the results of this inspection to Mr. C.

Wamser, the General Manager of Plant Operations, and other members of the Entergy staff. No proprietary information was provided to the inspectors during this inspection.

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

C. Wamser, General Manager of Plant Operations
M. McKenney, Emergency Planning Manager

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

None

LIST OF DOCUMENTS REVIEWED