IR 05000315/1986002

Insp Repts 50-315/86-02 & 50-316/86-02 on 860121-24.No Violations,Deficiencies or Deviations Noted.Major Areas Inspected:Emergency Preparedness Program,Including Detection & Classification & Protective Action Decisionmaking

ML20151U390
Person / Time
Site:	Cook
Issue date:	02/06/1986
From:	Foster J, Phillips M, Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20151U359	List: IR 05000315/1986002 ML20151U356
References
50-315-86-02, 50-315-86-2, 50-316-86-02, 50-316-86-2, NUDOCS 8602110008
Download: ML20151U390 (16)

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U.S.~ NUCLEAR REGULATORY COMMISSION

REGION III

Reports No. 50-315/86002(DRSS); 50-316/86002(DRSS)

Docket Nos. 50-315; 50-316 Licenses No. OPR-58; DPR-74 Licensee: American Electric Power Service Corporation Indiana and Michigan Electric Company 1 Riverside Plaza Columbus, OH 43216 Facility Name: Donald C. Cook Nuclear Power Plant, Units 1 and 2 *

Inspection At: Donald C. Cook Site, Bridgeman, MI Inspection Conducted: January 21-24, 1986-Inspectors: W Team Leader Date f$h T. Ploski Date

.?# [ I

. Foster '

DJc '

Approved By:

[$ Chief M.Phillips,h

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Emergency Preparedness Section Date Inspection Summary Inspection on January 21-24', 1986 (Reports No. 50-315/86002(DRSS);

50-316/86002(DRSS))

Areas Inspected: Routine, unannounced inspection of the following areas of the Donald C.-Cook Nuclear Plant emergency preparedness program: cmergency detection and classification; protective action decisionmaking; notifications and communications; shift staffing and augmentation; changes to the emergency preparedness program; knowledge and performance of duties (training); public information program; licensee audits; activations of the licensee's emergency plan; and licensee actions on previously identified emergency preparedness items. The inspection involved 108 inspector-hours by three NRC inspectors and one consultan Results: No violations, deficiencies, or deviations were identifie gRo2110000 060206 ~

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DETAILS 1. Persons Contacted

• Smith, Jr. , Plant Manager

• Blind, Assistant Plant Manager

• Simms, STA Supervisor

• Loope, Emergency Planning Coordinator

• Baker, _0perations Superintendent

• J. Steetzel, QC Superintendent

• S. Wolf, QA Auditor

• K. Pinkowski, QA Auditor

• T. Harshbarger, Emergency Planning, AEPSC G. Arent, Operations / Administration Compliance Coordinator D. Young, Accounting Supervisor T. Lenon, Document Control Coordinator J. Rischling, QC/ Administration Compliance Coordinator H. Rumser, Shift Supervisor R. Blythe, Shift Supervisor N. Wollenslagel, Shift Supervisor L. Boone, Shift Supervisor G. Tollas, Assistant Shift Supervisor R. Freehling, Assistant Shift Supervisor J. Buursma, Assistant Shift Supervisor G. Zimmerman, Assistant Shift Supervisor H. Dannhardt, Shift Technical Advisor R. Ptacek, Shift Technical Advisor D. Karnes, Shift Technical Advisor B. Springman, Shift Technical Advisor R. Sieber, Unit Supervisor C. Smith, Unit Supervisor V. Woods, Unit Supervisor

.C. Archey, Unit Supervisor

• Personnel listed above attended the exit meeting on January 24, 1986.

2. Licensee Actions on Previously Identified Notices of Violation /85002-02, 316/85002-02 (Closed) Severity Level V Violation for Failure to Biennially Review PMI-2070 A review was made of PMI-2070, " Training," to verify that this procedure had been reviewed on a biennially basis as require During the January 1985 inspection (Reports No. 315/85002; 316/85002) the latest review of PMI-2070 was dated September 5, 1979 (Revision 6). PMP-2070 was reviewed on July 26, 1985 (Revision 8) and earlier on February 26, 1985 (Revision 7).

These two revisions in 1985 meet the requirements for biennial reviews. This item is closed.

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. /85002-03; 316/85002-03 (Closed) Severity Level IV Violation for Failure to Train Key Emergency Response Personnel The inspector reviewed lesson plans, individuals' training records, and test results associated with specialized emergency preparedness training conducted during 1985. Training records were checked for about 50 percent of the personnel assigned to the onsite emergency organization and the Emergency Operations Facility (EOF). With the exceptions of several persons who were required to be trained on a yet to be finalized " Security During Emergencies" module, the inspector determined that specialized emergency preparedness training requirements had all been completed by those individuals whose records were checked. The training had generally been completed on the approved modules during the periods February through April and November through December 198 Based on a review of several lesson plans, the inspector concluded that training information had been derived from the following reference documents: the emergency plan; relevant implementing procedures; applicable portions of 10 CFR Part 50; and relevant NUREGs. This item is close /85002-04, 316/85002-04 (Closed) Severity Level IV Violation for Failure of Shift Supervisors to Make Apprcpriate Protective Action Recommendations It was observed through interviews and walkthroughs that each of the four Shift Supervisors interviewed, along with their key Emergency Plan assistants, were able to produce satisfactory protective action recommendations using the flow charts contained in PMP-2080

.EPP.00 This item is close /85002-05 (Closed) Severity Level IV Violation for Untimely Classification and Notifications Review of condition sheets for the event showed that, with one diesel generator down for maintenance, the second diesel generator was declared out of service following an overspeed trip. The Shift

. Supervisor delayed declaring an Unusual Event while the reason for the overspeed trip was investigate This delayed notifications of State and county agencies. Subsequently, in 1985, Shift Supervisors were given augmented classification training in addition to annual Emergency Plan Trainin A spot check of this training during walkthroughs demonstrated correct understanding of this aspect by Shift Supervisors. This item is close . Licensee Actions on Previously Identified Open Items /82005-16, 316/82005-16 (Closed) Meteorological Monitoring System During March 15-26, 1982 an Emergency Preparedness Implementation Appraisal (EPIA) was conducted at the D. C. Cook site, with the results of this Appraisal reported in IE Report No. 315/82005, 316/82005. A recommendation for improvement contained in the Appraisal Report stated that a comparative study should be

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undertaken to assess the representativeness of wind oata from the present tower location for predicting the real time flow of-releases from the Reactor Building. In January 1983, Supplement No. 1 to NUREG-0737 was issue Supplement No. I stated that a reliable indication of meteorological variables for site meteorology-must be'provided. It also stated that "no changes in existing meteorological monitoring systems are necessary if they have historically provided reliable indication of these variables that are representative of meteorological conditions in the vicinity (up to about ten miles) of the plant site." In view of the requirements of NUREG-0737, Supplement No. 1, and the fact that the NRC had already expressed concern over the representativeness of the onsite

'. meteorological data, the issue was again addressed in the Safety Evaluation Report (SER) that was sent to AEPSC under cover letter-dated September 8, 1983. In the SER this was referred to as Clarification Item 4, and pertained to Planning Standard H, Emergency Facilities and Equipment, from NUREG-0654 and 10 CFR Part 50.47(b)(8). This item was also addressed during the January 23-27, 1984 routine emergency preparedness inspection (Report No. 315/84-01, 316/84-01), which stated that this issue would be deferred to the EFR Appraisa Currently, to address NRC concerns on this issue, the licensee is in the process of obtaining several dispersion studies carried out at other nuclear facilities on the Great Lakes. The first step will be

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~to examine these studies in addition to other available data in an attempt to better characterize the meteorological regime in the vicinity of the D. D. Cook site. Obtaining a better characteriza-tion of the meteorological regime should assist in determining the representativeness of the present meteorology tower and determining any necessary future action To consolidate and update this item, Open Item 315/82005-18, 316/82005-18 which was established during the EPIA in 1982, will be closed, and a new Open Item 315/86002-01, 316/86002-01 will be use /82005-18,'316/82005-18 (Closed) Evacuation Time Estimates The licensee completed a revised Evacuation Time Estimates Study in 1984, and has provided this-study to the Berrien County Emergency Services (via letter dated November 18, 1985) for inclusion into the Berrien County Plan. This new study included the prompt notification system currently in use. This item is closed. This also resolves Clarification Item 5 from the SE However, in reviewing this item, it was determined that the licensee's procedures contain no provisions for incorporating evacuation time estimates into the protective action recommendations (PAR) provided to offsite agencies. Since consideration of evacuation time estirr.ates could significantly alter a PAR, providing PARS to offsite authorities without these estimates included may make

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-the recommendation of. limited value as well as inappropriate. The licensee has recognized this p'roblem, and a review of revised procedures currently in the approval process have addressed this concern. This will be examined further during the next exercis /84005-02, 316/84005-02 (Closed) Site / Corporate Emergency Organization A review was made of Revision 4 of the D. C. Cook Emergency Plan dated September 30, 1985. It was determined that the plan contained updated flowcharts that-specified the present site and corporate emergency planning organizations. This item is-close /85002-01, 316/85002-01 (Closed) False Statement A review was made of PMP-2080 EPP.006 dated September 13, 1985, and

'it was verified that it has been modified to specify the use of 50-foot level wind data as the primary level. This addressed the NRC concerns over use of the 50-foot level as opposed to the 150-foot level for primary wind information. .The licensee's response to the NRC on the false information regarding this item (dated March 13, 1985) stated that they "believe that what occurred was a random, inadvertent error," and that " additional layers of review or additional- procedural changes would be unduly burdensome-without a commensurate benefit in.the quality of NRC submittals."

The NRC agrees with the licensec's assessment in this matter. This item is close /85008-01, 316/85008-01 (Closed) Revise Exhibit 8 of PMP-2080 EPP.012 Exhibit B of PMP-2080 EPP.012, now provides space to log the callbacks from offsite agencie This item is close . Licensee Actions on Activations of the Emergency Plan /850XX-01 (Closed) Fire Onsite Lasting More Than Ten Minutes Review of condition sheets for the event showed that a fire was discovered and reported on March 31, 1985 at 0345. An Unusual Event was appropriately declared at 0355, and the State, county and NRC notified in eight, seven, and 20 minutes, respectively, following NOUE declaration. The fire was extinguished at 0405 and the event terminated. This item is close /850XX-02 (Closed) Hydrazine Spill A review of condition sheets showed that an odor was first detected and. reported at 0947 on April 27, 1985. Precautionary area evacuations were prompt, and when the hydrazine spill (leak)'which was the source of the oder was discovered an Unusual Event was

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declared at 1021. Subsequent State, county and NRC notifications were made in a timely fashion. Augmented classification training was subsequently provided to Shift Supervisors in calendar year 1985. This item is close c. 315/850XX-03 (Closed) Contaminated Injury Requiring Hospitalization Review of event condition sheets revealed that the accident occurred at 0920 on April 29, 198 An Unusual Event was declared at 1015, generally coincident with the arrival of the ambulanc State, county and NRC notifications were completed in eight, five, and 11 minutes, respectively. -The ambulance departed at 1032, and the patient was decontaminated at the hospital with no problems. The event was terminated at 1328. This item is close d. 315/850XX-04 (Closed) Both Diesel Generators Declared Inoperable Due to faulty Batteries Review of event condition sheets showed the batteries were found inoperable at 1645 on July 17, 1985 and an Unusual Event was declared simultaneously. Notifications.of State, county and NRC were completed in ten, seven, and 20 minutes, respectively. This item is close e. 315/850XX-05 (Closed) Contaminated Injury Requiring Hospitalization Review of event condition sheets showed an accident occurred at 2204 on August 11, 1985 and an Unusual Event was declared at 2307, coincident with departure of the ambulance. State, county and NRC notifications were completed in five, nine, and 18 minutes respectively. This item is close f. 316/850XX-01 (Closed) With One Diesel Generator Out for Maintenance the Second Diesel Generator Failed an Operability Test Review of event condition sheets showed that the second diesel generator failed the operability test at 0719 on April 2, 198 An Unusual Event was declared at 0730, with notifications to State, county and NRC being completed in eight, eight, and 16 minutes, respectively. The NOUE was terminated at 0813 when one of the diesel generators was restored to operation. This item is close g. Unusual Event on May 14, 1985 Due to Hydrazine Leak With Unit 1 defueled, a hydrazine lead in the No. 1 and 4 feedwater gallery necessitated evacuation of personnel from the area and securing area ventilation and containment purge. A review of event condition sheets showed that the spill was reported (odor) at 1321 and an Unusual Event declared at 133 State, county, and NRC

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notifications were completed within nine, eight, and 20 minutes, respectively. The event was -teminated at 1850 following cleanu ' Licensee actions during this event were appropriate, Unusual Event on September 4, 1985 Due to Activation of Seismic Instrumentation At 0840 on September 4, 1985 the Shift Supervisor reported receiving

" Glitches" on three of four seismic monitors. PMP-2080 EPP.001, ECC - EARTHQUAKE, was the appropriate procedure, and was reference This ECC specified the classification of an UNU!UAL EVENT for "Any activation of seismic instrumentation that is verified to be the result of an earthquake." No instructions were provided for determining or verifying that the activation was the result of an earthquak Subsequently C&I reviewed the tapes and at 1709 that day concluded that an earthquake had occurred. The Shift Supervisor immediately classified the event as NOUE, end notifications to State and county authorities were completed nine minutes later. Notifica-tion to the NRC was not completed until 44 minutes after event classification, and while within the maximum one hour, appears excessive, and was not done immediately after notifying State and county authoritie It is recommended that ECC-3 be revised to provide direction to shift personnel in determining whether the disturbance was seismic-related, such as providing phone numbers to call the National Earthquake Center and local universities which might operate seismic equipment for confirmation or denia It was noted that following the NOUE declaration the National Earthquake Center was called and they reported no indication of an earthquak The event was then terminated at 1807 and designated " false earthquake," the result of an apparent instrument proble Unusual Event on September 6, 1985 Due to Injury Requiring Hospitalization in Excess of 48 Hours An accident, which did not involve contamination, required the hospitalization of the victim. Subsequently, when it was. learned hospitalization would exceed 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, an Unusual Event was declared at 1635 on September 6, 1985. No event form was available in the file However, it appeared from the log entry that State and county notifications were accomplished in a timely fashion. The NRC was notified at 1707. The NOUE was terminated at 1720, although the injured person remained in the hospital. A review of this incident determined that the Emergency Action Level (ECC-20) that requires the declaration of an Unusual Event for a injury requiring a hospital stay in excess of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, is inappropriat It is recommended that the licensee review this portion of ECC-20 for possible deletio Unusual Event on July 23, 1985 Due to the Unavailability of Both Diesel Generators on Unit 1 During a refueling outage on Unit 1, with one diesel generator out of service, the second diesel was declared inoperable due to a

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problem with the ESW pum The ESW pump was declared inoperable at 1645 and an Unusual Event declared simultaneously. A review of the log showed a statement that notifications were completed within 15 minute However, no copy of the notification form was available in the fil NRC notification was completed at 1704. The NOUE was terminated at 0020 when the ESW pump, and thus diesel generator, was restored to servic . Emergency Detection and Classification As documented in the previous Inspection Report (50-315/85002(DRSS), and 50-316/85002(DRSS)), PMP-2080 EPP.001 contained adequate Emergency Action Levels (EALs) to activate the emergency program. Revision 5 to EPP.001

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1had been issued with an effective date of September 6, 1985. Significant among the changes of'the revision was the incorporation into PMP-2080 EPP.001 of the information previously contained in PMP-2080 EPP.002 (NOVE), EPP.003 (ALERT), EPP.004 (SITE AREA EMERGENCY), and EPP.005 (GENERAL EMERGENCY). However, the majority of the recommendations provided in Section 5 of the previous report have not yet been incorporated. The. inspector was informed that draft copies of 13 new procedures were in the review / approval process. These draft procedures, numbered EPP.101 through EPP.113, will be initial issues, and will replace-a number of current EPP's, and are expected to encompass not only the recommendations contained in Section 5 of the previous report, but will effect a number of other changes generated through the licensee's own internal reviews. Because these draft procedures were not yet effective, no comments are provide Based on the above findings, this portion of the licensee's program is adequat . Protective Action Decisionmaking A discussion of the results of walkthroughs and interviews with Shift Supervisors, Assistant Shift Supervisors, Unit Supervisors and Shift Technical Assistants (STAS) is contained in Section 10. In general, the

. shift personnel interviewed exhibited marked improvement over the level of knowledge and facility with protective action decisionmaking demonstrated during the January 1985, inspection. This reflected the additional emphasis which~was placed on Emergency Plan training during 198 Nevertheless, weaknesses remain, the most common being a general lack of facility with handling the ECCs and EPPs, which comes only with regular- review of and practice with those procedures. The issue of the new procedures referred to in Section 5 preceding, should result in marked improvement in consolidation of EAL guidance and consistency in radiological data unit Based on the above findings, this portion of the licensee's program is adequat '

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- Notifications and Communications The f.nspector reviewed the " Accident Information Reporting Data Sheet,"

which was. Exhibit A to Procedure PMP-2080 EPP.012, and the " Nuclear Plant Accident Notification Form - Parts 1 and 2," which was Exhibit C to PMP-2080 EPP.020. These forms served as the means for documenting initial and followup messages, respectively, to be transmitted to State and county officials following any emergency declaration. These forms addressed all the information needs listed under Planning Standard E, Criteria 3 and-4, in NUREG 0654, Revision 1. The inspector determined

.that although-the followup message form was contained in a procedure titled " Activation and Operation of the TSC," its location was adequately referenced in PMP-2080 EPP.012 (Initial Offsite Notification) and PHP-2081 EPP.003 (Followup Offsite Communications).

The inspector examined records of 1985 communications-equipment tests performed in accordance with PMP-2082 EPP.055 (Drills and Exercises).

This procedure indicated that Security would perform monthly communications tests with the State and county Emergency Operations Centers (EOCs); the Operations Department would perform monthly tests of the Emergency Notification System (ENS) telephones in the Control Room and TSC; and that the Accounting Department would perform monthly ENS tests from the EOF to the NRC Operations Center. The inspectors determined that records of these communications tests were maintained by

.the department responsible for performing the equipment test The adequately detailed test records indicated the following: Security had been contacting the State and county EOCs at a much greater frequency than monthly; Operations had been contacting the NRC Operations Center from the Unit 1 Control Room daily during the period and from the Unit 2 Control Room daily since October 1985; Operations had contacted the NRC

. Operations Center monthly from the TCS during the period; and accounting staff had contacted the NRC Operations Center from the E0F at least monthly since January 198 Regarding tests of communications equipment linking the various Emergency Response Facilities (ERFs), the inspector concluded that no periodic testing was procedurally required or documented. However, such communica-tions equipment was utilized during the annual exercise, the practice exercise, and during both semiannual emergency plan drills. Therefore, such communications equipment were, in fact, tested on at least four occasions during 198 Had communications equipment malfunctioned during these events, corrective actions might be initiated as for any other type of drill or exercise critique ite However, it is recommended that the licensee implement a formal procedure for periodically testing communica-tions equipment linking ERF Based on the above findings, this portion of the licensee's program is adequat .

8. Changes to the Emergency Preparedness Program The most significant change to the Emergency Preparedness Program in 1985 was that the licensee hired a full-time Emergency Planning Coordinator (EPC) who started May 1, 1985. This is the first time the licensee has dedicated an individual full-time to emergency preparedness task One of the first tasks of the EPC has been to revise all the Emergency Plan Procedures (EPP's). As of the date of this inspection, all the PMP-2082's had been revised as issued, the PMP-2080's were in the review / approval process, and the PMP-2081's still needed to be don The Emergency Plan also went through a major revision in 198 Due to a limited capability in the training department, the EPC has also been conducting all onsite emergency preparedness training. The goal is to transfer the training responsibilities over to the training department prior to the end of 198 A review was made of the records for distribution of the EPP's. Each EPP has its own distribution sheet. It was determined that changes in the EPP's were being sent out within 30 days as required by 10 CFR Part 50, Appendix E, V. Holders of the EPP's are required to insert the updated procedures and respond within ten days that they have done so. If a response is not obtained, document control will issue a followup letter at ten day interval A review was made of PMP-2082.EPP.009, Revision 3, " Maintenance of the Emergency Plan Procedures." Section 4.1.3 of this procedure requires the EPP's to be reviewed at least annually by the Plant Nuclear Safety Review Committee (PNSRC). An examination of the meeting minutes from PNSRC meeting No. 1854 (on December 26, 1985) verified that all procedures were reviewed annually as required. Section 4.1.2 of PMP-2082 EPP.009 requires that the Nuclear Safety Design Review Committee (NSDRC) conduct an annual audit that includes a review of the Emergency Plan and EPP' A review of this audit (No. 115, dated March 13, 1985) determined that this was done as require A review was also made of approvals for all EPP's and EPP Instruction and Procedure Change Sheet It was determined that all sheets were properly approve Based on the above findings, this portion of the licensee's program is acceptabl . Shift Staffing and Augmentation The inspector examined the licensee's current and proposed procedural provisions for augmenting on-shift personnel following an emergency declaration. The inspector also reviewed records associated with two of the quarterly Emergency Plan Drills which included among their objectives a demonstration of off-hours staff augmentation capabilitie __--_____ _ ---_- _

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Current provisions for augmenting on ' shift personnel were described in PMP-2080 EPP.088, titled " Initiating Manning of Emergency Response Facilities and Calling Off-Duty Plant Personnel." This procedure included the names and home telephone numbers of supervisory and staff personnel and those technician level personnel who would report to the TSC or EOF. Call-out information for tE -hnician level personnel who would report to the OSA were maintained separately from this procedure by various department or section supervisors. The Emergency Planning Coordinator intended to include call-out information for all emergency organization members in one, new procedur This proposed procedure was available in draft form as PMP-2080 EPP.107, titled " Notification of Plant Personnel." Although this change in procedures would have little impact on which personnel would be responsible for the quarterly verification of call-out information, at least the call-out data for all emergency response personnel would be consolidated in one location, namely PMP-2080 EPP.10 The draft of PMP-2080 EPP.107 had undergone corporate review and was ready for plant revie During 1985, the licensee had conducted quarterly Emergency Plan Drills having multiple objectives, including the completion of the periodic-emergency preparedness drill requirements. These quarterly drills were essentially mini exercises of about three to six hours duratio The February and September 1985 drills included among their objectives a demonstration of off-hours staff augmentation capabilitie The inspector concluded, however,-that neither augmentation demonstration was a real test of the current revisions to the call-out lists. For the February drill, the copy of PMP-2080 EPP.008 utilized for the call-out was modified so that the callers could only contact certain personnel whose participation was desired. For example, technicians who were working backshif t were exempted from drill participation. Also, based on discussions with the Emergency Planning Coordinator, the inspector concluded that some participants had prior knowledge of the exact date of this off-hours dril In the September drill, the coordinator instructed personnel to test a draft of the proposed call-out procedure

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instead of the current revisions to the call-out list ain, the inspector concluded that at least some drill participants probably had prior knowledge of the exact drill date and that some persons had been exempted from drill participatio It is recommended that the licensee conduct periodic, unannounced call-out drills utilizing the current revision of the call-out procedure to better demonstrate its off-hours staff augmentation capabilit Drill participants need not report to their duty stations, but need only to accept the notification call During a review of 1985 emergency preparedness training records, the inspector determined that at least three persons had been identified for most emergency organization positions. However, only two persons were listed for the following key positions: Radiation Assessment Coordinator, Environmental Assessment Director, OSA Manager, OSA Communicator, TSC Scribe, and EOF Scribe. The inspector expressed concern regarding the licensee's capability to staff these positions during a prolonged

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emergency activation, should one of the two persons qualified for these positions become unavailable for duty due to vacation, illness, accident, employment termination, or other caus The licensee should have at least three individuals fully trained for each position in the emergency organizatio This is Open Item No. 315/86002-02; 316/86002-0 Based on the above findings, one open item was identified concerning this portion of the licensee's progra . Knowledge and Performance of Duties Walkthroughs were conducted with four perso.n teams from four of the five operating shift Each team was composed of the Shift Supervisor, the Assistant Shift Supervisor, a Unit Supervisor, and the Shift Technical Assistant (STA). The purpose of the walkthroughs was to assess the adequacy of training of these shift teams and their understanding of, and ability to implement their duties and responsibilities as assigned according to the Emergency Plan and procedures. Weaknesses were identified in this~ area during the February 13-17, 1984, inspection, (Inspection Reports No. 50-315/84005; 50-316/84005), and also during the January 7-11, 1985, inspection (Inspection Reports No. 50-315/85002; 50-316/85002). The scope of these walkthroughs were as follows: Each of the team interviews was approximately two hours in duration. Generally the first hour was spent in direct questioning of the teams regarding EAL's, classifications, purpose of the Emergency Plan and Procedures, duties and responsibilities of the Onsite Emergency Coordinator (OSEC),

notification procedures and time requirements, fission product barrier discussions, and the like. The second hour was devoted to situation analyses, i.e., the teams were presented with snapshot parameters in situations involving a LOCA into containment with varying degrees of core damage / core melt condition The teams were asked, based on the information supplied, to arrive at event classification, and protective action recommendations. Additional areas addressed were dose projection calculations, questions based onsite boundary and offsite radiation levels, seismic events, CO2 discharge, and loss of both diesel generators of one unit. Because of time constraints these additional areas were not presented to all teams, but one or more areas were presented to each team. The following are specific results of the walkthrough * Each team was able to adequately classify the situations presente However, in some instances the times required to reach a correct classification were excessiv * The teams were familiar with the offsite notificatian form However, some team members were weak in their understanding of call-back verificatio * The one team asked to demonstrate or discuss dose rate calculations was weak'and uncertain in the use of the nomograms in PMP-2080 EPP.00 i

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• There was an inconsistency of understanding among teams as to whether a skeleton crew was required to go the the EOF at ALERT, or whether this was discretionary on the part of the OSE * In delineating the duties of the OSEC several teams required considerable prompting to arrive at the duty involving authority to exceed 10 CFR Part 20 radiation exposure limits to protect vital equipment or to save lif It was subsequently noted that this responsibility was not included in the listing of OSEC responsibili-ties provided in PMP-2080 EPP.015, although it is specified in the Emergency Plan, Section 12.3.3.2.1 and also addressed in PMP-2082 EPP.001, Section 3.1.1. In addition, it was noted that neither the listing of OSEC duties in EPP.015 nor the listing in the Emergency Plan specified those responsibilities which may not be delegated to other elements.of the Emergency Organization, as described in NUREG-0654, II. * Each of the four teams experienced some degree of difficulty in using the protective action decisionmaking flow charts in PMP-2080 EPP.001, Exhibit B. This was due in part to a lack of practice, but was also because the flow charts themselves were often awkward to use. Among other shortcomings, these flow charts are set up to be entered at the least serious level and progress to the most seriou (Reversing this process would cause the operator to look at the most serious condition first, and work in the direction of lesser severity until the existing condition were reached.) In spite of these impediments each of the teams was able to arrive at correct protective action recommendation * One team member was quite adamant in his belief that road and weather conditions were not necessary to consider in developing protective action recommendations. It was noted that he would have_been overruled by the other members of his tea * It-is recommended that several members of each shift, (Shift Supervisor, Assistant Shift Supervisor, Unit Supervisors and the STA) be encouraged to periodically review various parts of the Emergency Plan and Procedures 11 order to upgrade and maintain their

. familiarity and facility with their Emergency Plan duties, as an adjunct to their annual Emergency Plan retrainin In addition to the walkthroughs, a review was made of lesson plans, individuals' training records, and test results associated with specialized emergency preparedness training conducted during 198 Although Procedure PMP-2082 EPP.006, titled " Emergency Plan Training,"

indicated that the plant's Training Section was responsible for the development, im4ementation, and maintenance of the Emergency Plan Training Prograf., the inspector determined that the Emergency Planning Coordinator had served as the principal training instructor during 1985, had developed the training modules, ar.d had maintained the training records of persons who had received specialized emergency preparedness training in 198 ._____-_____-________a

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liine emergency plan training modules were identified in PMP-2082 EPP.00 The inspector determined that lesson plan development had been completed for all modules except those titled " Emergency Communications and Notifica-tion" and." Security During Emergencies.'" However, the former had been sufficiently developed so that training had been accomplished, including training handouts and a test on lecture materia The EPC indicated that initial training on the " Security During Emergencies" module would be completed by June 1986, as relevant procedures were still being revise The inspector examined several lesson plans and concluded that they were based on the following references: applicable sections of 10 CFR Part 50; the Emergency Plan; relevant implementing. procedures; and relevant NUREG Training provisions included tests for each of the module PMP-2082 EPP.006 also included an emergency plan training matrix which identified the training module requirements for most positions in the emergency organization. The EPC indicated that the matrix was out of date, as some changes in the emergency organization positions and titles had been implemented but were not yet reflected in the matri A revision to the matrix was being developed that would list all position titles in the emergency organization and'the associated training requirement The inspector examined individual training records for over 50 percent of the persons identified as members of the plant's emergency organizatio Records were complete, readily available, and included: which modules were required training; training attendance dates; test scores; and copies of test cover sheets signed by the students. -The records of at least one person assigned to each position in the emergency organization were checked, regardless of whether of not the position was listed in the current revision of the training matri The inspector concluded that each person whose records were examined (approximately 100 persons in all) had successfully completed training on all appropriate modules

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during 1985, except for those persons who had not been trained on the yet to be developed " Security During Emergencies" modul Based on the above-findings, this portion of the licensee's program is adequat . Public Information Program The inspector verified that a public information Emergency Preparedness booklet had been developed and distribute The booklet's contents were reviewed in 1985, and draft revisions coordinated with County and State Police officials. Records indicated that the licensee distributed the revised booklet (with monthly billings)

to 75,000 utility customers in Michigan during the month of August,198 The licensee had also obtained a listing of health facilities, motels,

-and parks in the Emergency Planning Zone (EPZ), and had hand delivered supplies of the booklets to those facilities during August and September of-198 Records were available to verify locations, quantities, dates of delivery, and the individual performing the delivery of these booklet .-________-_-_____________-_.]

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In addition, the licensee has taken out an advertisement in the public

'information booklet provided.to visitors to the nearby Warren Dunes Park, briefly advising of the availability of emergency informatio The booklet was reviewed and found to contain appropriate information as to methods and times of public notifications, protective actions, general plant information, listing of local broadcast stations, a return mailer for individuals wishing to indicate the'ir needs for special assistance, and a point of contact for additional informatio Licensee personnel indicted that they have volunteered for FEMA review of their revised booklet, but have not yet received a response from FEM The licensee presently plans a yearly review and redistribution of the booklet in its entirety, as opposed to the previous practice of issuing supplements to the booklet rather than entire booklet Based on the above findings, this portion of the licensee's program is adequat . Licensee Audits The inspector reviewed NSDRC-115, which was the QA Audit Summary Report of the Cook Emergency Plan. The audit was performed during the period of February 19-22, 1985. Since the previous audit was conducted during February 1984, the requirements to perform the audit every twelve months has been satisfie The review of the audit determined that the licensee addressed items that had been addressed in previous audits, as well as followed up on the status of NRC emergency preparedness open items, violations and weaknesse New audit findings are classified as Corrective Action Requests (which are items that must be corrected) and Recommendations (which are items that are optionally corrected). After completion of the audit, findings are sent to the plant for review and response and are tracked. A review of the audit showed that the scope and depth were adequate, with one exception. The 10 CFR Part 50.54(t) requirement that "an evaluation for adequacy of interfaces with State and local governments" be reviewed as part of the audit, was not addressed in the audit repor Discussions with members of the QA audit team determined that the team did in fact review the interfaces with State and local governments, but failed to state this in the repor In addition, the depth of this review was minimal. Since this evaluation of interfaces is a specific requirement of 10 CFR Part 50.54(t), the licensee is strongly encouraged to address their review results on this item in the twelve month audit repor In addition, there is no provision to provide a copy of the portion of the audit that addresses the adequacy of interfaces with the State and local governments to these government It is recommended that the licensee develop a formal procedure to make this portion of the audit available to State and local governments as specified in 10 CFR Part 50.54(t)'.

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Personnel conducting the audit were from American Electric Power Service Corporation in Columbus, Ohio, who had no direct responsibility for the implementation of the emergency preparedness progra Currently the

' licensee.is in the process of developing an agreement with other utilities in the State of Michigan to assist each other in-the performance of the 10 CFR Part 50.54(t) twelve month review requirement Based on the above findings, this~ portion of the licensee's program is adequat . Exit Interview The_ inspectors held an exit interview on January'24,'1986, with the representatives dtnoted in Section 1. The NRC team leader discussed the scope and findings of the inspectio The inspectors also discussed the content of the report to determine if the licensee thought that any of the information was proprietar The licensee responded that none of the information should be proprietar