IR 05000528/1986015

Emergency Response Appraisal Insp Repts 50-528/86-15 & 50-529/86-15 on 860519-23.No Deficiencies or Violations Noted.Major Areas Inspected:Licensee Implementation of NUREG-0737,Suppl 1

ML20212P371
Person / Time
Site:	Palo Verde
Issue date:	08/22/1986
From:	Fish R, Prendergast K, Temple G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20212P369	List: IR 05000528/1986015 ML20212P366
References
RTR-NUREG-0737 50-528-86-15, 50-529-86-15, NUDOCS 8609030107
Download: ML20212P371 (27)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION V

Report Nos. 50-528/86-15 and 50-529/86-15 Docket Nos. 50-528 and 50-529 License Nos. NPF-34 and NPF-51 Licensee: Arizona Nuclear Power Project P. O. Box 52034 Phoenix, Arizona 85072-2034 Facility Name: Palo Verde Nuclear Generating Station Units 1 and 2 Inspection at: Palo Verde Site - Wintersburg, Arizona Inspection Conducted: May 19-23, 1986 Inspectors: (,N JJAhp 6)2\

C. M Teriple, Emergency Preparedness Analyst Date Signed O'&k % Yu &

K.' M. Prendergast, Emergency Preparedness Analyst DatbSi[gnedh h th Team Members: T. II. Essig, Manager, llealth Physics Technology Section, Battelle, Pacific Northwest Laboratories (PNL) .

J. V. Ramsdell, Senior Research Scientist, PNL P. J. Ilof, Senior Technical Specialist, PNL M. K. Lindell, Research Scientist, Battelle-Human Affairs Research Centers G. R. Bryan, Jr., Reactor Operations Engineer, Comex Corporation Approved by: b!t I(. F. Fish, Chief, Emergency Preparedness Section Dite Si'gned Summary: '

Inspection on May 19-23, 1986 (Report Nos. 50-528/86-15 and 50-529/86-15)

Areas Inspected: An announced appraisal of the Emergency Response Facilities (ERFs) was conducted using IE Inspection Procedure 82212 to determine if the licensee has successfully implemented the requirements in Supplement 1 to NUREG-0737 and the regulations. The appraisal covered the Technical Support Center (TSC), Operations Support Center (OSC), Emergency Operations Facility (EOF), as well as the lustrumentation, supplies and equipment for these facilitie Results: No significant deficiencies or violations of NRC requirements were identiffed, f,[0 g p,,$ 3

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TABLE OF CONTENTS FOR THE DETAILED ERF EVALUATION ,

Page N .0 Technical Support Center 1 j

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1.1 Physical Facilities l'

1.1.1 Design, Location, and Structure 1 ,

1.1.2 Size and Layout 1 1.1.3 Equipment and Supplies 2 1.1.4 Communication Systems 3 1.1.5 Power Supplies 3 1.1.6 Conclusion 4-1.2 Information Management 4 1.2.1 Variables and Parameters 4 1.2.2 Emergency Response Facilities Data Acquisition and Display System and Interfaces 5 1.2.3 Dose Assessment 7 1.2.4 Conclusion- 8 1.3 Functional Capability 8 1.3.1 Operations and Control Room Support 8 1.3.2 Manual Dose Assessment 9 1.3.3 Conclusion 10 2.0 Operations Support Center 10 2.1 Physical Facilities 10 2.1.1 Design, Location, and Habitability 10 2.1.2 Equipment and Supplies 11 2.1.3 Communications 11 2.1.4 Conclusion' 11 2.2 Functional Capability 11 2.2.1 Staffing and Activation . 11 2.2.2 Conclusion 12

3.0 Emergency' Operations Facility 12

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3.1 Physical Facilities 12 3.1.1 Design, Location, and liabitability, 12 3.1.2 Equipment and Supplies 13 3.1.3 Communications 13 3.1.4 Power Supply 14 3.1.5 Conclusion 14

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3.2 Information Managementi

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3.2.1 Variables, Parameters, and Display Interfaces 14 3.2.2- Manual Information Systems . - 14 3.2.3 Dose Assessment 14  :

3.2.3.1 Source Terms 16

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13.2.3.2 Meteorology 17-3.2.3.3 Computerized Dose Assessment 20 3.2.4 Conclusion ,

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3.3 Functional Capability -

3.3.1 Operations and TSC Support 22

$.3.2 Conclusion ,

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Attachment A - Persons Contacted - t

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DETAILED ERF EVALUATION 1.0 Technical Support Center (TSC)

1.1 Physical Facilities >

1.1.1 Design, Location, and Structure The licensee's TSC is common to all three units. The TSC is located just inside the' protected area, below grade approximately 300 yards from Unit I and 150 yards from Unit 2 (within a ten minute walk). In order to meet the two minute transit time goal (NUREG-0696) from the Control Room (CR) to the TSC, and to facilitate CR support early-on in an emergency, the licensee maintains a satellite TSC (STSC) for each of the three units. The STSC for each unit is located in a room adjacent to the CR. There are no security barriers between the CR and STSC and no major ones between the CRs and the TSC. The TSC and the STSCs were built an accordance with the Uniform Building Code and were designed to remain operable under adverse conditions such as high winds and flood The STSCs are primarily an extension of the CR and are protected by the CR ventilation system and the CR shieldin The TSC has been designed to have the same habitability as the CR under accident conditions. TSC personnel are protected by ade<1uate shielding and a ventilation system designed to ensure habitability during a design basis accident. Shielding for the TSC consists of two-feet thick walls and a roof made of twenty inches of concrete with a steel top. The shielding is more than adequate for limiting the exposure of TSC personnel to less than 5 rem for the course of an accident. Based on a physical inspection of the emergency air handling unit (during operation) and a review of the documentation resulting from the acceptance testing, the appraisal team concluded that the system was operational and capable of providing the TSC with a positive pressure. The air handling unit was also noted to provide heating, cooling, and humidity control. A walk-down of the ventilation system dirclosed that the system's radiation monitoring instrumentation was located in a section of ducting which would be isolated once the system was activated. This means that the air being monitored for radiation is not the same air being supplied to the TSC. Licensee personnel stated that they had been aware of the problem for approximately five months ard that steps were being taken to correct this situatio In the interim, a health physics (llP) technician would be dispatched to the TSC to monitor the habitability of the facility during periods of activatio .1.2 Size and I,ayout The TSC is approximately 11,500 square feet in size and has a radial design in which the Emergency' Coordinator (EC) and his immediate staff occupy an area (approximately 900 square feet)

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in the center of the TSC. The central area is permanently l partitioned from an outer ring of work areas occupied by I

additional members of the TSC staff. Work stations within the i . central area are located in three rows that provide an adequate ( amount of space for circulation within the TSC. Work stations l are located at standard width trbles that provide adequate space for reviewins, documents and drawings. The EC's work station is located on an elevated platform within the central

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area of the TSC. This location gives the EC an unimpeded view I of the area and due to the close proximity, facilitates i communication between the EC and the members of his immediate staff. The central area can be entered / exited by any one of three doors linking it to the remainder of the TSC, thus, avoiding traffic bottlenecks. 'rhe appraisal staff judged the layout of the 'ISC to be adequate to support its functio .1.3 Equipment and Supplies l All of the records, drawings, and document support equipment l provided in the TSC are located within the central area or in the records room (a satellite Drawing and Document Control (DDC) library) located adjacent to the outer ring of offices.

l, Document s available to TSC personnel include Technical i1 ^5pecifications, Final Safety Analysis Report (FSAR), Emergency Plan Implementing Procedures (EPIPs), equipment manuals, and l piping and instrument drawings (P&lDs). The appraisal staff

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noted that a copy of the Emergency Plan (EP) was not readily l available, however, this was rectified prior to the end of the l appraisal. Although the library contains some hard copy

documents for ready reference, microfiche is used as the primary media.

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Radiological equipment and supplies are maintained in the TSC emergency lockers. Radiological instrumentation, which is i operated by a qualified llP techniciac, provides the capability to monitor TSC dose rates, surface xatamination, and

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I radionuclide concentrations in ai The appraisal staff L verified that the air sampling and radiation monitoring instruments were operable and within the calibration perio The contents of the TSC emergency kits were compared with the inventory lists contained in EPIP-38, " Emergency Equipment and Supplies Inventory," and found to be consistent with one l another. EPIP-38 requires a quarterly inventory of all emergency locker Various support supplies are contained within the emn :ency lockers in the TSC or are mounted to the walls (e.g. ,10 mile Emergency Planning Zone (EPZ), maps, steam tables, clerical supplies, etc.). Although the licensee has no documented method for controlling consumable supplies (clerical), there was an ampic supply available at the time of the appraisal.

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1.1.4 Communication Systems The licensee has provided multiple and redundant emergency communication systems for transmitting and receiving information between the various ERFs and the offsite agencie These systems have been described in Section 7 of the licensee's EP. During the appraisal, the communication systems were found to be consistent with the EP and operable. Although alternate communication methods exist, selected lines have been provided with backup power to ensure continued operation during a loss of offsite power. However, based on discussions with licensee personnel and a physical inspection, the appraisal staff ascertained that a majority of the communication systems have been wired through a main distribution frame (MDF) which is located in a room in the Servics Building. Although multiple switches for the communication systems have been provided, the appraisal staff questioned the proximity of the switches to the sprinkler heads for the fire suppression system. During the discussions, licensee personnel stated that activation of the fire suppression system (or for that matter a fire) would incapacitate the MDF resulting in a loss of approximately 95 percent (%) of the site communication system The following communication systems would be affected: the Emergency Notification System (ENS), the microwave and radio pager systems, and the telephone system. Since the loss of this communications room would result in a loss of the licensee's primary and backup methods for communicatinE with the State and the NRC, corrective action is warranted. The licensee needs to provide a backup system for communicating with the State and the NRC that would survive if the primary method was los .1.5 Power Supplies Primary power for both the TSC and Emergency Operations facility (EOF) originates in a common offsite power non-vital 13.8 kilovolt (KV) line which branches near the EOF and feeds the primary side of separate service transfarmers serving the TSC and EOF. TSC power proceeds via its dedicated transformer and an output breaker to 480 VAC panel L-50. No alternate power is provided; however, a dedicated TSC emergency diesel generator (DG) provides emergency power to the L-50 bus. In the event of a loss of normal power to L-50, the DG will auto-start and auto-load af ter a dead bus transfer. A load shedding network is provided to shed all but two breakers, a dedicated ilVAC system and motor control center M-61. All non-HVAC TSC loads come from M-61. The normal power breaker to L-50 is interlocked with the DG breaker to prevent simultaneous closure. If normal power was lost, the TSC would momentarily blackout during the dead bus sequencing of the DG. Power would then be restored to all TSC loads. In the interim, the Emergency Response Facilities Data Acquisition and Display System (ERFDADS) computer main frame would survive f rom its uninterruptible power supply (UPS); however, local terminals

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within the TSC would not survive. Work in progress at the local terminals would require reentry. The appraisal staff concluded that the TSC was provided with sufficient normal and emergency power supplies to ensure survival in the event of a loss of normal offsite powe .1.6 Conclusion Based on the findings in Section 1.1, this portion of the licensee's program meets the requirements of Supplement I to NUREG-0737. However, the Region intends to track the following open items: Ensure that the air being sampled by the radiation monitoring instrumentation, located within the TSC ventilation system, is the same air supplied to the TS *

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(86-15-01) (Section 1.1.1) Provide a backup system for communicating with the State and NRC that would survive if the primary method was los (86-15-02) (Section 1.1.4) ,

1.2 Information Hanagement 1.2.1 Variables and Parameters The licensee submitted a proposed listing of Regulatory Guide (RG) 1.97, Revision 2 variables, instruments, and their availability in an August 1, 1984, letter (ANPP-30092) (Arizona Nuclear Power Project). That listing was modified by a December 5,1984, letter (ANPP-31334). By letter dated June 18, 1985, the NRC informed the licensee that their listing was acceptable. The RG 1.97 variables programmed for availability within the TSC are identical to those planned for the E0F. The licensee committed to provide RG 1.97 Type A-E and other variables to the CR, TSC, and EOF via the ERFDAD The licensee also committed to develop a Safety Parameter Display System (SPDS) as required by Supplement I to NUREG-0737. A Safety Analysis Report on the Palo Verde Nuclear Generating Station (PVNGS) SPDS (ANPP-32008) was submitted by the licensee on February 27, 1986. ANPP informed the NRC on April 22, 1986 (ANPP-3o303) that PVNGS was experiencing problems and would have to slip the duc date. ANPP indicated that the SPDS would be ready for operation, including operator training, by October 30, 1986. This matter has been incorporated into the operating license as a license conditio Since the ERFDADS cannot be declared operational until the SPDS is completed, the entire ERFDADS was considered to be inoperational at the time of the appraisa _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _

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l 1.2.2 Emergency Response Facilities Data Acquisition and Display E System and Interfaces Plant safety parameters are monitored and provided to the TSC and EOF via the ERFDADS.- This section briefly describes the hardware and software which comprise the ERFDADS in its present ,

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i Hardware for the ERFDADS is supported by three data acquisition systems (DAS) and a single TSC computer system (TSCCS). Each DAS configuration includes two MODCOMP 7821 computer Isolated IE signals and non-lE signals are input. Other computer system inputs to the DAS are the Radiation Monitoring System (RMS) and channels A and B of the QSPDS (Qualified SPDS). If a DAS computer fails, the TSCCS switches the failed i computer to standby and activates the previously inactive DAS !

compute The TSCCS consists of two MODCOMP 7870 computers with two hard copy operator consoles, a line printer, a 9-track magnetic tape unit, and two 300 megabyte removable cartridge disk unit Numerous color monitor / terminals are supported by one of the two comununication processors. The terminals located in the STSC (2), TSC (8), and EOF (6) are ISC color monitor / terminal One computer operates as the master, while the other remains in standby until a failure occurs. A common shadow memory prevents loss of field data. The meteorological interface and the three DAS units are input to the TSCCS. It should be noted that the Chemical and Radiological Analysis Computer Systera (CRACS) is being replaced by IBM personal computers (PCs) for dose assessment using EPDOSE (written in BASICA).

Each of the three dual DAS units receives inputs from some 1100 :

analog and digital signals through M0DACS. Analog signals are :

digitized and converted to engineering units before being transmitted to the TSCCS. Two pairs of trains isolate type IE i safety-related digital and analog signals from non-lE signal i

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Transmission from each remote DAS unit to the TSCCS is via two optically isolated high speed fiber optic links, one for each Central Proressing Unit (CPU). Data collection and storage is under control of the TSCCS and is stored on one of two 300 megabyte rotary disks. Since switchover of a failed disk unit is a manual operation, a means to alert responsible personnel .

of the need for a switchover is recommende [

The maximum scan rate of user selected signals is 10

, ' scans /second. Normal sampling is 2 seconds / scan for all digital signals and 8 seconds / scan' for all analog signals. The cathode ray tube (CRT) update rate is approximately 2 second From the time a signal is sampled to the time it is available for display varies between 5 and 30 seconds, depending on the *

sensor. Color changes can take up to 1 minute to update. The ,

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l appraisal staff determined that the data acquisition rate was

! sufficient to acquire and store data. The ERFDADS software establishes appropriate priorities to these tasks to assure required data are not los ERFDADS employs a three-level hierarchy of display to assist

. the operator in focusing on specific detailed information. The highest. level displays the following six safety related l , parameters in the form of deviation bar graphs: Reactivity l Control,IIcat Removal, Pressure and Inventory Control, Indirect l Radiation Release, Containment Integrity and Maintenance of Vital Auxiliarie ,

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. The appraisal staff conducted a spot check of the Category 1 findir.gs in Appendix A of ANPP-32008 and concluded that not all l- '

of the Safety Parameter Observations (SP0s), identified in the

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document, have been corrected to date. All of the SP0s will be l corrected before the October 1986 deadline. In addition to i ,

correcting all of the SP0s, the appraisal staff recommends that '

all possible valid operating sequences be exercised to determine when problems occur and what needs to be done to

, correct the cause. The appraisal staff also concluded that the l casual user would benefit. f rom a " help" function.

l Additionally, operating from the ISC color monitor / terminals l did not appear to be user-friendly for the following reasons:

l (1) inadvertent switch from " dumb" mode to the " smart" mode l requires re-initialization of the terminal; (2) occasional terminal " lock-up" results in having to turn off terminal power for 10 seconds in order to recover; (3) operator key entries

, are not buffered; and (4) " Screen Read Errors" were flagged on l the terminal.

l l As previously mentioned, process, radiological and meteorological variables can be displayed on the CRTs that are linked to the ERFDADS. ERFDADS displays are accessed by means of function keys and menu Safety parameter displays (SPDs)

include deviation bar graphs, trend plots, and safety indicator

! blocks. Displayed variables are grouped by function and are

! color coded by r.tatus. With one exception, color coding

! follows a green (normal status), yellow (low /high deviation),

! red (low / low /high-high deviation), and blue (invalid value)

convention. Reactor coolant pumps are color coded red (flow)

and green (no flow). Deviation bar graphs have redundant l coding (length of bar and color of bar) to indicate deviations.

l ERFDADS can also display system mimics (P& ids) and

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pressure-temperature displays. Other displays can be accessed that provide parameter values, measurement units, high and low

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limits, and other potentially useful diagnostic information.

l Individual displays are readily legible and understandable to the operator. Selected ERFDADS terminals are linked to Printronix line printers to obtain hard copy. The entire SPD and P&lD display scla are hierarchically organized to provide a logical organization to the data. Displayed values are updated (sensor to screen) at latencies ranging from 5 to 30 seconds, i

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with color changes for alarmed values taking an additional 30 seconds. This is within the timeliness requirements for ERF Existing documentation on ERFDADS, contained in Procedure N P-1S01, appears to be suitable only for the expert user (e.g., software engineer). The document is 77 pages long and may be quite intimidating to emergency response personnel who use the system only infrequently. TSC and EOF personnel would benefit from a simplified user's guide for certain display These displays would probably be limited to the SPDs, P& ids, Pressure-Temperature Displays and 15-minute Weather Tower Displays. Other displays could be accessed through the Computer Support Coordinator in the TS .2.3 Dose Assessment According to the licensee's EP and EPIPs, the TSC is activated upon declaration of an alert. The EOF is activated at the same time. For dose assessment purposes, the licensee has established the long-term assessment capability in the EO This capability exists in the TSC, but will only be used if the EOF is not functiona The initial dose assessment (such as would be performed on the backshift) is performed in the STSC. The initial dose assessment is performed in accordance with EPIP-14A, " Release Rate Determination," Revision 6, Permanent Change Notice (PCN)

5, dated May 8, 1986, and EPIP-14B, " Initial Dose Assessment,"

Revision 4, dated May 5, 1986. EPIP-14A describes methods to be used for computing release rates from: (1) gaseous effluent release points (plant veat, fuel building vent, and condenser air removal system), (2) main steam lines, and (3) isolated containment leakage. EPIP-14B describes the initial dose assessment method to be used by the Radiation Protection Monitor (RPH) (onshift) until relieved by the Radiological Assessment Coordinator (RAC) in the EOF. The dose calculation method is totally manual (supplemented by a hand-held calculator for arithmetic operations) and enables the user to calculate whole-body and thyroid dose rates and 2-hour dose

, projections at the site boundary and other fixed distances and locations ranging from 1-10 mile Source term inputs are available either from the RMS terminals located in the CR and Radiation Protec'. ion Office or from the ERFDADS, both of which provide real-time indication of airborne releases via monitored effluent paths. Principal effluent release paths include the plant vent (handles effluents from

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the Auxiliary Building, Radwaste Building, and containment purges); Fuel Building Vent (handles effluents from the Fuel Building and, during an accident, a major portion of the Auxiliary Building); and the Condenser Vacuum Pump / Gland Seal Exhaust Vent. All three vents (replicated on each unit) have real-time, monitoring capability in accident ranges for noble gases up to IE+5 microcuric/ cubic centimeter (pCi/cc) and for

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. 8 iodines and particulates up to IE+2 pCi/cc. Other post-accident monitors include the Main Steam Line Effluent Monitors (range up to 1E+4 rem / hour) and Containment Area Monitors (up to 1E+7 rem / hour). EPIP-14A addresses the use of data generated by all of the above-mentioned monitoring system Key additional post-accident monitoring capability includes the Post-Accident Sampling System (PASS) which can collect samples from the reactor coolant system and the containment atmospher Samples are remotely analyzed via an intrinsic germanium detector.

l Meteorological data are available in the STSC via an ERFDADS l te rmir.al . As previously mentioned, these terminals are located in several areas (e.g., CR, TSC, and EOF). Meteorological data displayed include time-averaged (including 15 minute) wind speed, wind direction, and temperature differenc .2.4 Conclusion Based on the findings in Section 1.2, this portion of the licensee's program should meet the requirements in Supplement 1 ,

to NUREG-0737 once the ERFDADS and SPDS are completed in 1 I

October 1986. The following item will be classified as an open item and tracked by the Region: Complete the ERFDADS and SPDS (86-15-03) (Section 1.2.1)

The following items are suggested for improving your progra (1) Exercise all possible valid operating sequences for the ISC color monitor / terminals to determine what problems exist in order for them to be fixe (Section 1.2.2)

(2) Evaluate the need for a " help" functio (Section 1.2.2)

(3) Provide a means to alert personnel in a timely manner when switchover of a failed disk is imminent. (Section 1.2.2)

(4) Provide a simplified user guide for ERFDADS terminals that briefly describes the function buttons and the principal types of displays that would be appropriate for use in the TSC and EOF. (Section 1.2.2)

1.3 Functional Capability 1.3.1 Operations and Control Room Support The functional capability of the TSC was evaluated by presenting an NRC developed accident scenario to key members of

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the licensee's staff normally assigned to the facility during an emergency. Licensee personnel responded to the postulated circumstances by describing their actions and how the equipment and supplies available in the TSC would be used. The evaluation showed that the TSC would be adequately staffed and capable of performing the assigned function It should be noted that the responsibilities for dose projections (assessments), licensee protective action recommendations (PARS) and offsite notifications transfer to the EOF, upon its activatio .3.2 Manual Dose Assessment During the appraisal, a walkthrough of the manual dose assessment method was conducted. Three RPMs (HP technicians),

each of whom were trained to act as the interim Radiological Protection Coordinator (RPC) in the STSC, were selected at random. A two part scenario entailing major fuel damage was employed during the walkthroughs. The scenario was designed to test the ease of use and timeliness of EPIPs 14A and 14B, as well as the timeliness with which the significance of the calculated doses was assessed (i.e., PARS) via EPIP-15,

" Protective Action Guidelines," Revision 3/PCN 2, dated March 28, 1986. The latter point focused on the accuracy and timeliness with which the interim RPC provided the interim EC advice relative to protective actions to be recommerded to the State and local governments.

I During the first part of the walkthrough, the interim RPCs were asked to assess the potential source term based on high containment area monitor readings. This entailed using EPIP-14A only. Times required to perform this assessment were:

Technician "A," 21 minutes; Technician "B," 17 minutes; and Technician "C," could not perform the required calculation The second half of the scenario (Fuel Building Vent release)

entailed implementation of EPIP-14A, ~14B, and -15. Times required to perform these assessments were: Technician "A," 62 minutes; Technician "B," 29 minutes; and Technician "C," 47 minutes. The times required to perform these radiological assessments by a sample of interim RPCs suggests that the licensee may have difficulty including a radiological assessment in the notification to State and local governments which occurs within 15 minutes of declaration of an emergency, if the emergency occurs on a backshift. The appraisal staff observed that the principal reason for a lack of timely

, implementation stemmed from the fact that none of the

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calculational process (EPIP-14A, -14B, and -15) used by the

! interim RPC was computerized. Ironically, EPIP-14B was revised l on May 5, 1986 (Revision 4) to delete the computerized dose

[ assessment method in favor of the manual method.

l l During the walkthroughs, only one of the three interim RPCs

! (Technician "A") appeared even sli8htly familiar with EPIP-15 l and was able to formulate a reasonable PAR. EPIP-15, l

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appeared not to have been written with RPMs in mind. Thus, the relationship of parameters such as projected dose rate, release-duration, evacuation-time estimates, and shielding factors, may

.not be sufficiently clear to the interim RPC.to facilitate preparation ~of an adequ' ate PAR.- Technician "B" declined to prepare a PAR,. citing unfamiliarity with EPIP-15 1 Technician

"C",' although apparently not aware of the existence of EPIP-15,

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nevertheless attempted to prepare a PAR. The recommendations l .resulting from this effort differed significantly from those which would have resulted from'the application of EPIP-1 .3.3 Conclusion Based on the findings in Section 1.3, this portion of the licensee's program meets the requirements of Supplement l'to NUREG-0737. However, the Region intends to track the following open items:

Develop a method for accomplishing initial dose assessment

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which~ meets the 15 minute goal and reduces the chance for error in the calculation (86-15-04) (Section 1.3.2)

, Clarify-the method by which protective actions are formulated (based on radiological conditions) to indicate more clearly (with the interim RPC in mind) how projected doses, start and duration of release, and evacuation time-

[. estimates relate to one another in the context of-

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Environmental Protection Agency (EPA) Protective Action Guides. .(86-15-05) (Section 1.3.2)

l i 2.0 Operations Support Center (OSC)

2.1 Physical Facilities

2.1.1 - Design, Location, and liabitability The OSC is located in the lunchroom (140 Foot Icvel) of each of

! the Units' Auxiliary Buildings. The OSC proper is 30 feet by 20 feet; however, the men's locker room and the IIP access control station, both of which are located in the immediate l vicinity, would be used as staging areas for monitoring / repair

! teams and to alleviate congestion in the'0SC, once accountability is completed. The OSC does not have any special shielding or ventilation system; however, a' portable air

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sampler is used to monitor habitability in the OSC. Periodic i surveys are conducted by a llP technician to monitor direct l radiation levels. Since the.0SC.is not protected by vital power, emergency lighting, battery powered air samplers, and flashlights have been provided. If radiological or other conditions necessitate the abandonment of the OSC, the licensee has identified an alternate OSC in the Service Building. Since this alternate OSC space is currently used for personnel i

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offices, some time would be required to bring this area to a state of readiness (i.e., rearrange desks, move bookcases, etc.). However, both the OSC and alternate OSC appeared adequate in size to suppbrt their intended functio .1.2 Equipment and Supplies Tlie OSCs have been supplied with appropriate equipment and supplies including radiological monitoring equipment, portable air samplers, potassium iodine (KI), first aid supplies, protective clothing, self-contained breathing apparatus (SCBAs), plant floor diagrams, EPIPs and clerical supplie During the appraisal, an inventory of the OSC emergency cabinets was conducted. All equipment was found to be operational except for a few hand-held radios which had dead batteries because they had been left in the "on" positio However, replacement batteries are always kept in the cabinet The OSC contains two display boards: one that describes event status (this is an identical copy of the event status board in the TSC and EOF) and the other that lists the personnel available to staff radiation protection, field monitoring, search and rescue, damage control, fire and emergency repair team Since briefings on tasks and radiation hazards are conducted elsewhere, this level of information appears to be adequat .1.3 Communications Communication capabilities in the OSCs were found to be adequate and as described in the EP. These capabilities include dedicated telephone lines for communications with the CR, TSC, STSC, and EOF, as well as hand-held radios for inplant/ field team us .1.4 Conclusion Based on the findings in Section 2.1, this portion of the licensee's program meets the requirements of Supplement I to NUREG-073 .2 Functional Capability 2.2.1 Staffing and Activation The OSC is partially activated at the unusual event level with personnel drawn from'onshift staff, under the leadership of the Instrument and Control (I&C) Foreman. The OSC is fully activated by onshift emergency personnel at the alert leve Recalled personnel are only utilized for special situations or as required by long-term personnel rotation. Onshift emergency personnel include individuals from the following disciplines:

I&C, maintenance, chemistry, and radiation protectio _

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Individuals with specialized training in first aid, search and rescue, and operation of the PASS are also include The early activation of the OSC at the unusual event level and the availability of personnel from the unaffected units will provide sufficient staffin .2.2 Conclusion

. Based on the findings in Section 2.2, this portion of the licensee's program meets the requirements of Supplement 1-to NUREG-073 .0 Emergency Operations Facility 3.1 Physical Facilities 3.1.1 Design, Location, and Habitability The EOF is common to all three units and is located outside the

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protected area, below grade in the Administration Annex Building. This building is several hundred yards southeast of Unit 1. The facility has been built in accordance with the 4 Uniform Building Code and will withstand adverse conditions of high wind and floods. The EOF contains operational space that

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consists of the Emergency Command Center (ECC) (approximately 2,000 square feet), Emergency Operations Director (EOD) office (approximately 300 square feet), NRC offices (approximately 600 square feet), auxiliary staff offices (approximately 650 square feet), and EOF library (approximately 300 square feet).

Additional support space includes restrooms, sleeping quarters, and a lunch room. The EOF provides more than adequate space for the utility, offsite (State and county), Federal Emergency Management Agency (FEMA) and NRC personnel who would be present during an emergency. The layout of the E0F separates the support areas from operational areas and also separates different operational areas from one anothe The EOF has a ceiling consisting of two feet thick concrete and walls of one foot thick concrete. The E0F was built below grade to increase the protection from gamma radiation. The protection factor for the EOF has been determined to be at least 350. The EOF is protected from airborne radiation hazards by an emergency ventilation system which is similar to the systems used in the TSC and the CRs. The system is comprised of a dedicated air handling system which utilizes High Efficiency Particulate Air (REPA) and charcoal filtration and monitors to detect particulate, iodine and noble gas activity. An alarm and monitor readout for the system are located in the E0F. The emergency ventilation system is manually activated from the EOF. Upon activation, the system provides the EOF with positive pressure. Make-up air (30%) is filtered by llEPA and charcoal before being suppliod to the EOF. The system also provides temperature and humidity control. Documentation was reviewed which showed that tests of

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the system had been performed and that the system operated as expected. During the appraisal, the local readout of the

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radiation monitor indicated the monitor had been in the " fail" mode for several days. This matter was discussed with several different individuals; however, the reason for the monitor registering in the " failed" mode could not be explained and the licensee was apparently "nable to return it to an operable status prior to the end of the appraisal. Given the proximity of the EOF to the plant, it is suggested that the licensee review the appropriateness of the priority associated with returning this readout to an operating statu The licensee has designated the Palo Verde Inn, located approximately 8 miles northwest of the plant, as the alternate E0F. On January 31, 1984, the location of the alternate EOF was approved by the NRC based on the increased habitability of the EOF and the unlikely possibility of an EOF evacuatio Approval for the location of the primary EOF was based upon a June 16, 1983 letter from the licensee to the NRC, in which the increased EOF habitability was discussed. The June 1983 letter stated, in part, that a dedicated diesel generator would be provided to insure continued operation of the EOF liVAC. During the appraisal, the subject of emergency power was addresse The appraisal staff learned that although there is a primary and alternate source of offsite power for the EOF, a dedicated diesel generator has not been provided. A portable diesel generator is available and could be bolted into the bus wor However, it would not provide sufficient power to operate the EOF HVAC system. Since the approval of the location of the alternate EOF was based on the increased habitability of the primary EOF, it is important that there be assurance that the EOF will not need to be evacuated because the HVAC is inoperabl .1.2 Equipment and Supplies Radiological emergency kits are located in the EOF to provide emergency protection. These kits were found to be appropriate and as described in EPIP-38. The kits included such items as a frisker, an ion chamber, an AC powered portable air sampler, SCDAs and dosimeters covering several ranges. Appropriate support items, such as filters, cartridges, batteries, and clerical supplies, are also located in the kits. Supplies which would be used for decontamination purposes are also located in the E0F. Records and drawings available to E0F personnel are comparable to those supplied to the TS .3 Communications

.

As with the TSC and OSC, communication capabilities in the EOF have been addressed in Section 7 of the licensee's E The licensee's communication system more than adequately satisfies the guidance in NUREG-0696, except for the problem described in Section 1.1.4 of this report. The system was

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found to be operational and consistent with the description provided in the E .1.4 Power Supply -

This subject has been addressed in Sections 1.1.5 and 3.1.1 of this repor .1.5 Conclusion Based on the findings in Section 3.1, this portion of the licensee's program meets the requirements of Supplement 1 to NUREG-0737. However, the Region intends to track the following open item: Provide the EOF with a diesel generator sufficient in size to opere*.e the HVAC system to assure that habitability is as mentioned in the June 16, 1983 lette (86-15-06) (Section 3.1.1)

The following item is suggested for improving your program: Determine the adequacy of the priority currently being given to the operability of the EOF ventilation system radiation monitor readou (Section 3.1.1)

3.2 Information Management 3.2.1 Variables, Parameters, and Display Interfaces The variables, parameters and display interfaces in the EOF are the same as for the TSC. (Sections 1.2.1 and 1.2.2)

3.2.2 Manual Information Systems The EOF has a large number of status boards, all of which are

, located within easy viewing range of those who will use the Data on each status board are labeled and grouped for each location. Displayed variables have the proper units of m'easurement permanently labeled on the status boards. One status board (source term status and trends) is formatted for displaying trended data. Large EPZ maps and an aerial photograph are located on the walls in different areas of the ECC. One large EPZ map is mounted on a drafting table for plume plotting with isopleth .2.3 Dose Assessment The EOF dose assessnient procedures are described in EPIP-14C,

" Continuing Dose Assessment," Revision 2, dated May 5, 198 This procedure describes the use of the IBM PC and the EPDOSE computer code in order to make cont.inuing dose assessment EPDOSE is a menu-driven code that includes modules for source term estimation, atmospheric transport and diffusion, dose

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, estimation, and emergency :classi.fication~. It is the primary procedure for use' in the EOF (and in the TSC as a backup).

'Although not explicit;in' EPIP-14C, heavy reliance is placed on the' expertise and competence 1of the ANPP staff in the interpretation of. the EPDOSE _ output and in the formulation of protective action: recommendations.'

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. ... e EPDOSE. requires that'the, user enter..the following information:

failed fuel fraction (1~or 100%), reactor shutdown date and time, release date and time, atmospheric stability, wind speed'

and direction, and release rates for noble gases and Iodine 131 (I-131). The code.can'be used for releases that occur while

, the reactor is operating. Atmospheric stability may be entered as a stability class (A through G) or as a temperature difference, which is available from the ERFDAD If release rates are unknown, the code can compute release rates from monitor readings, plant operating conditions, and design leak rates. laten all required information has been entered, the

, code computes noble gas dose. rates, adult and child thyroid dose rates, and 2-hour dose commitments. It also determines, using a straight-line Gaussian model, the normalized center-line concentration (X/Q),' plume arrival time, and effective plume age at the site boundary, and at 2, 5, and 10 miles in the downwind direction.' Input data and the results of model' computations are contained in a printed " Current Release Dose Projection Report". In addition, emergency classification, dose rates, and an indication of plume position are displayed on the IBM PC monitor. The EPDOSE code can

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produce these results within 5 minute The assumptions and computational procedures included in the EPDOSE code are adequate for initial dose estimates in the STSC. However, the EPDOSE code has two significant limitations

'that make it inappropriate for use as a-primary dose assessment method for the TSC and EOF; (1)-it computes only the dose commitment from the current plume segment (release) rather than accumulating dose commitment fro'm all segments; and (2) when computing dose commitments, all plume segments are assumed to persist for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. As a result of these two limitations, the code cannot adequately estimate doses within the exposure pathway EPZ if meteorological conditions or' release rates change during the course of an event. Further, model dose projections may lead to nonconservative PAR The EPDOSE code has three additional weaknesses that detrac from its viability as a primary dose estimation method. These weaknesses are: . It does not make dose estimates in the ingestion pathway EP . It does not estimate deposition and dose from material deposited on surface .

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'r The default meteorological assumptions contained in EPIP-14B

, and EPIP-14C appear unduly restrictive. It is probable that m_

these assumptions (particularly the assumption of G stability)

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would be inappropriate in the event of an accidental releas i

'- More realistic default assumptions would be appropriate. These i

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assumptions could be based on season and time of day. Default assumptions should not be used when other data are availabl For example, there are accepted methods for estimating stability from cloudiness, wind speed, season, and time'of da .2.3.1 Source Terms Primary points through which releases of airborne radioactivity could occur, following an accident, include the Plant Vent, the Condenser Air Removal System, and the Fuel Building Vent. The Plant Vent, located on the outside wall of the Turbine Building (exhausts at roof level, 240 foot elevation), receives input streams from the Auxiliary Building (two 30,000 cubic feet per minute (cfm) parallel systems), the Radwaste Building (two 25,500 cfm parallel systems) and the Containment Purge Exhaust (two'16,500 cfm parallel systems for refueling purges and one 2,200 cfm system from operator purges). The Condenser Air Removal System handles the condenser vacuum pump exhaust (four pumps at 60 cfm each) and the turbine gland seal exhaust (flow rate dependent on packing leakage).

The Fuel Building Vent, located on the roof of the Fuel Building, normally only exhausts the Fuel Building via one of two 21,750 cfm parallel systems (both unfiltered). In an emergency mode (safety injection signal), two parallel 6,000 cfm KEPA/ charcoal filter trains automatically activate, filtering exhausts from the Fuel Building and elevations below 100 feet in the Auxiliary Building. This system causes a negative pressure of -0.25 inches of water to exist in the lower levels of the Auxiliary Buildin All three of the above release points are monitored by a low and high range channel and sampled off-line. The high range channel of each monitor (Plant Vent, Condenser Air Removal System, and Fuel Building Vent)-is identica Noble gas monitoring is provided by two Geiger-Mueller

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(GM) detectors (intermediate and high range) which have a combined range of about six decades ending at 1E+5 pCi/c An overlapping range of about one decade is provided for

'

these detectors. Real time monitoring (up to 1E+2 pCi/cc)' -

is also provided for iodines and particulates via a GM detector which is positioned adjacent to each of three particulate and charcoal / silver zeolite cartridge unit '

An alarm auto-initiates sampling of the next uni .

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.provides for:real-time monitoring (bottom five decades) of

> noble gases via'a. beta scintillator, however, only the t Plant Vent:provides-for real time m t monitoring of iodines

. and_particulaths. All.'three monitors ~have filter /

- cartridges for particulate and iodine. sampling, respectively.

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<< Readouts fo'r'al'~three l monitors can be obtained from the RMS and 'the ERFDADS. The<RMS, which reads out in;the CR and Radiation Protection Office, provides both instantaneous and time-averaged values. _The ERFDADS, which. reads out'in numerous locations, provides.only instantaneous values of radioactivity concentration in the vent. All three monitoring-systems have-the detector-calibration factor built into the instrument's microprocessor so that the detector output (normally in units of counts per minute (cpm)) can be. converted, after taking the sampling volume into account, to units of pCi/cc being released from the ven .

_ _

t The inspector reviewed the calibration of the high range channel of the three monitors and determined that thel vendor provided the initial calibration results based o gaseous Xenon 133 (Xe-133) source and. sealed Cesium 137 (Cs-137) and Strontium 90 (Sr-90). point sources. Point-sources, similar to the ones used by'the vendor, were obtained by the licensee from the vendor. Source strengths were in the range,of approximately'0.8-80 pCi-for the Cs-137 sources and approximately 0.5-50 pCi for the Sr-90 sources. The range of source strengths enabled the licensee to calibrate up to nearly 100 pCi/cc (top end is 1E+5 pCi/cc). The. remainder of the high range' detector was electronically calibrated (linearity check).

Upon loss of station AC power, only the Fuel Building Vent Monitor will continue to function, since it is the only effluent monitor connected to a vital bus. While this monitor will:likely be exposed to a major portion of gaseous effluents associated with an accident, the-Plant

' Vent Monitor is also likely to detect'significant release It would appear to be prudent to also connect this monitor to a vital bus. Recognizing this, the licensee has already' initiated'such a change (PCN-85-13-SQ-041). The licensee is encouraged to continue this effort to completio .

3.2.3.2 Meteorology Regional meteorological information for use in the emergency response facilities is obtained from the National Weather Service (NWS) via continuous weather broadcasts and telephone calls to the regional office in Phoenix, Arizona. -The NWS has agreed, in writing,.to move

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a portable meteorological system to the Palo Verde site in-the event of an emergency, -and ANPP and the-NWS have discussed having an NWS meteorologist in the EOF ~during an

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emergenc Onsite meteorological data consists of the wind direction and speed at the 35 and '200 -feet ' levels, temperature difference between the-35 and 200 feet levels, ambient air temperature, and dew point temperature. LData for these parameters are available'in the ERFs via ERFDADS. These

, fdata are obtained-from' instrumentation on the onsite:

. meteorol'ogical ' tower. New: instrumentation installed in

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,- October'1985 includes two independent sets of wind sensors

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at each level, two independent temperature difference systems, and two' sets of. signal conditioning. Following conditioning, signals.from.the. wind and temperature

' difference sensors are split;<a' digital' signal from each

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~ sensor is sent'tot a meteorological data acquisition computer at -the tower, and an snalog signal is sent to a strip chart recorder. The strip chart. recorders arefalso

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located at the tower. An independent set of wind sensors is located on a short mast (approximately 7 feet) at the ~

meteorological tower site. Signals from these sensors can I

be recorded-using a battery powered strip chart recor' der.

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Electrical power for the meteorological system.is provided by a single source of offsite power. There is no

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provision for alternate or backup power, and the meteorological data acquisition computer'does not have an-UPS. To minimize adverse effects resulting from the loss of power to the system, the meteorological data are stored in a nonvolatile memory and the data acquisition system includes an autoboot capability.'fANPP. dose assessment procedures (EPIP-14B and EPIP-14C) specify default meteorological assumptions to be used in the event of complete meteorological system failur Surveillance activities related to the meteorological instrument system includes: daily checks of the electronics calibrations, weekly inspections of strip

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charts and data listings, and quarterly system i calibrations. The spare parts inventory for the meteorological system appears adequate to handle the

,- adverse effects of sensor and electronics failure Since installation of the new meteorological instrumentation and data acquisition system, the data recovery rate for 15-minute averages of wind direction, wind speed, and temperature difference has been near 100%.

The meteorological data acquisition computer checks signals to ensure that they are reasonable and compares signals from corresponding sensors. If the difference

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between signals for a sensor pair is within limits, the signals are averaged and the data are marked as valid.

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, . 19 When the difference between signals is'out of limits and one signal is out of normal' range, the other is use When a difference is out of limits and neither. signal is out of range, the signalJfrom the (designated) primary system is used. The selected signals are then transmitted to an ERFDADS data acquisition compute The ERFDADS includes three meteorological displays:

10-second, 15-minute, and 1-hour average data. These ERFDADS displays must be accessed directly by entering the display address, (i.e., they can not be accessed through a menu in the same manner that'the reactor operation parameters are displayed). The addresses of the meteorological displays are contained in the ERFDADS guide, but they are difficult to find. All three meteorological data displays have a common appearance, with the averaging period shown at the top of the sensor lis The amount of data used in computing the average for each sensor is presented as a confidence fraction following the dat If the confidence fraction for an averaging internal falls to 0.5, the average is marked as invali The confidence fractions for all sensors tend to increase and decrease together, which indicates that data transmission between the meteorological and ERFDADS data acquisition computers was responsible for the observed changes in confidence fraction rather than performance of individual sensor It should be noted that the data presented in the 1-hour average display, are generally not 1-hour averages. The data displayed are averages computed from the signals received since the beginning of the hour that are updated each 15 minutes. Thus,_for the first 15 minutes of the hour, the data displayed are averages for the past hou For the second 15 minutes of the hour, the data displayed are averages for the first 15 minutes of the hour. For the third 15 minutes:of the hour, the data displayed are 30-minute averages, and for the last 15 minutes of the

' hour, the data displayed are 45-minute average Hard copy output of wind direction, wind speed, and temperature difference is not routinely available in the CRs or any of the ERFs. 'In the event that meteorological data can not;be obtained'through ERFDADS, it is necessary to obtain the data directly from the hard copy at the meteorological tower. Similarly, there is no provision

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for access to meteorological data for previous periods through the'ERFDADS even though the data are archived in the system. Finally, as previously mentioned, at the time of this appraisal, ERFDADS was not fully operationa ,r 3 ,

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-Although the meteorological data' acquisition system and'

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data recovery rate are adequate, the fact that-wind

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i (stability) are not available'to the CRs and to the other -

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ERFs, except through a system that is not yetp o'erational, ' " ~

4, ,, indicates a situation where the intent of the NRC position s .

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in Paragraph C.3 of RG 1.23 does' not appear to have been' <

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3.2.3.3 Computerized Dose Assessment d -

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, As previously stated, the EPDOSE computer program used;by

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the licensee contains modules for source term estimation,

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emergency classification._ D_isks containing this code and- "

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IBM PCs to run them'are' located'in both the EOF and TSC, ,

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'. the latter being used as .a backup (e.g. , in' the event of N loss of power in the EOF).

i s 1, - The basic EPDOSE code computes whole body and thyroid dose-

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rates and-dose commitments based on a fixe'd 2-hour release 1 . for four fixed distances, including the outer boundary .of

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the 10-mile EPZ. Effluent' releases from plant. vents are

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manually input to the EPDOSE code directly, as a monitor reading. The time delay after reactor shutdown is used to adjust the effective energy and dose factor'for mixtures of noble gases and iodines. The basic code.(the use of-

-which is' documented in EPIP-14C) does not accept effluent

, ,-sample results, only effluent-. monitor readings. Thus, it-is not possible to adjust the source term for a measured-mixture of noble gases and iodines. Two radionuclide mix libraries-are contained in the code, one corresponding to .

little fuel damage (1% of core' inventory from the ,

Combustion-Engineering Standard Safety Analysis Report-(CESSAR)) and another corresponding'to massive fuel damag (100% of core inventory from WASH-1400). '

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According to. licensee representatives, several options are

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presently available (or are under development) in the EPDOSE menu to correct.a few of the weaknesses of the' base

{.. code-(e.g., the inability to accept a release which has not yet occurred, as well as the inability to calculate

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' doses other than-for four fixed distances). Othee

, weaknesses in the licensee's dose assessment methodology

-(mentioned earlier in this section) are not addressed by these options and need to be corrected.

The licensee has performed limited validations of the code. Comparisons have been made with the State of

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i Arizona, with good agreement (within 10%) noted. The appraisal staff selectively compared EPDOSE results with hand calculations based on RG 1.109. Acceptable agreement-(within 30%) was noted.

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, 21 3.2.4 Conclusion Based'on the findings in-Section 3.2, this portion c-f the I licensee's' program meets the requirements of Supplement I to NUREG-0737. However, the following open items will be tracked by the Region: The dose model warrants revision to address the following areas: ,

(i) the 50-mile ingestion pathway EPZ (ii). ground deposition of radionuclides and doses therefrom (iii) inputting of source terms based on isotopic-analyses of effluent samples

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(iv) calculation of doses at locations other than the

. four fixed distances of site boundary, 2, 5, and

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10 miles

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(v) flexibility in the duration of the projected

. exposure period T2 hour). Should allow for

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other values based on. plant conditions, and for ~

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a truncation of the exposure when the wind shifts away from the sector of interest. Also,

. the dose assessment would benefit from a code that had the ability to accurately assess re-exposed sectors due to wind shift.

f (86-15-07) (Section 3.2.3) Continue present efforts (PCN-85-13-SQ-041) to connect _the l Plant Vent Monitor (Ru-143 and -144) to a vital bus.

I (86-15-08) (Section 3.2.3)

% Provide for hard copy recording of meteorological l parameters (wind direction, wind speed, and temperature ,

, difference) in the CRs and other appropriate location (s).

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(86-15-09) (Section 3.2.3)

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In addition, the following items are suggested for improving the program:

(1) The 15-minute averages of meteorological data for the previous 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> that are stored in ERFDADS could be made

- readily available to the TSC and EOF. (Section 3.2.3)

(2) The 10-second average and 1-hour average meteorological displays on the ERFDADS could be eliminated or modified to minimize the chance of using inappropriate meteorological data in dose assessments. (Section 3.2.3)

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.(3) An alternate or backup source of power as' well as an UPS could be provided for the meteorological syste ,

'(Section 3.2.3) ,

(4) Written instructions could be provided which describe procedures for extracting meteorological data from the strip charts in the' event that meteorological data are not

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available through the ERFDAD (Section 3.2.3)

.(5) Written procedures could be provided that indicate: when the NWS should be contacted, who'in the NWS should be centacted, and what information should be requeste (Section 3.2.3)

3.3 Functional Capability 3.3.1 Operations and TSC Support The functional. capability of the EOF was evaluated by presenting a NRC-developed accident scenario to key members of ,

the licensee's staff.normally assigned to the facility durin '

an emergency. The individuals. responded to.the postulated circumstances by describing the actions that would be taken and

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by demonstrating how the equipment and supplies available in the EOF would be used. The evaluation showed that'the EOF would be adequately staffed and capable of performing the assigned function '

3.3.2-Conclusion Based on the findings in Section 3.3, this portion of the

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licensee's program meets the requirements of Supplement I to NUREG-0737:

4.0 Exit Interview An exit interview was held with the licensee on May 23, 1986, for the purpose ,of discussing the preliminary findings of the appraisal. Those i . licensee' personnel who' attended the meeting have,been identified in Attachment A tosthis report. In addition to.the NRC Team Leader and the appraisal team, Mr. R. 'F. ; Fish, Chief, Emergency' Preparedness Section, Region V, was present. The licensee was informed that no significant'

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deficiencies or violations of NRC requirements were identified during the

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appraisal, s I-During the exit, interview, the' NRC Team Leader made no attempt to i categorize all of the findings. The licensee was informed that the

, appraisal report would include a number of open items, which would

, be tracked by the Region, and a number of items for improving the

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1icensee's program. All of the open items described in the body of the report, except for 86-15-06, were specifically mentioned. A considerable portion of the exit interview focused on the weaknesses described in

.Section 3. The licensee acknowledged the importance of this subject.

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Subsequent to the appraisal, based upon .the concerns expressed by -

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the appraisal team, the licensee initiated a systematic revision to their offsite' dose calculation program ~(EPDOSE). A summary of th revisions being made was transmitted to the NRC by a letter dated

~ July 18, 198 It should be noted that the licensee stated in this

-- transmittal that the changes to the dose code were already over 90%

completed and that the remaining changes were expected to be finished by approximately August 1, 1986. In addition, the licensee stated that a Validation Plan for the revised software was also being develope '

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ATTACHMENT A

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Persons Contacted

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J. Allen, Manager, Operations 0. Bankston, Computer Engineer

• T. Barsuk, Supervisor, Onsite Emergency Planning

• H. Bieling, Supervisor, Offsite Emergency Planning K. Bowe, Radiation Protection Technician L. Brown, Manager, Chemistry and Radiation Protection T. Burton, Senior Computer Engineer J. Bynum,. Plant Manager L. Clyde, Supervisor, Shift Technical Advisors C. Cole, Radiological Engineer P. Egebrecht, Supervisor, Nuclear Process Chemistry K. Gross, Supervisor, Compli.:nce D. Hoppes, Supervisor, Reactor Engineering D. Karner,_Vice President, Engineering M. Lantz, Supervisor, Radiation Protection Support D. Larson, Foreman, Instrument and Control

• J. Mann, Supervisor, Health' Physics and Chemistry (Corporate)

D. Nelson, Manager, Securit J. Ong, Radiological Engineer L. Papworth, Manager, Operations Engineering S. Peace, Radiation Protection Technician D. Peckham, Meteorologist (Corporate)

G. Perkins, Manager, Radiological Services A. Porter, Foreman, Instrument and Control R. Roberts, Shift Technical Advisor J. Schmadeke, Supervisor, Computer Maintenance D. Sexton, Foreman, HVAC J. Shawyer, Nuclear Process Chemistry Engineer F. Short, Radiological Engineer (Contractor Staff)

M. Toole, Radiation Protection Technician P. Trager, Supervisor, Process Computer Engineering S. Waters, Operations Engineer K. Wright, Emergency Planning Coordinator

• D. Yows, Manager, Emergency Planning and Preparedness 0. Zerigue, Manager, Technical Support

• Denotes those present at exit interview on May 23, 198 Persons Present at May 23, 1986 Exit Interview Only R. Baron, Compliance Representative W. Ide, Director, Quality Assurance / Quality Control (Corporate)

J. Matteson, Supervisor, Quality Audits and Monitoring W. Quinn, Manager, Licensing C. Russo, Manager, Quality Audits and Monitoring E. Van Brunt, Jr., Executive Vice President J. Vorces, Manager, Nuclear Safety