IR 05000461/1987025

Insp Rept 50-461/87-25 on 870720-24.No Violations, Deficiencies or Deviations Noted.Major Areas Inspected: Emergency Preparedness Program,Actions on Previous Open Items,Activations of Emergency Plan & LER Review

ML20236H465
Person / Time
Site:	Clinton
Issue date:	07/29/1987
From:	Foster J, Ploski T, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236H454	List: IR 05000461/1987025 ML20236H451
References
50-461-87-25, NUDOCS 8708050202
Download: ML20236H465 (16)

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   - U. S. NUCLEAR REGULATORY ~ COMISSION REGION III -   j f         l Report No. 50-461/87025(DRSS)

l Docket No. 50-461 License No. NPF-55 l l Licensee: Illinois Power Company l 500 South 27th St*,eet J

  :Decatur, IL 62525
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Facility Name: Clinton Nuclear Power Station, Unit 1 l

Inspection At: Clinton Site, Clinton, Illinois { Inspection Conducted: July 20-24, 1987 Inspectors [ h[[d

   . t. Foster
      '7 Date /

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       !

eam Leader

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   . J. Ploski
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Date / /

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 ' Approved By: [ 74 m   - r>Ip/97
   . SneiI, Chlet  Uate / /

mergency Preparedness-Section Inspection Summary Inspection on July 20-24,1987(ReportNo. 50-461/87025(DRSS)) Areas inspected: Routine, unannounced inspection of the following areas of- the clinton Power Station emergency preparedness program: actions on previous Open Items; activations of the licensee's emergency plan; LER review; emergency detection and classification; dose assessment; protective action decisionmaking; notifications and communications; chan preparedness program; shift staffing and augmentation;ges knowledge andto the emergency performance of duties (training); licensee audits; and maintaining emergency preparedness. The inspection involved two NRC inspector Results: No violaticns,_ deficiencies, or deviations were identifie e708050202 870730 T PDR G ADOCK O 4jia i _ - _ - _ _ _ _ - _ -

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DETAILS 1. Persons Contacted Illinois Power Company c

*J. Perry, Manager - Nuclear Program Coordination   !
*R. Gardner, Supervisor - Emergency Response   I
*D. Waddel Su)ervisor - Emergency Preparedness
*J.Brownell,_icensingSpecialist    l
* I Campbell,irector
*J. Weaver, D - LicensingManager - Quality Assurance
*W. Connel, Mana0er - Nuclear Planning & Support
*R. Freeman, Manater - Nuclear Station Engineering   l F. Spangenberg, Fanager - Licensing and Safety   I W. Yaroz Emergency Planner    l R.Fernaid Fire Protection Instructor J.Dodds,$mergencyPreparednessTrainingInstructor J. Neuschwanger, Shift Supervisor H. Bouska, Assistant Shift Supervisor G. Motesgood, Shift Technical Advisor K. Grooms Assistant Shift Supervisor C.Driskell,StationQASpecialist,LeadAuditor-EP,RP
* Denotes those personnel listed above who attended the exit interview on July 24, 198 . Licensee Actions on Previously Identified Open Items (Closed)OpenItem 461/870003-01: Delayed declaration of a General Emergency during the last evaluated exercise. The licensee has revised Procedure EC-02, " Emergency Classification," to clarify when and has trained personnel to a General the Emergency Emercency revised procedur should bePlann declared,ing Bulletin 87-01 (dated to advise recipients of the changes to February 193rocedure Ed 1987)

02 and provide was issuecas to the changes some background

)rillshavebeenheldwiththeobjectiveofverifyingthataGeneral  ,

Emergency is promptly declared under appropriate conditions, and Discussion Scenarlos have been held to amplify upon other trainin This item is close (Closed)OpenItem 461/870003-02: Inadequate contamination control in the E0F environmental laboratory during the last evaluated exercis Drills have been held to observe actions in the E0F environmentallaboratory,andsomeproblems(suchasinconsistent locationofsupplies)wereidentified. Procedures pertaining to the E0F environmental lab have been revised to correct observed inadequacies, and personnel have been trained on the revised procec ures. Licensee personnel indicated that laboratory operations and contamination control will continue to be observed during the remaining 1987 drills. This item is close _

_. - i , . .. 3. Activations of the Licensee's Emergency Plan l

A review of licensee and NRC records indicated that four activations of l the licensee's Emergency Plan had taken plac ! On March 22, 1987, the reactor was manually scrammed when an operator  ! noticed' control rods moving into the core as the result of a loss of  ! instrument air pressure. The reactor scram occurred at 0415 hours, and an Unusual Event was declared at 0425 hours. The scram was determined to 1 be a normal scram (no other systems were affected). The Unusual Event was terminated at 0535 hour On May 6, 1987 the reactor was manually scrammed after a motor driven feedpumpreguiatingvalvelockedinpositionandreactorlevelincreased to near the trip setpoint. The scram occurred at 0617 hours, and an Unusual Event was. declared at the same tim All systems functioned as  ; required for a successful reactor scram. At 0705 hours, with the reactor i shut down and stable, the Unusual Event was terminate On May 24, 1987, at 0815 hours, the reactor tripped on high flux signals

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from Average Power Range Monitors 8 and D. Due to control problems associated with a feedwater regulating valve, cold water had been introduced to the vessel, and vessel level increased, causing an increase in power level. Water level oscillations caused a power excursion which i reached the high flux trip setpoint of 40% (used during startup test l programs), and the reactor scrammed. An Unusual Event was declared at 1817 hours, and was terminated at 1855 hour On June 10, 1987, at approximately 1850 hours, operating personnel felt an earth tremor. Seismic activity was reported to the NRC at 1945 hours (no emergency classification was made at that time), and operational checks and walkdowns were conducted. Seismic monitoring data was not immediately available due to control room instrumentation being inoperative (Technical Specifications allow seismic instrumentation to be outofserviceforextendedperiods). Plant personnel were assigned to walkdown and inspect the cooling lake dam for possible damage. On alant systems June 11, 1 $87, at 0345 hours after analyzing data recorded onpassiveseismicinstrumentation,thelicenseedeclaredanUnusual Even At 0355 hours, the' Unusual Event was terminate The inspector's review indicated that the licensee had followed the letter of the guidance in Procedure EC-02 relative to classification of a seismic event, as detailed in the section " Natural Phenomenon Initiating , Events." However Procedure EC-02 provided for indication of a seismic event to be primar,ily by Control Room seismic instrumentation, which was inoperable. The licensee did make a notification call to the NRC and to local' authorities of the event, advi(sing of seismic activity, but no. class)ification wasIllinois made until approximately nine hours after the event. As Control Room personnel felt that the earthquake was of sufficient magnitude to call personnel into the plant and assign them to perform alant system and cooling lake dam inspections, the event should have 3een more promptly i

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l classifie One possible classification.would have been via the Emercency Action evel "Other" (Attachment 9, Page'1), which provides for declaration of an Unusual Event for "Other station conditions that warrant increased awareness on the part of State and/or local offsite authorities.". It was 'noted that the Clinton Power Station Emergency - j Plan in Table 4-1 ( Page 2 of 2) lists "any earthquake" as an example ' initiatingconditionforanUnusualEven Discussions were held with licensee personnel regarding revision to the seismic event section of Procedure EC-02 to allow. increased personal judgementineventdeclaration. Revision-to' Procedure EC-02 is in progress, and the revised section (in draft) now refers to "any l earthguake' felt'in plant or detected on seismic. instrumentation," and 1 contains' provisions for classification escalation in the event that

seismic instrumentation is unavailabl The inspector reviewed documentation related to each plan activatio In general, event classifications and notifications had been performed promptly and within timeframe -goals. It was noted that notification to the NRC for.the March 22, 1987 event almost required one hour. Discussion with licensee personnel indicated that.the necessity to notify the NRC immediatel following'$ tate and local a'uthorities had been stressed

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_following th y'is even in general A documentation consisting package of the related hadNuclear Illinois been assembled for each event,ing System Accident Report (NARS) forms, closecut letter-toEvent Notification the NR Worksheets,ffered The packages di somewhat as toand written sum content, and it is recommended that the licensee determine which documents related to activations should be collected. Discussion with licensee personnel also indicated that each event is analyzed and critiqued in depth, but few packages contained documentation of such critiques or related corrective actions where problems were identifie Three of the.'above events were reactor scrams which were eithe automatically or manually initiated. ~On MayL28, 1987, the licensee revised the emergency, classification guidance contained in Implementing Procedure EC-02 to more clearly define the requirements for classifying events related to a reactor scram. Previousl relating to "other than controlled shutdown" y, the had been guidance interpreted in EC-02 to mean than any reactor scram would require classification as an Unusual Even Licensee guidance now indicates that an "other than normal shutdown'means '

:a shutdown of the reactor where significant plant systems do not function or CPS-TS limits were exceeded during shutdown, or f

> as anticipated,in situations rema after shutdown which indicate a potential degradation of the level of safety of the station." This guidance is consistent with  ! that provided in NUREG-0654, and is acceptabl Duringtheinspection,areviewofLicenseeEventReports(LERs) generated during September, 1986 - July, 1987 was performed to determine'if events had been properly classified under the EP progra Tho inspector reviewed the following LERs: ,

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. LER N Brief Description 86-001-00 Reactor Water Cleanup System (RWCU) isolation 86-002-00 Secondary Containment negative pressure lost 86-003-00 Control Room Ventilation Chlorine Mode initiation 86-004-00 Auto Initiation of Standby Gas system 86-005-00 Failure to perform hourly firewatch ' 86-006-001 Auto Initiation of Essential Service Water 86-007-00 Reactor Water Cleanup System Isolation 86-008-001 Containment Isolation of Instrument Air 86-009-001 Operator Error Resulting in Tech. Spec. Violation 86-010-00 Auto Initiation of Reactor Protection System 86-011-00 Auto Initiation of Shutdown Service Water System 86-012-00 Reactor Water Cleanup Inboard Containment Isolation 86-013-00 Operator Error Resulting in RPS Actuation 86-014-00 Stancby Gas Treatment System Initiation 86-015-01 Auto Initiation of an Engineered Safety Feature 86-016-001 Operator Error Resulting In Tech. Spec. Violation 86-017-00123 Engineered Safety Feature Actuation 86-018-00 Reactor Water Cleanup Outboard Containment Isolation 86-019-001 Control Room Ventil. Engineered Safety Feature Actuation 86-020-00 Auto Switch of High Pressure Core Spray pump suction 86-021-00 Reactor Water Cleanup Room A high temperature trip 86-022-00 Inadvertent Withdrawal of Control Rod 24-21 due to error 86-023-00 Automatic Actuation of The Reactor Protection System 86-024-00 Auto Closure of Group I Containment Isolation Valves 86-025-0001 Auto Actuation of Shutdown Service Water Pump 87-001-0001 Auto Initiation of Div. I Emergency Core Cooling System 87-002-00 Control Room Ventil. "A" Shift to Hi h Chlorine Mode 87-003-00 Control Room Ventil. "B" Shift to Hi h Chlorine Mode 87-004-00 Auto Initiation of Div. I Emergency ore Cooling Systems 87-005-00 Auto Actuation of Containment Isolation Valves 87-006-00 Partial Group I Containment Isolation due to blown fuse 87-007-00 Auto Actuation of Safety Relief Valve B21F041F 87-008-00 Tech. Spec. Violation due to missed channel chm ks 87-009-00 ' Manual Actuation of Standby" Gas Treatment System Train 87-010-00 Control Room Ventil. "A & B Shift to High Chlorine Mode 87-011-00 Control Room Ventil. "A & B" Shift to High Chlorine Mode 87-012-00 Control Room Ventil. "B" Shift to High Chlorine Mode 87-013-00 Auto Isolation of Reactor Water Cleanup System 87-014-00 Auto Actuation of High Pressure Core Spray 87-015-00 Reactor Core Isol. Cooling Steam Tunnel Temp. Timers 87-016-00 Auto Actuation of Containment Isolation Valve 1E51-F063 87-017-00 Manual Scram following Auto Closure of Air Valves 87-018-00 Manual Start of Shutdown Service Water Pump 87-019-00 Auto Actuation of Safety Relief Valve 1821-F041C 87-020-00 Auto Isolation of Reactor Water Cleanup System 87-021-00 Auto Isolation of Reactor Core Isolation Cooling System 87-022-00 Auto Actuation of High Pressure Core Spray System 87-023-00 Auto Isolation of Div. II Hydrogen /0xygen Monitor 37-024-00 Auto Isolation of Reactor Water Cleanup, System 87-025-00 Manual Actuation of the Reactor Protection System (UE) j

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87-026-00 Auto Actuation of High Pressure Core Spray System 87-027-00 Auto Isolation of the Reactor Water Cleanup System 87-028-00 Noble Gas Detector Calibration Tech. Spec. Violation 87-029-00 AutoActuationofReactorPrctectionSystem(UE) All LER events were found to be )to)erly classified as either an Unusual Event, or as not falling under t1e Emergency Plan program (no Emergency Action Level had been met).

No violations of regulatory requirements or deviations from commitments were identified. However, the following item is recommended for improvement:

* Determine which documents related to activations should be collected. Procedurally assure that activation document packages also contain documentation of activation critiques and reference to related corrective actions where problems were identifie . Emergency Detection and Classification (82201)

The Clinton Power Station Emergency Plan, Revision 6, dated December 11, 1986, Section 4.1.2, defines initiating conditions, or plant parameters for each emergency classification, and references Table 4-1 of the plan, , which provides example initiating conditions for each classification. The CPS Initiating Conditions, or Emergency Action Levels are not found in the Emergency Plan itself, but are found in Implementing Procedure EC-02,

" Emergency Classifications." As noted elsewhere, the EALs are under revision, and licensee pe M onnel stated that the revised EALs will be incorporated into a pending Emergency Plan revisio and interviewed The inspector one shift reviewed of Control the Emergency Room personnel Plan consisting of and Procedures,ft Supervisor, one Shi two Assistant Shift Supervisors, and one Shift Technical Adviso The licensee's emergency classification and action level scheme was consistent with the guidance contained in Appendix 1 of NUREG-0654, Revision 1. The licensee demonstrated the ca) ability to analyze and assess emergency conditions on a twenty-four lour basi ;

The individuals interviewed exhibited outstanding attitudes, both toward their normal duties and to the interview itsel They were uniformly knowledgeable, and enthusiastic. When a team member made an error, the other members were quick to step in and correct; minor weaknesses pointed out and suggestions made were accepted constructivel A spot check of several Emergency Operating Procedures (E0Ps, or Off-Normal Procedures) confirmed that each E0P has, as an item under

" Operator Actions," a direction to advise the Shift Supervi3or to check the EAL's (Procedure EC-02) for a possible classification of the even No violations or deviations were identified in this are l l

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m i 5; Protective Action Decisionmaking (82202)

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A review of the Emergency Plan and Procedures, along w*th the interview i 4 .of. shift operating personn?l, demonstrated that the authority and  ! responsibility to make protective action recommendations were clearly j delineated and understood. Personnel demonstrated. facility and

 ; familiarity with the procedures, and made reference to them. .The ability of the licensee to assess and analyze emergency conditions and to make recommendations to protect the public and onsite workers was adequately-demonstrate ;
. No violations or deviations were identified in this are . NotificationsandCommunications(82203)

The inspector reviewed selected procedures and conducted discussions with' L ' personnel who have notifications or communications responsibilitie . Interviews with shift operations personnel included questions relevant to communications and notifications associated with the various emergency classification It was determined that the licensee-had the capability

 .to notify and communicate among the appropriate licensea personnel, offsite agencies and authorities, ana the general public in the event of a radiological emergenc Procedure EC-07 " Emergency Plan Notification " addressed State, local, NRC and internal notification requirements following an emergency declaration. The. procedural guicance accurately reflected the regulatory requirements regarding the timeliness of initial notifications to the State and the NRC Operations Center. However, Procedures EC-07 and FE-06,
 '" Emergency Communications Equipment " were inconsistent regarding which StateagencieswouldbecontactedVIathededicatedNuclearAccident ReportingSystem(NARS). Procedure FE-06 correctly stated that the Illinois Emergency Servit.es and Disaster Agency (IESDA) and Illinois Department of Nuclear Safety (IDNS) would be simultaneously contacted via the NARS, whereas Procedure EC-07 indicated that only IESDA would be contacted using the NARS. Procedure EC-07 also indicated that IDNS would-be provided with periodic followup information following any Alert, Site u  Area or General Emergency declaration. While the enclosed Followup
 ~ Message Form accurately reflected the message content gui'ance in Criterion E.4, the form did not contain NUREG-0654, Revision 1,ing a verbal description of the conditions that
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3rovisions for document j 1ad warranted the emergency declaration. Since the 1987 revision of the NARS form, which is used only as an initial notification message form, no longer has provisions.for documenting the conditions that led to the emergency declaration,the location for documenting thereason Followup (Message s) given Formfor to the IDNS is the presently the optimum licensee.'s declaratio i Procedure EC-07 listed both arimary and backup telephone number information for the various :ederal, State, and local emergency response-organizations. Proced ve FE-06 not only described the various emergency communications systems available onsite, but it also provided guidance on proper communications techniques and protocol ,

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Periodic tests of emergency communications equipment was addressed l

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in Procedure AP-09,,9 Emergency Communications Operability Checks."

Monthly operability check requirements included radios and facsimile 4 machines, where such equipment was maintained in an emergency response facility. Periodic tests of the offsite sirerasystem was addressed in ProcedureAP-07,"AlertandNotificationSystem(ANS)." The proc,edure ' also addrened semiannual and preventative emergency maintenance , provisions. The inspector reviewed monthly communications egulpment and

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ANS test results, for the period April through June 1987, which were adequately documented per Procedures AP-09 and AP-07, respectivel The test documentation included corrective actions initiated and completed on identified problem Based on the above findings this portion of the licensee's program is ,

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* Procedure FE-06 should be revised to indicate that both IESDA and IONS are contacted simultaneously via the NAR * TheFollowupkessageFormshouldberevisedtoincludeprovisions fordocummtingthacondition(s)whichwarrantedtheemergency f

classificatio ' 7. Changes to the Emergency Preparedness Program (82204) The inspector reviewed' coordination with offsite support agencies and determined the program in place was adequat Letters of Acreement were found correct ofrsite support agency training was conductec as required, and the licens,ee remained responsive to offsite agency concern Clinton procedures provide for written notice to the NRC within 24 hours of any declaration of Unusual Event. The inspector advised that such notification is not a required action or stendard practice persor,inel responded they would continu,e the notifications a good as, and lic practic Drill records indicated that re uired Health Physics environmental monitoring, medical and assembl / accountability drills were conducted and critiqued as required per NUREG 0654, Revision 1. Problem areas were assigned to the cognizant personnel, with completion dates. A review of  ! the tracking system indicated timely follow up on all tasks.

I' All changes to the Emergency Plan and procedures are part of the licensee administrative review process. Implementing Procedure AP-02, Revision 4, established administrative guidelines for approval, change, revision and distribution of the Clinton Emergency Plan and related document In March, 1987, the organization of the Emergency Response Organization was change The overall management is now assigned to the Su)ervisor - Emergency Response, who supervises the Supervisor - Emergency )lanning, and the Supervisor - Emergency Exercises. Licensee management has indicated their intent to move the ERO to the Licensing and Safety grou _ _ _ _ _ _

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l Major revision took ) lace in the Field Team Handbook, utilized by field , monitoring teams. Tie inspector briefly reviewed the new manual, which i appeared to be an improvement over the previous editio A tracking system, utilizing a personal computer, has been institeted, and all commitments work items, or items to be considered are now placed onthissystem(drillandnon-drillitems).

An agreement was reached with other midwest utilities to share personnel for drill evaluators or calling the Anewpagersystemofthirteenpagersallows" entire group of thirteen individuals and is used to chaining"llEPpersonnelto ca the,sitetorespondto,orbeginevaluationofEmergencyPlan activation The positions of EAL Evaluator and Protective Action Guideline Coordinator (both E0F positions) have been combined, as it was recognized that an EAL Evaluator would a t be needed once the General Emergency

 ' ossification was reache No violations or deviations were identified in this are ' 8. ShiftStaffingandAugmentation(82205)

The inspector reviewed minimum shift staffing and capabilities for all shifts and concluded the emergency response organization met the Revision 1. The Emergency Plan guidelines of Table lists the oosition, B-1 of NUREG-0654,ing alternates report function, location and responsibi'lities for each posit. io ProcedureAP-10,"EmergencyResponseOrganization(ER0) Assignments," contained the licensee s provisions for establishing and maintaining its P0. The Supervisor - Emergency Response was responsible for approving assignments to the ERO and for maintaining an ERO Roster of sufficient numbers of trained personnel. The Director - Human Resources was responsible for providing the Supervisor - Emergency Response with weekly updates on employee status changes that could effect the roster. In addition, the accuracy of employee contact information was verified on a quarterly basis by the sending of the roster to relevant department The >rocedure also addressed provisions for making temporary changes to the ERO Roster for reasons such as extended sick leave, maternity leave, or extended travel. The Supervisor - Emergency Response would decide if such temporary situations warranted having ancther individual trained and added to the roste , The inspector reviewed the current ERO Roster, which was a computer 198 printout dated July and an alternate indivi10, dual for each management and technical staffThe ros position in every emergency response facility. Some key management and administrative support positions had more than two persons identifie ;

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l: L [' l ' Approximately 150 in plant team members and 20 field survey team members were identified in the roster. In accordance with Procedure AP-10, the inspector determined that no individual had been assigned to more than one ERO position. Onc recent change to the ERO roster was the combining of the E0F's EAL Evaluator and Protective Actions Evaluator positions into a single position. The licensee indicated that these positions were consolidated based on drill and exercise experience. The licensee also indicated that the designation of primary versus alternate for any - given ERO position was not always prioritized based on lowest estimated , travel time from residence to the Statio Activation of the ER0 was described in Procedures EC-01, " CPS Emergency

      " Emergency Plan Response Organizations Notification." In order to demonstrate and Staffing,"

its capa and EC-07,bility to aucment onsite staff based on the 30 and 60 minute goals of Table B-1 of N[ REG-0654, Revision 1 the licensee has conducted semiannual, off-hours augmentation calloutdrillsinaccordancewithanemergencyplancommitment. The inspector reviewed very detailed records of off-hours augmentation drills conducted in January and June, 198 The records included: objectives; scenario;chronologyofsiajorevents;critiguecomments estimated segmentation times of certain positions versus; the 30 comparisons and of 60 minute goals stated in the NUREG and listings of the estimated responsetimesofroughly100to140otherEROmemberswhowerealso notified during the drill The licensee correctly concluded that both drills has successfully demonstrated the capability of augmenting onshift personnel with the < 11 and 14 ERO positions corresponding to the 30 and 60 minute augmentation positions identified in Table 3-1. The inspector noted that the 100 to 140 additional persons who had also been involved in the drills held scientific, technician, maintenance, public i various engineering,inistrative information, and adm support positions in the licensee s ERFs including the JPI The licensee indicated that both drills involved the notification of sufficient personnel to completely staff all of the ERF The estimated response times of these persons generally ranged from under 30 minutes up to about 3 hours for a few individuals. While the licensee verbally indicated that the augmentation timeliness of these individuals had been informally reviewed versus the time goals for having a given ERF sufficiently staffed to be declared opetitional, the drill records included no such analysis for any ER The inspector informed the licensee's emergency planning staff that one valid purpose of an off-hours augmentation drill is to determine whether the 30 and 60 minute augmentation goals can be met using the existing callout methodology and ERO Roster. However,amoremeaningfulobjective of these drills is to determine whether a given ERF can be sufficiently staffed so as to be declared operational within a reasonable time goal, suchasonehourfollowingthedecisiontobeginfacilityactivatio Such timely activations are facilitated by a minimum staffing" concept, which defines which positions must be filled before a facility is . declared operational. The licensee utilizes such a concept, outlined in

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___-_ . Procedure FE-0 However, a comparison between the positions described in Procedure FE-06 and positions marked (by red tape) as minimum staffing positions indicated some discrepancie Based on the above findings, this portion of the licensee's program is acceptable; however, the following items should be considered for improvement:

  * An additional goal of off-hours augmentation drills should be to evaluate the timeliness that each ERF would be sufficiently staffed in order to be declared fully, operational. For the TSC, OSC, and E0F, the time goal for achieving fully operational status should be 60 miryutes following the appropriate emergency classification decisio * The licensee should assure that the minimum staffing neens for each ERF, as reflected in Procedure FE-06, are correctly reflected in practic No violations or deviations were identified in this are . Knowledge and Performance of Duties (Training) (82206)

The Emergency Plan delineates training requirements in Section The details of the training program are located in Administrative Procedure AP-05, which references a training matrix of requirements for each position in the Emergency Response Organizatio The inspector reviewed relevant records and discussed the training i program for the Emergency Response Organization (ERO) with cognizant prsonnel. Initial and annual refresher training requirements for all ERO management, steff, and support positions were specified in different training matrices. Annual refresher training needs were identified by the EP Training Instructor and the EP staff, and were then approved by the Director - Nuclear Training and the Supervisor - Emergency Respons Lesson plans developed by the training instructor, with technical assistant.e from a General Training,ppropriate groups, were approved by the Supervisor -Superv the affected technical group. For example, the Supervisor - Chemistry would be in the approval chain for a lesson plan on the use of the ! post-accident sampling syste j l At present, the license did not utilize examinations as a means of l demonstrating that all ERO members had adequately understood the training i they had received. Instead, the adequacy of the training provided and { the capabilities of the ERO members were measured by the individual's J performances during functional group, single facility, and integrated ERF ) drills that were all scheduled during each calendar quarter. T le 1 licensee did indicate, however, that exami1ations were being considered I for at ieast some ERO positions. As a cor. sequence, the licensee also j realized that it would have to decide whether or not veteran ERO members j l

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should eventually have the opportunity to pass a written examination on relevant training topics instead of attending annual classroom refresher trainin The inspector selected a random sample of 25 members of the ERO to

~ determine whether they had completed all training requirements within the last 12 to 15 months. Training records were reacily available on computer printouts, with training attendance sheets also readily available as backup documentation. The inspector concluded that'all 25 individuals had completed all training requirements within the last 12 month The sample of persons whose records were checked included primary and alternate individuals having management, staff, technician, or administrative support positions in the ER No violations or deviations were identified in this are . DoseCalculationandAssessment(82207)

The inspector reviewed the equipment and procedures to be used for dose assessmen Computerized and manual offsite dose calculation provisions were addressed in Procedures RA-16 and RA-01, respectively. Detailed instructions for operating the computer system were in Procedure CPS No. 7410.70,'" Computerized Emergency Dose Calculations." The manual calculation methods were of two types: first, to allow Control Room (CR) personnel to rapidly make rough off-site dose estimates during the initial stages of a serious emergency; second, as a backup methodology for TSC and E0F staff to generate an offsite dose calculation should the computerized methodology become unavailabl The manual methodology to be used by CR staff would arovide rough estimates of whole body and child thyroid doses at tie site boundary and standard distances of 2, 5, and 10 miles downwind. The source term would be determined from area, process, or vent stack radiation monitor readincjs, plus assumed flowrates for the Heating / Ventilation / Air Conditioning.(HVAC)systemorStandbyGasTreatmentSystem(SGTS),as appropriate. Other calculation assumptions included: a specified set of relatively adverse meteorologice.1 conditions; a default release duration; 99 percent iodine filtration via the SGTS; and specified flowrates through the HVAC and SGTS. The inspector understood that meteorological readouts in the CR were on a multipoint strip chart recorder, which would input parameter values difficult make and timea consuming determination for CR of time-averaged,Thus, default m teorological personne conditions would be used by CR staff. Refinements to this methodology that could be used by TSC and EOF staffs included: input of real-time meteorological data; input of actual SGTS or HVAC sample analysis results for noble gas and/or radiciodines; and input of an estimated release ; duration other than the default value. Assumptions remaining in the manual calculation method used by TSC and EOF staffs included the 99 percent iodine filtration efficiency and the specified flowrates through the HVAC and SGT L

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. The' licensee's computerized dose calculation methodology was'a segmented Gaussian plume model.i Source term and meteorological data could be automatically or manually entered into the com) uter model. The licensee-indicated that the model had a-subroutine whici performed some unspecified quality checks on these input aarameters. The ins walkthrough.with a-gualified ")ose Assessor - Com)pector attempted a-uter" in the licensee's ER3; While the' individual was quite familiar wit 1 system hardware and-coftware,hewasunabletogenerateanoffsitedosearojectionusingthe computerized model. Heeventuallydeterminedthat'tieprogramwas unusable due'to some error in the " standard source term' data file If

--such a data file already contained some erroneous information, the dispersion model could not be run until the error in the data file had been eliminate The inspector noted that there were separate positions titled " Dose Assessor Computer" and " Dose Assessor - Manual" in the ERO. In the event that the computerized model would be unavailable, as was the case duringthiswalkthrough,.offsite'doseprojectionswouldbemanuall performed-by the other staff while the person (s) tasked with generating doseprojectionusingthecom making'that method available.puterized model would be free to work on The adequacy of thetlicensee's computerized and manual offsite dose calculation provisions will be evaluated in Emergency Response Facility (ERF) Appraisal,   greater which has been detail as part of an tentativel scheduled for the Spring of 198 s       i Basedontheabovefindinfollowingitemshouldbeconsidered'forthis acceptable; however, the      portion of t improvement:
* To reduce 'the potential for error in relying on manual dose calculation methods, the licensee should implement a backup computerized methodology which can be run using a peisonal compute . LicenseeAudits(82210)'

The licer ve's Quality Assurance group performs an audit every twelve '; months which meets the. requirements of 10 CFR 50.54(t). Individuals ' assigned to perform the audit had no responsibilities for implementing I the Emergency Response Program. The inspector confirmed through record review that the audit has been performed within twelve aonth period Licensee procedures provide for the conduct documentation and corrective action associated with audits. theEmergencyPlanaudit j for 1986 ) August 25(AuditQ38-86-47,1986."CPSEmergencyPlan")was-performedduring

 - September 17, The audit report was comprehensive and 3 professional, involving two auditors'and resulting in seven Audit    )

rindings and several observations. This year's audit is scheduled for j September, 198 j

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_ _ _ _ - - - - _ _ __ - - - ___ - - _ _ __ - _ . _ _ _ _ - - _ _ _ _ ,e . E Also reviewed was Quality Assurance Audit Report Q38-86-63,' dated November 14, 1986,' which was conducted to verify that an adequate

  : interface exists between the utility and offsite authorities. This audit was conducted during October 22 - November 12, 1986, and included interviews with onsite 3ersonnel and offsite representatives. Workin relationships the CPS' Emergency Flan, Emergency Plan Training and problem areas,were discussec. during these interviews. The audit was well detailed and' comprehensive, and contained five recommendations for ilhprovement of offsite interface CFR50.54(t) requires ~thattheannua;emergencypre)arednessaudit address the adecuacylof the interface with offsite authorities, and that the audit be mace available to offsite authorities. Documentation was available to show that Audit 038-86-63 had been provided to offsite authorities, and a contact and telephone number were provided should the
 . recipients have any questions concerning the repor The licensee had also performed a " limited scope" unscheduled audit
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9-16, 1987 of (Audittheld Monitorin emergency) This auditresponse was performedcapability

       .to verify that the    during JanuaryE0 in procedures, for'g Field Kits Teamcontained  operations. adequate This audit was   equipment, adequate, as described and resulted in one findin .' Illinois Power also performed an " Integrated Quality Assurance Program Evaluation" for the. period January 1, 1987 through March 31, 198 Emergency Pre aredness was one of the seven areas reviewed in the evaluatio he evaluation concluded that the emergency Plan could be
 . effectively implemented, but recommended: increased attention to detail relative to procedural compliance and documentatio Audit findings are~ tracked via a computer tracking system. If an audit finding cannot be resolved, the problem is escalated to upper management for resolutica. Responses to audit findings must contain remedial correctiveaction(toresolvethepresentdeficiency),genericcorrective action (topreventrecurrence),'andacompletiondate. Proposed correctiveactionsareevaluatedbytheQA,groupforadeguacy,andif determined not to be adequate, the responsible organization is advise l No violations or deviations were observed in this are . MaintainingEmergencyPreparedness(82701)
             !
 . Procedure FE-05, " Emergency Eguipment and Supplies," listed nine locations for various categories of emergency equipment and administrative. supplies; identified six types of emergency kits; and       1 specified supervisors responsible for ensuring that periodic inventories       ]

were completed. The procedure also included inventory checklists which  ! listed mnimum quantities of emergency equipment and supplies maintained , at a total of 19 onsite and offsite locations. The procedure required

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that inventories be. conducted at least quarterly, after emergency I 14 l A _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ - -_D

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supplies usage, or afte' r a broken seal was_ discovered at a storage-location. Completed inventory checklists were to be reviewed by the'. Supervisor - Emergency Response prior: to transmittal .to Central File The inspector. reviewed completed inventory records beginning in April l 1987 and noted that all but two' required inventories 1ad been completed-E and adequately documented, including corrective actions taken on E identified deficiencies. Per correspondence dated July 15, 1987, the

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emergency planning staff had also identified that these two inventories had not.been completed by June 30. The staff had already scheduled these inventories to be done by July 24, which the inspector conciuded was j acceptabl u

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For " Sands-on". training purposes . the ERO has been divided into a primary h 1987, " hands-on" traininghas (ATeam)andalternate($ been conducted in the formTeam) group of functional, facility, and integrated fa.:ilit Procedure AP-04, "y drillsand Preparation that have-taken Conduct placeDrills of Emergency duringand each quarte Exercises," defined functional drills.as drills involving one or more persons who could perform a certain task. For example, a functiona drill could involve the protective action decisionmaking team in the EOF,

 - the administrative support staff in an ERF, or a post-accident sampling tea A facility' drill would test the interfaces between different work groupsLwithin a single ER An integrated facility drill would test th Interfaces between most or all of the-licensee's onsite and offsite ERF Functional and facility drills would typically last 1 or 2 hours, while an integrated facility drill could last about 4 hours.

1 The-inspector reviewed an internal memo dated March 25, 1987, which listed the quarterly integrated drill schedule for the A and B teams through the 1988 annual exercise. 'The inspector:also reviewed-internal

 - memos dated May_7 and July 13,~1987, which contained the functional and facility drill schedules leading up to the quarterly integrated drills scheduled for late July and late September, respectively. A total of eleven functional and facility drills had been scheduled prior to each integrated facility drill. 'A review of adequately detailed records indicated that the various types of functional, facility, and integrated drills had taken place on schedule and had been critiqued during the period January through early July 1987. The inspector also determined  ,

that the most recent annual medical drill involving participation of the l local hospital and ambulance service had taken place in December 198 ! This drill was critiqued by the licensee's medical consultar A review of the EP staff Y computerized action item tracking system report, dated July 22, 1987, indicated that many critique comments from

 - the various drills had been added to the tracking system and had been assigned to specific individuals for corrective action. Completed  >

corrective actions were also briefly described on the computer printou l The tracking system printout also listed the due dates for corrective l actions in progress and the numerical priority assigned to each ite ;

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The inspector discussed offsite. support agency annual training activities

with cognizant licensee personnel and' reviewed. relevant ~ record Local ) hospital and ambulance service staffs last received training on the i handling and care of contaminated / injured personnel from the. licensee's medical contractor in December,1986. Training records included an agenda of training activities, participant sign-up sheets, and evidence that site access procedures had been addressed in the trainin , Local ele-tronic and print media were offered orientation training in January 1987. she training session was conducted in cooperation with representatives.from IESDA and IDNS. The training included an overview of the licensee's and State's emergency planning efforts'plus a tour of the'JointPublicInformationCenter(JPIC).

Since the' licensee was in the process of revising the Station's EALs, the annual meeting with offsite officials to discuss these EALs has not yet-

?    taken place in 1987. . The licensee indicated that the meeting would likely take place in the fourth guarter of the year, following internal approval and training on the revised EAls. The Supervisor cmergency Response also indicated that he contacted County ESDA officiais on about a monthly basis, and met with IESDA and IDNS representatives ~ roughly once a quarter to discuss emergency preparedness issues of current interes Three'offsite firefighting organizations could respond to an onsite fir Annual training activities involving each of these offsite organizations included: responding to a simulated fire scene within the protected area, and classroom session on the use of self-contained breathing apparatus; an d Protected Area ingress and egress procedures.special hazards The scope of the train at the Station on the latter two topics was adequately described in Lesson Plan No. 1220 The 1987 drill and classroom training activities for the three local firefighting agencies were still in progress at the time of the inspectio The inspector reviewed letters of agreement with offsite support organizations and individual physicians. The bulk of the agreements were dated 1985, and were worded such that they would remain effective until revised or rescinde No violations or deviations were observed in this area.

. 1 ExitInterview(30703) . The inspectors met with the licensee representatives denoted in

   ~ Paragraph'1 on July 24 ~198 The inspectors summarized the scope and recults of the-insp,ection and discussed the likely content of the
   ' inspection report. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur ,

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