IR 05000482/1990029

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-482/90-29

ML20062H391
Person / Time
Site:	Wolf Creek
Issue date:	11/21/1990
From:	Collins S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
References
NUDOCS 9012040291
Download: ML20062H391 (3)

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! l Occket No. STN 50-482/90-29 License No. NPF-42 Wolf Creek Nuclear Operating Corporation ATTN: Bart D. Withers President and Chief Executive Officer P.O. Box 411 Burlington, Kansas 66839 Gentlemen:

Thank you for your letter of October 25, 1990, in response to our letter and inspection report dated September 25, 1990. We have reviewed your reply and find it responsive to the concerns raised in our inspection report. We will review the implementation of your corrective actions during a future !

inspectio

Sincerely, I

T.\-O VJin r1 O Samuel J. Collins, Director Division of Reactor Projects cc:

Wolf Creek Nuclear Operating Cor '

ATTN: Gary Boyer, Plant Manager P.O. Box 411 Burlington, Kansas .66839 Shaw, Pittman, Potts &.Trowbridge ATTN: Jay Silberg, Es M Street, NW i

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Washington, D.C. 20036

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l Wolf Creek Nuclear Operating Corporation -2- l Public Service Commission ATTN: Chris R. Rogers, Manager, Electric Department P.O. Box 360 Jefferson City, Missouri 65102 U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Wolf Creek Nuclear Operating Cor ATTN: Otto May>,;-d, Panager Regulatory Services P.O. Box 411 Burlington, Kansas 66839 Kansas Corporation Commission ATTN: Robert Elliot, Chief Engineer Utilities Division 4th Floor - State Office Building Topeka, Kansas 66612-1571 Office of the Governor State of Kansas Topeka, Kansas 66612 Attorney General'

Ist Floor - The Statehouse Topeka, Kansas 66612 Chairman, Coffey County Commission Coffey County Courthouse Burlington', Kansas 66839 Kansas' Department of Health and Environment Bureau of Air Quality & Radiation Control l

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ATTN: Gerald Allen, Public Health Physicist-Division of Environment Forbes Field Building 321 Topeka, Kansas 66620 Program Manager FEMA Region 7 911 Walnut Street, Room 200 Kansas- City, Missouri 64106

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W$LF CREEK NUCLEAR OPERATING CORPORATION Bart D. Withers c'w"Y/A ow October 25, 1990

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U. S. Nuclear Regulatory Conmission ATTN: Document Control Desk t DCT 2 9 @

Mail Station P1-137 Washington, D. C. 20555 .

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Reference: Letter dated September 25, 1990 from S. J. CollIhnT, NRC, to B. D. Withers, WCNOC Subject: Docket No. 50-482: Response to Exercise Weaknesses 482/9029-01 and 482/9029-0 , t Gentlemen This letter provides Wolf Creek / Nuclear Operating Corporation's (WCN00)

response -to Exercise Weaknesses: 482/9029-01 and 482/9029-03. . Exercise *, [

! weakness 482/9029-01 involved inadequate emergency staff augmentation in the'ir ^)

" control' room; Exercise weaknesei482/9029-03 involved the fallure to ensure y

• ' notification messages sent out;to. offsite -authoritiesi contained accuratep informatio '

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iIf'youhhaveanyiquestions(l,concerning1hismaftter,V;pleasecontactauor.yj ,

Mr. H. K. Chernoff of my' staf '

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Very truly yours,

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Bart D.. Withers L President and

! Chief Executive Officer

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Attachment

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cc W. B. Jones (NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a D. B. Spitzberg (NRC), w/a t

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! l Attachment to kH 90-0181 Page 1 of 2 Exercise Weakness (482/9029-01): Inadeaunte Emergency Staff Augmentation in the Control Room Response: During drills and exercises, actions taken by personnel are often limited by controllers due to availability of personnel and the obligation to not affect normal plant operation and staffin In past drills, additional personnel have not been made available to support simulator control room staffing augmentatio In addition control room personnel are trained to utilize available personnel as appropriat Based on these experiences, the simulator control room staff has handled drill scenarios with the resources available. Also, the Shift Supervisor was aware that the majority of the relief crew was participating in exercise activities in the plan Therefore, based on the circumstances, the Shift Supervisor did not request staff augmentatio The actions taken by the Shift Supervisor during the exercise were not in violation of minimum control room staffing requirement During actual plant incidents, which required additional personnel , shift supervisors have consistently augmented their normal shift compliment with off duty control room personnel and non-licensed shift personne Therefore, it has been determined that the weakness is a result of circumstances related to exerciee limitations. Player briefings will be conducted prior to the 1991 Exercise. During these briefings personnel will be instructed to initiate all actions they would normally take by interacting with the controlle Controllers will be instructed to limit these actions only when it affects actual plant operations, adversely affects the scenario, or raises a safety concern.

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Attachment to WH 90-0181 Page 2 of 2 Exercise Weakness (482/9029-03): Failure to Ensure that Information Contained in Notification Messanes Issued by the EOF was Accurate

Response: The identified weakness occurred when misleading release information was transmitted to the State and County due to the failure to annotate notification forms to indicate verification of release tennination was in proces j After a release has occurred and immediate notification has taken place, the State and County are kept informed of the plant status through follow-up notification messages form These forms are transmitted at approximately one half hour interval In the exercise, the atmospheric relief valve was isolated at 105 This information was conveyed to the Duty Emergency Manager (DEH) at 105 The DEM did not declare the release terminated due to a lack of verificatio The DEM wanted to ensure no other release path existe The first follow-up notification message was sent to the State and County at 1105 shortly after the DEH was notified of the valve closure. It reflected release in progress information because verification had not yet taken plac At 1107 the DEM held an EOF staff meeting in which the State and County were verbally notified that the valve was closed and the termination of release was pending field verificatio Soon after 1107, a field team was directed to take confirming measurement The second follow-up notification was issued at 1131. At this time positive verification of release termination from the field team had not been received, therefore termination was not stated. The DEM was aware of the valve isolatio However, when each follow-up notification message was issued, confirmation measurements reflecting the termination of the release were not available and, the DEM wanted to ensure there was no indication of another release pat In the past, follow-up -

notification forms normally have not been annotated. Therefore, the DEH did not consider adding notation to indicate confirmation of release termination was in proces A Required Reading memo has been sent to personnel responsible for completing and approving notification form This memo reinforces the need to assure the information on the forms is accurate and curren It also addresses that clarification of the information can be made on the form. It further states that if incorrect information is identified after notifications are made a new form is to be issued with the correct informatio This required reading will be completed by November 30, 199 The annual retraining for these positions will incorporate the information provided by the required reading and emphasize the necessity to assure information on the forms is current and accurat Annual retraining for these positions will be completed by May 31, 199 ,

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SEP 2 51990 .

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In Reply Refer To: l Docket: STN 50-482/90-29 l Wolf Creek Nuclear Operating Corporation ATTN: Bart O. Withers  !

President and Chief Executive Officer P.O. Box 411 1 Burlington, Kansas 66839 i Gentlemen:

This refers to the inspection conducted by Dr. D. Blair Spitzberg of this office and other accompanying personnel during the period August 27-31, 1990, of activities authorized by NRC Operating License NPF-42 for the Wolf Creek Generating Station, and to the discussion of our findings with members of your staff at the conclusion of the inspectio Areas examined during the inspection included the implementation of the emergency plan and procedures during the annual emergency response exercis Within these areas, the inspection consisted of selectiv,e examination of procedures and representative records, interviews with persor. del, and observations by the inspectors. The inspection findings are documented in the enclosed inspection repor Within the scope of the inspection, no violations or deviations were identifie The enclosed inspection report identified exercise weaknesses in your emergency I

preparedness program. Weaknesses involved the following: Notification messages sent out to offsite authorities containing inaccurate information concerning the radiological release status, and inadequate' emergency staff augmentation in the control room.

l Exercise weaknesses according to 10 CFR Part 50, Appendix E.IV.F.5, are I inspection findings that need to be corrected by the licensee. You are i requested to provide this office with a description of your corrective measures and yo9r schedule for completing these actions within 30 days after receipt of this lette '

We have also examined actions you have taken with regard to previously identified inspection findings. The status of these items is identified in

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paragraph 2 of the enclosed report.

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Wolf Creek Nuclear -2-Operating Corporation Should you have any questions concerning this inspection, we will be pleased to discuss them with yo

Sincerely, p,$hT ChN" Samuel J. Collins, Director Division of Reactor Projects

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Enclosure:

Appendix - NRC Inspection Report

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50-482/90-29

REGION IV i i

I NRC Inspection Report: 50-482/90-29 operating License: NPF-42 Docket: 50-482 j Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC) l P.O. Box 411 l Burlington, Kansas 66839  ;

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: Burlington, Kansas Inspection Conducted: August 27-31, 1990 Inspector: 'o 9- / 7- 90 Date Dr. D. B. Spitzgergf,r&afergency Prepareoness Analyst (NRC Team be& der)

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Accompanying l Personnel: K. M. Kennedy, Inspector, Region IV l G. R. Bryan, Jr. , Comex Corporation l

Approved: , /bd kMilli, B. Mur' ray, CElef,' Ra9iological f Protection and Dafte i M

Emergency Preparem ess Section  !

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Inspection Summary l Inspection Condu:ted August 27-31, 1990 (Report 50-482/90-29)

Areas Inspected: Routine, announced inspection of the licensee's performance and capabilities during an annual exercise of the emergency plan and l- orocedures. The inspection team observed activities in the control room (CR),

w:hnical support center (TSC), emergency operations facility (EOF), and the respense of the fire brigad Results: Wii.hin the areas inspected, no violations or deviations were identified. Two exercise weaknesses were identified by +.he inspection team (paragraphs 4 and 7). Weaknesses identified included the issuance of i notification messages to offsite authorities which contained inaccurate

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. information concerning the status of the radiological release, and inadequate emergency staff augmentation in the control roo The licensee demonstrated efficient activation of emergency response facilities, accurate and timely emergency classifications and accident assessment and mitigation, and established effective protective actions in response to the scenario data provided. The licensee's overall response demonstrated the capability to protect the health and safety of the public and to-implement the. emergency pla .

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DETAILS persons Contacted

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WCNOC

• J. Zell, Manager, Training

• K. Moles, Manager, Emergency and Radiological Services

, J. Bailey, Vice President, Nuclear Operations J * Wond, General Counsel

• R. Hagan, Manager, Nuclear Services

• F. Rhodes, Vt:e President, Engineering and Technical Support

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B. Withers, President, WCNOC

• K. Craighead, Emergency Response Planner

• H. Chernoff, Licensing Supervisor

• R. Logsdon, Mar.ager, Chemistry

_- * Norton, Mr.iager, Technical Support

• Williams, Manager, Plant Support

• Schreiter, Senior Engineering Specialist

• T. Morril, Manager, Radiation Protection

• J. Wesks, Manager, Operations

• R. Benedict, Manager, Quality Control

• Lindsay, Manager, Quality Assurance E

• D. Pickett, NRR Project Manager FEMA

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R. Bissell, Chief, Technological Hazards Branch, Region VII The inspector also held discussions with other riation and corporate

, persor.nel in the areas of security, health physi s, operations, training, and emergency response,

• Denotes those present at the exit intervie . Followup on previous Inspection Findings (92702)

(Closed) Exercise Weakness (482/8930-01): Failure of the EOF staff to be aware of significant reactor condition In the response letter of

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February 7, 1990, the licensee described the cause of this weakness as a failure of information flow from the operations assessment

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coordinator (OAC) to the operations status board recorders (OSRs). The

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licensee fulfilled their corrective actions by increasing the emphasis of improved communications flow during training given to OAC and OSR

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personnel in May and June 1990. Additional training was also given to the engineering teams in analyzing critical plant parameters during June 199 The inspector _ reviewed documentation of the training and also noted that

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-4-during the 1990 exercise, the EOF staff was aware of critical plant parameter (Closed) Exercise Weakness (482/8930-02): Inadequacies associated with I the scenario. The inspectors noted that for the 1990 exercise, attention was given to preparing a scenario that would ensure that all critical objectives could be met and that would be able to proceed smoothly in the ,

event that the control room simulator went down. While the inspectors did I note minor problems associated with the 1990 scenario, objectives were l met, the time line was maintained, and a brief simulator failure was I compensated for adequatel (Closed) Open Item (482/8930-03): Inspector concerns over the reliability of telephones in the emergency respcose facilities. The inspector .

reviewed the licensee's response to this concern which identified as the I probable cause of the observed problems some line splicing by the local telephone company onto the existing cable that supplias the EOF. This I work was being performed at the time of the 1989 exercise. The licensee I stated that no similar problems have been experienced since the previous I exercise and none were noted during the 1990 exercis ' Procram Areas Inspected The inspection team observed licensee activities in the CR, TSC, and EOF l during the exercise and evaluated the response of the fire brigade. The !

inspection team also observed emergency response organization staffing; l facility activation; detection, classification, and operational assessment; notification of licensee personnel, and offsite agencies; and formulation of protective action recommendations. Inspection findings are documented in the following paragraph The exercise was considered a partial participation exercise which involved participation by all elements of the licensee's emergency L response organization, and the state and local agencies. Neither Federal Emergency Management Administration (FEMA) nor the NRC participated in the I exercise although both were involved in the evaluation. The exercise l

, scenario involved indications of core damage caused by loose parts in the 1 l primary system followed by a steam generator (SG) tube rupture and the

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failure of a power operated relief valve (PORV) on the affected steam l he to fully close. This created an unmonitored release pathway for fission products. The scenario also included a contaminated injury victim, and a fire in the turbine building.

L There were various deficiencies identified during the course of the exercise; however, none of the observed deficiencies were of the significance defined in 10 CFR 50.54(s)(2)(ii). Each of the observed deficiencies has been characterized as an exercise weakness according to 10 CFR 50, Appendix E.IV.F.5. An exercise weakness is a finding that a licensee's demonstrated level of preparedness could have precluded effective implementation of the emergency preparedness plan in the event l

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5-of an actual eme genc It is a finding that needs licensee corrective actio . Control Room (82301)(1)

The inspection tesi observsd and evaluated the CR staff as they performed tasks in response to the txercise. The scenario was programmed on the CR simulator which incteased the realism of the emergency for operations personnel. The CR staff uns observed performing tasks including detection and classification of evel ts, analysis of plant conditions and corrective actions, notifications, at.d dispatch of a fire brigad The inspector noted that operator staff augmentation was not pursued by the CR staff during the exercise. Licensed operators were not requested by the shift supervisor (SS) or supervising operator to assist in the control room operations. Following the report of the fire, the balance of plant (BOP) operator was dispatched as the designated fire brigade leader and was out of the CR for over 30 minutes. This left one reactor operator and two senior reactor operators (including the SS) in the CR. During this time, a plant shutdown was in progress, a fire was in progress, a reactor trip and manual safety injection occurred, a PORV was stuck open, and a SG tube rupture was diagnosed, causing a radiological release to occur. The SS was forced to perform control board manipulations during this time that would normally be performed by the BOP operator. This hindered his ability to supervise overall plant operation At the time of the exercise, there would have been several licensed operators at the site which could have been called on to augment the CR staff. Failure of the CR staff to augment operations staff as needed in the CR during an emergency is considered an exercise weakness (482/9029-01).

The inspector observed that logs were not adequately kept in the CR during the exercise. The supervising operator maintained a log sheet for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after which no entries were made. The inadequate maintenance of logs by the CR was identified during the previous exercise as an improvement item. The inspectors continue to find that the logs maintained in the CR during exercises would not allow for the reconstruction of the events and actions that occurred during an acciden This observation will be considered an inspector followup item pending demonstration of adequate logkeeping in the CR during the next exercise (482/9029-02).

No violations or deviations were identified in this program are . Technical Support Center (82301)(2)

The inspection team observed and evaluated the TSC staff as they performed tasks in response to the exercise. These tasks included activation of the TSC, accident assessment and classification, notification, dose assessment, protective actions, and technical support to the CR. The TSC was efficiently activated and emergency management responsibilities were promptly transferred from the CR to the TSC. In contrast to the previous

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-6-exercise, the TSC was able to make a core damage assessment based upon the results of a primary coolant sample. The TSC dose assessment group performed well during the exercise and continued to run projections after the shift of responsibilities to the EO The TSC staff was noted to be correct in its classification of a site area emergency (SAE) despite the fact that the scenario was deficient in not anticipating this classification when the conditions were detected. Under the licensee's emergency action level classification scheme, a safety injection equated to EPP 01-2.1, Attachment 3.0, reactor coolant system (RCS) barrier breach, " Inability of energing system to maintain water inventory." This condition meant that two fission product barriers had been breached or challenged, conditions corresponding to a SA The inspector noted that the scenario did not provide data on forced flow reactor vessel level indicating systen (RVLIS). This data would have been accessible from the CR but in the event of a simulator crash, the data l would not have been available in the TSC from scenario data sheets had the staff wanted to run core cooling and inventory critical safety function l status trees following the. trip with the RCS pumps running. This l observation was determined to have hai no adverse impacts during the ;

course of the exercis No violations or deviations were identified in this program are . Fire Brigade Response The inspector observed the response of the fire brigade during the exercise to verify that objectives were satisfactorily met in this are The fire brigade was dispatched to respond to a fire in the turbine building. The inspector noted that the team responded adequately to the fire and that the fire fighting objectives were me During the' fire fighting exercise, it was noted that there were certain unnecessary delays experienced by the brigade that contributed to the 17-minute response time between callout and initial fire suppression. For -

example, although two backup fire leigade members responded immediately to the turnout locker, the five-man brigade did not reach full strength until 6 minutes after the announcement of the fire over the GAITRONICS because one of the primary brigade members had not initially responded. The inspector concluded that the fire brigade leader should have directed one of the backup individuals to suit up rather than wait for the primary member. Another minor delay was experienced when the team did not initially rig enough fire hose and as a result, had to pause before reaching the scene to add additional lengths of hose. The reduction of unnecessary delays in the response time of the fire brigade was identified as an exercise improvement ite No violations or deaations were identified in this are _ __

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The inspection team observed and evaluated the EOF staff as they performee i tasks in response to the exercis These tasks included activation of the !

EOF, accident assessment and classification, offsite dose assessment, I protective action decisionmaking, notifications, and interaction with !

state and local official The EOF was observed to be staffed expeditiously and facility accountability and habitability was promptly established. Command and control of the EOF staff was strong but could have been improved through more concise and frequent briefings over the PA system. Status boards !

were generally accurate and current, and good communications and teamwork I was evident between the EOF staff member The itispector noted that the first two notification update messages issued from the EOF contained inaccurate information concerning the status of the radiological release despite the true status being known by those approving the messages. This appeared to have been an oversight of these errors in approving the messages. Although the release terminated at 10:50 a.m. when the D SG 00RV block was shut, the EOF continued to promulgete followup messages until 12:20 p.m. showing that a release was in progress. The TSC recognized this error at 11:59 a.m. when reviewing EOF Message The TSC did not info - the EOF of this error, however, until 12:19 p.m. An accurate EOF Message 3 indicating the termination of the release was then issued at 12:20 p.m. As a result of these message errors, offsite state and local officials were incorrectly led to believe that a release was in progress for 1 1/2 hours after the release was terminated. Failure to ensure that information contained in notification messages issued by the EOF was accurate was identified as an exercise weakness (482/9029-03).

No violations or deviations were identified in this program are . Licensee Self-Critique The inspectors observed and evaluated the licensee self-critique for the exercise and determined that the process was capable of identifying weaknesses and characterizing their significance. Management involvement in the critique process was evident and while the formal critique was held the day following the exercise, it is expected that given a more thorough evaluation of the findings and their root causes, a more complete picture of the licensee's overall performance can be obtained.

l The licensee identified 1 deficiency and 10 weaknesses. The inspectors l noted that the licensee's characterizatien terminology was not consistent with that used by the NRC for items havin) roughly the same significanc For this reason, the term " deficiency" as used by the licensee did not

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correspond to a deficiency as defined by l') CFR 50.54(s)(2)(ii). Further, l some of the licensee-identified weaknesses appeared to describe what the l

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. NRC would characterize as improvement item The significant findings summarized during the licensee self-critique were as follows:

Deficiency Poor communications of data from the CR to TSC without release information system operable, and incorrect information or poor transfer of information regarding the release termination and evacuation of the nearby reservoi Weaknesses Evaluate disposition of mud room personnel (explained as a lack of control of team staffing from the mud room vs. the operations support center).

• Lack of sufficient personnel for CR communication * Improve communication *

Status board maintenance (TSC radiological status boards).

• Lack of EOF staff update * Calculated field team overexposure to the thyroi * Injection of "NRC player" during discussion of downgrading caused confusio * Misunderstanding of offsite radiological data (controller error).

• Establishing a radio link with simulato * Reestablish preexercise player briefing ,

The inspectors identified as an improvement item the licensee's

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characterization of the significance of exercise findings as presented in

! the critiqu . Exit Interview l The inspection team met with the licensee representatives indicated in paragraph 1 on August 31, 1990, and summarized the scope and findings of the inspection as presented in this repor The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during the inspectio _ _ __ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . . _ . . _ _ _ _ _ _ _

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