IR 05000219/1997008
| ML20197B938 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/04/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20197B924 | List: |
| References | |
| 50-219-97-08, 50-219-97-8, NUDOCS 9712240072 | |
| Download: ML20197B938 (13) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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. REGION I
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Docket No.
60 219 i
License No.
DPR< 16
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Report No.
50 219/97 08
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Licensee.-
GPU Nuclear Corporation i
1 Upper Pond Road i
Parsippany, NJ 07054 j
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Facility;-
Oyster Creek Nuclear Generating Station Dates:
October 20 24,1997
e inspectors:
W. Maler, Emergency Preparedness Specialist J. Jang, Senior Radiation Specialist L. Eckert, Radiation Specialist J. Schoppy, Senior Resident inspector
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S. Pindale, Resident inspector Approved by:
Michael C. Modes, Chief
Emergency Preparedness and Safeguards Branch
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Division of Reactor Safety i
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i EXECUTIVE SUMMARY i
Oyster Creek Nuclear Generating Station Full participation Emergency Preparedness Exercise Evaluation l
October 20 24,1997, inspection Report 50 219/97 08
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The inspectors concluded the licensee has an adequate onsite emergency plan and successfully implemented it. The licensee's overall response to tha scenario events was good. The inspectors opened an inspector follow up item to track a training deficiency identified as a result of the Emergency Control Center crew's f ailure to follow an abnormal operating procedure. The inspectors considered the licensee's failure to notify the state authorities within 15 minutes of the Site Area Emergency declaration to be an exercise
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weakness needing corrective action. The inspectors considered the licensWi critique process to be very thorough and to generally identify and characterize the major j
performance issues. The inspectors considered the licensee's control of the se,enarlo and
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the exercise conduct to be good. The inspectors closed an earlier ident! fled inspector follow up item related to the description of training requirements for supplemantal
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emergency response positions.
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Menort Details
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P3 EP Procedures and Documentation i
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Insoection Scoco (82701)
In the weeks prior to the exercise evaluation, region 11 inspectors reviewed several changes the licensee made to the emergency plan and implementing procedures.
The inspectors reviewed these changes in the NRC Region I office. They conducted this review to verify that the changes made to the emergency plan and implementing procedures were made in accordance with Part 50.54(q) of NRC
regulations, i.e., that they did not decrease the effectiveness of the emergency
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plan. The list of emergency plan sections and implementing procedures reviewed is
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contained in Attachment 1 of this report, b.
Conclusions
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Based on the licensee's determinations that the changes did not decrease the overall effectiveness of the emergency plan, and that the plan, as changed, continues to meet the standards of 10 CFR 50.47(b) and the requirements of
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Appendix E to Part 50, NRC approval of these changes is not required. The in-
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office review of these changes indicated they were made in accordance with
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10 CFR 50.54(q). The programmatic implementation of these changes will be inspected on site during a future emergency preparedness program inspection to
confirm that they have not decreased the overall effectiveness of the licensee's emergen::y plan.
P4 Staff Knowledge and Performance in EP a.
Exercise Evaluation Scooe (82301)
During this inspection, the NRC inspectors observed and evaluated the performance of the licensee's emergency response organization (ERO) during the biennial, full-participation exercise in the simulated emergency control center (ECC), tecFnical
support center (lSC), operations support center (OSC), emergency operations facility (EOF), and environmental assessment command center (EACC). The exercise was conducted on Tuesday, October 21,1997, from 4:30 p.m. until 11:20 p.m. The inspectors assessed licensee recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recommendations, command and control, communications, offsite radiological dose assessment, and the overall implementation of the emergency plan, in addition, the inspectors attended the post exercise critique to evaluate the licensee's self assessment of the exercise.
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Empfgency Response Facility and Critioue Observations and Findinas Emeraency Cpntrol Center (EQ_QJ The ECC, which is normally located in the control room, was located in the licensee's control tor,m si nv!sor for the exercise. The ECC in the simulator was adequately equippe ? to perform its emergency functions. Overall, performance in the ECC was good.
The emergency director demonstrated good f acility management and control. Both ho and the group operating supeivisor provided frequent and appropriate briefings to personnelin the ECC.
Overall, the ECC staff effectively analyzed plant conditions and appropriately implemented corrective actions with two exceptions. Those exceptions are detailed below. The control ronm staff relied heavily on the shift technical advisor's technical expertise, ana his performance was strong in this area.
Operators recognized that two torus to-drywell vacuum breakers had fai%d in the open position, but they did not discuss potential consequences or cornm e actions, nor did tLey inform the TSC of the valve failures. These open vacuum breakers limited the energy removal capability from the drywell during a subsequent loss of coolant accident and was an indication that should have been reported early to the other emergency response facilities.
Also, the operators, after consultation with the emergency director in the TSC, attempted 17 close the main steam isolation valves (MSIVs) following an ATWS event in order to terminate the release of radioactive material from the containment.
This action was not prescribed by EOPs, and was prevented by an IF/THEN statement in abnormal operating proceduro 2000-ABN 3200.26," Increase in Main Steam Line/Off Gas Activity." This procedure directs MSIV closure if the reactor has been successfully scrammed (there was an ATWS at the time). The operators acknowledged and announced the receipt of a control room alarm related to high main steam line radiation; however, they did not utilize either the alarm response proceduto or abnormal procedure 2000-ABN 3200.26. The ECC controller prevented the operators from closing the MSIVs. The controller's motive for doing so was to preserve the credibility of the plant radiation data rather than to prompt the crew.
The ECC personnel quickly and effectively detected and classified the unusual event and the alert conditions. The ECC staff promptly made the required offsite
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however, notification of the unusual event was made prematurely when the control room operator notified Ocean County for offsite firefighting support and informed the dispatcher that the licensee was planning to make a declaration of an unusual event soon.
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s Communications were generally effective, but some lapses in performance occurred.
As mentioned earlier, the operators did not report the opened torus to-drywell vacuum breakers to the other emergency response f acilities. Second, there was no announcement or acknowledgment in the ECC that an individual was missing during Site Accountability. Third, the transfer of ED control from the ECC to the TSC was not clearly communicated or announced.
ECC ernergency management implemented appropriate onsite protective actions early in the scenario while having responsibility for such actions. The reactor
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building was evacuated promptly after radiation levels increased, and the turbine
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building was evacuated af ter the ECC determined that operators could not close the
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MSIVs. The ECC staff interfaced effectively with radiation protection personnel assigned to the ECC.
Technical Sucoort Center fTSC)
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TSC performance during the exercise was good overall. The TSC was adequately equipped to perform its emergency response function. Emergency responders staffed and activated the facility within the time requirements of the emergency
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plan. The licensee maintained plant procedures used in the TSC up to date; however, they did not maintain the TSC ccpy of the plant Technical Specifications current through the latest amendments. Ameridments 189 through 192, which l
date be.ck to March 1997, were not entered in the TSC controlled copy.
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The emergency director (ED) maintained excellent f acility management and control.
His briefings to his staff were informative and frequent. He effectively utilized his subordinate advisors and kept the f acility noise to a manageable level.
Generally, the TSC staff's assessment and classification of the scenario events were accurate but some problems were noted. The ED's classifications of the site area emergency and general emergency conditions were accurate and timely. His concurrence with the ECC's decision to shut the MSIVs during an ATWS condition was not technically sound, however.
The TSC did not perform a quantitative assessraent of the extent of core damage as provided for in the emergency plan implementing procedures. The TSC engineers requested a PASS sample; however, they did not pursue secondary methods of evaluating mre' damage. This was attributable to the lack of a core assessment engineer in the TSC. This individual reported to the ECC during a previous event and was kept there when plant radiation levels made travel to the TSC unadvisable.
One of the scenario events was an inadvertent withdrawal of a traversing incore e
probe from a shielded condition. This event caused extremely high radiation levels in certain areas of the reactor building (some areas > 2400 mR/hr). As a result of this, the ED gave permission for the radiological assessment coordinator (RAC) to deviate from locked high radiation area controls without following the process for such procedural deviations. Specifically, the RAC dispatched guards to prevent i
entrance to the affected areas, although the technical specifications require
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areas greater than 1000 mR/hr to be locked to prevent entry into them. Discussion of this action indicated that it was being pursued under the provisions of Part 50.54(x) of NRC regulations. This deviation does not appear to be in accordance with 50.54(x) as this action was not immediately needed to protect public health and safety and there existed other actions, consistent with technical specification requirements that would provide equivalent protection. However, since the pace of scenario events precluded the implementation of these actions, the licensee's actions were appropriate for ensuring the immediate protection of onsite personnel.
The inspectors noted some lapses in radiological controls practices at the TSC during the exercise. A radiation protection technician distributed self reading dosimeters (SRDs) to all TSC members. Hmover, a large number of the SRDs were reading above 75% of scale when distributed (many read 190 mR on a 200 mR sceio) and the majority of TSC members did not perform an initial reading on their
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SRD prior to clipping it on. The inspectors did not note any responders re zeroing their SRDs.
There was a failure of a communication circuit between the TSC and the OSC during the exercise. This equipment failure necessitated the use of alternate communication methods between the two facilities. The two f acilities were able to communicate effectively using the alternate methods, such that the circuit f ailure did not adversely af fact the ability to respond to the scenario events.
Operations Suonort Center (OSC)
The licensee exhibited very good performance overallin the OSC. That facility was adequately equipped to perform its emergency function; however, some problems were noted. For example, the Plant Performance Monitor computer, which provided cata from the simulator, f ailed during the exercise. This f ailure prevented the radiation protection personnelin the OSC from being able to access the radiation data screens and determine real time radiation conditions. Also, the normalinter-f acility communication link between the OSC and the other emergency response f acilities f ailed, necessitating the use of alternate communication methods.
Othcrwise, OSC performance was very good. Staffing and activation was timely.
Proper accountability was performed within the f acility, and habitability checks were performed regularly. The team briefings were succinct and effective. The facility managem9nt showed good oversight of the onsite field teams and damage control teams. Thirty in plant tasks were accomplished by teams sent from the OSC.
Emeraency Oogrations Facility (EOF)
Overall, performance in the EOF was good, and the f acility successfully demonstrated the ability to perform consistently most of the emergency tasks assigned to it. The single exception was in the stea of offsite notification l
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The EOF f ailed to make a timely notification of the Site Area Emergency (SAE)
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declaration to the State of New Jersey. The Emergency Support Director (ESD)
declared the EOF to be activated at 7:14 p.m., tasked with the functional responsibility for making emergency notifications to offsite authorities. At the same time, the Emergency Director in the TSC declared a SAE due to an earthquake affecting systems required for safe shutdown.
During the turnover of the notification function to the EOF, the EOF discussed the status of pending notifications with the Emergency Control Center (ECC).
Confusion over the turnover of the status of the Site Area Emergency notifications led the EOF to believe that the ECC had notified the state of the SAE declaration,
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when, in f act, the ECC had not done so. It was not until 7:33 p.m., wher, ine ECC was notifying the state of the termination of an earlier dec:ared Notification of Unusual Event, that the ECC re'lized that the notification of the SAE had not been made. The ECC notified the state of the earlier declared SAE, but this notification did not occur until nineteen minutes after the declaration, and it was made serendipitously.
The inspectors noted that the EOF was able to perform the offsite notifications for a subsequent General Emergency (GE) declaration later during the exercise. These notifications were completed thirteen minutes af ter the GE declarafon.
- EOF performance wLs otherwise effective. The ESD exercised adequate command and control of the f acility, effectively using his subordinates and providing briefings to the f acility responders as important events occurred. He coordinated his actions and decisions with the state officials present in the EOF. The protective t.ctions developed in the EOF for the GE declaration were accurate and timely.
Environmental Assessment Command Center (EACC)
The EACC is a facility wholly located in the EOF. It is tasked with evaluating the offsite consequences of plant events and releases, and the Group Leader -
Radiological and Environmental Controls (GL R&EC) provides recommendations to the ESD based on knowledge of the radiologicalimpact of the event.
The licensee exhibited excellent performance in the EACC. Activation was timely, and adequate staff responded to the event. In fact, more respondors than are listed in the emergency plan were present. There were two GL-R&ECs and two Environmental Asst ssment Coordinators (EACs) at the EACC during the exercise while the emergency plan and staffing roster both specify only one person for these positions. The inspectors noted that, although it would be reasonable for the licensee to have additional responders for an actual event, the presence of additional responders beyond the minimum specified in the emergency plan made the task of evaluating the adequacy of the emergency plan more difficult. The presence of the additional responders also impacted performance in this area since the two sets of EACC supervision (GL-R&EC and EAC) tended to overload the single Meteorological / Dose Assessment Coordinator (MDAC) who was in charge of
developing dose projections and coordinating the offsite radiological monitoring teams.
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' The EACC members demonstrated the ability to perform the projected dose l
l calculations for given conditions and constraints. Thay also demonstrated their
ability to evaluate the projected doses. They reviewed the projected dose input
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- data carefully. They communicated effectively with each other, and the GL R&EC provided usefulinput to the ESD for the evaluation of radiological consequences and the formulation of protective action recommendations.
Joint Information Center (Ji_QJ The JIC is co located in the same building as the EOF. The inspectors were able to observe operations in this f acility to a limited extent. They observed one press i
briefing and the licensee's preparations for this briefing. The briefing was well-r i
coordinated with the offsite agencies also present at the JIC and valuable, accurate Information concerning the scenario was presented. Overall, performance in the
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JIC, as observed, was very good.
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Licensee Exercise Critlaue
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I The inspectors observed three stages of the licensee's critique process; the facility-specific critiques conducted immediately following the exercise completion, a
portion of the exercise controller debrief conducted on October 22,1997, and the formal presentation of licensee findings conducted on October 24,1007. All of
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these sessions were very thorough and self critical. The formal critique held on October 24 addressed each of the onsite exercise objectives and whether they were met. The licensee identified most of the same findings that were identified by the NRC inspection team, c.
Overall Exercise Conclusions The inspectors concluded that the licensee had an adequate onsite emergency plan
and had successfully implemented it. The licensee's overall response to the
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scenario events was good, and the previously mentioned deficiencies were not i
significant enough to preclude a satisf actory assessment. However, the inspectors
were concerned about some issues arising out of the licensee's performance.
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The Emergency Control Center crew's decision to shut the MSIV's with an existing ATWS condition was one of the inspector's concerns. This issue was of particular concern because the ED located in the TSC concurred in this decision after being
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consulted on it. This represents a training deficiency at severallevels of the emergency response organization. The inspectors considered this deficiency to be
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an item requiring follow up on during a future inspection (IFl 50 219/97 08 01).
.The inspectors considered the licensee's failure to notify the state authorities within 15 minutes of the Site Area Emergency declaration to be a weakness in an important standard of onsite radiological emergency response. The inspectors were
. particularly concerned about this late notifhation, even though it was made only four minutes late, because it might not have been me:de at all except for a happenstance discussion between the licensee and the state authorities of an j
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unrelated topic. The inspectors considered the licensee's f ailure to provide a timely notification of an emergency condition to represmt an exercise weakness needing corrective action anu aill follow-up on the corret teve action in a future inspection.
(IFl 50 219/97 0E 02)
The inspectors considered the licensee's critique process to be very thorough and to have generally identified and characterized the major performance issues. Tho inspectors noted that the formal critique addressed each of the onsite exercise objectives. The licensee's self evaluation of its performance identified most of the NRC-identified findings including the missed notification and the procedural comoliance issue associated with MSIV closure.
P8 Miscellaneous EP lssues P8.1 Scenerlo Review a.
inspection Scone (82302)
The inspectorr reviewed the licensee's onsite exercise objectives and scenario information during the weeks prior to the exercise.
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Observations and Findinns The licenseu had scheduled this exercise to be an off hours exercise, in which the participsnts would respond from their residences. The licensee had discussed and agreed with NRC Region I to test the off hours response aspect of the exercise as an independent, out-of-saquence activity. The licensee committed to coriduct the out of-sequence response as an unannouncei callout of the onsite emergency response organization some time after the exercise, c.
Conclusions The NRC considered the licensee's desire to conduct the unannounced, after-hours callout to be an acceptable alternative to demonstrating this during the exercise.
The f act that the actual exercise was not being conducted as an unannounced activity made the licensee's alternative proposal (an unannounced callout of responders from their residences) a more valid demonstration of offsite response.
P8.2 Exercise Control a.
Scone (82301)
The inspectors observed and evaluated the licensee's control of the exercise conduct, including the successful execution of scenario events, the safeguarding of the scenario events fror 'Jisclosure to the players, the effectiveness of the licensee's use of evaluators and controllers, and the interaction between the controllers and the exercise participants.
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Conclusions The inspectors considered the licensee's control of the scenario and the exercise conduct to be good. The flow of scenario events and the controllers' knowledge of their duties during the exercise indicated that the scenario had been carefully researched and the controllers adequately briefed on their expected duties. There was no evidence to indicate to the inspectors that the scenario events had been revealed to the players either before or during the exercise.
P8.3 Effectiveness of Licensee Corrective Actions on Previously Identified items a,
' CLOSED) Insoector Follow uo item (IFI) 50 219/96-03-05 (92904)
During the last EP program inspection (NRC Inspection Report No. 50 219/96-03),
the inspectors opened an inspector follow-up item relating to the licensee's description of the training requirements for the supplemental positions in the emergency response organization. The inspectors noted that the definitions of essential and supplemental positions in the emergency response organization was not consistent between the emergency plan, the EP training program procedure and the Emergency Plan implementing Procedure (EPIP) for the EP program administration. They also noted a discrepancy between revisions of the EP training program procedure regerding training requirements for certain ERO positions.
During that inspection the licensee's EP manager stated that he would review the training requirements and correct the discrepancy between the procedure revisions and ensure a consistent wording of the description of the various positions in the ERO.
i The inspectors for the inspection associated with this report discussed the corrective actions taken for this item with licensee representatives on October 22, 1997. The inspectore noted that the definitions of essential and supplemental positions were consistent between the two procedures in question, but that the definitions were not included in the emergency plan. Licensee EP staf f stated that they did not intend to describe the supplemental positions in the emergency plan but that they had resolved the conflict between the training program procedure and the EPIP. They had also resolved the discrepancy between successive revisions of the training program procedure, agreeing that the latest revision, which was more conservative in its training requirements, was the revision to which they would train and qualify their responders.
The inspectors verified that the intended actions of the EP manager as stated in IR 96-03 had been completed and that the discrepancies had been resolved. This inspector follow-up item was closed, i
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V. MANAGEMENT MEETINGS X1 Exit Meeting Summary The inspectors held an exit meeting with licensee management on October 24,1997 in the Oyster Creek Administrative Building second floor board room. They presented the findings as documented in this report. The licensee management acknowledged these findings.
PARTIAL LIST OF PERSONS CONTACTED Licensen F.
Applegate, NSA Assessor G.
Broughton, President, GPUN W. Cooper, Manager, Radiological Engineering and Industrial Safety 8.
DeMerchant, Licensing Engineer P.
Hays, Emergency Preparedness Manager E.
Johnson, Systems Engineer S.
Levin, Director, Operations and Maintenance M. Roche, Director, Oyster Creek M. Slobodien, Director, Radiological Health and Safety D.
VanNortwick, Emergency Planner LIST OF INSPECTION PROCEDURES USED IP 82301: Evaluation of Exercises for Power Reactors IP 82302: Review of Exercise Objectives and Scenarios for Power Reactors IP 82701: Operational Status of the Emergency Preparedness Program IP 92904: Followup - Plant Support LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Onened 50 219/97 08 01 IFl Training deficiency related to failure to follow procedural requirements during EP exercise 60-219/97 08-02 IFl Exercise weakness due to failure to notify offsite authorities within 15 minutes of a declared emergency condition G9fdd 50-219/96-03-05 IFl Licensee to resolve training requirements for essential and supplemental personnel.
Discussed None
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LIST OF ACRONYMS USED
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ATWS Anticipated Transient Without a Scram l
CFR Code of Federal Regulations EAC Environmental Assessment Coordinator
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EACC Environmental Assessment Command Center l
ECC Emergency Control Center ED.
Emergency Director-EOF Emergency Operations Facility EOP Emergency Operating Procedure -
- EPIP Emergency Plan implementing Procedure ERO Emergency Response Organization ESD.
Emergency Support Director:
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GL R&EC Group Leader, Radiological and Environmental Controls
GPUN.
- General Public Utilities Nucleer IFl Inspector Follow up item l
JIC Joint Information Center MDAC Meteorological / Dose Assessment Coordinator mR milliR6ntgen mR/hr milliR6ntgen per hour MSIV
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l OSC Operations Support Center RAC Radiological Assessment Coordinator SAE Site Area Emergency
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SRD Self Reading Dosimeter TSC Technical Support Center -
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i ATTACHMENT 1
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' Nuclear Corporate Emergency Plan and implementing Procedures Reviewed -
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DOCUMENT DOCUMENT TITLE REVISION NO.
6630 ADM-Oyster Creek Emer0ency Dose Calculation Manual
4010.03 EPIP OC.02 Direction of Emergency Response / Emergency Control Center
(ECC)
EPIP OC.26 The Technical Support Center
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EPIP OC.25 Emergency Operations Facility
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EPlP OC. 33 Core Damage Estimation
EPIP OC.27 The Operations Support Center
EPIP-OC.03 Emergency Notifications
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