IR 05000254/1982002
| ML20041F626 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 02/25/1982 |
| From: | Axelson W, Nicholson N, Paperiello C, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20041F619 | List: |
| References | |
| 50-254-82-02, 50-254-82-2, 50-265-82-02, 50-265-82-2, NUDOCS 8203170233 | |
| Download: ML20041F626 (45) | |
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
,
Reports No. 50-254/82-02(DEPOS); 50-265/82-02(DEPOS)
Docket Nos. 50-254; 50-265 Licenses No. DPR-29; DPR-30 Licensee: Commonwealth Edison Company Post Office Box 767 Chicago, IL 60690 Facility Name: Quad-Cities Nuclear Generating Station, Units 1 and 2 Inspection At: Quad-Cities Site, Cordova, IL Inspection Conducted: January 78-27 and February 8, 1982
- 4*
.2/a/m Inspectors:
. P. Phillips
,
4 (Team Leader)
/
'
.f ShW
/
. A. Nicholson f
i i
.f e. WA 2)13/7V
/
Approved By:
W. L. Axelson, Chief
'
/
/mergencyPreparednessSection V
Whf S
.k}
pe Chief
.
Emergency Preparedness and Program Support Branch Inspection Summary Emergency Preparedness Appraisal on January 18-27 and February 8, 1982 (Reports No. 50-254/82-02(DEPOS); 50-265/82-02(DEPOS))
Areas Inspected: Special announced appraisal of the state of onsite emergency preparedness at the Quad-Cities Nuclear Generating Station involved seven general areas: Administration of the Emergency Prepared-ness Program; Emergency Organization; Training; Emergency Facilities and Equipment; Procedures which implement the Emergency Plan; Coordination with Offsite Agencies; and Exercises, Drills, and Walk-throughs. The inspection involved 298 inspector-hours onsite by three NRC inspectors and two consultants.
Results: No items of noncompliance or deviations were identified; however, several significant findings were identified in the areas of Emergency Facilities and Equipment (Section 4), Procedures (Section 5), and Exercises, Drills, and Walk-throughs (Section 7.2).
r203170233 820301 PDR ADOCK 05000254 C
.
.
CONTENTS 1.0 ADMINISTRATION OF EMERGENCY PLAN......................................
2.0 EMERGENCY ORGANIZATION................................................
2.1 Onsite Emergency Organization....................................
2.2 Augmentation of the Emergency Organizations......................
2.2.1 Offsite Emergency Organization.............................
2.2.2 Onsite Emergency Organization..............................
3.0 TRAINING / RETRAINING...................................................
3.1 Program Establishment............................................
3.2 Program Implementation...........................................
4.0 EMERGENCY FACILITIES AND EQUIPMENT....................................
4.1 Emergency Facilities.............................................
4.1.1 Assessment Facilities......................................
4.1.1.1 Control Room......................................
4.1.1.2 Technical Support Center (TSC)....................
4.1.1.3 Operational Support Center (0SC)..................
4.1.1.4 Emergency Operations Facility (E0F)...............
4.1.1.5 Post-accident Primary Coolant Sampling............
4.1.1.6 Post-accident Containment Air Sampling............
4.1.1.7 Post-accident Gas, Particulate, and Radiolodine Effluent Sampling...................
4.1.1.8 Post-accident Liquid Effluent Sampling............
4.1.1.9 Onsite Laboratories...............................
4.1.1.10 Offsite Laboratories..............................
4.1.2 Protective Facilities......................................
4.1.2.1 Assembly / Reassembly Areas.........................
4.1.2.2 Medical Treatment Facilities......................
4.1.2.3 Decontamination Facilities........................
4.1.3 Expanded Support Facilities................................
4.1.4 News Center................................................
4.2 Emergency Equipment..............................................
4.2.1 Assessment.................................................
4.2.1.1 Emergency Kits and Survey Instrumentation...........
4.2.1.2 Area and Process Radiation Monitors.................
4.2.1.3 Non-radiation Process Monitors......................
4.2.1.4 Meteorological Instrumentation......................
i
.
.
4.2.2 Protective Equipment.......................................
4.2.2.1 Respiratory Protection..............................
4.2.2.2 Protective Clothing.................................
4.2.3 Emergency Communications Equipment.........................
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies...................................
4.2.5 Reserve Emergency Supplies and Equipment...................
4.2.6 Transportation.............................................
5. 0 EMERGENCY PLAN IMPLEMENTING PROCEDURES.................................
4 5.1 General Content and Format.......................................
5.2 Emergency Alarm and Abnormal Occurrence Procedures...............
5.3 Implementing Instructions........................................
5.4 Implementing Procedures..........................................
5.4.1 Notifications..............................................
5.4.2 Assessment Actions.........................................
5.4.2.1 Offsite and Onsite Radiological Surveys.............
5.4.2.2 Inplant Radiological Surveys........................
5.4.2.3 Post-accident Primary Coolant Sampling..............
5.4.2.4 Post-accident Containment Air Sampling..............
5.4. 2.5 Post-accident Stack Ef fluent Sampling...............
5.4.2.6 Post-accident Liquid Effluent Sampling..............
5.4.2.7 Analysis of Post-accident Samples................... 24 5.4.2.8 Radiological Environmental Monitoring Program (REMP)....................................
5.4.3 Protective Actions.........................................
5.4.3.1 Radiation Protection During Emergencies.............
5.4.3.2 Evacuation of Owner Controlled Areas................
5.4.3.3 Personnel Accountability............................
5.4.3.4 Personnel Monitoring and Decontamination............
5.4.3.5 Onsite First Aid and Rescue.........................
5.4.4 Security During Emergencies................................
5.4.5 Repair and Corrective Actions................
.............
5.4.6 Recovery...................................................
5.4.7 Public Information.........................................
5.4.8 Fire Protection............................................
5.5 Supplemental Procedures..........................................
5.5.1 Inventory, Operational Check, and Calibration of Emergency Equipment, Facilities, and Supplies............
5.5.2 Drills and Exercises.......................................
5.5.3 Review, Revisions, and Distribution of Emergency Plan and Procedures......................................
11
..
.
..
=
.
.
6.0 COORDINATION WITH OFFSITE GR0UPS......................................
6.1 Offsite Agencies......................................
..........
6.2 General Public and Transient Populations.........................
6.2.1 Information Distribution...................................
,
6.2.2 Prompt Notification of the Public..........................
1 6.3 News Media.......................................................
6.4 NSSS Vendor......................................................
7.0 DRILLS, EXERCISES, and WALK-THROUGHS..................................
7.1 Drills and Exercises...........................
.................
7.2 Walk-throughs of Emergency Response Personne1....................
.
8.0 LICENSEE ACTIONS ON PREVIOUSLY IDENTIFIED ITEMS RELATED TO EMERGENCY PREPAREDNESS..............................................
9.0 PERSONS CONTACTED.....................................................
10.0 E'?.IT INTERVIEW........................................................
ANNEX A - FIGURES 2.1 GSEP Station Group Organization 2.2 Limited Response Offsite GSEP Organization 2.3 Full Response Offsite GSEP Organization 5.4 Simplified Emergency Notification Scheme f
%
I ill
..
.-.
..
...
.
-
.
.
-
_-
_
..
-
.
,
l
J
i
DETAIIS
,
1.0 ADMINISTRATION OF EMERGENCY PLAN
!
Responsibilities from the Corporate level for emergency planning begin with the Division Vice President, Nuclear Stations. The Supervisor of
Health Physics and Emergency Planning serves as the Cerporate-Emergency Planning Coordinator (EPC) and reports to the Division Vice President,
Nuclear Stations through the Technical Services Manager. The EPC has a
staff of Health Physicists, Emergency Planners, and Meteorologists to assist him in implementing his responsibilities.
At the Quad-Cities Station, the Administrative and Support Services
'
Assistant Superintendent has the responsibility to coordinate station compliance with the requirements of GSEP and provide a training program j
to ensure knowledgeable performance by assigned personnel. Normal day to day coordination of station GSEP functions has been delegated to the CSEP Coordinator, who is appointed by Station management.
Personnel assigned an emergency function are given euthority.to perform
'
assigned duties by specific tables in the GSEP. The Shift Engineer serves
as the Acting Station Director in the event of an emergency. For CECO, the Station Director. is 'n charge of the overall onsite emergency response and reports to the Corporate Command Center Director or Recovery Manager
(depending on the accident classification) during an emergency. The Shift
Foreman becomes the Acting Station Director if the Shift Engineer becomes
!
- unavailable. The Recovery Manager.is the designated individual from CECO
who has requisite authority and knowledge to manage the overall. recovery operations.
,-
'
Coordination of the onsite and offsite organizations and the corporate.
emergency organization is the responsibility of the Administrative and Support Services Assistant Superintendent. Coordination of planning l
between the licensee and offsite groups is the responsibility of the EPC.
,
Selection criteria for personnel responsible for assigned emergency plan functions are based on the individual's normal responsibilities in the same
-
!
organization and follow ANSI N18.1.
The EPC is appointed by the Division
!
Vice President, Nuclear Stations, and is qualified to perform the emergency
planning function. Training of emergency planners is performed as a matter
of practice. Actual training received is subject to the availability of l
appropriate courses and the availability of individuals to be scheduled for
!
those courses.
The corporate and site administration relies on the Quality' Assurance
.
'
organization to audit the emergency preparedness program which includes the plan and implementing procedures. They ensure performance in the areas of training and training records, exercises and drills, and docu-
,
mentation and implementation of corrections to deficiencies reviewed and considered valid.
,
i
.
-
.
.
. _... - -., _,,
_. _
_-_ -
_
.
e
,
.
The corporate manager of QA was interviewed during'the LaSalle emergency preparedness appraisal.1 The site manager of QA was interviewed concerning the station QA program. This program included a review of training and training records, implementation of the GSEP, distribution of GSEP and QEP changes, calibration of instrumentation used during emergencies, and offsite interfaces. QA records indicated that audits of the GSEP program had been conducted during May and December 1981. Deficiencies identified are tracked by the QA department to assure correction.
<
The QA inspector prepares an inspection procedure based on his review of the plan and procedures. In a letter from Mr. G. Abre11 dated December 30, 1981, each station was provided with a GSEP audit matrix which covers all areas required by 10 CFR 50.54(t). This matrix is then used by the
'
inspector to prepare his inspection procedure. This matrix covers' the minimum areas that are required to be audited and guarantees that all of
,
the required GSEP sections are audited at least once during each year.
'
s The Quality Assurance program provides a complete audit to en'sure.that corrective actions are implemented and required recourse actions be taken
-
by the manager of QA for items not resolved by the required response'date.
The licensee clearly understood the requirements of 10 CFR 50.54(t) and outlined how the requirements for independent audits would be met.
Station QA personnel are independent from the station management and report to QA-
,
management in Chicago.
>-
<
,
Based on the above findings, this portion of the licensee's program is J-
acceptable.
-
,
,-
2.0 EMERGENCY ORGANIZATION f
/
.
2.1 Onsite Emergency Organization
'
l
'
,
'
/. ;
'
The inspectors verified that an effective emergency organization.was in
' ' ~
place by a review of the emergency organization and respensibility assign '
_
ments described in the GSEP and QEPs. The structure of the onsite emer-gency organization is provided on the attached Organization Chart,Hshown as Figure 2.1.
The organizational implementation ensures that an Acting
-
Station Director is onsite in the Control Room at all times. Each Station'
Group Director's position includes at least three qualified individuals to,
_
act as that Director to ensure an adequate line of succession for all posi-~
,,
tions. There is no formal documented selection criteria established; how-s ever, this selection is usually based on the normal working duties of these individuals and the standards developed by the Institute for Nuclear Power
>
Operation (INPO),
i.e., Rad / Chem Supervisor becomes Rad / Chem Director, Master Mechanic becomes Maintenance Director, etc.
All of the senior Station Group Directors along with one alternate were interviewed and found to be aware of their emergency responsibilities and authority. Each had a working knowledge of the emergency plan and the implementation of the sections for which they are responsible.
- IE Inspection Reports No. 50-373/81-14; 50-374/81-09.
.. -
.__
-
.
-.
- _. - -.... - -
_ - - -
-
_
f
..
.
.
Based on the above findings, this portion of the licensee's program is acceptable.
2.2 Augmentation of the Emergency Organizations j-l 2.2.1 Offsite Emergency Organization
!
l The augmentation of the offsite emergency organization is made by contacting
the Corporate Command Center Director (CCC Director). Either he or the designated CCC Duty Officer activates the corporate personnel shown in
'
Figure 2.2 for the less serious emergencies such as an Alert. When a Site Area or General Emergency is declared, the full offsits recovery organization
is dispatched ta the nearsite Emergency Operations Facility (EOF) to support
<
the onsite emergency organization. This expanded augmentation is shown in
'
'
Figure 2.3, which delines.tes the management structure for the various func-tional areas. An adequate line of succession exists for each offsite Director or Manager position..Although there is no documented selection criteria
!
,
establishe'd, the Division Vice President, Nuclear Stations selects all
individuals needed to fill the various offsite GSEP positions using the standards developed by INPO.
Supporting contractors and vendors are specified in the plan, and written
. agreements are in effect. Main, responsibilities for offsite Directors and
"
'
Managers include: public information; overall management of the emergency,
-including' repair and corrective actions; offsite radiological assessment; l
radwaste operations';Juanpower planning; and logistical support.
,
?
.
,
- The/ licensee has not' procedurally specified how the EOF will achieve full functional operation within one hour as specified in Section 4.3 of a
NUREG-0696. The licensee ha's sufficient' personnel available to accomplish this,.but has not addressed this in their notification procedures.
In a memo from theiDivision Vice President,-Nuclear Stations to the Director of Nuclear Licensing, the licensee stated that a prioritized' phone notification y
procedure would be prepared to address this issue; however, this procedure has not been prepared. This is discussed further in Section 5.4.1 of this report.
,
-
,
,
,
!
Based on the above f'indings, this portion of the licensee's program is
~
'
-
acceptable.
'
,
'
/
,
2.2.2 ansite Emergency Organization
,
,
-
The Acting Station Director (usually the Shift Engineer) initially augments the onsite emergency organization by contacting the Shift Foreman who will notify the Operations Director and Station Director. The full augmentation schem,e is presented in QE? 310-T1, and is further discussed in Section 5.4.1 of this report. The licensee has never conducted a drill or test of this not'ification scheme to see if the 30 and 60 minute personnel augmentation goals of Table B-1 in NUREG-0654, Revision 1, can be met.
Further, the I
licen'see has not established any specific procedure which ensures a prior-itized augmentation.
i
~
,
,.
,
?
. i
,
w e
w
,
+
r w
i-esue-g
--w4
- i-
+,-me-t=<wy-'
-.t--e+r y
rw--
+-------er
---s y
r-'s---
~m r-~No
e~4T
-- < - - - -va
____
.
.
..
-
>
.
Based on the above findings, this. portion of the licensee's program is acceptable (procedural inadequacies are discussed in Section 5.4.1); however, the following matter should be considered for improvement:
The licensee should conduct unannounced offshift augmentation drills
.
to ensure that the goals of Table B-1 of NUREG-0654, Revision 1, can be met.
These drills should be documenced, conducted on a semi-annual i
basis, and identified deficiencies corrected.
3.0 TRAINING / RETRAINING 3.1 Program Establishment The inspectors discussed the training program with a training supervisor.
A training program for initial orientation and annual retraining of onsite employees is in place. Both the initial and the annual training contains general information on emergency response. This information describes the emergency plan, responsibilities of non-essential personnel, and location of the assembly areas.
Records of attendance are maintained and were reviewed by the inspectors.
Those individuals having particular emergency response roles are annually provided specific training which covers the functional areas of the indi-vidual in the emergency organization. This annual training is conducted from an outline prepared by the Station Training Department.
Pertinent QEP's are the basis of instruction in the functional areas of response.
The licensee's training records system is used to ensure that annual retraining is conducted.
Annual training is offered to offsite support personnel (law enforcement, fire department, ambulance personnel, hospital personnel, pertinent counties and State organizations). Since many of the offsite support agencies are manned by volunteers and individuals who work shifts, many members of such organizations are unable te participate in this annual training which is in addition to the annual exercise.
Hospital and ambulance personnel are trained by Radiation Management Corporation (RMC) personnel. Representatives of offsite support groups who have participated in training offered by the licensee indicated it to be satisfactory. News media personnel are trained by the corporate public information staff in conjunction with the annual exercise.
According to site training personnel, instructors are selected and trained by corporate training personnel and have in the past attended short courses (3-4 days) in instructional techniques offered by major educational institu-tions.
Based on the above rindings, this portion of the licensee's program is acceptable.
- _ - -_--_______ -_____-__ - _
.
.
3.2 Program Implementation The inspectors conducted several walk-throughs with Quad-Cities employees (e.g., Shift Engineers, Shift Foremen, Rad / Chem Technicians, Station Group Directors, and security personnel). With the exception of the Acting Station Directors and newly assigned Station Group Directors, all emergency response personnel demonstrated that the training program was adequate.
These employees either knew the proper response to a given scenario or were able to immediately find the proper procedure.
Newly assigned Rad / Chem and Environs Directors with the responsibility for environmental monitoring and offsite dose assessment expressed concern regarding the lack of training received.
Some of these directors were unable to access the offsite dose projections programs on the computer, but had to contact the corporate office. The training given to these individuals who were assigned emergency response roles since the last formal GSEP retraining was discussed with the training department. This training is informal and unstructured without a formal evaluation (test)
to ensure such individuals can perform their assigned emergency response roles. The licensee stated that those personnel who have been recently assigned Station Group Director positions will be trained immediately.
Walk-throughs with Acting Station Directors demonstrated a lack of training in their emergency response functions. For example, when given a scenario, several of the Acting Station Directors attempted to classify the event using the generic portion of the GSEP rather than the appropriate imple-menting procedure. Their appeared to be no formal evaluation criteria to determine if Acting Station Directors had an adequate understanding of duties and responsibilities during an emergency. This is discussed further in Sections 5.3 and 7.2 of this report.
Based on the above findings, this portion of the licensee's program is acceptable.
Specific deficiencies described above are discussed in Sections 5.3 and 7.2.
4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room A review was made of the Control Room to determine its adequacy in meeting the criteria of NUREG-0696 and ANSI /ANS-3.7.2.
The following documents were also reviewed: GSEP Section 7.1.1; Quad-Cities Annex Section 7.1.1; QEP 410-1, Control Room; QAP 1300-2, Standing Orders 30, 31, and 32; QAP 1900-3, Control Room Access; and Q0A 5750-13, Toxic Air or Smoke in the Control Room. Current copies of the emergency plan and implementing proce-dures were available in the Control Room. Emergency equipment and decisional aids specified in the emergency plan and implementing procedures were readily i
i n -
. - -
.
.
available. C.amon monitor readouts were provided for both Units 1 and 2.
Communications with the TSC, OSC, EOF, Corporate Command Center, and the NRC were provided in the Control Room with back-up capabilities. Communications systems were tested and found to be fully operational. Emergency equipment in the Control Room, including respiratory protection, fire extinguishers, radios, and access keys, were readily available.
Based on the above findings, this portion cf the licansee's program is acceptable.
4.1.1.2 Technical Support Center (TSC)
The inspectors examined the TSC and associated equipment, plans, and procedures to determine its adequacy in meeting the criteria of NUREG-0696.
The TSC is near'y completed with the Safety Parameter Display System (SPDS),
plant operating records, and some as-built drawings and emergency supplies yet to be installed or added. The following documents were also reviewed:
GSEP Section 7.1.2; Quad-Cities Annex Section 7.1.2; and QEP 420-1, Onsite Technical Support Center.
The TSC is located about 100 feet south of the Service Building which houses the Control Room. The distance between the TSC and the Control Room can be easily and safely traversed in less than two minutes. The size of the TSC is more than adequate for 25 people. Data display terminals, records and communication equipment are readily accessible, except that some as-built drawings and plant operating records, which are stored on tape cartridges, are not yet available.
The TSC has basically the same shielding capability as the Control Room.
A study by Sargent and Lundy (Project 5954-00) found that post-accident radiation levels would not exceed 2.2 mrad / hour in the Control Room, TSC or the OSC. The ventilation system for the TSC and the OSC includes HEPA and charcoal filters which receive regular preventive maintenance and annual testing.
The TSC communications system includes dedicated telephones and backup radios to the Control Room, OSC, EOF, and the NRC. Other phones and radios provide communications with the HP network, State and local agencies, other emergency control centers, and field monitoring locations. A total of five outside phone lines, three NRC lines, and 22 extensions are provided in the TSC.
The TSC contains current copies of the emergency plan and implementing procedures, plant operating procedures, as-built drawings, technical specifications, FSAR, and equipment operating manuals. However, only the electrical and mechanical as-built drawings were available at the time of the inspection.
Based on these findings, the TSC is considered acceptable for interim use; however, the permanent TSC is an Open Item pending installation of the Safety Parameter Display System (SPDS).
.
.. --
--
.-
.-.
.
._ -
l
.
.
.
,
4.1.1.3 Operational Support Center (OSC)
The inspectors examined the OSC to determine its adequacy in meeting the criteria of NUREG-0696. The OSC is adjacent to the TSC and part of the same building.
It is served by the same shielding, ventilation, and radi-ation monitors as the TSC. The OSC is located as stated in the emergency plan and implementing procedures. The OSC is large enough to accommodate 50 people or more in a standby capacity.
Primary and backup communications are provided between the OSC, the Control Room, and the TSC.
The TSC and OSC building appears to be very well designed and built.
Locating l
the OSC adjacent to the TSC seems to be an advantageous design feature.
Based on the above findings, this portion of the licensee's program is acceptable.
,
4.1.1.4 Emergency Operations Facility (EOF)
.l
.
The Emergency Operations Facility is an interim use facility located in the station's Information Center.
It is located as specified in the station emergency plan, and appears to have sufficient working space for assigned
,
personnel and media representatives. The installed communications equipment appears to be adequate.
The licensee recently reviewed QEP 550-T4 dated December 1981, which
' identifies inventories of materials and equipment to be maintained in the EOF. However, the licensee has not yet stocked these items. The inspectors reviewed the materials and equipment listed in the inventory and found them to be acceptable.
A tour of the EOF indicated that several essential records, which would be useful in the event of activation of the EOF, were not located in the EOF.
The Final Safety Analysis Report (FSAR) and as-built Piping and Instrument Diagrams (P& ids) were not available.
,
The licensee has initiated construction of a permanent Emergency Operations Facility near Morrison, Illinois. The completion date for the permanent EOF is currently estimated to be late in 1982. Completion of this EOF is an Open Item.
The following action is required to achieve an acceptable program:
The licensee must ensure that the interim EOF contains a copy of the
.
pertinent portions of the FSAR and as-built P& ids.
4.1.1.5 Post-accident Primary Coolant Sampling 4.1.1.6 Post-accident Containment Air Sampling
-
Interim post-accident sampling procedures were reviewed as described in Sections 5.4.2.3 and 5.4.2.4; however, walk-throughs of these interim procedures were not conducted.
'
- -.
.
-
-
-- _
- - --
.
. -.
.,.
.
The permanent online sampling system, designed to meet the NUREG-0737 specifications to complete sample collection and analysis in three hours, is cur.ently being installed. The licensee submitted a request on December 15, 1981, to NRR, Division of Licensing, for a 90 day extension of the NUREG-0737, January 1,1982, deadline. This request has not been denied.
A Sentry High Radiation Sampling System (HRSS) for each unit is being installed in a shielded concrete housing near each respective reactor building. The HRSS building for Unit I was examined. Each HRSS has the following primary capabilities:
(1) liquid sample collection from the reactor's recirculation loop, demineralizers, RHR heat exchangers, drywell and torus drains, and other primary points; (2) liquid sample collection from the radwaste system collection tanks; (3) containment gas sample col-1ection; (4) chemical concentration analysis; (5) continuous containment air monitoring; and (6) gas chromatography.
This system provides a 1000 to 1 sample dilution capability for liquid samples. The liquid sample vial is inserted into the collection chamber, which is shielded by a nine-inch thick leaded glass pane, via a lead cask.
A remote handling device is used for valve selection and manipulation on the instrument panel. Grab gas samples are collected in vials permanently positioned in a lead cask.
Both liquid and gas casks are fitted with wheels to transport samples to the counting laboratory.
Shielding for the two HRSS buildings appears adequate for habitability following an accident. All HRSS building drains collect in a holding tank below the sampling floor.
This system is scheduled to be operable by April 1, 1982.
Based on the above findings, post-accident primary coolant and containment atmosphere sampling capability is an Open Item.
4.1.1.7 Post-accident Gas, Particulate, and Radioiodine Effluent Sampling The licensee is installing a remote sampling system SPING (Special Partic-ulate, Iodine, and Noble Gas) which meets the requirements of NUREG-0578.
This system will be operational by April 1982; however, it will not meet all of the requirements of Task Item II.F.1 in NUREG-0737. The SPING system could be unaccessible for sample collection during the release of a Regula-tory Guide 1.3 source term.
Because of this, the licensee plans to install a Victoreen system which will initiate when the SPING switches to its highest range. The licensee submitted a request to delay compliance with NUREG-0737 for this task item on November 20, 1981. This request has not been denied.
The Victoreen system will be installed during the fourth quarter of 1982.
These systems will provide for the collection of grab samples from the main chimney and the reactor building vent. Results of in-line monitoring of these effluents through the SPING system will be provided to a terminal in the Control Room. Under limited accident conditions, individual grab samples can be collected for isotopic analysis. A backup marine battery can provide a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> power supply if necessary.
.
.
Based on the above findings, this portion of the licensee's program is an Open Item.
4.1.1.8 Post-accident Liquid Effluent Sampling The inspector examined the liquid effluent sampling point located in an enclosed tank farm area west of the turbine building. All post-accident liquid releases would be made on a batch basis from the river discharge tank which can be sampled for radioactivity.
When full, the licensee can switch to backup tanks. Routine sampling and analytical procedures (QRP 300-4), as described in Section 5.4.2.6, would be followed. Remote sample handling tools and portable shielding are available if necessary.
This sampling point would be accessible during post-accident conditions.
Based on the above findings, this portion of the licensee's program is acceptable.
4.1.1.9 Onsite Laboratory and Post-accident Sample Analysis TWo onsite counting laboratories are potentially available for post-accident sample analysis. The routine operations counting laboratory, shielded by concrete walls and fitted with a closed venti 11ation system, is located on the second floor of the Service Building and would be used until background levels interfered with analysis or the room became uninhabitable. A backup laboratory at the eastern end of the TSC would be used at that time.
Service Building counting laboratory equipment includes:
(1) three func-tional lithium drif ted germanium Ge(Li) detectors and one additional standby Ge(Li), coupled to two multi-channel analyzer (MCA) systems; (2) three low level alpha / beta gas proportional detectors; and (3) a liquid scintillation counter. Backup computer disks for the MCA system are available in the chemists' office and CECO corporate headquarters. As yet, this MCA system is not calibrated for HRSS geometries. Chemical analyses and appropriate dilutions can be conducted in the adjacent hot laboratory where samples can be stored in lead caves after analysis.
The PARAPS (Post-Accident Radionuclide Analysis Portable System) is located in the TSC backup counting laboratory.
Samples are transferred there in a lead cask if the primary counting laboratory is not functional or is unin-habitable. This system consists of a shielded intrinsic germanium detector coupled to an MCA identical to those in the Service Building counting labor-atory. The detector shield limits the mobility of this system.
PARAPS is not yet functional as HRSS calibration geometries are not complete. Currently, no backup computer disk (s) exists for the PARAPS.
Solid cinderblock walls provide shielding for the TSC counting laboratory which is fitted with a closed ventilation syster. The room's compactness may require an operator to vacate during analysis of a high activity sample when counted outside the detector shield. Based on the above considerations, the TSC counting lab appears to be accessible during post-accident conditions.
1
_ - - -
a
'
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matters should be considered for improve-ment:
HRSS counting geometries for the Service Building laboratory MCA
.
analyzer system should be developed.
Backup computer disk (s) for the PARAPS whould be provided.
.
4.1.1.10 Of fsite Laboratories The licensee's procedure ED-21 addresses offsite laboratories. Appendix I of this procedure lists the capabilities, equipment, and analyses that can be performed by each of the offsite laboratories operated by Eberline.
In addition, the licensee's normal Radiological Environmental Monitoring Program (REMP) contractor, Hazelton Environmental Science, also has sufficient capa-bility to satisfy the emergency requirement for offsite laboratory services.
For relatively hot samples as well as low level samples, the licensee has available counting labs at their Zion, LaSalle, and Dresden Nuclear Stations.
The licensee plans to install counting facilities capable of analyzing environmental samples at the permanent EOF, which should be completed prior to October 1982.
Based on the above findings, this portion of the licensee's program is acceptable.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The inspectors examined the assembly areas which are located in the Unit 1 and 2 trackways of the turbine building, the machine shop, service building lunchroom, TSC, and OSC. With the exception of the machine shop, all areas were equipped with emergency lighting. The machine shop is located next to the stores warehouse, which is equipped with adequate portable lighting.
Offsite relocation centers are located at Albany Park and Rivardale High School.
If site evacuation is required, the Rad / Chem Director is respon-sible for ensuring that personnel monitoring is conducted at the offsite relocation cente.rs.
None of the station assembly areas are equipped with protective clothing, although respiratory protection equipment and some area radiation monitoring equipment is available.
Protective clothing is stored in the station ware-house and at the radiation protection control point near the Unit 1 trackway.
This clothing should also be available at the other assembly areas in case radiological conditions in the plant require its use.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improve-ment:
.
'
A supply of protective clothing in each of the assembly areas should
.
be provided.
4.1.2.2 Medical Treatment Facilities 4.1.2.3 Decontamination Facilities The inspectors examined the personnel decontamination area (same as the medical treatment facility) to determine its adequacy in meeting the criteria of NUREG-0654, Revision 1.
The decontamination facility did have adequate decontamination supplies and equipment, operable and calibrated radiation survey instruments, a sink, shower, first aid supplies, and some respiratory protection equipment. The room also contains a telephone. Provisions for disposal of solid and liquid radioactive waste were in place. Replacement clothing was readily available from the storeroom. A copy of the appropriate station QEPs were not located in this room; however, a copy of the RMC Plant and Hospital Procedure Manual for first aid and decontamination was present.
The personnel decontamination area also serves as the first aid treatment room.
It is located on the ground floor of the Service Building adjacent to the employee locker room, and is easily accessible from the Unit 1 trackway. The first aid / decontamination room was ivand to be relatively small, crowded, cluttered, and unsanitary.
It is regularly used during shift changes for routine decontamination; six to ten people were observed using this small area during the inspection. The room is also used to store out-of-service radiation survey instruments, contaminated laundry, radiation protection supplies, respiratory protection equipment, a clothes washer, and some lead shielding. Although there is merit in the combina-tion of first aid and decontamination functions in a single area, the space provided is less than adequate and this problem is compounded by the storage of extraneous equipment and supplies. Under these conditions, it is unlikely that even one victim on a stretcher could be properly treated and/or decontaminated in this facility.
Based on the above findings, the following action must be taken to achieve an acceptable program:
The first aid / decontamination facility must be remodeled such that
.
all equipment and supplies not needed for first aid or decontamination are removed and stored elsewhere; adequate space for the administration of first aid (such as a horizontal working surface) is provided; and the room maintained in a sanitary condition.
4.1.3 Expanded Support Facilities The inspectors examined Expanded Support Facilities. The licensee will augment emergency resource personnel from Zion, LaSalle, and Dresden Nuclear Stations.
Space is available for contractor (i.e., General Electric and Sargent & Lundy) personnel in the interim EOF, and for the GE onsite representative in the permanent TSC.
Space for five NRC personnel is also provided in the interim EOF. Adequate communications (i.e., three separate outside telephone lines) are available to support these NRC personnel.
If
,
.
additional resources are needed; i.e.,
trailers, they can be provided through the Corporate Command Center's Manpower and Logistics Director. Additional communications equipment can be provided through the Communications Director.
Based on the above findings, this portion of the licensee's program is acceptable.
4.1.4 News Center The auditorium portion of the station Information Center (approximately 1600 square feet) has been designated as a temporary News Media Center in the event of an emergency. Telephone service has been provided; however, two phone jacks were found to be inoperative. Copying equipment and other supplies are brought to the News Center upon activation. The News Center contains an operative public address system and audio-visual equipment.
The permanent News Center will be located near the permanent EOF.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improve-ment:
Inoperative telephone jacks in the interim EOF for use by news media
.
personnel should be repaired.
4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Survey Instrumentation The inspectors examined the emergency kits and survey instrumentation maintained by Quad-Cities Station. The kits and instruments were located at the TSC, OSC, EOF, and the guardhouse in accordance with QEP 550-1.
Access to the kits is controlled by several keys which are readiif avail-able to the Radiation Protection staff.
Inventories maintained in the QEP's and in the kits were undergoing revision at the time of the inspection. The most recent inventories were not yet provided in the kits. Survey equipment found in the kits were operable and current _y calibrated. However, GM survey meters were removed from all the kits for calibration at the time of the inspection. With one exception, the instruments provided were appro-priate for emergency monitoring with proper measuring capabilities, ranges, and sensitivities. A capability for meast rement of radiciodine concentra-tions in the field is not presently avail tle.
Eberline SAM-2 instruments with this capability are being obtained. This is an Open Item. The number of survey instruments in each of the emergency kits is considered minimal, with no allowance for damaged, contaminated, or incperable instruments.
The instruments are properly maintained and calibrated, but calibration check sources were not yet included in the kits.
The emergency kits located in the TSC and the EOF were being stocked with supplies other than instruments at the time of the inspection, consequently they were incomplete. This is an Open Item.
-,
-.
O
.
The inspectors considered the inclusion in the kits of survey instrument operating characteristics, such as efficiencies and energy sensitivities, a very good practice.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matters should be considered for improve-ment:
The most recent inventory should be provided in each emergency kit.
.
Survey instruments assigned to emergency kits should be replaced with
.
-
others when calibrations are due to ensure a continuous state of preparedness.
Additional survey instruments should be provided in emergency kits to
.
allow for damaged, contaminated, or inoperable instruments.
Calibration check sources should be added to completely stock the
.
emergency kits.
Inclusion of Eberline SAM-2 instruments in the field team kits and stocking of the emergency kits in the TSC and EOF are Open Items.
4.2.1.2 Area and Process Radiation Monitors The area and process radiation monitoring program was reviewed to determine adequacy in meeting NUREG-0654 planning standards. The review included a tour of the Control Room monitor readouts, discussions with engineers, haalth physicists and the instrument foreman, and a review of calibration and maintenance procedures.
Area radiation monitor readouts were located in the Centrol Room in' accord-ance with procedures. Area monitors are GM tubes encased in an aluminum housing. This apparatus appears to be able to withstand high temperatures and humidity. Calibrations appear adequate and current. Conversion charts are posted in the readout area for effluent releaser, i.e.,
counts per minute to microcuries or microcuries per cubic centimeter.
TWo high range containment monitors are mounted in the drywell penetrations for each unit with a range of 1 R/hr to 10' R/hr. All area monitors are provided with emergency power.
The results of this review indicate adequate methods, instrumentation, and equipment for assessing and monitoring plant conditions are in place and properly maintained.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.1.3 Non-Radiation Process Monitors No monitors are currently installed to detect ammonia, chlorine, or sulfur dioxide concentrations in the Control Room atmosphere. During the fourth
O
.
quarter of 1981, a contractor study was completed to determine Control Room habitability based on chemical toxicant concentrations under accident condi-tions. The report and ensuing recommendations were forwarded to the Office of Nuclear Reactor Regulation (NRR), Division of Licensing for consideration.
According to licensee statements, a monitoring system will be installed in accordance with NUREG-0737, Item III.D.3.4 by January 1,1984.
4.2.1.4 Meteorological Instrumentation The bases for the review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97 and the criteria set forth in NUREG-0654, Revision 1; NUREG-0696; and NUREG-073).
The information reviewed was the GSEP and the Offsite Dose Calculational System (ODCS) dated July 1980. Observations of the meteorological monitoring tower and the licensee's remote access capability are also included in the review.
The current meteorological instrumentation and SYFA compute? system pro-vided the basic parameters (i.e., wind direction and speed and an estimator of atmospheric stability) necessary to perform the dose assessment function in the TSC.
However, the TSC only becomes operational upon being staffed by either the Rad / Chem or Environs Director. The only meteorological infor-mation available in the Control Room is a dial indication of wind speed and direction from'a 10-meter tower located near the switchyard. At the time of the appraisal the dials in the Control Room appeared to be operational.
All strip charts for recording the meteorological parameters measured on the tower are located in the instrument shack near the base of the primary tower, and the charts for recording wind speed did not appear to be providing accurate data. When queried, the SYFA computer in the TSC could not provide data due to software operations which were taking place at CECO's corporate office in Chicago.
Wind and vertical temperature difference (AT) measured at different elevations on the primary tower are to be used as a backup to the primary measurement elevations, and hindcast, nowcast, and forecast for the station from regional meteorological data supplied by the licensee's contractor will be used as a tertiary backup. This type of backup is acceptable on an interim basis as a compensating action.
The licensee's meteorological measurements tower meets the criteria of Regulatory Guide 1.23 regarding instrumentation, siting, and exposure of instruments. The licensee maintains a program for inspection and preventive maintenance. The instrumentation readouts in the Control Room are checked daily; servicing is done weekly; and calibrations are done bimonthly.
All sensors appeared to be operable but the apparent malfunc-tioning of the strip chart recorders would not allow a determination of the reasonableness of the data at the time of the inspection. The licensee has factored meteorological conditions into their dose assessment procedures.
The meteorological assessment capability is consistent with the characteris-tics of the Class A model in NUREG-0654, Revision 1.
_
_ _ _ _
_
_
.
.
The licensee is notified of severe weather conditions by the System Power Load Dispatcher, who has access to the NOAA wire services (facsimile and teletype) for providing this information.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improve-ment:
A real time recording of wind direction and speed-at two levels,
.
one for ground level and one for stack releases, and an indicator of atmospheric stability should be installed in the Control Room in accordance with the implementation schedule provided in Task Item III.A.2 of NUREG-0737.
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The inspector reviewed the respiratory protection program to determine its adequacy in meeting the criteria of Regulatory Guide 8.15, NUREG-0041, and NUREG-0654, Revision 1.
Adequate supplies of respirators and self-contained breathing (SCBA) devices are strategically located throughout the plant for both routine and emergency use.
Facilities and equipment are available onsite for decontamination of respirators and for refilling SCBA devices.
These facilities would be accessible during most emergency conditions.
Backup equipment and facilities would be available from other CECO nuclear plants if required.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.2.2 Protective Clothing A review was made of the availability of protective clothing that would be used in an emergency. There was both an adequate supply and a range of sizes of protective clothing that would be accessible during an emergency.
Additional supplies could be obtained either from ether CECO nuclear plants or from vendors.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.3 Communications The inspectors examined the Onsite/Offsite Emergency Communications System to determine if this system is as described in the Plan and meets the planning criteria of NUREG-0654, Revision 1.
A Health Physics Network (HPN) telephone line was not located in the TSC but is located in the Rad / Chem Supervisors office and in the NRC Resident Inspectors' office. All other equipment identified in the GSEP was avail-able and observed to be in place at the appointed locations. This system
l.
-.
.
.~
-.
._
.
o
.
provides a 24-hour per day capability to notify the NRC, State (both Illinois and Iowa), and local authorities. Routine monthly operational checks are conducted of the HPN-and NARS communication lines.
Individual
'
onsite locations are-tested on a rotational basis. A May 7, 1981,
- communications drill of the GSEP system identified a problem with the emergency monitoring team radios, which was subsequently corrected. All other communication systems were operable. Currently, all phone lines
within the protected area are on a vital bus; the Emergency Notification
'
System (ENS) in the TSC is fitted with a temporary plug to a vital bus.
I The ENS in the NRC Resident Inspectors' office and all telephone lines at the interim EOF are on non-vital power.
IE Bulletin 81-15 requested that
'
the licensee provide backup power for the ENS network. The licensee plans
'
to do this upon completion of the permanent EOF. This is an Open Item.
Backup communications were provided as specified in the plan and criteria of NUREG-0654, Revision 1.
Based on the above findings, this portion of the licensee's program is acceptable. Providing backup power for the ENS network is an Open Item.
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplies Needs for onsite damage control include temporary shielding, lifting -
equipment, welding equipment, high level radiation waste handling and storage capabilities, and decontamination supplies and equipment. The inspectors determined that these needs could be met from onsite supplies.
Extra equipment, if required, can be obtained from nearby Byron Nuclear Station through the Manpower and Logistics Director at the CCC. The Stores Director maintains a complete inventory list of-all equipment available from any site within Commonwealth Edison.
Based on the above findings, this portion of the licensee's program is acceptable.
4.2.5 Reserve Emergency Supplies and Equipment
,
f The Quad-Cities Nuclear Station has an inventory of supplies, including:
i
protective clothing, radiation detection instruments, respiratory equipment, first aid supplies, decontamination supplies and equipment, and dosimetry
.
for the radiological environmental monitoring teams.
In: addition, Quad-l Cities Station can obtain supplies including compatible radiation detection instrumentation, communications, and transportation equipment from any of i
the licensee's other nuclear stations. The Stores Director has-a procedure
,
to inventory and obtain emergency reserve supplies. Adequate quantities of
'
emergency reserve supplies are maintained at specified minimum stock levels onsite.
Based on the above findings, this portion of the licensee's program is acceptable.
4 t
.-
. - -
_.
.
-..
- - _ _.
-
..
, _ -.
.
4.2.6 Transportation There are no vehicles specifically set aside for offsite monitoring teams to ensure transportation will be available at the time of an accident.
However, there is a listing of vehicles located onsite which may be used in the event of an emergency. This listing is maintained by the GSEP coor-dinator. The description includes the vehicle type, CECO vehicle number, and the department to which it is assigned. Keys are available from the department to which it is assigned during normal work hours and through the Shift Engineer during offshift hours. The vehicles listed as being potentially available provided an appropriate selection and size of equip-ment. All vehicles were not licensed for offsite operation. There was no date on the listing of the vehicles.to indicate when it was compiled; however, a visual check revealed at least ten of those listed were available.
The licensee is currently considering the procurement of a van to be dedicated for emergency field team use.
Based on the above findings, this portion of the licensee's program appears to be acceptable; however, the following matter should be considered for improvement:
The licensee should acquire appropriate dedicated vehicles or imple-
.
ment a system to ensure that an appropriate number and type of station vehicles will be immediately available for use by field monitoring teams.
5.0 EMERGENCY PLAN IMPLEMENTING PROCEDURES 5.1 General Content and Format The inspectors reviewed all of the GSEP implementing procedures. All pro-cedures were arranged in the following format:
(1) Purpose; (2) References; (3) Prerequisites; (4) Precautions; (5) Limitations and Actions; (6) Pro-cedure (actual body of the procedure); (7) Checklists; and (8) Technical Specification References. This format coincides with the licensee's administrative procedure for procedure writing.
Procedures were written to cover all of the functions specified in the GSEP, and were organized by general function. All Station Group Directors also had a procedure which specified their responsibilities during an emergency; however, these procedures did not reference the appropriate functional procedure for the implementation of specific duties, e.g., Rad / Chem Director is responsible for determining evacuation routes, but QEP 360-3 is not referenced in his procedure. This condition exists in several of the other Station Group Director's procedures. Further, although specific responsibilities may be specified, e.g., Administration Director arranges for food and sleeping facilities for the onsite employees, the actions to be taken to implement these responsibilities are not specified. The Technical Director is responsible for accumulating, tabulating, and evaluating data on plant conditions such as plant operating data; however, how this will be imple-mented, including parameter trending is not specified.
.
'
Based on the above findings, the licensee's program is acceptable; however, the following matter should be considered for improvement:
All Station Group Director's procedures should be revised to include
.
references of appropriate QEP procedures used to implement specific functions or actual descriptions of the method for implementing that Director's responsibilities.
5.2 Emergency Alarm and Abnormal Occurrence Procedures
The licensee has Emergency Operating Procedures (QGAs) and Abnormal Occurrence Procedures (Q0As). One set (QGAs) is primarily used for the protection of the reacter core and containment, and the other_(QOAs) deals with less severe abnormalities. The inspectors reviewed these procedures and determined that most of the QGAs and QOAs do not adequately interface with the Emergency Plan. Those procedures that describe emergency conditions that warrant the classification of the event do not direct the user (Nuclear Station Operator) to inform the Shift Engineer of a possible GSEP condition.
The failure of the procedures to interface is a significant deficiency which could lead to a failure to classify and report the event in a timely manner.
The licensee prepared procedure QEP 200-T2 which is a procedure cross refer-ence for emergency action IcVels; however, the operators first instinct is to go to his operations procedures (QOAs and QGAs) rather than to the QEPs to find the appropriate procedure.
In addition, this approach requires the operator to determine that he has a GSEP emergency first, and then go to his operating procedure, rather than their normal approach to operations of-the plant, e.g.,
if a problem arises, go to the operations procedure that fits the problem. This cross reference is useful to personnel at the TSC or EOF to ensure that the operators are taking appropriate actions to mitigate the consequences of an emergency, but it will not ensure that the operator will identify that a GSEP emergency exists and have the Shift Engineer appropriately classify the event.
The following QOA and QGA procedures, which deal with events listed in the Emergency Action Levels (EALs), must require, as a subsequent operator action, that the Shift Engineer be notified to classify the event and initiate GSEP as necessary:
QGA 1 QGA 2 QGA 3 QGA 5 QGA 7 QGA 10 QGA 11 QGA 12 QGA 16 QGA 17 QGA 18 QGA 19 QGA 20 QGA-T1 Q0A 010-4 Q0A 010-5 QOA 201-1 Q0A 201-2 Q0A 201-3 QOA 201-5 Q0A 300-5 Q0A 800-1 QOA 1000-2 Q0A 1000-4 QOA 1100-2 Q0A 1300-1 Q0A 1300-2 Q0A 1300-6 QOA 1400-1 QOA 1600-1 QOA 1600-2 QOA 1600-5 Q0A 1700-3 Q0A 1700-4 QOA 1700-5 QOA 1700-6 QOA 2300-1 QOA 2300-3 QOA 4100-1 Q0A 4400-1 QOA 5400-1 QOA 5400-2 QOA 5750-13 Q0A 6100-2 Q0A 6500-1 Q0A 6500-2 POA 6500-3 QOA 6500-4 Q0A 6500-5 QOA 6500-6 Q0A 6600-1 Q0A 6600-2 U)A 6600-4 Q0A 6800-1 QOA 6800-2 QOA 6900-1 Q0A 6900-2 and QOA 6900-3 In addition to the above procedures, all procedures that involve operations when a Limiting Condition for Operation (LCO) has been exceeded should cue the operator to notify the Shift Engineer to classify the event in accordance with GSEP when a unit shutdown is required by the Action Statement of the LCO.
.
Based on the above findings, the following action must be taken to achieve an acceptable program:
All QGA and QOA procedures which could conceivably result in the
.
declaration of a GSEP Emergency Classification, i.e.,
those listed above, must contain a statement to direct the user to inform the Shift Engineer or Station Director of a GSEP condition requiring possible classification of the event. This shall be implemented during the next revision to each procedure.
In the interim, a table shall be placed in the QGA and Q0A procedure manuals referencing the user to the EPIPs.
5.3 Implementing Instructions Separate GSEP procedures existed for each Station Group Director. These procedures specified each Director's responsibilities, and the management level within the GSEP to which he reports. However, in most cases, these
,
procedures did not reference the functional procedures to be used to implement each Director's responsibilities (see Section 5.1 of this report).
The Shift Engineer (SE), as the Acting Station Director,'has complete authority over the initial operations of the Station Group and is respon-sible for the initial notifications and protective action recommendations.
Individual emergency classifications, e.g., Alert, Unusual Event, etc.,
comprise subsections of the notifications procedure. Emergency classifi-cations are made based on observable information which is readily available using QEP 200-T1, which is the table of EALs versus emergency classifications.
Although the Station Director's procedure requires him to classify the event and make appropriate notifications, there is no procedure specifically for the use of the Shift Engineer. During some of the walk-throughs, Shift Engineers attempted to classify the event using the generic section of the plan, and had great difficulty coming up with the appropriate protective action recommendations for the offsite public given various General Emer-gency scenarios. Although QEP 350-1 contained a table of protective action recommendations based on emergency classifications, this table is not the same as the one used by the Recovery Manager or Corporate Command Center Director to make their protective action recommendations (See Section 7.2 of this report). None of the Shift Engineers was familiar with the means of determining if the offsite projected dose exceeded the recommended dose levels given in QEP 350-1.
A simplified version of GSEP Table 6.3-1 must be provided for the Acting Station Director.
Although Shift Engineers did specify what actions they would have the RCTs under their direction perform, these actions were varied from SE to SE using the same scenario. The Shift Engineer should be provided with guidance for use of the RCTs available to him during an emergency, e.g., prioritization of sample collections or surveys based on the conditions of the emergency.
As stated in Criterion II.J.4 of NUREG-0654, Revision 1, evacuation of all non-essential personnel is required for any Site Area or General Emergency; however, none of the Shift Engineers initiated the evacuation / assembly siren when given the appropriate emergency classification.
. - -
,
.
--
--
-
-
Based on the above findings, the following action must be taken to achieve an acceptable program:
A procedure must be prepared for the Acting Station Director (Shift
.
Engineer or Shift Foreman) which clearly delineates the actions he is to take during an emergency. This procedure must include the classification of the event, appropriate notifications, how to fill out the NARS form for protective action recommendations, the prior-itization of tasks for the RCTs under his direction, and the sounding of the assembly / evacuation siren for any Site Area or General Emergency.
This procedure should not contain any extraneous information that is not needed by the Acting Station Director to implement his responsi-bilities. All Acting Station Directors must be trained on the use of this procedure. This training must include a means to verify that an adequate understanding of duties and responsibilities has been achieved; i.e., walk-throughs of the procedure.
5.4 Implementing Procedures 5.4.1 Notifications
'
For all Emergency Classifications, QEP 310-1, Initial Notification, delin-eates who will be notified and what onsite organizations must be augmented based on the classifications. The sequence for these actions is also specified. Notification action levels are consistent with 10 CFR 50.72.
All copies of the EPIPs contain the station telephone directory; however, there is no procedure actually specifying who the primary or alternate individuals for filling Station Group Director positions are, nor is there any means to ensure that individuals who are closest to the plant (and thus could respond in the shortest period of time) would be notified first. QEP 310-T1 shows a notification scheme for augmenting plant staff and activating the TSC and OSC; however, no phone numbers are specified, and it is not clear whether or not the Directors notified will complete the notifications at home prior to coming onsite, or wait until they have arrived onsite to complete this notification.
It is apparent that the Station would not be able to meet the shift augmentation goals of Table B-1 in NUREG-0654, Revision 1.
When initial notification and augmentation is performed, planned messages are not used to ensure that persons contacted know where they are to report or the class of emergency that exists.
Figure 5.4 shows the means by which offsite agencies are notified based on the Emergency Classification. There is a direct phone connection between the Control Room and the System Power Load Dispatcher, and between the Control Room and offsite agencies. Since most notifications to offsite agencies will be made by the Corporate Command Center Director, the licen-see has set up a duty officer system, requiring that one of the individuals qualified to act as the CCC Director be on 24-hour per day call. This form of notification was set up by the State of Illinois and agreed to by the licensee. This system has been demonstrated to be timely. Notifications to offsite groups are made using the NARS form. The Operations Director's procedure includes a verification that the Station Director has been notified.
O
.
Procedure CC-1 specifies which offsite support organizations are to be notified and the degree to which offsite augmentation is implemented based on the Emergency Classification. The CCC Director will notify all personnel required to man either the CCC or both the CCC and EOF using a telephone call list. Although this phone list is available to all CCC Directors at all times, this phone list is not yet prioritized to ensure that a Recovery Manager will be at the EOF within 60 minutes of determining that the EOF must be activated. This is specified in Criterion II.B.5 of NUREG-0654, Revision 1, and Criterion 4.3 of NUREG-0696.
By letter from Mr. L. O. De1 George to Mr. J. G. Keppler dated January 19, 1982, the licensee committed to pursue as a goal a 30 and 60 minute aug-mentation objective. This will be accomplished by establishing a 24-hour duty-call individual who would be notified first after a station emergency.
This individual would initiate a prioritized notification procedure. This procedure will be prioritized by least travel time of the individuals speci-fled in Figure 4.2-3 of the GSEP.
In addition, the licensee is developing a prioritized Recovery Manager notification list. This call list will enable the responsible corporate Duty Office to notify the Recovery Manager who would require the least travel time to a particular EOF.
Based on the above findings, the following actions must be taken to achieve an acceptable program:
The licensee must prepare a procedure for station augmentation such
.
that augmentation capabilities defined in Criterion II.B.5 of NUREG-0654, Revision 1, can be met.
This procedure must include a description of the phone tree, and be prioritized to ensure timely shift augmentation.
The CCC Director's call list must be prioritized such that a Recovery
.
Manager will be at the nearsite EOF within 60 minutes of determining that the EOF must be activated.
5.4.2 Assessment Actions The inspectors reviewed the licensee's Environs Group (EG) procedures; Environmental Director (ED) procedures; QEP 180-1, Rad / Chem Director Implementing Procedure; QEP 130-1, Technical Director Implementing Pro-cedure; and the QEP 330 series of procedures (Assessment Actions). These procedures all address assessment actions during an emergency. These procedures were reviewed against the planning standards and criteria of NUREG-0654, Revision 1.
'
The licensee has interim methods available to make a rapid estimate of offsite dose from an unplanned release of radionuclides; however, this procedure (QEP 330-4) is contradictory with the identical ED-16 procedure.
Since the revised Table 6.3-1 of the GSEP does not require that the off-
'
site dose estimate be immediately available for making protective action decisions, QEP 330-4 should be deleted and the appropriate ED procedure used. In addition, QEP 330-4 references Table QEP 350-T1, which contradicts the recommendation guidelines specified in EOF-1 and CC-1 (see Section 5.3).
.
.
After initial notification of a GSEP condition and the activation of the TSC, the Technical Director is responsible for performing the long term assessment of the GSEP condition. This assessment requires the Technical Director to identify the critical data points and control parameters that the Operations staff should monitor. However, the Technical Director is not provided with a checklist or form to assist him in implementing this duty and ensure that these critical data points can be trended (analyzed for rates of change). This form or checklist should be provided as part of this procedure.
Although both the Station Director (ptfar to arrival of the Rad / Chem Director) and Rad / Chem Director are responsible for directing the Rad / Chem Technicians (RCTs) during an emergency situation, neither of their imple-menting procedures provide any guidance on when and in what order reactor
. coolant, containment atmosphere, or effluent samples should be collected.
This prioritized guidance should be provided in both the Station Director's and Rad / Chem Director's procedures.
The initial determination of an emergency classification and the assessment of actions to take is made by the Shift Engineer using QEP 200-1, Emergency Conditions. This procedure relates all of the EALs to the appropriate emergency classification.
When the TSC is activated, the Rad / Chem Director reports to the TSC and the Environs Director reports to the EOF. The Rad / Chem Director is initially responsible for coordinating offsite surveys until the arrival of the Er.virons Director. The licensee has no overall procedure which orchestrates the implementation of the accident assessment program, but rather has defined managerial positions responsible for the various aspects of accident assessment.
Separate procedures (ED and EG) have been prepared to allow the individuals responsible for offsite dose projections to compute the following:
(a) exposure rates; (b) evacuation distance based on the EPA Protective Action Guides; (c) individual organ doses based on actual isotopic mix of the release; (d) doses based on actual field measurements; (e) determining the evacuation range based on the activity in containment; (f) determining whether sheltering or evacuation should be recommended; (g) determining the deposition rates based on the release; and (h) estimating the dose based on raw milk or grass sample results. These procedures also allow the licensee to determine the total population dose at any time during the accident.
These procedures are routinely used by the Rad / Chem Director, Environs Director, Environmental / Emergency Coordinator, Environmental Director, and their staffs.
Actual dose projections will be made based on containment activity or effluent releases.
If instrumentation is inoperable, the licensee will quantify release projections based on actual sample results.
Procedures exist for updating federal and state radiological assessment personnel at least every fifteen minutes of changes in assessment results and the results of any offsite surveys conducted.
..
. _ _.
.
-
- _
-_
_
__
__
..
.
. - Based on the above findings, this portion of the licensee's program is acceptable; however, the following matters should be considered for. improve-
,
ment:
Procedure QEP 130-1 should include a checklist or form to conduct
.
- trend analysis of plant radiological and operational parameters that the Technical Director deems critical.
i
.
Procedure QEP 330-4 should be deleted or. revised to include the correct
.
dose factors that are.in procedure ED-16.
F Procedures QEP 110-1 and QEP 180-1 should be revised to specify when
.
and in what order of priority reactor coolant, containment air, and/or effluent samples should be collected.
!
5.4.2.1 Offsite and Onsite Radiological Surveys Radiological surveys offsite are conducted by the licensee using procedures
in the EG series. There is no procedure for onsite out-of plant surveys,
although many of the procedures in the EG series can and should be applied to these surveys. EG-3 is currently under revision. The inspectors reviewed
,
all of the EG procedures including the revision of EG-3 and determined that
'
they were adequate. A procedure similar to the newly revised EG-3 should be developed for the Station. This procedure should include a diagram of the site so that beta-gamma and gamma readings can be recorded.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
The licensee should prepare a procedure for onsite out-of-plant
.
surveys similar to the newly revised EG-3 which contains a diagram of
,
the site so that both gamma and beta gamma readings can be recorded.
!
5.4.2.2 Inplant Radiological Surveys
The inspector reviewed the procedures for inplant radiological surveys to determine their adequacy in meeting the criteria of NUREG-0654, Revi-sion 1.
The review included the following Quad-Cities Nuclear Power Station documents: GSEP 6.2.2; QEP 330-2, 330-5, 330-6, and 330-7; and a Sargent and Lundy study (Project 5954-00) of inplant radiation levels t
following certain accident sequences. The methods, equipment and routes j
to be used for emergency radiological surveys were specified in these l
procedures. Provisions were included for complete recordkeeping. Sample
!
collection, labeling, and delivery points were also specified. Primary and backup communication equipment and prccedures were provided. Radiation protection guidance for survey teams was also included. The Sargent and Lundy study was referenced in the QEPs; however, only one copy was available
,
in the Rad / Chem Supervisor's office.
i
.
Based on the chove findings, this porticn of the licensee's program l
1s acceptable; however, the following matter should be considered for improvement:
!
!
!
.
-.w
-. - -
+.e-
-n
. - -,
e.
--e m
.,
.--
w
, -. -,,,..
.-
,
w-
- -,. - - - -
,-,--m
-
--
.
.
Additional copies of the Sargent and Lundy plant shielding design
.
study (Project 5954-00) should be provided in the TSC and EOF.
l 5.4.2.3 Post-accident Primary Coolant Sampling 5.4.2.4 Post-accident Containment Air Sampling 5.4.2.5 Post-accident Stack Effluent Sampling Interim post-accident sampling procedures QEP 330-5, 330-6, and 330-7 were reviewed and discussed with the Lead Chemist. These procedures appear adequate with provisions for representative sample collection, appropriate
. sample identification, and ALARA exposure considerations for the sampling team.
Operating procedures for the Sentry HRSS discussed in Sections 4.1.1.5 and 4.1.1.6 are currently being prepared. Thesa procedures should include the following:
(1) a checklist for the system operator to follow for sample collection; (2) a list of necessary sampling apparatus; (3) measures to main-tain personnel exposure levels as low as reasonably achievable; (4) sample identification methods; (5) means for sample transport and handling; and (6) sample dilution methods.
With respect to QEP 330-7, there are no instructions indicating when to fill the portable intrinsic germanium dewar with liquid nitrogen in order
to complete iodine analysis within two hours from sample collection.
The lack of these procedures is an Open Item.
5.4.2.6 Liquid Effluent Sampling Routine procedures (QRS 300-4) for liquid effluent sampling will be followed for post-accident sample collection. These procedures were reviewed and discussed with the Lead Chemist and an Engineering Assistant.
No provisions have been made for high activity post-accident samples, e.g.,
appropriate emergency precautions and limitations. The licensee can meet the three hour combined sample collection and analysis time frame specified in NUREG-0737, pending accessibility of the liquid effluent sample point.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
l A procedure should be developed for sampling high level liquid
.
effluent samples. This procedure should indicate all appropriate precautions and limitations.
5.4.2.7 Analysis of Post-accident Samples Interim post-accident sample analysis procedures were reviewed and discussed with the Lead Chemist. Routine laboratory facilities and equipment will be used for analysis of post-accident samples. Both routine operational and
i o
'
emergency procedures address post-accident sample analysis. These proce-dures outline methods for handling highly contaminated samples, including sample dilution and/or decay, control of hood air flow, construction of a lead brick cave, and determination of source to detector distance.
No operational procedures are available for the two remote sampling systems, the HRSS and SPING. These procedures should include the following:
(1) a guide for the operator to follow for sample analysis; (2) a list of pertinent analytical apparatus and equipment; and (3) measures to maintain personnel exposure levels as low as reasonably achievable, particularly during sample handling, preparation, and analysis periods.
The above lack of procedures is an Open Item.
5.4.2.8 Radiological Environmental. Monitoring Program (REMP)
Emergency environmental monitoring is coordinated by the Environs Director using procedure EG-1, which covers all aspects of offsite sampling and surveying.
If a full REMP program is deemed appropriate.for a particular emergency, the management structure outlined in procedure ED-1 would be followed. The ED and EG series of procedures cover all aspects of the REMP program, including arrangements for contractor laboratories, additional personnel for monitoring and analysis, and dose assessment through the ingestion exposure pathway. The licensee also has the capability to imple-ment this program through the assignment of personnel from any of their other nuclear stations.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The inspector reviewed all procedures that pertained to radiation protectica during emergencies to determine their adequacy in meeting the criteria of NUREG-0654. The following documents were reviewed: GSEP Sections 6.4 and 5.5; Qucd-Cities Annex Section 6.4; QEP 360-2, 360-3, 360-4, and 360-5; Environmental Emergency Procedures ED-10, ED-11, ED-12, ED-19, ED-22, EG-1, EG-2, EG-3, EG-4, EG-5, and EG-18; and relevant procedures in the QRP and QRS manuals. Although these procedures seem to ctver all key elements of the emergency radiation protection program, there is no overall procedure that explains the organizational structure or logic of the program. QRP 100-4 and QRP 100-33 contain emergency procedures for loss of coolant accidents, but they are not referenced in similar QEP procedures. Conse-quently, the inspector received the impression that these procedures are rather disjointed and would be difficult to use under the stress of a real emergency.
The various proccdures that were reviewed did include appropriate instructions for such things as personnel dosimetry, exposure records,
-
-
.
..
a
.
access controls, dose assessment, and provisions for limiting' exposures or preventing unnecessary're-exposures. Plans for expanding the respiratory protection program in the event of-an accident including provisions for extra respirators, decontamination supplies, and'the capability to rapidly-refill air bottles were included in the procedures. The procedures provide adequate controls for changing and: unusual conditions, such as varying dose rates. Delegation of the radiation' protection program functions.is left to the judgement of the Rad / Chem Director for onsite activities and the Enviorns Director for offsite activities.
Based on the above findings, this portion'of the licensee's program is acceptable; however, the following matters should be considered for improve-ment:
An overview procedure should be developed which orchestrates the
.
onsite emergency radiation protection program. A cross reference table similar to QEP 200-T2 may be useful.
Identical and similar procedures should be consolidated and obsolete
.
procedures should be eliminated or updated,'e.g., QRP 100-4 and 100-33 should either be updated as QEPs, or eliminated.
5.4.3.2 Evacuation of Owner Controlled Areas The inspectors reviewed QEP 360-1, Drywell Evacuation; QEP 360-2, Plant Evacuation and Assembly; QEP 360-3, Site Evacuation; QEP 110-1, Station Director Implementing Procedure; QEP 170-1, Security Director Implementing-Procedure; QEP.180-1, Rad / Chem Director Implementing Procedure; and QEP 120-1, Operations Director Implementing Procedure. The following-problems were identified in the review of these procedures:
(1) evacuation of.per-sonnel located within the owner controlled area but outside the protected area is not addressed in any procedure; (2) there are no provisions for personnel surveys or radiation monitoring in the assembly areas; and (3) it is not clearly specified that a site evacuation of all nonessential personnel
will be conducted for any Site Area or General Emergency.
Although QEP 360-2 specifies that an assembly of plant personnel will be
{
conducted for a Site Area or General Emergency situation, the corresponding
procedure for actual site evacuation (QEP 360-3) does not require this be conducted for any Site Area or General Emergency unless radiological con-ditions prohibit. There is no provisions in the site evacuation procedure l-or individual Station Group Directors' procedures for determining which personnel are nonessential and which are essential. This could result in the evacuation of personnel that are necessary in an emergency.
j Although the licensee operates a warehouse, visitors center, and plans to
also occupy a training building outside of the protected area fence, none i
of the licensee's procedures address the necessity for notifying the
individuals occupying these structures that they should evacuate the area.
Criterion II.J.1.d in NUREG-0654, Revision 1, specifies that the licensee shall establish the means and time required to warn or advise onsite
i
j
4
.-.-y
--,.
. -.,
,--,,,,v.--3-
. _ -..w
,, -
,,y--,..-,,
,,,, -,,,
y,_.,,,,,,wm,
-,,,,,,,,..,m-,.,-y,
,.-, - -
w,,
,
%-.-,
a n
%
,
we,
,~,,,y-
---r-
-
.
.
Individuals and individuals who may be in areas controlled by the operator, including persons who may be in the public access areas on or passing through the site or within the owner controlled area. The licensee must establish a procedure such that when site evacuation is required, individ-uals at these locations will be notified to evacuate.
The licensee maintains radiological monitoring equipment which is capable of monitoring direct radiation and airborne radioactivity in all assembly areas other than the machine shop. Since the machine shop will be used as an assembly area, this area must either be provided with appropriate radiological monitoring equipment, or an RCT must be dispatched to this area to perform the appropriate monitoring.
In addition, the Rad / Chem-Director's procedure does not address monitoring of personnel in the assembly areas for contamination. QEP 360-2 states that personnel will assemble and normal undressing and removal of protective clothing will be waived. Either this procedure or QEP 180-1 should specify that these people will be monitored for contamination and decontaminated prior to evacuation from the site.
.
Although the Operations Director is specified in the Plan to be responsible for implementing any assembly / evacuation actions, the Station Director's procedure states that he is to contact the Technical Director for these actions.
If instructed to evacuate the site, non-essential personnel will report either to Riverdale High School or Albany park, depending or whether a release is taking place or not and the direction the plume may be traveling.
The determination of which reassembly area to go to and the route to take is specified in QEP 360-3.
Based on the above findings, the following actions must be taken to achieve an acceptable program:
The appropriate QEP procedures must describe the provisions and time
.
required for notifying personnel outside of the protected area but within the owner controlled area (e.g., visitors center, warehouse, and old training building) that they should evacuate the area.
QEP 360-3 must clearly indicate that a site evacuation will be con-
.
ducted for any Site Area or General Emergency unless radiological conditions prohibit.
In addition, the following matters should be considered for improvement:
QEP 110-1 should be revised to indicate that the Operations Director
.
is responsible for implementing assembly procedures.
QEP 360-2 should be revised such that the title / positions of nonessen-
.
tial personnel will be provided to the Security Director if site evacuation is required.
.
O
.
QEP 180-1 should be revised to indicate that RCTs will be dispatched
.
to the assembly areas to monitor and decontaminate if necessary_all personnel still wearing protective clothing; and an RCT will be dis-patched to the machine shop to monitor the area for direct and airborne radiation levels.
5.4.3.3 Personnel Accountability The inspectors reviewed procedure QEP 170-1, Security Director Implementing Procedure. The Security Director accounts for all personnel within the protected area at the time the assembly siren is sounded in accordance with his procedure and procedure QEP 360-2.
Station accountability is conducted in the assembly areas by a security guard, who will contact a spokesman for the assembled group to determine if any personnel are unaccounted. The guard then contacts the Secondary Alarm Station (SAS) operator who will compile the list of unaccounted personnel. Accountability drills have been conducted and have demonstrated the capability to account for all personnel within 30 minutes.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.3.4 Personnel Monitoring and Decontamination The inspectors reviewed QEP 370-1, First Aid Procedure; QEP 370-2, Decon-tamination of Personnel; EG-10, Offsite Personnel Decontamination; and QEP 360-2, Plant Evacuation and Assembly. The licensee defines the methods and techniques for decontamination of personnel. These procedures are adequate to ensure that personnel will be properly monitored and decontaminated once contamination is detected. RCT monitoring teams will be dispatched to ensure that site evacuees are nonitored and decontaminated. EG-10 provides for the survey, release limits and decontamination of relocated personnel and the survey and release of vehicles.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.3.5 Onsite First Aid and Rescue The inspectors reviewed GSEP Sections 6.5 and 7.5; Quad-Cities Annex Section 7.5, QEP 370-1, QEP 550-1, and the Radiation Management Corporation (RMC)
Plant and Hospital Procedure Manual. This review was made to determine their adequacy in meeting the criteria of NUREG-0654, Revision 1, and ANSI /ANS-3.7.1.
The RMC Plant and Hospital Procedure Manual was available in the first aid supply cabinet, but copies of QEP 370-1 and 550-1 were not found in the room. The RMC manual described methods for receiving, recovering, trans-porting, and handling injured persons who may also be contaminated.
It also described the interface and criteria for using offsite medical services.
Radiation protection guidance was also provided for rescue teams. However, the RMC manual is not referenced in QEP 370-1 or 550-1.
The RMC manual and QEP 370-1 adequately address actions to be taken for first aid and rescue.
.-
-_
.
. -
.
' Based on the above findings, this portion of the licensee's program is acceptable; however, the following matters should be considered for improvement:
A copy of QEP 370-1 should be provided in the first aid / decontamination
.
facility.
The RMC manual should be referenced in QEP 370-1.
.
5.4.4 Security During Emergencies The inspectors interviewed the station Security Director regarding the measures to be taken during station emergencies. The Security Director will instruct the guard force regarding these actions. Basically the guard force will remain "on post" immediately following the declaration of an emergency. All guard force members have portable radios to communicate from their assigned posts. Walk-throughs of station security personnel indicated that they had been trained in the GSEP and its relationship with the station's Security Plan. All security personnel are issued and wear dosimetry while on shift. The inspector reviewed selected security proce-dures and verified that they interface with the GSEP.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.5 Repair and Corre:tive Actions Repair and corrective actions are not addressed with a specific imple--
menting procedure. Repair and corrective actions will be implemented by the Maintenance Director. QEP 610-1 addresses reentry following GSEP Emergencies, and specifies actions and equipment necessary for reentry operations.
As stated in this procedure, a Radiation Protectionman or Health Physicist will always accompany the reentry team.
Preplanning for reentry will be made prior to actual entry into the plant. Based on the accident, procedures will be prepared by either the Maintenance or Operations staff prior to repair operations.
Based on the above findings, this portion of the licensee's program is acceptable.
5.4.6 Recovery The CCC Director (limited activation) or the Recovery Manager (full activation) has the authority to deactivate the GSEP organization. The procedures used (either EOF-1, CC-1, or EOF-9) specify how he will close out or recommend reduction in emergency classifications. This is based on an evaluation of stabilized plant conditions in comparison with Emergency Action Levels, and in consultation with NRC, State, licensee, and NSSS vendor representatives. The positions in the recovery organization are shown in Figure 2.3.
In addition, the Station has prepared QEP 620-1, Recovery Following GSEP Emergencies. The inspectors reviewed this proce-dure and determined that it was adequate.
,.
-
!
_
i
.
Based on the above findings, this portion of the licensee's program is
'
acceptable.
5.4.7 Public Information The inspectors reviewed procedures CC-4 and EOF-4 which relate to public [
<
information activities and verified that they were acceptable. These
procedures were adequate in scope and content, and specifically delineated
.a_
'
'-
the responsibilities of the Information Director and Emergency News Center
-
>
Director. Thsee responsibilities included collection, verification, and
,
dissemination of information on emergency situations to the public via the
.
-q j'
news media; issuing' approved press releases; coordinating the release of information with other involved agencies; providing a technical spokespersonf
'
.
,
at the Emergency News Center; and establishing coordinated arrangements fer
'
dealing with rumors. These procedures also identify the contacts with news media organizations to ensure that they are informed of any GSEP_ emergency. -
,,
.e
,
Based on the above findings, this portion of the licensee's program is
'
acceptable.
5.4.8 Fire Protection Although the licensee has not prepared fire preplans, the Fire Marshall stated that the Station is currently drafting a form for each fire alarm which will indicate what material is available for combustion. The licensee's status with regards to fire preplans is currently under review by the NRC's Office of Nuclear Reactor Regulation. The. licensee's Fire Hazards Analysis Report does contain drawings of all plant areas which are color-coded to indicate to the user if the fire can affect safe shutdown equipment. This report is located only in the Shift Engineer's office.
Walk-throughs with some Shift Engineers and Shift Foremen (Fire Brigade Chief) indicated that it is difficult to determine from the fire alarm
panel in the Control Room whether the fire can or cannot affect safe shutdown equipment. The Station Fire Marshall agreed with the inspector that the fire alarm form should include a description of what safe shut-down components or electrical cables may be in the fire area, and thus guide the user to notify the Shift Engineer of a possible Emergency Plan condition and request him to classify the emergency per QEP 200-T1.
Based on the above findings, this portion of the licensee's program is
.,
acceptable; however, the following matter should be considered for
-
improvement:
'
s, The licensee should include in the fire alarm forms a description of
.
the safe shutdown equipment that could be affected by a fire, and a
'"
statement to request the Shift Engineer to classify fire emergencie.
in accordance with QEP 200-T1.
.
~,
-
%
v l
,
-
.
o -
c
'
5.5 Supplemental Procedures
,
5.5.1 Inventory, Operational Check, and Calibration of Emergency Equipment, Facilities, and Supplies
-
.'
/
The'inspectprs reviewed the licensee's program for inventory, operational check, and calibration to determine its adequacy in meeting the criteria
- _
~
of NUREG-0654 and the requirements of 10 CFR 50 Appendix E.
The review included'an evaluation of QEP 550-1 and an examination of inventory and calibration records. Procedure QEP 550-1 did not ir:1ude provision for inven' tories of first aid, decontamination, or re piratory pro * action l supplies' and equipment.
Inventory and calibration records were found to be current and complete. The Rad / Chem Department is responsible for conducting the quarterly inventories and rotating instruments for cali-
,
bration.
,
,
The licensee does not include in their communications check procedure
"(QEP 530-2) provisions for testing communications with the NRC Regional and, Headquarter's Operation Cer;ers from the Control Room, TSC, and EOF
.
as. required by Section IV.E.9.d in 10 CFR 50, Appendix E.
Based on the above findings, the following action must be taken to achieve
'
an acceptable program:
QEP 530-2 must be revised to ensure that communication checks with
.
the NRC as required by 10 CFR 50, Appendix IV.E.9.d are conducted.
/
In addition, the following matter 'should be considered for improvement:
QEP,550-1 should be revised to add procedures for inventories of c
first aid, decontamination, and respiratory protection supplies and
-
_ equipment. -l
,
~
5.5.2 Drills and Exercises Drills and exercises are administered and conducted in accordance with Ewritten scenarios developed by the Corporate Office.
Local assistance is provided by the Station GSEP Coordinator.
Exercises are coordinated with appropriate State and local agencies.
Licensee observers, provided for all drills, supply comments during a critique held following the drill.
Documentation of critique comments contained an evaluation of the overall drill with areas noted that required change or improvement. The inspectors reviewed the records of several recent drills and determined that comments of observers had also been documented.
,
QEP 530-2 states communication drills are held annually; however, NARS dnd HPN communication systems are checked monthly by station personnel.
Environmental monitoring, medical emergency drills, and an exercise are conducted annually. Health Physics drills are conducted semiannually.
Fire drills are conducted in accordance with station technical specifi-cations.
r
!
,
>
i
.
Based on the above findings, this portion of the licensee's program is acceptabis.
5.5.3 Reviews, Revisions, and Distribution of Emergency Plan and Procedures The station procedures are prepared, reviewed and distributed in accordance with published administrative procedures in the 1100 series. New procedures and revisions are submitted to the Technical Staff Supervisor for an initial review. Subsequently, the procedure undergoes an onsite review and a safety evaluation review. Following completion of the above reviews and approvals, the reproduction, distribution (onsite and offsite), and maintenance of appropriate records are handled by the Procedures Coordinator, who clearly defined the approval and distribution mechanisms.
Annual review of the GSEP and QEPs is the responsibility of the Technical Staff Supervisor. The most recent annual review was accomplished in February 1981.
The home telephone numbers of all station CECO employees are reviewed quarterly. This is the responsibility of the Technical Staff Supervisor.
The latest Quad-Cities Station Group Directory appears in the CECO GSEP Telephone Directory dated October 1981.
During walk-throughs of the Station Group Directors, the inspectors deter-mined that not all alternate directors had a copy of the GSEP or emergency procedures. The inspectors reviewed the list of personnel in the GSEP telephone directory against the procedures manual controlled copies dis-tribution list. This review indicated that one Security Director, two Administration Directors, two Stores Directors, two Maintenance Directors, and one Technical Director did not have copies of the GSEP or associated procedures. Of the directors interviewed who did not have a copy of the GSEP, none were able to state the date of the latest procedure revision, nor could they state when the last procedure change that affected their functions occurred.
Based on the above findings, this portion of the licensee's program is acceptable; however, the following matter should be considered for improvement:
All personnel listed as being in the line of succession as any of
.
the Station Group Directors should have a current copy of the GSEP and implementing procedures (QEPs).
6.0 COORDINATION WITH OFFSITE GROUDS 6.1 Offsite Agencies The licensee has made agreements with offsite organizations whose help may be needed in the event of an emergency. These organizations are:
.
'
1.
Illinois Department of Nuclear Safety 2.
United States Department of Energy 3.
Illinois State Police (District #7)
4.
U.S. Army Corps of Engineers (Rock Island District)
5.
Illinois Emergency Services & Disaster Agency 6.
Rock Island County Emergency Services & Disaster Agency 7.
Whiteside County Emergency Services & Disaster Agency 8.
City of East Moline Civil Defense 9.
Clinton County Office of Civil Defense & Disaster Services 10.
Scott County - Municipal Civil Defense & Disaster Services 11.
Whiteside County Sheriff 12.
Iowa State Patrol (Post #12)
13.
Rock Island County Sheriff 14.
Albany Fire Department 15.
Jane Lamb Memorial Hospital 16.
Dailey/Gibson Funeral Home (Ambulance Service)
17.
Iowa Office of Disaster Services 18.
Radiation Management Corp.
19.
Murray and Trettal, Inc.
20.
Hazelton Environmental Sciences 21.
R. S. Landauer, Jr.
and Company 22.
Illini Hospital Ambulance Service 23.
U.S. Coast Guard Marine Safety Office (St. Paul, MN)
24.
Cordova Fire Department Letters of agreement were reviewed and all of the above listed offsite agencies had been sent and had returned their letters confirming their agreements.
The Station Superintendent has provided a written invitation to the above offsite agencies to visit the station for familiarization purposes and to provide radiological training or retraining. Contacts were made by inspectors during visits or via telephone with responsible representatives of one or more of each of the following offsite organizations:
federal, State of Illinois, State of Iowa, counties in both states, local law enforcement, ambulance service, local hospital, and fire departments listed in the licensee's site specific plan. The representatives in each case were aware of the agreement and were able to describe their expected response in the event of an emergency at Quad-Cities. Representatives of the contacted offsite organizations reported they had been notified of the annual exercise held in May 1981. Responsible representatives of the contacted offsite organizations were satisfied with the current agreements between their agency and the licensee and stated their intent to honor that agreement.
The inspectors visited the Jane Lamb Memorial Hospital and interviewed the hospital administrator and patient care representatives.
In addition, they visited the radiation emergency area set aside for use at the hospital, and examined the equipment which would be used to monitor and treat individ-uals arriving from the Quad-Cities facility. The room contains an examina-tion table, portable shielding equipment, contamination control materials, guides for emergency room personnel which consists of charts mounted on the wall listing basic steps with sketches of procedures for decontaminating an
.
individual, a locked cabinet containing protective equipment, and currently calibrated radiation detection instruments.
The Director of Patient Care Services expressed a good understanding of her responsibilities and procedures to follow in response to an emergency involving a radioactively contaminated injury victim. She indicated satisfaction with training supplied by the licensee and their emergency medical consultant (Radiation Management Corporation).
Based on the above findings, this portion of the licensee's program is acceptable.
6.2 General Public and Transient Populations 6.2.1 Information Distribution Emergency information pamphlets describing what to do in case of an emergency at the Quad-Cities Nuclear Station were mailed to the adult permanent population within the ten mile EPZ.
In addition, bulk deliveries were made to motels, parks, and other such places where the transient adult population would be located. A log is kept of locations and dates of these bulk deliveries. The pamphlets contained a statement that further informa-tion could be obtained by contacting the licensee's public information office, but very few requests for such information were received. The pamphlet also gave the address of the state and local agencies who could provide more information. The licensee stated a similar mailing will be made this year, and that other alternatives are being considered for future years, such as putting the information in the telephone book. The pamphlet contains information on radiation, actions to take in the event of an emer-gency, and the means by which the public would be notified of an emergency.
Based on the above findings, this portion of the licensee's program is acceptable.
6.2.2 Prompt Notification of the Public As of January 27, 1982, CECO had not installed a prompt public notification system meeting the design objectives of Appendix 3 in NUREG-0654, Revision 1.
Established schedules for the system were as follows:
j ITEM DATE Survey Completed Completed June 1981 Equipment Bids Solicited Completed July 1981
-
Equipment Ordered Completed August 1981 Equipment Received Completed November 1981 Permits Received Informally Received, Documentation not Complete Installation 52 Required l
Of the 52 sirens required, the inspectors determined by visual observations on January 26, 1982, that 18 sirens were installed in Rock Island County out
._.
of the 18 required,1 siren was installed in Whiteside County out of the 7 required, 1 siren was installed in Clinton County out of the 17 required, and 1 siren was installed in Scott County out of the 10 required.
During the first week of February, the resident inspector conducted a random sample verification that siren installation had been completed. The prompt public notification / warning system was tested by the licensee on February 1, 1982. All sirens were satisfactorily " growl" tested. Radio tests for Whiteside County indicated 3 out of 7 sirens functioned; Clinton County indicated 12 out of 17 functioned; Scott County indicated 6 out of 10 functioned; and Rock Island County indicated 0 out of 18 functioned. The licensee has express ordered a new encoder for Rock Island county.
The licensee has agreed to correct the above noted deficiencies by June 1, 1982, in accordance with the provisions of 10 CFR 50.54(s)(2). This is an Open Item.
6.3 News Media The inspectors discussed the current news media program established by the licensee relevant to coordinating and disseminating accurate information to news media organizations. A Reporter's Guide brochure has been prepared which covers the following subjects: operating cycle of a BWR, radiation, emergency planning, training, and a glossary of common reactor / radiation terms. This guide was disseminated to radio /TV/ newspaper media personnel during the May 20, 1981, annual exercise. Training for media personnel
_
is offered by the licensee, and special press days for briefing and tours are conducted in conjunction with the annual exercise. This training includes contacts with appropriate licensee personnel for the dissemination of news releases.
Based on the above findings, this portion of the licensee's program is acceptable.
6.4 NSSS Vendor The inspectors discussed the functions and tasks of the NSSS vendor (General Electric) with the onsite GE representative at the Quad-Cities site. GE will respond if requested by the licensee, providing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a team of experts to assist and support the licensee. GE maintains a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day duty system for rapid activation of the service. Further, an analysis support group in San Jose, California will assist the GE team and the licensee. A Letter of Agreement with GE has been executed. EOF procedures exist to coordinate advisory support from GE and other support organizations such as INPO. The onsite GE representative would proceed to the TSC if requested and act as a communicator between the station and San Jose in the transmission of plant data for analysis by the San Jose team.
Based on the above findings, this portion of the licensee's program is acceptable.
.. _ --
_
_
-_
_ _ _ _ _ _
. - _ _ -_
-
__
__
'
7.0 DRILLS, EXERCISES, AND WALK-THROUGHS 7.1 Drills and Exercises All drills and exercises required by the plan and procedures have been conducted in accordance with established criteria and coordinated with offsite agencies. The corporate office has established a management
,
control system to assign responsibility for corrective actions for those
items found to be deficient or in need of change as a result of drills or exercises.
Based on the above findings, this portion of the licensee's program is acceptable.
7.2 Walk-throughs of Emergency Response Personnel
,
J The inspectors conducted several walk-throughs of the following emergency tasks: emergency detection, notification, protective action decision making, offsite environmental monitoring, dose calculations, and Station Group Director responsibilities. The onsite emergency response walk-throughs included several Shift Engineers, Shift Foremen, Station Group Directors, Rad / Chem Technicians (RCTs), security personnel, and Health Physicists.
Most individuals interviewed were aware of their emergency responsibilities and roles. Training was provided to those interviewed. Walk-throughs of RCTs and Health Physicists involving offsite environmental monitoring and
]
post-accident sampling indicated that they were properly trained in plume
monitoring techniques. All individuals were aware of proper sample / survey locations. Walk-throughs of security personnel indicated that they were aware of proper implementation of security procedures during emergencies.
Walk-throughs of Station Group Directors indicated that they were aware of their emergency responsibilities and the means for implementing them.
Walk-throughs of Shift Engineers and a Shift Foreman (Acting Station Directors) indicated a basic lack of ability to make protective action decisions and properly classify events. Although most individuals were able to correctly classify emergencies, some were unable to locate the correct procedure, and instead used Tables 5.0-1 through 5.0-4 of the
generic GSEP. This usually resulted in an incorrect emergency classi-fication. When these Shift Engineers were shown where QEP 200-T1 was located, they were easily able to correctly classify events. Tabbing of the critical QEPs used by the Shift Engineer would have saved significant time in the classification of the event and in the notifications required.
All individuals were able to make the correct notifications given different scenarios; however, they were unable to make adequate protective action decisions given General Emergency scenarios. Although QEP 350-1 provides protective action guidelines, none of the Acting Station Directors referenced this procedure nor did they know where to find it.
None of these individuals was aware of the means for determining whether projected doses offsite exceeded the EPA recommended Protective Action Guides (PAGs).
A revised protective action recommendation table was used by the licensee
,
- - - - -.. -
-
,
, _ _... - - - -. - -
,.. - -, - -
-.,. -
,-n..
-.,,
r
.
. at the exercise conducted at the Dresden site. This table has been incor-porated in the EOF and CCC series of procedures; however, it is not used in the licensee's current Station QEPs, nor is it in the current version
-
of the licensee's GSEP. This revised table is superior to the licensee's current table in that initial protective action recommendations are con-sistent with the guidance in Appendix 1 of NUREG-0654, Revision 1.
How-ever, this table is still too complicated to be used by the Shift Engineer.
Since the Shif t Engineer will make protective action recommendations without access to offsite dose projections, protective action recommendation guidance should be provided to the Shift Engineer based only on the projected status of the plant and radioactive material available for release e.g., containment radiation monitor readings. The minimum recommendation should be sheltering a two mile radius and five miles in the three downwind sectors.
(see Section 5.3)
Based on the above findings, the following action must be taken to achieve an acceptable program:
The licensee must incorporate the revised protective action recom-
.
mendations table (Table 6.3-1) into the GSEP and appropriate station QEPs.
In addition, the following matter should be considered for improvement:
All critical QEP procedures should be tabbed for easy access.
.
8.0 LICENSEE ACTIONS ON PREVIOUSLY IDENTIFIED ITEMS RELATED TO EMERGENCY PREPAREDNESS For the purposes of tracking, all of the following previously identified items are considered closed, and those items not completed have been reopened in this report. These previously identified items are as follows:
RCTs were not trained in interim emergency procedures.
.
There is an insufficient supply of high range portable radiation
.
survey instruments for use in an emergency.
High activity sample handling capabilities are suspect, owing to lack
.
of shielded work space in hoods and on bench tops.
The combined personnel decontamination and medical treatment facility
.
is too small and inadequately equipped, and it inappropriately shares space with the whole body counter.
9.0 PERSONS CONTACTED CECO Personnel
- N.
Kalivianakis, Station Superintendent
- T.
Tamlyn, Assistant Superintendent, Operations
- L. Gerner, Assistant Superintendent, Administration and Support Services
- R.
Bax, Assistant Superintendent, Maintenance
- T. Kovach, Rad / Chem Supervisor
4
.
.
'
- D. O'Connor, Personnel Administrator
- R. Carson, GSEP Coordinator, Lead Health Physicist
- G. Gary, Lead Chemist P. Farron, Shift Control Room Engineer J. Vahrenwald, Shift Control Room Engineer G. Tietz, Technical Staff Supervisor G. Toleski, Director of Security D. Jessen, Technical Support Staff J. Schnitzmeyer, Technical Support Staff J. Belshause, Procedures Coordinator J. Wunderlich, Technical Support Staff R. Robey, Senior Operations Engineer G. Spedl, Senior Operations Engineer W. Bielasco, Health Physics Staff G. Price, Maintenance Master Mechanic T. Keith, Health Physicist K. Donavon, Station Staff M. Schilling, Health Physicist C. Paulson, Shift Foreman D. McCarthy, Shift Engineer C. Kepler, Shift Engineer T. Davis, Shift Engineer D. Hoffman, Shift Engineer D. Warren, Shift Engineer L. Butterfield, Storekeeper S. Simpson, Storekeeper Staff K. Leech, Security Staff F. Faley, Office Supervisor R. Huebler, Engineering Assistant R. Cadigan, Health Physicist A. Schmidt, Instrument Foreman J. Forrest, Radwaste Staff Assistant J. Derrecks, Chemist P. Behrens, Chemist R. Moore, Chemist R. Wiebenga, Chemist V. Neels, Chemist D. Wykoff, Engineer M. Koon, Engineer M. Hesse, Rad / Chem Technician T. O'Horo, Rad / Chem Technician
- R. Flessner, Supervisor, Radioecology and Emergency Planning, CECO L. Litterski, Meteorologist, CECO J. Barr, Emergency Planner, CECO K. Collins, Environmental Engineer, CECO R. LaPlaca, Meteorologist, CECO R. Mayer, Supervisor, Computer Systems, CECO Non CECO Personnel R. Brager, General Electric Representative M. Barnes, Director, Clinton County Office of Civil Defense and Disaster Services
-
.
'
L. Kimmel, Whiteside County Sheriff W. Welch, Chief, Albany Fire Department G. Weeks, Associate Administrator, Jane Lamb Hospital C. Mults, Director, Patient Care Services, Jane Lamb Hospital B. Peterson, Assistant Administrator, Environs Services, Jane Lamb Hospital L. Katcharian, Commanding Officer, U.S. Coast Guard and Marine Safety Office H. Poel, Chief, Cordova Fire Department L. Booth, Radiation Management Corporation, Manager Midwest Office J. Dooley, Director, Scott County Office of Civil Defense and Disaster Services D. Stockwig, Gibson Ambulance Service, Port Byron The inspectors also interviewed several members of the security force.
- Denotes those present at the exit interview.
10.0 EXIT INTERVIEW The inspectors and senior management from NRC Region III met with licensee representatives (denoted in Paragraph 9) at the conclusion of the appraisal on January 27, 1982. The inspectors summarized the scope and findings of the appraisal.
l
r
'
&
e
e MINEX A FIGURES i
i
!
l
&
O
s D
E th w >o
-
w
E V W
WZ Ow p-EE W
o y
a
=
m.1 me
'
iO w
-
vc
-
=
.
i. w
-
.
OE W
W5 E
YW
-.
<o w
Y b
>
zE m
m 2*
.~
-,
E tD MO
-
C1.
T
N D
O U
- o
y O
CU ew
~
e e
Se
- > w
"
O
$
w w Bs w-O O
=
-
ma
[ Z O_
.
-
s
<?
>-
U)
-J<e O
W g
O w
M' E *=V
h
.C_
-w O
bC m
'"" 6 W
W
>C<C C >o
=
g
"V Muummul C Mw
>
bb M
Eo O4 th Z=
OO
>-
M 4-m wb ao O
- - -
r i
=
-
.
a ch Z
.
O
-
M.O
< u 2E uma zw oo w
o Cr
- *-
k.-
o 2 o-unusug an U mummmun e:
w
-
o *-
>C
~:
in
=U o
E
'
eg w u
o oO Cr
-
U Eo w
unusuu W umuus: -
E ummum
- m o
t ou AC A
m M-m
O
q w
2m numa er o
o e-J
>== n Vb w 2gDw o a U-
,
uo et
- .
2'
O
-
>==
th 2 4:1
. *,
=J Zo N
5'
'
- E o e. -
g g
EU unummu et
,.-
z
=m
>p G
^
8:1
- >st wo Z-
-
zi >-
O
$J m m z o mmma Wo
D oW w$
E-O w
o
>O w
u y
o eseee neeet w
namn est W
z e-
n
== tr-
- -
ch
- m
c.o m
.
. * -
8 ~w ~
su
ow W
N v Cz:
- r
-
- E
> =.
.
o C
.
Nm W
Eh *
.
w
- E
2
w
- w
- o o
LA.
CZ"
-
.
g h
o *Z O
. >-
c
- er
mW
>=
t w,,
.
o u
. 45')
e c
W z
-
-
w th s.......s-w O
FE J"
a oW 4 0 zom
" G.
C 2 ett--
po w
m w
ow
=r *-
w wg M
gu M
gg w c6 2-W
>= (n o
m
- -
CE" a
$/3 Q
h
w m
6--
ze a
wo
~
c.3 >-
mum U
men J
a w
-
wC wC
>= o z
+-
-
to gg-ck ww
6
- E m
m
=
-
=J o
- E w
Z O5m ao w
- '
w *-
w 4 WU M
att zW
>=
6 b M
zO W
f
\\
%
/
o e-us b
- s6 e
gg
=N c ode
- g! =e'=(I o
I
,
wS==Lm c., m wzz W
g oou
- cr e
o-zO I
w O202-aw w
l w;;;=,
dEo w
w c z s -l 3
<
=
,
l=?=
l w ay cd2
"
l
=
m M
!
C o-s oo w
w a >- o M
E<
EMwi Ee L5
w wzi wo iz
,
-
d @E *
2"
'um8 6-.c=
8, cr i
s,.' E u-6*
i
-
eso
- o
,e=-
Z 3wo g
o"&
- C~ U '
O z
CC 6 M
"" 2 2 l C
_
!
5O n- '
w l
'ak
<
i,>
i w
~
Z-m
-
!,.
6 c
wz e
um a m
M 2_ 5 ElE l
lE2 O
'
c ce
-
_w e
o zz o
u.
.
-
0 A. wv "U yC
,
,8
,<o<
w gm
, "< 1
<8 M<
2o y3
-
Q.
mg
)
o-a m
g g*
g W '= =
2v
,.;
w OEf
}h-E
~
m g
!
-
o-
=
c: z w
o n. w w
l QCc vg w#a
..................... -
oy *
O I
m" N W
w l
a.
va
9 c.
-
cz
<
dm M2
-:<%o D ". :
u
Ew w
.
au
<<
-oe:
o o eO
. a cm 2
< cr Z.
u
_.
g
- Ch. w a
- O o.
C. 2
I....O.................l.
l
.
W LLJ gz
[
j u.
a w
T
- E5
%, ce t E iE:.
m eoe s
'uI m
._
w m-s a c <
iu w-g-
z c6 2 ig o
z C" i
!
e.
cc -
i voa z
oo. jl
=
wm2
== s
-
um $ u gan. < l
,.
--.
.
J
m
,,,,
>W G!
<
l
_a
.
D
'
N
~g
C o
Z" o
8 D e-Cr
-
f Q* cr o I u. l 9 Ce U
l
'"J
e" o ow I
I' E 6,
inua T C-O mumumme < l t.- o LaJ i
! e>C Z E" d'.
e --O e-
C summme ~r,,,
-
c f
O mo zw g
DE c
2o ce iI c
w en -
N o
m mas <
-
z v
U
9mg, E~E M
w,
-u<~w.
5wo
' CI*
O f w
=='
gg c oOO-z-c. o w 8""'
- ? C c:
2 -,J =
zo
<
-
ds.
20*
I.:> CE
!
N
$ c:'
!
C c
<
= *0
- =
u.
-0 w
"-i
<
M U
~W
>
Dg,
_ a:
g cr r
m z
. o c=
Ms' '
~l I
[El
s
.i,. a g u '
-
-.e-v-2v -
~
_
- .- E
= =.
2 S. = '
g
.
G~:
_.
= _e
_..
u.-
l -.
-
,
-
_ _.
. -.
. _ _
.
.
-
,
k.
=
.
~.
$IIyIg E
E
<
<
T
. -
T E
A
-
A
.
!
-
T T
A S
SY
-
SY
-
SY I
E lI T
T
-
^C SI
,
S I
-
S R
,
S TI CN U
,
LE UR S
O I
U E
R OE O
,
AC Ol
-
I Ol H
LG U
,
C C
T
,
N Ul I
A G
,
E G
N Ui i
l U
-
- l
,
1G l U
-
E A
iA G
l u
w f
iA
,
N
,
N A
iA O
,
O N
_
C C
O
,,
C
,
- '
,
_
-
_
-
S, E,
i,g
_1, M,,
g I
I A
S g,
A S
O A
'
O D
N D
N f
P D
"
P S
O S
O N
Y
E I
S N
E y,
I E
'
I r
I
.:
W,
E 0,
M j,
E T,
g" H
C I
"
C S
T, N0,
"
[
R N
R R
E i,
R E
E G
E T
j T
EN/A
T T
ENR A
TEO N,
EN l
T Rr E
TER A
OA A CI R.,
ACO R
T C
M
-
C R
C o
R T
O C
O DE l
c
!
OD P D E Y f
P NR C
P E
RNR i
R N R R
4. T O
D
"
AI O AI AI
!
R i I.
E M
OCM D CMD V O
C
2'
N M
M O
M E
O O
C
.
C c.
O C
E RY E
C R
U C C.
.
G N T
L
.
I
_ '
.
F E
'.
G E"
R
.
E M
'.D
^F. E
.
E T
" A
.
-l
^V D
R li lE E
R l
.
M l
"2 R
E f
MRH C
Ri
,
E l
C EE E
EC
,
"i
.A L
WA
,_
i I
T T
S OP A
I P
Y YOP A
_
SPS P
I PS
-
M!
D
-
D S
I
-
I IS lD Y
l
_
S
.,
O
!J. A
_
f
0' A R
_ '
_
L
-
.
_
-
_
l l
I I
-
_
R R
.
N O N O
'1.I!
,
0T C
0T N 0 C
ll C {
R lC l
l N
A E f R
C A E l
'
T R TR N
AE S
I SI T R
"
D D
"
D
_
_
_
Y
_
_
C
_
NT T
Y N
0N N C
E l E E
N GR l D V
E AI E
T C G
~
E R
M
-
RC E
E
-
OA L
_
P A
M L
_
S U
T E
A N
S R
~
R A
U E
E n
R N
l I
U A
iS e
I r
_
-