IR 05000255/1982003
| ML20054D069 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 03/29/1982 |
| From: | Axelson W, Nicholson N, Paperiello C, Rozak S, Schumacher M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20054D064 | List: |
| References | |
| 50-255-82-03, 50-255-82-3, NUDOCS 8204220304 | |
| Download: ML20054D069 (13) | |
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-255/82-03 Docket No. 50-255 License No. DPR-20 Licensee: Consumers Power Company 212 West Michigan Avenue Jackson, MI 49201 Facility Name: Palisades Nuclear Plant
Inspection At: Palisades Site, Covert, MI Inspection Conducted: February 22-23 and March 5, 1982 Y knebobol
/>Iarc/ d 2, /fJW Inspestors:
N. Nich son
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M. Schumacher Approved By:
W. L.
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T1,l981 Emergen y Preparedness Section 7'{,ll? &
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C./ J.
eriello, Chief Emergency Preparedness and Operational Support Branch Inspection Summary Inspection on February 22-23 and March 5, 1982 (Report No. 50-255/82-03)
Areas Inspected: Routine, announced inspection and observation of an emer-gency exercise involving an integrated response from the State of Michigan (small scale) and various local counties. Areas observed included: Command and Control of the Control Room; Technical Support Center; Operations Support Center; Interim and Near-Site Emergency Operations Facility; and post-accident
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sampling and surveys. The inspection involved 94 inspector-hours onsite by four NRC inspectors.
Results:
Significant problems regarding:
scenario development, approval and implementation; management control of the OSC; timely activation of the EOF; and training of the emergency organization were identified.
These are summarized in an Appendix to the letter transmitting this report and are specifically discussed in Section 5 of this report.
8204220304 820402 PDR ADOCK 05000255 O
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t DETAIIS
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1.
Persons Contacted Licensee Personnel *
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- G.
Petitjeon, Technical Engineer l
- J. Ellis, Chem /HP Staff
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- B. Henton, CPCO-Midland Facility
- R. Harrington, CPCO-Midland Facility
- R. Lovell, CPCO-Midland Facility i
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- W. Mullins,-HP Staff
- W. Miller, CPCO-General Office, Jackson
- K.
Farr, CPCO-Public Affairs
- R. DeLong,-HP Staff
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- J. Rang, Plant Superintendent
- R. Montross, Plant Manager
- A. Kowalczuk, Chem /HP Superintendent
- M. Jury, CPCO-General Office R. DeWitt, CPCO-General Of fice
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Other Personnel
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M. Jackson, General Physics Company
- denotes those present at the exit interview on February 23, 1982.
- denotes those present at the special exit interview on March 5, 1982.
l NRC Observers and Areas Observed W. Axelson, Interim Emergency Operation Facility (EOF)
M. Schumacher, Technical Support Center N. Nicholson, Operation Support Center, OSC; Post-Accident Sampling 15. Rozak, OSC, Command and Control i
P. Bolton, EOF, South Haven G. Carbough, OSC, Health Physics Activities W. Thomas, OSC, Health Physics Activities 2.'
General
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An exercise of the licensee's Consumers Power Corporate Nuclear Emer-
gency Plan and the Palisades Nuclear Plant Emergency Plan was conducted
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on February 23, 1982, testing the integrated responses of the licensee, I
State and local organizations to a simulated emergency. The exercise tested the-licensee's response to a large release of radioactivity to the primary coolant and a steam generator tube failure. Attachment 1 describes the. scenario. The exercise was integrated with a test of the State of Michigan (small scale) and Van Buren, Allegan and Berrien
Countias.
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General Observations
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a.
Procedures This exercise was conducted in accordance with 10 CFR 50, Appendix E requirements using the licensee's Emergency Plans and the Emer-gency Plan Implementing Procedures used by the Site and Corporate Personnel, b.
Coordination The response was marginally coordinated, orderly and timely. Due
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to an inadequate scenario, the licensee was unable to test cap-abilities.
Further, those areas which were exercised, indicated significant weaknesses in the licensee emergency preparedness program.
c.
Observers Licensee observers monitored and critiqued this exercise along with eight NRC observers and several FEMA observers. FEMA obsarved and will report on the responses of the State and local governments.
d.
Critique The licensee held a critique on February 23, 1982, the day of the exercise. The NRC and the licensee identified deficiencies.
4.
Specific Deficiencies Noted The major deficiencies identified by the NRC are included in Appendix A to the letter of this report and are listed under Specific Observa-tions, Section 5.
5.
Specific Observations a.
Control Room The resident inspector observed control room operations throughout the course of the exercise. Observations included verification that the Shift Supervisor and control room operators understood their responsibilities and that appropriate Emergency Plan Im-plementing Procedures'(EPIPs) were followed.
Operations personnel were not fully involved in this exercise because the scenario did not provide sufficient data to challenge them. When the TSC was activated, some confusion arose in the i
control room regarding who was responsible for ensuring Public Address (PA) announcements are made particularly for a site evacuation.
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'Techncial Support Center
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The drill scenario was non-mechanistic and overly simplistic
and did not present a significant challenge to the plant staff, particularly the operating group. The operators were easily able to find a way to terminate the release by simple cool down, alleviating the need for repairing the valve forseen by the scenario designers.
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The challenge to the health physics staff was also not significant.
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It essentially required proper reading and intrepreta ion of high range instruments in terms of release rate, translating this source term into a projected dose, and recommending the appropriate emer-gency condition to the Site Emergency Director (SED). The approp-riate condition (General Emergency) was chosen and an evacuation
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recommendation covering three downwind sections was made to the state. The recommendation was flawed in that it did not include all sectors in the near field (out to 2 miles) where wind vagaries i
and time constraints dictate evacuation regardless of wind direc-tion.
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There was some delay (17 minutes) between high effluent monitor alarms (0911 real time) and the decision to declare a General Emergency (0928). There was an additional 17 minute delay until
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the PA announcement was made (0945). Similarly, there was a 20 minute delay between the SED's decision to evacuate nonessential personnel (0943) and implementing with a PA announcement (1003)
onsite. Uncertainties about the extent of realism to be used in the exercise regarding PA announcements probably contributed to the delay but even so, the overall time of 52 minutes was overlong.
In addition, the evacuation announcement, when made, did not carry enough information. While the onsite evacuation route (the normal access road) was specified, no instructions were given about avoid-ing the plume.
Persons driving north along the Blue Star Highway would have driven through the plume. There was also no evidence to observers in the TSC that anyone was set to control traffic outside the plant.
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The Technical Support Center (TSC) is inadequate to support an l
extended emergency.
It consists of a viewing gallery and three small adjacent offices.
It was small, crowded, and lacked space
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to display information via status boards, screens, etc.
There was no official clock designated for the drill and none was within sight of most people participating. The noise level which could have become a problem was kept to a reasonable level by the participants. Within the TSC, the chain of command and the assignments were well defined.
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Information handling was the principal weakness noted at the TSC.
The status board was a large message tablet kept chronologically.
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Trends were not plotted nor was information arranged or displayed in synoptic fashion via maps, building plan drawings, release pathway schematics, etc.
These are all devices that can and should be preplanned.
Instead, information regarding doses and dose rates, for example, was generally recorded on sheets of paper and retrieval of information was heavily dependent on the individual recording the data. The system worked reasonably well during this exercise but uould not have given a more complex and presumably more realistic scenario.
There was confusion as to which of two high range effluent read-outs belonged to the steam dump monitor and which to the stack monitor.
It was resolved by an unnecessary potentially significant exposure, and possibly dangerous entry to the roof near the steam dumps.
Entry to observe the leaking valve was apparently made in paper coveralls and with a conventional filter respirator rather than SCBA which was indicated by the known offsite doses and by resonable prudence. The briefing for this entry included the admonition to limit dose to 25 rems.
It appeared to the obser-vers that authority for setting this dose did not come from the Site Emergency Director (SED) as required.
The briefing and direction for this entry came from the TSC, not the OSC as would be normal. There appeared to be no debriefing of the accompanying health physics technician as to dose rate i
conditions met in the course of this entry.
It is important that such information not be lost.
The lapse (approximately 20 minutes) between an announced primary coolant value of 350 uCi/g dose equivalent I-131 and the request for a confirming resample appeared to be too long.
There was no check made of personal dosimeters for people in the TSC/ control room area. This should be added to the assigned health physics technician duties in procedure E-41.
There were some communications problems such as limited range of radios from the OSC to the offsite monitoring teams (requiring control for the TSC), the failure of some TSC telephones to ring on incoming calls, and the failure of the NRC red phone to work initially. The latter difficulties were adequately surmounted; however, telephone head sets are recommended for key telephone circuits. The problem of radio range can be solved by use of an effective antenna system to replace the hand set attached units that were being used.
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c.
Interim Emergency Operations Facility (EOF) (Jackson, MI)
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The inspector observed the activation and operation of the interim EOF. This EOF is located on the first floor of the Consumers Power corporate building located in Jackson, Michigan, which is approximately 100 miles from the plant.
At approximately 0800, it was determined to activate the EOF and licensee personnel began to arrive.
Full activation was not evident until 0845. This is much too slow. The EOF should be fully staffed in about 5 to 10 minutes during normal working hours and no longer than one hour for offhours cases.
The major reasons for not achieving timely activation of the EOF were:
(a) inadequate training of personnel (b) no formal organization status board and sign in status board (c) inadequate scenario to demonstrate capabilities (d)
lack of human factor engineering relevant to desk and office identification of major functions and tasks particularly for the communication functions to the State and from the TSC.
Due to an ineffective scenario, both the reactor safety and engineering support groups were not exercised and their cap-abilities were not demonstrated.
The interim EOF did not supervise or direct the offsite monitor-ing teams. This function was implemented from the site TSC.
However, plant personnel were dispatched to the near-site EOF (South Haven) and they eventually took over this task. The interim EOF must be capable of directing the offsite monitoring teams within one hour or as soon as possible after declaration of an emergency thus relieving the TSC of this function.
Dose assessment function were implemented in a timely manner.
However, the TSC and EOF were both implementing this task. The EOF should relieve the TSC of this task as soon as possible.
Recommended protective measures due to the simulated release were made. They included a 0-2 mile evacuation in Sectors C, D and E and inplace sheltering from 2 to 10 miles in these down-wind sectors. This was not technically correct. Full radial evacuation should have been recommended for the 0-2 mile area.
This is a procedure problem which must be corrected.
During the simulated release, forecasting of possible changing meteorological conditions was not conducted by the licensee.
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This was primarily due to a procedure error. The Health Physics Team Leader procedure needs to be revised to reflect this task.
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The licensee has the capability to access site meteorological data and the capability to call up the National Weather Informa-
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tion Service which provides forecasting capability.
During the EOF activation, no periodic updates were verbally given to the EOF staff. However, status boards were kept up-to-date.
In general, the inspector determined that the following items must be corrected:
Retraining must be provided to all EOF staff personnel to
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ensure they are aware of the position location and functions.
Organization charts and sign-in charts, which will be highly
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visible, need to be provided to ensure timely activation of the EOF.
Communication capability with site environs teams needs to
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be established from the EOF.
Interim EOF procedures must be submitted to the NRC in
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accordance with 10 CFR 50, Appendix E.
d.
Near-Site Emergen y Operations Facility (South Haven)
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The near-site EOF was not truely tested during this exercise because the EOF staff dispatched from Jackson, Michigan, did l
not arrive until noon time.
By this time, the scenario was winding down and the EOF staff had nothing to do.
The delay was primarily due to a malfunction landing gear on the plane which was used to transport the staff.
Site personnel were dispatched to this EOF and implemention offsite surveys was directed at 10:30 a.m.
However, survey team results were not posted or analyzed, but instead were relayed back to the TSC.
This is unacceptable. Offsite survey team supervision, direction, data acquisition and analyses must be conducted from the EOF within one hoar after declaration of an emergency requiring activation of the EOF. Further this data must be communicated to cognizant offsite authorities from the EOF.
e.
Operations Support Center (OSC)
Several problems were noted in the Operations Support Center (OSC)
which was originally established primarily in the lunchroom of the Services Building. Most were the result of poor communications and information management. The public address system was barely audible in the OSC.
General noise levels at times interferred with the leader's ability to communicate by telephone, intercom, and radio.
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There appeared to be little or no debriefing of survey teams and no established procedure for recording in-plant survey results
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although the OSC 1cader was able to provide survey results when requested. No status board was used and verbal status updates were given infrequently. There was some confusion as to what area (s) constituted the OSC. Originally the center was established in the lunchroom of the Services Building. An area approximately one floor above the lunchroom was also referred to as the OSC in the emergency plan. Shortly after the scenario called for the release to begin, the OSC was ordered to evacuate to an alternate site in the Feedwater Purity Building based on a high area radia-tion level in the upper OSC area. The apparent understanding in the TSC at the time was that the OSC had shifted operation
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to this upper area.
In fact operations were still based in the luncheon area where the scenario radiation Icvols were low (5 mrems/hr). The evacuation took more than 30 minutes to complete. At the new OSC site radio.ommunications with survey teams were very poor. There was confusion as to how many radios were available and who had possession of them. The OSC lost all communication with survey teams that went out of the plant.
Several other problem areas were also noted. An inexperienced technician was one of two people sent to survey an area of potent-fally high radiation. After the transfer of the OSC to its alter-nate site, habitability was monitored periodically by collecting
air samples. Continuous monitoring was done only haphazardly.
Generally all survey instruments were turned off.
At one point two people were sent out to check on the out of plant survey teams since the OSC radio communications were lost. This secondary team was not issued survey instruments although a General Emergency was in effect and the team was to drive approximately under the plume. The use of high radiation dosimetry and KI capsules was not addressed. The issuing of equipment appeared to be poorly managed and at times there was a scarcity of survey instruments.
Before any official announcement of a downgrading of the exercise, personnel'in the OSC were accurately speculating as to when the exercise would end. This suggests that the scenario was too predictable.
f.
Post-Accident Sampling and Analysis The post-accident sampling and analysis teams were under the immediate direction of a team manager who reported to the OSC controller.
Following a preliminary briefing by the team manager regarding plant status and team member assignments, he and the teams were transferred from the OSC lunchroom assembly area to the cold laboratory for further briefing, sampling and analysis procedural review, and preparation for entry into the sampling area. This preparation included dressing out in anti-contamina-tion clothing and respiratory protection equipment, and collection r
of sampling apparatus and survey instrumentation. The total time for sampling and analysis, beginning with the initial request for
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a primary coolant sample, was approximately two and a half hours.
The sample was collected from the Nuclear Steam System Supplier (NSSS) panel according to interim post accident sampling procedures.
The licensee is currently in the process of upgrading the system to ensure sample collection within one hour from initial notifica-tion according to NUREG-0737 criteria; approximately two hours were required using the interim system. No air samples in the NSSS panel area were collected because of time limitations. A secondary coolant sample was collected and analyzed prior to that of the primary system, this collection was not observed by an NRC representative.
In general, the actual sample collection time was minimized and health physics procedures appeared adequate; exceptions and general observations are as follows:
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Communications between the OSC controller and the team manager were poor.
Initially, sampling team members were directed by the team manager to enter the sampling area wearing anti-contamination clothing and full face masks fitted with iodine cartridges; just prior to entry, the OSC controller ordered self-contained breathing apparatus (SCBA) and raingear. This resulted in a twenty minute delay.
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Radiation / chemistry technicians need. SCBA training. One tech-nician entering the sampling area did not appear to know how to adjust his face mask and required assistance; he also removed his SCBA prematurely near the NSSS panel, a potential airborne area based on simulated readings of approximately 150-250 mrem / hour.
No remote handling tools were used, particularly for the
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diluted sample during transport for analysis and storage.
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Inplant/Offsite Survey Teams TWo survey teams were dispatched from the OSC at 0930. The inspector accompanied the onsite out-of plant team.
Surveys were performed on the access road and at locations directed by the TSC.
Supervision and direction of the survey teams (out-of plant) was still being implemented from the TSC.
Offsite survey teams were dispatched using 8) x 11 inch maps.
These maps were small scale and not sufficiently detailed to indicate side roads, landmarks, etc., which would be necessary for proper survey team direction.
OSC radio communications to the survey teams failed and caused the TSC to dispatch the teams.
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The survey teams performed adequately and would have located the plume had it been a real event.
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6.
Exit Interview
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The inspectors met with licensee representatives (denoted in Para-graph 1) at the conclusion of the exercise on February 23, 1982.
An additional exit interview was held in Region III NRC Office on March 5, 1982, with Messrs.
M. Jury, W. Miller, R. Krich, and C. Snow of your staff.
During the March 5, 1982 exit interview, the deficiencies listed in Appendix A were discussed in detail.
Scenario development and approval wcs also discussed for the upcoming Big Rock Point exercise scheduled tor April 6, 1982.
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Attechment 1
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EMERGENCY EXERCISE CHRONOLOGY WITH TSC MESSAGES
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Time Event / Message Emergency Class / Expected Actionc
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05h5 High activity in the Primary Coolant Unusual Event System
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Notify Duty & Call Sunt.
fjessagetoShiftSupervicor:
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Notify Power Controller This is an Exercise - Sampling of 3.
Notify NBC primary coolant indicates specifi
Notify Van Buren Sheriff i
activity of 100 uCi/g dose equivalent 10.
Notify Michigan State Police I-131 has been greater than 1.0 uC1/g
Notify Chem /HP Supt
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for the past 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
Failed fuel mon-38.
Notify Public Affairs Director itor (RIA-0202) hac gone off scale.
THIS IS AN EXERCISE" Initiate plant chutdown due to Tech Spec specific activity limit.
- Numberc refer to Attachment 2 of EI-2 Emergency Action Checklist 0700 Shift Augmentation Unusual Fvent continuec Mescage to Shift Supervisor:
Perform chift augmentation to test time required to meet UUREG 0654
" - THIS IS AN EXERCISE" - You have
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not determined the cauce of the high
activity in the Primary Coolant System and have decided to begin shift augmen-tation to provide technical support.
Augmentation callc will be made to personnel scheduled for "B" chift the day of the exercice. General Office personnel are provided to make these calle for the SS - THIS IS AN EXERCISE" 0800 Increased activity in the Primary Alert Coolant System PCS activity indicates a cevere losc of fuel cladding.
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I S N RCISE - Sampling of primary coolant system indicates speci-
Notify Van Buren Sheriff fic activity of 350 uCi/g dose equiva-10.
Notify Michigan State Police lent I-131.
-THIO IS AN EXERCISE -
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Notify Chem /HP Sunt 18.
Notify Property Protection Sur
Establish TSC 20.
Establish OSC 22.
Initiate on-site monitoring 2h.
Provide 15-minute updates
Meteorological data - obtain &
analyze 32.
Perform personnel accountabilit 38. Notify Public Affairs Director
- Non-Darticipating personnel will return to work after accountability chec., '
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Time Event / Message bergency Class / Expected Action
0900 Turbine & Reactor Trip.
Alert continues 22.
On-site monitoring continues Message to SED from SS:
2h.
15-minute updates continue
"THIS IS AN EXERCISE - A
Analysis of met. data turbine trip has occurred. The continues.
Main Steam Isolation Valves (MSIV's)
have isolated. Atmospheric steam dump valves have opened - THIS IS AN EXERCISE".
0901 Message to SED frcm SS:
"THIS"IS AN EXERCISE - The reactor has tripped. - THIS IS AN EXERCISE."
0915 Message to SED from SS:
General Emercenev
"THIS IS AN EXERCISE - The high radio-2.
Notify Powe.'- Controller
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activity alarm on the steam generator 3.
Notify NRC blowdown monitor has sounded (RIA-0707).
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Notify G0 Control Center Condenser off-gas monitor high radio-
Notify Van Buren Sheriff activity alarm has sounded (RIA-0631).
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Notify Michigan State Police THIS IS AN EXERCISE" 11.
Notify Michigan Dept. of Healt 17.
Notify Chen/HP Supt.
Message to SED after the high range 18.
Notify Property Protection Su; steam dump monitor is checked:
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Establish EOF
"THIS IS AN EXERCISE - High range 22.
Continua on-site monitoring steam dump monitor indicates a reading 23.
Initiate off-site monitoring of 12 mrem /hr.
High range stack 2h.
Continue updates monitor indicates a reading of 1
Provide dose estimates.
mrem /hr - THIS IS AN EXERCISE."
Analyre met. data.
Message to SED from SS:
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Analyze effluents 28.
Provide release & dose projec-
"THIS IS AN EXERCISE - Containment tions pressure is normal.
Containment radia-33.
Evacuation of non-essential tion monitors read normal levels - THIS p s eP IS AN MCISE
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Notify Public Affairs Directo:
- Simulated 0925 Release continues.
Have maintenance initiate repair Message to SED from the SS:
"THIS IS AN EXERCISE - An automatic l
atmospheric steam dump valve (POS 0780)
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has failed to seat. A manual atmospheric steam dump valve (104 MS) has broken l
preventing us from stopping the release l
THIS IS AN EXERCISE ".
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. Time Event / Message Emergency Class / Expected Actions 1115 Release ends.
Consider downgrading of exercise.
Message to TSC Maintenance from repair crew (given by TSC exercise controller):
"THIS IS AN EXERCISE - The manual atmospheric steam dump valve has been re-paired. The valve has been closed - THIS IS AN EXERCISE.
1200 End of exercise for plant personnel.
1130 EOF (near site) staff arrive.
Establish communications links with plant, GO, and offsite agencies.
Participate in recovery re-entry phase with offsite agencies.
1300 Exercise Terminates.
1330 Critique of exercise.