IR 05000269/1993008
| ML16148A754 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/23/1993 |
| From: | Barr K, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML16148A755 | List: |
| References | |
| 50-269-93-08, 50-269-93-8, 50-270-93-08, 50-270-93-8, 50-287-93-08, 50-287-93-8, NUDOCS 9304060178 | |
| Download: ML16148A754 (12) | |
Text
REG(4 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-269/93-08, 50--270/93-08, and 50-287/93-08 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Docket Nos.:
50-269, 50-270, 50-287 License Nos.:
DPR-38, DPR-47, DPR-55 Facility Name:
Oconee Nuclear Site Inspection Cond cted:
March 1-5, 1993 Inspector:
J..Krehi adiation Specialist Date Signed Approved by:
K. P!.'Barr, S'hie{
-
5i Ba i-eate Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards SUMMARY Scope:
This routine, announced inspection was conducted to assess the operational readiness of the site emergency preparedness program, and included selective review of the following programmatic areas: (1) Emergency Plan and associated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3) organization and management control; (4) training; and (5) independent and internal audits and review Results:
In the areas inspected, no violations or deviations were identified. Program strengths included an aggressive schedule of training drills, involving annual participation in the Control Room simulator by each of the five Operations shifts (two of these drills each year entail off-hour recall of the emergency response organization); strong management support; and well-designed and maintained emergency response facilitie Areas for potential program improvement were identified to the licensee as follows:
(1) Clarifying certain commitments/requirements in the Emergency Plan and its implementing procedures (Paragraph 2).
(2) Improving management oversight of the training program for the emergency response organization (Paragraph 5).
9304060178 930323 PDR ADOCK 05000269 G
REPORT DETAILS Persons Contacted Licensee Employees
- H. Barron, Station Manager P. Brandt, Technical Specialist, Emergency Planning
- R. Brown, Senior Technical Specialist, Emergency Planning
.*J. Davis, Manager, Safety Assurance T. Grant, Technical Specialist, Emergency Planning
- KJ. Hampton, Vice President, Oconee Nuclear Site,
- C Jennings, Manager, Emergency Planning 0. Kohler, Operations Shift Superviso *M. Patrick, Manager, Regulatory Compliance
- B. Peele, Manager, Engineering
- S. Perry, Assistant Licensing Coordinator J. Price, Operations7 Shift Supervisor P. Stovall, Director, Operator Training Other li-censee employees contacted during this inspection included operators, security force members, technicians, and administrative personne Nuclear Regulatory Commission
- B. Desai, Resident Inspector
- A. Gibson, Director, Division of Reactor Safety, Region II I P Harmon, Senior Resident Inspector
- A.. Herdt, Chief, Reactor Projects Branch No. 3, Region II
- D. Matthews, Director,, Project Directorate 11-3, Office of Nuclear Reactor Regulation
- L.,Wiens, Licensing Project Manager, Office of Nuclear Reactor Regul ati on
- Attended exit interview on March 5, 1993 Abbreviations used throughout this report are li-sted in the last paragraph, Emergency Plan and Implementing Procedures (82701)
This area was inspecte 'd to determine whether significant changes were made in the licensee's emergency preparedness program since January,1992
(the date of the last inspection of this area), to-assess the impact of any such changes on the overall.,state of emergency preparedness at the
facility, and to determine whether the licensee's actions in response to actual emergencies were in accordance with the Emergency Plan and its implementing procedures. Requirements applicable to this area. are found in 10 CFR 50.47(b)(16), 10 CFR 50.54(q), Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla The inspector reviewed the licensee's system for making changes to the Emergency Plan and the EPIPs. Through selective review of applicable documents, the inspector confirmed that licensee management approved revisions-to the Emergency Plan and EPIPs, as required. Copies of the Emergency Plan, EPIPs, and Emergency Telephone Directory (latest revision dated February 26, 1993) available for use at the CR, TSC, OSC, and EOF were selectively checked and found to be current revision The version of the Oconee Emergency Plan in effect at the time of the current inspection was.Revision 93-1, dated March 1, 199 The licensee had made a total of four revisions to the Emergency Plan since the aforementioned January 1992 inspection (viz., Revisions 92-2, 92-3, 92-4, and 93-1).
The NRC's formal licensing reviews of these changes were pending at the time of the current inspection. Discussion with the EPM and selective review of the Plan disclosed that several significant programmatic modifications had been made via the subject revisions as a result of the Duke Power Company reorganization which occurred on November 1, 199 These included: (1) incorporation of emergency planning information and commitments which were previously located in the corporate emergency plan, which was known as the Crisis Management Plan; (2) the associated transfer of overall authority and responsibility for emergency planning from the corporate headquarters to the site; (3) redistribution of certain emergency response functions between the TSC and the EOF; and (4) the designation of the Shift Manager to provide initial expertise in the area of core/thermal hydraulics until the TSC is operationa During this inspection, the inspector did not identify any decrease of the effe ctiveness of the licensee's Emergency Plan caused by these and other changes. However, the NRC's review of the Plan changes has not been completed. That review will be the subject of separate correspondenc The inspector's selective review of the Emergency Plan noted the following statements in Section B.5:
"The TSC and OSC will be activated within 75 minutes. The EOF...
will be staffed and operational by a minimum staff within 75 minutes."
The inspector asked the EPM to explain the phrase, "within 75 minutes", since the Plan contained no specifics as.to the manner in which time t=0 was determined for the 75-minute period. The EPM stated that the intent (and practice) at Oconee had always been to "start the clock" upon declaration of an Alert or higher emergency clas The EPM also noted that procedures RP/0/B/1000/19 and /20 (applicable to the TSC and EOF, respectively)
clearly specified that the subject 75-minute period commenced upon declaration of the emergency class which warranted facility activatio The EPM agreed to add a statement in the next revision of the Emergency Plan to clarify the licensee's planning basis in this regard. Such a change would neither increase nor decrease the effectiveness of the Plan, but would simply elucidate the licensee's existing commitments in
this are Revisions to the EPIPs since January 1992 were discussed with the EP Various changes were made to upgrade and/or clarify the EPIPs, including several modifications to the EALs in procedure RP/0/B/1000/01,
"Emergency Classification."
(The NRC's formal evaluation of these EAL changes will be encompassed in the previously referenced reviews of revisions to the Emergency Plan.)
Completion in February 1993 of the ERDS communications link.with the NRC Headquarters Operations Center required the creation of a new Enclosure 4.4, addressing ERDS operation, for each of procedures RP/0/B/1000/02 through /05 (see Paragraph 3 for additional information regarding ERDS).
The inspector's review of these and other selected EPIP changes disclosed none that decreased the effectiveness of the licensee's emergency preparedness program or response capabilit The inspector reviewed records pertaining to the two emergency declarations made between January 1, 1992 and the date of the current inspectio Both were classified at the NOUE-level, and are summarized as follows:
TIME DECLARED/
DATE TERMINATED DESCRIPTION OF EVENT 09/30/92 4:10 p.m./4:10 Shutdown of Units 1 and 2 initiated per TS /19/92 10:25 p.m./
Unit 2 reactor trip due to loss of 10/20/92 3:25 offsite.power caused by switchyar maintenance activities The inspector's assessment concluded that both of the events described above were correctly classified based on the licensee's EALs, and that notifications thereof to State and local governments and the NRC were made in accordance with applicable requirements. However, it was noted during this review that the NOUE declaration on September 30, 1992, occurred nearly two hours after the event which resulted in the applicable EAL being me The EAL used for this classification was
"Unit shutdown initiated per TS 3.3 (ES Systems)," as contained in Enclosure 4.1.10 to EPIP RP/0/B/1000/01. The inspector reviewed the completed documentation for this EPIP, as well as LER No. 269/92-12, which indicated that shutdowns of Unit 1 and Unit 2 began at 2:18 and 4:00 p.m., respectively, on September 30, 1992. A NOUE was declared at 4:10 p.m., after shutdown of Unit 2 had commence (Units 1 and 2 were shut down in response to reaching the end of the 24-hour period associated with the LCO entered on the previous 'day at 3:10 following a determination of LPI cooler inoperability per TS 3.3.2.a(2).)
Section D.2 of the Plan stated,, "A classification procedure, RP/0/B/1000/01, will be utilized by the Emergency Coordinator to classify events as they occur."
Step 2.1 of that procedure stated,
"Compare actual plant conditions to the Emergency Action Level(s)
then declare the appropriate Emergency Class as indicated."
Since the criteria of the EAL quoted previously were satisfied when the Unit 1 shutdown began at 2:18 p.m., the inspector determined that the licensee failed to adequately implement the Emergency Plan and the EPIPs. The
licensee's untimely declaration of a NOUE (112 minutes after the applicable EAL criteria were satisfied) represented a apparent violation of the Emergency Plan and EPIP requirements cited above. Although the emergency preparedness staff routinely reviewed the response to each emergency declaration in an effort to identify problems or inconsistencies which may have occurred with respect to the requirements of the EPIPs, the untimely declaration of the subject NOUE was not identified as a problem by the license On March 18, 1993, during a telephonic conference between licensee management representatives and NRC Region II staff regarding the apparent violation, additional information was provided by the licensee in reference to a request made to the NRC on September 30, 1992 at 1:00 p.m. for a Temporary Waiver of Compliance from TS 3.3.2.a. The specific additional information which had not been provided by the licensee during the onsite phase of the inspection was that the September 30 teleconference involved a detailed discussion of the operational issues and the NRC's full understanding of the licensee's intended course of action. This teleconference was followed by a written request from the licensee and the NRC's formal approval of the Waiver in a letter dated October 1, 1992. This letter granted a Temporary Waiver of Compliance for 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> from 3:10 p.m. on September 30, 199 The licensee's position, as expressed in the March 18 teleconference, was that the "shutdowns" of Units 1 and 2 on September 30 were actually power reductions which were not intended to take the units to shutdown, and therefore did not meet the intent of the subject EA The licensee stated that this information was not accurately reflected in the LER referenced above. The inspector confirmed the additional information provided by the licensee through interviews with Region II personnel and-review of the relevant correspondence. As a result, NRC Region II management determined that the proposed violation discussed above had not occurred-.
Section A.3 of the Emergency Plan specified the organizations with which the licensee maintained letters of agreement, and stated that these agreements "shall be updated as necessary and at least every three (3)
years... " Copies of the agreement,letters, as displayed in Appendix 5, were found to be current. The licensee was in the process of updating the ten agreements which.were dated in May 1990; ten other letters o agreement were.dated 1991 or later, and would not be updated during 1993 unless necessitated by organizational or other unforeseen change The licensee conducted the required annual review of EALs with governmental authorities during calendar year 1992 through the-issuance of letters dated December 7, 1992 to the State of South Carolina Emergency Preparedness Division, Pickens County Emergency Management Agency, and Oconee County Emergency Preparedness Agency. Each of the three agencies responded in writing by December 30, 1992, certifying review of, and concurrence in, the EALs for the Oconee Nuclear Statio No violations or deviations were identifie.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
This area was inspected to determine whether the licensee's ERFs and associated equipment, instrumentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes in this area upon the emergency-preparedness program. Requirements applicable to this area are found in 10 CFR 50.47(b)(8) and (9),
10 CFR 50.54(q),Section IV.E of Appendix E to 10 CFR Part 50, and th licensee's Emergency Pla The inspector toured the licensee's ERFs, which included the CR TSC, OSC, and EOF. Selective examination of emergency equipment, supplies, and communications systems located in these facilities indicated that the licensee was maintaining an adequate level of operational readiness for responding to an emergenc The TSC and OSC, located adjacent to.the Units 1 and 2 CR and the Unit 3 CR, respectively, were both relatively small, but had been steadily upgraded and refined during the past several years to maximize use of the available space. Recent equipment additions included large-screen overhead monitors in both facilities for the display of plant data. The TSC was within the ventilation envelope of the CR for Units 1 and 2, and therefore had no separate emergency ventilation syste The EOF was located in Clemson, SC, about 10 miles from the site. It was a spacious and well-designed facility which had become operational about two years ago. Revision 92-2 of the Emergency Plan effected a change of name of this facility from Crisis Management Center to EOF in order to achieve consistency with the terminology used by the NRC and the nuclear industry. During the inspector's tour of the EOF, licensee personnel conducted an impromptu test of the emergency generator by opening the main electrical circuit breaker for the facility. The inspector observed that the propane-powered generator was able to start and accept load within approximately 3 seconds of the breaker-openin The inspector noted that the gauge on the propane fuel tank indicated about 65% of capacity; a full tank would provide enough fuel for 24-36 hours of generator operation, depending upon load, according to a licensee representative. A battery backup system at the EOF was designed to power the entire telephone system for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> even if the emergency generator did not function. A system of 12 designated "power failure" telephones was in place to allow for limited communications capability if the telephone battery backup system faile Inspection of the battery backup system hardware, located in the telephone wiring/switching room, determined that the system included no local indication (such as a "power on" light) to confirm operability, and the
"charge/discharge" meter read zero. Thereforeivisual observation alone could not determine whether the.system was in a normal standby status or totally inoperable. Although the inspector was informed that inoperability of this system would be indicated at a 24-hour Security station at the corporate office in Charlotte, NC, the licensee planned to consider whether to modify the battery backup system to provide a positive local indication that the system was at least energize The inspector reviewed the status of the ERD The EPM informed the inspector that the ERDS for Oconee was declared operational on February 16, 1993, following an acceptance rud of several hours in which the data link with the NRC Headquarters Operations Center was established and validated. The licensee planned to begin quarterly testing of the ERDS (as required by Section VI.1 of Appendix E to 10 CFR Part 50) starting in the second quarter of 199 The inspector reviewed the operational readiness of the Alert and Notification System. This system included 60 -fixed sirens (33 in Oconee County, 27 in Pickens County) in the 10-mile EPZ around the Oconee Nuclear Site. The system was upgraded during 1992 to provide computerized feedback regarding each siren's operation during any mode of testing or actual activation. The inspector reviewed a FEMA-required Siren Availability Report for 199 This report, dated January.17, 1993, showed an overall siren availability of 99.26% in 199 This availability factor -included results of all siren testing for 1992 (i.e., silent, growl, and full-cycle modes).
The inspector noted siren availability based on the quarterly full-cycle tests only indicated an availability factor of 97.9%. The inspector reviewed documentation of the annual preventive maintenance program for the sirens, which was performed by the licensee's Commodities and Facilities group during May 199 With very few problems disclosed by this program, it appeared that the siren feedback system was successfully identifying operability problems-so that corrective actions could be promptly implemente Based upon ERF walk-downs, review of changes to the EPIPs, inspection of selected emergency equipment and supplies, and statements by licensee representatives, the inspector concluded that no degradation of ERF capabilities had occurred. since January 199 No violations or deviations were identifie.
Organization and Management Control (82701)
This area.was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on the emergency preparedness program, and to verify that any such changes were properly factored into the Emergency Plan and EPIP Requirements applicable to this area are found in 10 CFR 50.47(b)(1) and.(16),
Section IV.A of Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla The organization and management of the emergency preparedness program were reviewed and discussed with licensee representatives. The corporate reorganization, effective on November 1, 1991, resulted in the transfer of responsibility for emergency preparedness from the corporate office to the licensee's three nuclear sites. Concurrent with this transfer of responsibility was the relocation of many corporate
functions and personnel to the site. Analogously, many ERO functions were shifted from the [OF (formerly at the corporate headquarters) to the TS The inspector reviewed these changes and noted that the totality of functionsoperformed by the ERO did not change, but only the locations o~f the persons performing those function The individual serving as EPM had been in that position for ten years and reported directly to the Safety Assurance'Manager, who in turn reported to the Site Vice President. These factors helped to provide a measure of assurance that emergency preparedness at the Oconee Nuclear Site would receive appropriate management attention and would have good
"visibility"r to site personne The inspector reviewed the licensee's management strategy for ensuring compliance with the Emergency Plan requirements addressing the planning standard of 10 CFR 50.47(b)(2), which specifies that "timely augmentation of response capabilities is available." The applicable Emergency Plan requirements were contained in 'Section N.2.g, which specified semiannual drills to test the response time of the ERO. This commitment was fulfilled during 1992 by means of off-hour 'drills conducted on April 21 and November 1 With one exception, activation times for the TSC, OSC, and [OF were well within the 75-minute requirement (see Paragraph 2).
The exception occurred during the second drill when 119 minutes were needed for the EOF to achieve activatio The required personnel were in place at 63 minutes after the applicable declaration, but turnover was delayed because the offsite communicators were not ready to transfer their. function from the TSC to the [O (The licensee had implemented corrective action in an effort to prevent recurrence of such a delay.) In addition, the licensee conducted a weekly unannounced pager test (usually on Tuesday or Wednesday evening)
to verify the availability of personnel listed on the Weekly Duty Roster to staff the minimum required positions for the TSC, OSC, and [O This weekly off-hour test involved only no tification of [RO personnel and determination of their availability, and did not include actual reporting to the site.. This was a management control strategy which was not required by the Emergency Pla The results of these weekly tests conducted during 1992 provided the licensee a high level of confidence that the [RFs could be staffed during off-hours in accordance with Emergency Plan commitment No violations or deviations were identifie.
Training (82701)
This area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilitie Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15),Section IV.[ of Appendix [ to 10 CFR Part 50, and the licensee's Emergency Pla The licensee maintained the Emergency Response Training Manual, which is referenced in Section 0.5 of the Emergency Plan as the governing document for such training. The status of the training program was evaluated by selecting names of 19 ERO personnel from the Weekly Duty Roster and reviewing individual records to verify that applicable training requirements were being implemented. This review disclose that, for the sample of personnel in question, the required training had been provided and was current, based on the criteria contained in the Emergency Response Training Manua The inspector reviewed the licensee's training objectives and associated lesson plans for several key ERO positions. The training material content appeared appropriate relative to the need to address the duties and responsibilities of each of the selected position The review of training records included a discussion and audit of the licensee's methodology for tracking the retraining of ERO personne The inspector noted that the licensee had in place a computer-based system which included (for each person) name, ERO assignment, required training module(s), and last date(s) of training. However, this system as presently configured was not an effective management tool for insuring that retraining was completed prior to the specified expiration date (15 months from last training for a given module) because it did not include a method of "flagging" names of individuals whose training was close to expiring. The inspector and the EPM discussed various approaches to modifying the subject tracking system to enhance management oversight of the training program bysaverting expired ERO training. The EPM stated that this matter would be considered as a possible area for program improvemen In an effort to gauge the effectiveness of the emergency response training program, the inspector conducted an-interview with one OSS, the position designated as interim E This interview was designed to ascertain the (potential) EC's understanding of emergency classification, offsite notifications and PARs, site evacuation, emergency worker dose limits, and nondelegable responsibilities of the E This 75-minute interview began with technical questions relating to the duties, responsibilities, and functions of the EC during an emergency situation, and then presented four accident scenarios that required event classification and PAR formulation, as appropriate. The inspector delineated the guidelines for the interview at the outset, including the "open book" nature of the evaluation. The EPM was present during the interview to allow for confirmation and firsthand understanding of observations. The OSS was judged to have demonstrated an adequate understanding of his duties and responsibilities in the event of an emergency. All emergency classifications and PARs were timely and correct. No concerns were identified during the intervie The inspector reviewed the licensee's assessment and documentation of ERO performance during the ten emergency response training drills conducted in 1992. Of these -ten, three were site assembly drills, one was an Appendix R (fire) drill, and one was a limited function involving loss of offsite power. The remaining five drills (one of which was th annual NRC-evaluated exercise) formed the core of the ERO'training program, and allowed for participation by allfive Operations shifts, in each case using the CR Simulator to drive the drill play. Two of these commenced during off hours, as discussed in Paragraph 4, abov Following every ERO drill, the EPM prepared a detailed critique which was ultimately distributed to the entire ERO in the form of an "Critique Summary Report" from the Site Vice President.1 This appeared to be a very effective method of conveying information to the ERO regarding
"lessons learned" from drills. The inspector determined that the licensee's drill critiques identified substantive issues for corrective action and that the licensee was monitoring the status and progress of such planned corrective actions. The inspector reviewed the critique records for indications of repetitive performance problems during 199 No adverse trends were identifie The Oconee drill schedule for 1992, as delineated above, was very aggressive. The level of dedication of the licensee's resources to maintaining and improving emergency response capabilities was considered indicative of station management's commitment to the emergency preparedness progra No violations or deviations were identifie.
Independent and Internal Reviews/Audits (82701)
This area was inspected to determine whether the licensee had performed an independent audit of the emergency preparedness program, and whether the emergency planning staff had conducted a review of the Plan and the EPIPs. Requirements applicable to this area are found in 10 CFR 50.54(t) and the licensee's Emergency Pla The inspector reviewed reports documenting the most recent annual independent audit of the emergency preparedness program. This-audit was conducted by the licensee's Quality Verification Department during the period November 16 -December 8, 1992, and was documented in Audit Report No. CM-92-01 (ALL). This was a company-wide audit which examined the emergency response capability for the licensee's three nuclear stations and the General Office in Charlotte, N The inspector determined that the audit teams utilized qualified personnel, including some with emergency planning experience. The audit checklists were comprehensive and detailed, and encompassed appropriate emergency preparedness procedures, regulatory requirements, and guidance. The audits scrutinized the implementation of the Emergency Plan and EPIPs, training, drills and exercises, facilities and equipment, interfaces with offsite agencies, and program documentation. No audit findings or follow-up items were identified regarding Oconee. A licensee letter dated February 2, 1993 transmitted a copy of the subject audit report to the State of South Carolina and Oconee and Pickens Countie The most recent annual internal review of the Emergency Plan was completed on December 31, 1992. This documented review identified several problems which were corrected in Revision 92-4 of the Plan. The
EPIPs were reviewed and documented individually by the cognizant station organization (e.g., Radiation Protection, Operations, etc.).
These reviews appeared to be effective in meeting the intent of the Emergency Plan requirements in Sections P.4 and No violations or deviations were identifie.
Licensee Action on Previous Inspection Findings (Closed) Violation 269, 270,'287/92-02-01:
Failure to maintain and distribute controlled copies of the EPIPs in accordance with Appendix 6 of the Emergency Pla The inspector reviewed the licensee's March 17, 1992 response to the Notice of Violation and verified the.implementation of the corrective.actions listed therei (Closed). Inspector Follow-up Item 269, 270, 287/92-02-03:
Revising matrix in Emergency Response Training Manual to accurately reflect module requirements for each ERO positio The subject matrix was revised to achieve consistency with Figure0-1 of the Emergency Pla.
Exit Interview The inspection scope and results were summarized on March 5, 1993, with those persons indicated in Paragraph 1. The inspector described the areas reviewed and discussed the inspection results in detail, including a proposed violation described in Paragraph 2 and two areas for possible program improvement listed in the "Summary" section of this repor Questions and dissenting comments were received from the licensee regarding the proposed violation. Although proprietary information was reviewed during this inspection, none is contained in this repor On March 18, 1993, the licensee telephonically provided additional information regarding the proposed violation. As discussed in Paragraph 2, NRC Region II management determined, following review of the additional information, that the proposed violation discussed during the onsite exit interview had not occurred. Licensee management was so informed on March 1.
Abbreviations Used in This Report CFR Code of Federal Regulations CR Control Room EAL Emergency Action Level EC Emergency Coordinator EOF Emergency Operations Facility EPIP Emergency Plan Implementing Procedure EPM Emergency Planning Manager EPZ Emergency Planning Zone
III ERDS Emergency Response Data System ERF Emergency Response Facility ERO Emergency Response Organization ES Emergency Safeguards FEMA Federal Emergency Management Agency LCO LimitingCondition for Operation LER Licensee Event Report LPI Low Pressure Injection NOUE Notification of Unusual Event NRC Nuclear Regulatory Commission OSC Operationa] Support Center OSS Operations Shift Supervisor PAR Protective Action Recommendation TS Technical Specification LSC Technical Support Center