IR 05000277/1992033

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Corrected Insp Repts 50-277/92-33,50-278/92-33,50-352/92-28 50-353/92-28 on 921123-25.Previously Missing Line from Page 8 of Original Rept Appears at Top of Page 9
ML20127J200
Person / Time
Site: Peach Bottom, Limerick  Constellation icon.png
Issue date: 12/11/1992
From: Laughlin J, Mccabe E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127J139 List:
References
50-277-92-33, 50-278-92-33, 50-352-92-28, 50-353-92-28, NUDOCS 9301250062
Download: ML20127J200 (23)


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TABLE OF CONTFK13 Persons Contacted . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - . . . . I Emergency Ex ercise . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 Pre-exercise Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-

        ~ .2 Exercise Scenario . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Activities Observed . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Exerche Finding Classifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Exercise Observations . . - . . . . . . . . . . . . . . . . . . . . . . . . . . - . . . . . . . . 4 Simulator Control Room (SCR) . . . . . . . . . . . . . . . . . . . . . . . . . . . 4- Technical Support Center (TSC) . . . . . . . . , . . . . . . . . . . . . . . . . . 5 Operational Support Center (OSC) . . . . . . . . . . . . . . . . . . . . . . . . 5 Emergency Operations Facility (EOF) . . . . . . . . . . . . . . . . . . . . . . . - 6 4.4.1 Protective Action Recommendations (PARS)  .............. 6-
  .4.4.2 Dose Assessment, Field Teams and Air Sampling . . . . . . . . . . . 7 Emergency News Center (ENC) . . . . . .................... 7 Previously identified items . . . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . 8
      . Emergency Action level (EAL) Change . . . . . . . . . . . . . . . . . . . . . . . . . . 10 _ Licensee Critique and NRC Exit Meeting . . . . . . . . . . . . . . . . . . . . . . . . 10 Attachments Licensee Agenda For Management Meeting with NRC Region I- Licensee Corrective Actions List
 ' Licensee Release Pathway Assessment Aids 9301250062 92i216 PDR ADOCK 05000277 g  .PDR
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DETAILS - Persons Contacted The following individuals attended the exit meeting on November 25,199 C. Adams, Emergency Preparedness Manager R. Bohner, Emergency Preparedness Instructor R. Ilrown, Supervisor, Site Emergency Preparedness R. Charles, Manager, Nuclear Support Division J. Clymer, Engineer, Chesterbrook Emergency Preparedness V. Cwietniewicz, Superintendent of Training J. Doering, Plant Manager J. Gerhart, Physicist, Emergency Preparedness M. Ilammaker, Emergency Preparedness D. IIelwig, Vice President, Limerick L. Ilopkins, Manager of Operations J. Jankauskas, Emergency Preparedness S Keenan, Supervisor, Chesterbrook Emergency Preparedness R. Kinard, Supervisor, Chesterbrook Emergency Preparedness S. Mainal, Nuclear Engineer, PA Bureau of Radiation Protection R. Mandik, Supervisor, Chesterbrook Ernergency Preparedness A. Mantey, Engineer, Chesterbrook Nuclear Maintenance T. McFadden, Supervisor, Dosimetry Branch N. McKenney, Senior Instructor, Chesterbrook Emergency Preparedness M. Moore, Emergency Medical Assistance Program J. Muntz, Technical Superintendent D. Oltmans, Director, Nuclear Chemistry A. Parducci, Limerick Emergency Preparedness D. RiFay, Nuclear Quality Assurance, Technical Monitor W. Russell, Limerick Emergency Preparedness Planner K. Schlecker, Physicist, Limerick Emergency Preparedness M. Shuler, Physicist, Nuclear Support Division D. Smith, Senior Vice President, Nuclear J. Waddington, Jr., Coordinator, Emergency Communications The inspectors also interviewed and/or observed the actions of other licensee personne .0 Emergency Exerrise The Limerick Generating Station (LGS) partial-participation exercise was conducted on November 24,1992, from 8:00 a.m. to 2:00 p.m. The Commonwealth of Pennsylvania partially participated in the exercise by sending representatives to the Emergency Operations Facilit Off-site activities were not inspecte _ - _ _ _____ _ _

. 2 Pre-exerrise Activities Exercise objectives were submitted to NRC Region I on August 21, 1992 and the complete scenario package on September 23, 1992 for NRC review and evaluatio Region I representatives discussed the scenario with the licensee's emergency preparedness staff on October 23,1992. The scenario was assessed as an adequate test of the major portions of the Emergency Plan and Implementing Procedure NRC exercise observers attended a lleensee scenario briefing on November 23,1992. The scenario was discussed in depth and all NRC observer questions were answered. The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in exercise activities to prevent disrupting normal plant activitie .2 Fxercise Scenario The scenario provided a challenging test of the LGS Emergency Response Organization's (ERO's) ability to analyze and mitigate a severe accident. Information in the scenario package was excellently presente The exercise scenario included the following simulated events:

* Initial conditions: Unit I was operating at 100% power for the last 150 days. IAw Pressure Coolant Injection loop 1 A, Standby Liquid Control Pump IC, and the Reactor Core Isolation Cooling System were out of service. Fuel pin leakage resulted in off gas noble gas activity of 700 uCi/sec, which increased after a recent rod shuffl * Increase in off gas activity to 5050 pCi/se * Break in a freeze seal supply line, resulting in release of nitrogen inside the power block, and an Aler * Clogged Control Rod Drive Pump suction Site e Spurious High Pressure Coolant Injection actuation due to a failed controller, resulting in minor clad damage, reactor scram, and Group I Main Steam Isolation Valve closur * Failure of Source Range Monitors and Intermediate Range Monitors to insert into the cor e Failure of Residual Heat Removal System heat exchanger I A inlet valve to ope e Steam Relief Valve failed ope * Total loss of annunciators (a Site Area Emergency).

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  • Trip of all condensate pumps due to ruptured discharge line.
  • Break in Residual IIcat Removal IB discharge line to the reactor vessel, resulting in a Loss of Coolant Accident.
  • General Emergency condition involving high drywell radiation.
  • Release of radioactive material from the drywell via a hydrogen recombiner, resulting in a stack release to the environment.
  • Exercise termination. Activities Observed The NRC observed the activation and augmentation of the Emergency Response Organization, activation of Emergency Response Facilities, and actions of emergency response personnel. The following were observed: Selection and use of control room procedures. Detection, classification, and assessment of scenario events. Direction and coordination of emergency response. Notification of licensee personnel and off-site agencies. Communications /information flow, and record keeping. Assessment of off site consequences, and protective action recommendations (PARS). Technical support, repairs and corrective actions. Communication with the media and the public. Accident analysis and mitigation.

1 Accountability of personnel.

I Post-exercise critique by the licensee. Exercise Finding Chtssifications Emergency preparedness exercise findings were classified as follows.

Exercise Strength: A strong positive indicator of the licensee's ability to cope with abnormal plant conditions and implement the Emergency Pla f Exercise Weakness: Less than effective Emergency Plan implementation which did not of itself constitute overall response inadequacy.

Area for Improvement: An aspect which did not significantly detract from the licensee's response, but which merits licensee evaluation for corrective actio . __

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. 4 Exercise Observations Activation and utilization of the Emergency Response Organization (ERO) and Emergency Response Facilities (ERFs) were consistent with the Emergency Plan and Emergency Plan Implementing Procedure The licensee used their control room siniutator in the dynamic mode. The lack of significant exercise control discrepancies (i.e. controller communications allowed timely removal of simulated faults based on player responses) showed attention to detail in scenario development and prediction of player responses, ne Vice President of Limerick was present in the ERFs during the exercise and the Senior Vice President, Nuclear, attended the critique and exit meeting, showing licensec management commitment to E .1 Simulator Control Room (SCR)

SCR operator response to simulated casualties was prompt and effective. Good teamwork was demonstrated. The crew quicidy recognized abnormal conditions such as the inadvertent liigh Pressure Coolant Injection System initiation, stuck open safety relief valve, failure of the source and intermediate range detectors to insert, and failure of two Low Pressure Coolant Injection System valves to open. Procedure use was excellent. Operators effectively established response priorities for equipmcr.t failure The Shift Manager (SM) and Shift Supcivisor (SS) exercised excellent command and contro The SM correctly classified the Alert, and notifications by the shift were timely. SCR internal communications and those with the Technical Support Center (TSC) were good. However, the SM did not inform his crew when he became the Emergency Director or when that duty was transferred to the TS The SCR controller noted that Procedure ERP-101, " Classification of Emergencies," was not l the correct revision. The correct revision was located and provided to the operators.

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The following exercise strengths were observed
* SCR command and contro * Prompt recognition of abnormal plant condition * Use of procedure No exercise weaknesses were observe The following area for improvement was identified:
* Assuring use of current procedures.

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5 Technical Support Center GSC) The TSC was prepared for use by procedure and activated in a timely manner. The Emergency Director (ED) briefed his staff and ensured status boards were up to-date before activation. The ED exhibited strong command and control. lie maintained good communications with the Simulator Control Room and the Emergency Operations Facility, conducted regular team leader meetings with his staff, and gave frequent and thorough briefings to facility personnel. The six team leaders provided excellent feedback that resulted in sound decision-making and proper establishment of priorities.

Event classifications for the Site Area Emergency and General Emergency were correct and notifications of off-site officials and the NRC were timely. Status boards were frequently updated and accurately presentated event data.

The following exercise strengths were observed: e ED command and contro o ED use of staff fnr decision-making.

No exercise weaknesses or areas for improvement were identified. Operational Suppod Center (OSC) OSC activation was timely. The OSC Coordinator (OSCC) demonstrated good command and control. Telephone and radio communications were timely for maintenance team coordinatio Sufficient personnel were available for plant needs, and the OSCC was proactive in dispatching teams for repairs and investigation.

The OSC demonstrated excellent accountability. Personnel were required to check in and out with the OSCC, who maintained a list of available people for maintenance and health phy:ics functions. Personnel also posted accountability cards on the OSC tagboard and carded in and out when entering and leaving. Further, personnel were logged in and out on the job assignment status boar The OSCC gave periodic briefings to OSC personnel, but these were brief and cursory. No information was provided on event classification, status of events, work priorities, recommended protective actions, or dispatched team updates. The OSCC was very busy with phone calls, radio communications, log-keeping, team brief' m gs, and facility briefings, in addition to command and control duties. Also, the only record of team briefings and debriefings was maintained on status boards, and no pernW,ent records were kep . . . - --

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The following strength was observed:

* Accountability of personne No exercise weaknesses were identified. The following areas for improvement were noted:
* Facility status briefing qualit * Number of duties assigned to the OSCC.

, o Permanent records of team briefings / debriefing .4 Ducrgency Operations Faellity'(EOI) Personnel staffed the EOF at the Alert level, and the facility was activated at the Site Area Emergency. The EOF was activated in a timely manner. The Emergency Response Manager (ERM) assumed control after a thorough turnover from the ED, providing a plant status update to EOF staff, and receiving reports from his team leaders that sufficient personnel were availabl , The ERM used his staff effectively to assess plant problems, core damage, and radiological conditions on-site and off-site. He interfaced well with the Dose Assessment Team Leader and the Dose Assessment Group Leader to keep them apprised of changing plant conditions, and thoroughly discussed protective action recommendations (PARS) with them before issuance. He frequently communicated with the Commonwealth of Pennsylvania representatives from the Bureau of Radiation Protection and Ge Emergency Management Agency by briefing them on plant conditions, discussing PAR declarations and their bases, and responding to requests for informatio The following exercise strength was identified: e ERM command, control, and communication There wuc no EOF exercise weaknesses or areas for improvemen .4.1 Protective Action Reconunendations (PARS) A Loss of Coolant Accident (LOCA) occurred at 1056. At 1110, drywell radiation levels reached 10,000 R/hr., leading to a General Emergency declaration. After thorough discussion with his staff, the ERM issued a PAR for evacuation of the two mile radius and five miles downwind. Four downwind sectors were selected based on a projected wind shift to the sout This PAR was consistent with federal guidance and licensee procedures.

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At 1132 the Commonwealth of Pernsylvania declared a State of Disaster. At 1140 the ERhi announced that the CommonweaPn of Pennsylvania had decided to evacuate the full ten mile Emergency Planning Zon At 1146 discussions between the ERM and Dose Assessment Team Leader (DATL) concluded that a PAR change was needed to reflect the change in wind direction. Additionally, drywell radiation levels were increasing, so the ERM discussed with the DATL whether a PAR extension was warranted. The ERM and DATL decided to wait until drywell radiation levels reached 50,000 R/hr. before extending the PAR. The existing PAR was changed by rotating the downwind sectors north by two sectors. To do so, a recommendation of evacuation was withdrawn in two sectors and provided in two others. No release was in progress at this tim EPA-520, " Manual Of Protective Actions Por Nuclear Incidents," Chapter 5, Section 5.2, points out that " Withdrawal of protective actions from areas where they have already been implemented is usually not advisable during the early phase because of the potential for changing conditions and confusion." Inspector teview found no procedural direction concerning withdrawal / modification of PARS due to wind shift At 1200 the release started. With main stack readings increasing, the ERM discussed updating the PAR with the DATL. When drywell radiation levels exceeded 50,000 R/hr., the ERM issued a PAR of evacuation of the Ove mile radius and ten miles downwind. This PAR was consistent with licensee procedure The PAR change due to the wind shift and the absence of procedural guidance for this action was assessed as an area for improvement.

e 4.4.2 Dose Assessment, Field Teams and Air Sampling Overall, the dose assessment staff performed well. They proactively projected doses based on postulated failures, and good Ogures were available prior to the less of Coolant Accident (LOCA). The ERM directed the DATL to provide a dose projectior: due to a planned drywell purge. This was initiated based on a four-hour release. The DATL later decided to confer with the engineering staff for a more accurate release duratio Licensee Held team samples verified the validity of projected doses. Severallicensec air samples were taken to determine the iodine release. The DATL remained cognizant of possible protective actions for emergency workers in the plume, (This scenario did not necessitate the use of potassium iodide.) The Field Survey Group Leader maintained good control of the Geld teams. No field team communication discrepancies were observe .5 Lucrgency News Center (ENC) ENC activation was timely. All news releases were reviewed for accuracy and approved by the ERM before release. Media briefings were held frequently and the information presented was

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discussed with Pennsylvania representatives beforehand. The Corporate Spokesperson conferred with the ERM prior to each media briefing to ensure that his information was correct and up to date. News briefings were conducted in a controlled manner and the simulated media asked good questions. The one actual media person present, Ms. Melissa Dribben of the Philadelphia Enquirer, was given a facihty to'ir by the license .0 Previously identifled items Closed (IFl 50 12-12-01) The NRC had identified two weaknesses in EOF / ENC performance at the Peach Bottom annual exercise on August 26,1992 (Inspection Report 50-277,-278/9219). As a result, the licensee scheduled a management meeting with the NRC on September 17,1992 (Agenda attached) to discuss corrective actions. An NRC inspector observed the Limerick dress rehearsal drill from the common Peach Bottom /Limericl EOF / ENC on October 14,1992 to observe the effectiveness of corrective actions. At that time, the licensee gave the inspector a more detailed list of planned corrective actions (copy sttacted) for the EOF / ENC, and draft copies of planned procedure changes to be used in the dress rehearsal and the Limerick November 24,1992 annual exercise. NRC inspection of EOF performance during the Limerick exercise assessed EOF performance in relation to the Peach Bottom exercise weaknesse The following is a summary of specif,e corrective actions observed during the Limerick dress rehearsal and annual exercis * Company vice presidents and one general manager were trained to be Emergency Response Managers (ERMs) instead of senior plant management. The Vice President, Peach Bottom functioned as ERM for both drills, and there was notable improvement: ERM command, control, and communications was a strength in the Limerick exercis * New Corporate Spokespersons (css) were trained: A newly trained CS filled that position for both drills, with marked improvement in Emergency News Center functio * Training for ERMs, Assistant ERMs, and dose assessment teams in. the areas of protective action recommendation (PAR) developa.cnt, PAR upgrade, and release pathway assessment was improved as follows, PAR procedures were changed to reflect current guidance (NRC Response Technical Manual, RTM 91) for severe core damage, and to require the ERM to consider plant status and dose assessment in PAR development as well as to provide a copy of the PAR development sheet to State representatives, Canned PAR upgrades were provided consistent with NUREG-0654 guidanc Assessment aids for release pathway analysis were developed and placed in the

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EOF and TSC for use by dose assesstnent teams (Attachment 3). The interface between EOF and TSC dose assessment was clarified. The TSC team now continues as a dose assessment resource after turnover to the EOF.

  • ERhi review of press releases is now required. This brought good results. The CS regularly conferred with the ERhi for plant status updates and appraval of press releases.
  • The following emergency response procedures (ERPs) were revised to clarify expected actions such as potassium iodide prioritiration, PAR development and upgrading, EOF-TSC dose assessment team interfaces, and ERht approval of press releases, ERP-101, Classincation of Emergencies ERP-C-1200, Emergency Response hianager ERP-C-1300, Emergency Operations Facility (EOF) Dose Assessment Team leader ERP-C 1310, Emergency Operations Facility (EOF) Dose Assessment Group ERP-C-1320, Emergency Operations Facility (EOF) Field Survey Group leader During the Peach Bottom exercise, EOF command, control and communications problems resulted in non-recognition of the release pathway, in PAR formulation flaws, and in absence of consideration of potassium iodide for use by Deld teams. During the Limerick exercise, EOF command, control and communications were an exercise strength. The release pathway was correctly diagnosed, PARS were appropriate and, although iodine was not a factor in this scenario, its potent;al use was discussed and the licensee had changed procedures to highlight the importance of potassium iodide fer personnel safety. Therefore, the Peach Bottom exercise weakness was shown to have been corrected.

Closed (IFl 50 277/92-19-02) Accuracy of information disseminated. During this exercise, news releases were accurate and were approved by the ERhi before dissemination.

The following areas for improvement identified during the previous annual Limerick emergency exercise (Inspection Report 50 352/91-07; 50-353/91-08) were acceptably demonstrate Simulator Control Room:

* Senior Emergency Response Organization manager prepositionin * Delay in requesting off site emergency services due to communications burde * Entries not made in bound log books when events occurre Technical Support Center:
* Uncertainty of lew Pressure Safety System set point pressur * Consideration of useful operational life of Stand-By Gas Treatment Syste _ _ _ _ - _ _ _ _ - _ _ .
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-      10 Operations Support Center:
* Sufficient emergency communications equipment availabilit Emergency Operations Facility:
* Implementing Procedure us .0 Duergency Action Level (CAL) Change The licensee revised ERP-101, " Classification of Emergencies," Table 4.2, Appendix 11
" Boundary Degradation /LOCA" prior to the exercise. The first General Emergency (GE)

condition in this category previou!.ly read: 1) Scram with LOCA A@ no ECCS. Indicated by: a. Failure to bring Reactor level above -129" efter 3 minutes, b. AND Containment pressure greater than 20 : .. The revision (Revision 1) changed item "a" to read: a. Failure to bring Reactor level above -161".

NRC review concluded that item "a" in the new revision was potentially confusing since it is unclear as to when the condition is met. The revision provides no literal obligation to declare a General Emergency if reactor water level drops below -161" (i.e., top of active fuel) as long as level is restored to that value in some unspecined time period. This concern was expressed to the licensee at the exit meeting. Also, the licensee identified this item as an important area for improvement during their formal critique of the exercise. The NRC subsequently requested and received from the licensee their 10 CFR 50.54(q) review and 10 CFR 50.59 safety evaluation for this change. This issue will be further reviewed (IFl 50-352,353/92-28-01). Licensee Critique and NRC Exit Meeting On November 25,1992 the NRC team attended the licensee's exercise critique lead controllers summarized the licensce's observatiors. Each area was evaluated for: strengths /significant improvements, areas for improvement, and recommendations. The critique was thorough, identified most NRC findings, and was assessed as a good self-examinatio After the critique, the NRC team met with the licensee (see Detail 1.0 for attendees) to discuss the inspection finding The team leader summarized exercise strengths and areas for inprovement. The licensee was informed that there were no exercise weaknesses and that their exercise performance demonstrated the ability to implement the Emergency Plan and Implementing Procedures to protect public health and safety. Licensee management acknowledged NRC findings. The licensee concurred with the NRC areas for improvement associated with the OSC, said that the OSC was already being evaluated for improvement, and commented that all NRC findings would be evaluated for appropriate actio .. . . . . . - . . , . . _ _ . . . _ .

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Attachment 1 .

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A G E t1 D A kW GEMEtJT MEETitJG WITil NRC ltEClON 1 September 17, 1992

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* PURPOSE: To discuss the results of the August 26"'  ... D.M. Smith Peach Bottom Annual Exercis * Discussion of identifled weaknesses and corrective  ... C.L. Adams action * Review of NRC perspective on the development of  ... C.L. Adams Protective Action Recommendations (PAR) for the Plume Exposure Emergency Planning Zon * Discussion of PECo Emergency Operations   ... D.M. Smith Facility / Emergency News center in NRC emergency respons * Conclusion     ... D.M. Smith

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C0RREC1IVE ACT10NS

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EMERGENCY OPERATIONS FACILITY j

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 . TABLE TOP DRILLS FOR ALL EMERGENCY RESPONSE MANAGERS, ASSISTANT EMERGENCY RESPONSE MANAGERS, AND DOSE ASSESSMENT TEAM FOCUS ON PAR DEVELOPMENT, PAR ' UPGRADE, RELEASE PATHWAY ,
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ASSESSMENT ,

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 - CLARIFICATION OF INTERFACE EXPECTATIONS BETWEEN E0F AND TSC DOSE ASSESSMENT TEAMS EXPECTED :
 - REVISIONS OF PROCEDURES TO CLARIFY ACTIONS
 + KI PRIORITIZATION
 + NOTIFICATION OF PARS
 + COMMUNICATION OF INGESTION PATHWAY ASSESSMENT
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 - ADDITIONAL COMMUNICATIONS  FOR FIRE BRIGADE EQUIPMENT ROOM
 - CATEGORIZING DRILL RESULTS IN REGARD TO IMPORTANCE
 - CHANGE- IN ASSIGNMENT OF EMERGENCY RESPONS .

MANAGERS L

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ACTIONS

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C0RRECTIVE (CONT.)

! EMERGENCY NEWS CENTER

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 - REQUIRE EMERGENCY RESPONSE MANAGER REVIEW 0F PRESS RELEASES
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 - REVISED EMERGENCY COMMUNICATIONS PLAN AND PROCEDURE
 - READ AND SIGN FOLLOW-UP FOR CORPORATE SP0KESPERSON, TECHNICAL ADVISORS, EMERGENCY RESPONSE MANAGERS, AND ASSISTANT EMERGENCY RESPONSE MANAGERS
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PROTECTIVE ACTION-  !

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REC 0!NENDATION DEVELOPMENT l f

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  . NUREG-0654,  REV. 1 AND IE IN 83-28        i
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   .. MINIMUM PAR 2 MILE SHELTER - CIRCLE 5 MILE SHELTER - DOWNWIND       ,

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   - PAR UPGRADE 5 MILE EVACUATION - CIRCLE 10 MILE EVACUATION - DOWNWIND
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  . RTM 91           _ .
   .. MINIMUM PAR 2 MILE EVACUATION - CIRCLE 5 MILE EVACUATION - DOWNWIND SPECIFIC /MORE   JUDGEMENT ;

- .. PAR UPGRADE LESS BASE .. PLANT CONDITIONS / DOSE ASSESSMENT - USED TO - PAR PROBABLY MORE- DOSE BASED UPGRADE ' CONSISTENT WITH EPA PAG . KEY MANAGER JUDGEMENT

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CORitECTIVE ACTIONS FOlt . EOF / ENC o EllM/AERM assignment changes. VPs and NQA-GM to be ERM Train new Corporate Spokesperson STATUS: . Decision Made 9/14 DMS s

        . Training Scheduled 9/25  _ S. Keenan
        . Training:

D.B. Miller .. Qualified 10/05 C.R. Itainey .. 1st Day Training 10/01 J.B. Cotton .. 1st Day Training 09/29 D.R. llelwig .. 1st Day Training Sche /12 D.R. IIelwig and G.R. Rainey Mint-Drill 10/22 J.B. Cotton at INPO, complete training mid-November

        . New Corporate Spokespersons Scheduled  10/09 to be traine . 1able Tops for existing ERMs to be scheduled and conducted by end of Octobe STATUS:   . Schedule S. Keenan
        . Conduct R. Mandik/S. Keenan Table Tops for DAT To include release pathway assessment, release pathways, and PAR development. Focus on EOF-DATM interf ace with TSC-DATM and EOF-Engineerin STATUS:   . Class conducted 10/6
        . Class conducted 10/7
        . One additional class to be scheduled and conducted for all others prior to 10/3 .- Assessment aid for release pathway assessmen STATUS:   Being developed   S. Keenan To He Completed 10/15, af ter drill use J. Cerhart/

N. McKenney

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* . Read and Sign procedure changes and PAR philosophy for ERMs and
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DATL/DAC STATUS: To be issued 10/14 with procedure change , ERM to be assigned as reviewer of press release Communications Plan Revised 10/6 STATUS: .

  . Communications Procedures Revised 10/6
  . Read and Sign for Corporate Spokespersons 10/15
  . ERM Proca. dure Change Draf ted 10/05
  . ERM Procedure Change Final - Scheduled 10/22

_ 7. Collateral ERO changes associated with ERM changes: To be completed approximately 10/31 with exception of J.D. Cotton (at INPO for 5 wee'<s training) . Procedure Changes for ERM, DATL: Scheduled for 10/2 Ref. Action items: CTAl A0656968 A0657035 A0660636 EPAlT Q0003178 Q0003179 Q0003180 Q0003181 Q0003182 Q0003183 Q0003184 Q0003185 Q0003186 Q0003187 Q0003190 Q0003191 Q0003192

   - Q0003193 Q0003194-Q0003196
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