IR 05000344/1989028
| ML20042D289 | |
| Person / Time | |
|---|---|
| Site: | Trojan File:Portland General Electric icon.png |
| Issue date: | 12/22/1989 |
| From: | Good G, Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20042D287 | List: |
| References | |
| 50-344-89-28, IEIN-89-019, IEIN-89-19, NUDOCS 9001080224 | |
| Download: ML20042D289 (18) | |
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. U.lS. NUCLEAR REGULATORY COMMISSION
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REGION V
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p Report No.'
~50-344/89-28 C
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'50-344 b.
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x-LLicense No-NPF-1-
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Licensee:'
Portland General Electric-
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121 S. W. Salmon Street
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Portland, Oregon 97204
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Facility'Name:; Trojan.
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Inspection ^at:
Rainier,. Oregon I
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1 Inspection ~ Conducted:
November 13-17, 1989
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Inspector:
NT-Ab..;
Q/2OIN
G.'M. Goody Emergency Preparedness, Date Signed'
Analyst, Team Leader
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R.' C. Barr, Senior Resident Inspector,. Trojan
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G. A. Stoetzel, Pacific Northwest Laboratories G. R. Bryan,JJr., Comex Corporation j
Approved by::
C M.' S h aw4%T Emerge (Yulas,ChiefnW Preparedness and'
G. P,
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Date Signed-
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' Radiological Protection Branch
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SUMMARY:'
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Insp'ectihn on November 13-17, 1989 (Report No. 50-344/89-28)
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l Areas-Inspected: Announced inspection to follow-up on previous emergency-
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preparedness inspection findings (a violation, an unresolved item, an exercise
- weakness and-three open items identified during the 1988 annual exercise), to a
follow-up on an NRC Information Notice, to address the Operational Status of the Emergency Preparedner.s Program (procedures and licensee audits), to observe a medical emergency drill, and to observe the 1989 emergency exercise and associated' critiques.
This exercise involved full, offsite agency
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participation.
Inspection procedures 92702, 92701, 82701, 82301 and 30703
'were used.as guidance.
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Results:
Three exercise weaknesses, one-unresolved item, and three open. items were identified during'this inspection.- :The exercise weaknesses involved: (1)
the inability of_the Technical Support Center to provide adequate and timely supporttotheControlRoomandEmergencyOperationsFacility(d;($)(thelack EOF)-
2) the failure of the E0F to classify one event in a timely manner, an
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of. adequate management and control involving dose assessment capabilities in
'the EOF. The exercise weaknesses are described in Sections 9 and 11 of this
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report.- The unresolved item:is described in Section 8 and involved the
. hydrogen analyzers and whether there is a potential for a ~ common mode failure.
The three.open items identified during this inspection are described in
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Sections 3.B and 9.
All of the follow up. items were closed.
The exercise indicated that the li~censee.needs:to improve Lits level of preparedness, i
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DETAILS L-Persons Contacted J. Benjamin, Supervisor, Quality Operations (QO) Audits F. Casella, HbH Associates, Inc. (contractor)
C. Cox, Emergency Planner
- S..Harlos,. Trainer,SupervisorEmergency Preparedness (contractor)
J.~'Heitzman, Shift F. Jones, Emergency Planner C. McKeown, HMM Associates, Inc. (contractor)
R. Nelson, Manager, Nuclear Safety and Regulation Department (NSRD)
D. Nordstrom, Manager, Q0 Branch A. Puzey, Supervisor, Administrative Services K. Reed, Procedures Chief Clerk
'L. Rocha, Health Physicist
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J. Thale, Supervisor, Emergency Preparedness (EP)
M. Vigliani, HMM Associates, Inc. (contractor)
W. Williams, Regulatory Compliance Engineer G. Zimmerman, Manager, Radiological Safety-Branch 2.
Action on Previous Inspection Findincs and NRC Information Notices (IN)
(Inspection Procedures 92702 and 92701)
(Closed) Violation (89-04-01):
Failure to follow EP-001 for pressure boundary leakage event on November 14,1988.
This violation was issued because the licensee failed to classify an Unusual Event after the plant staff determined that pressure boundary leakage existed.
Based on the licensee's corrective actions, as documented in NRC Inspection Report No.
50-344/89-04, no response to the violation was required.
Follow-up on this' matter focused on the EP staff's process for reviewing plant events to determine whether the Radiological Emergency Response Plan (RERP) was being' properly implemented during plant events.
The inspection disclosed-that the EP staff has an adequate program for reviewing plant events; however, it appeared that there could be a lag between the actual event and the time it takes for the EP staff to become aware of the event.
Since the EP staff recently relocated to the Trojan site, from the corporate office in Portland, this lag time should be reduced.
This violation is considered closed.
(Closed) Unresolved Item (89-04-02):
A concern regarding the licensee's ability to complete required training for emergency response personnel in a timely manner.
The inspector reviewed the EP Training Qualification Update Listing and held discussions with one of the EP trainers. The inspector found that, for the most part, training was current for key positions and that nearly all positions had an adeguate number of trained individuals to fill the positions.
During the review of the qualification listing, t1e inspector noted that the expiration dates were set at twelve months from the last training.
Since RERP Overview training for approximately 75% of the emergency response personnel had to be conducted during the three month extension period, the licensee was cautioned against consistent use of the extensien period, because it gives the appearance that a fifteen month training year is being used.
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The' inspector suggested that one way to guard against this potential was to not reset the clock-(i.e., continue.to use the expiration date month as.the anniversary month) when the extension period is used.
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personnel were_ confident =that the extension periods would not have to be used.for the next cycle of-RERP Overview training.
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the training issue,:the inspector reviewed the licensee's. Radiological Emergency Response Notification Call Lists (Topical Report PGE-1008A) to determine' whether individuals listed had completed their emergency-response training.
The inspector found that the licensee's system-consisted of a: series of call trees initiated by various plant management personnel.
The individual managers then call members of their staffs to respond.
Individuals are not called to respond to a specific emergency" response position.
The inspector concluded that the licensee's process did not provide a positive method to verify the training qualification status of individuals called upon to respond to an emergency, because the callout below the manager level, is conducted based on the individual l
manager s personal knowledge and/or personal records.
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PGE-1008A is not annotated in any way to indicate the training-status of the individuals who are listed.
During the latter part of this inspection, the inspector was provided with a copy of Nuclear Quality Assurance Department-(NQAD) Audit of the Emergency Response Plan, AP-621, dated November 16, 1989.
AP-621 documents a finding (Finding No.1) that states in part that "It is evident that there is a lack of coordination between the Call Lists and the training reports." This finding was based on a comparison between a list of trained personnel and PGE-1008A, and the fact that five individuals were listed in'PGE-1008A, but were not trained for the positions to which they were assigned.
Nonconforming Activity Reports (NCARs) P89-468 and P89-478 were issued as a result of the audit finding.
This unresolved item is considered closed; however, the inspector intends to follow-up on the response to the NCARs during the routine inspection program.
(Closed) Open Item (88-41-01):
Lack of ability to provide clear, accurate and timely notifications.
This item was identified as an exercise weakness during the 1988 exercise and was based on the licensee's inability to make the offsite agency notifications within 15 minutes as required by emergency procedure EP-003, " Initial Notifications forTrojanEmergencies." During this exercise the offsite agencies were notified within 13 minutes of the Alert declaration.
This exercise weakness is considered closed.
(Closed) Open Item (88-41-02):
Plume location capabilities for the Technical Support Center (ISC).
During the 1988 exercise it was identified that the TSC had no means of identifying the location of the plume and that information regarding the plume location was not provided over the public address (PA) system to advise workers of areas to avoid.
Since the 1988 exercise, a plant map has been added to the TSC to provide a visual means of tracking / describing plume location.
In addition, emergency procedure EP-101, "TSC," was revised to emphasize that personnel leaving the TSC be advised of any hazards.
During this exercise, TSC personnel plotted wind direction and various radiation
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TSC personnel were also cautioned to not leave the TSC j
without first contacting the Manager, Personnel Protection.
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Regarding the PA announcements, it was noted that none of the plant PA e
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- include the location of the plume.
It should be noted that the Control Room (CR) makes the. plant PA announcements; however once.the TSC is
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activated,TSC-personnelareresponsibleforprovidingtheCRwith
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specific onsite protective action recommendations-(PARS).- Radiological conditions and hazardous areas to avoid fall under the realm of onsite-PARS.
It is important to note that all non-essential personnel had-
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This item is
-considered closed; however, the matter of the content of the PA announcements will'be added to the exercise weakness described in Section 9.
-(Closed) Open Item (88-41-03):
Incomplete Operational Support Center
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(050) field-team work forms.
The previous two exercise evaluations noted-that Section IV of the OSC work form (dealing with return and debriefing of of field teams) was not always completed when the teams returned to the OSC.
The latest revision te EP-102, "050," dated September 18, 1989,
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no longer requires documenting triefing and debriefing of OSC teams.
- During this exercise, briefings and debriefings were conducted verbally.
The debriefings observed during this exercise appeared to be adequate.
'This item is considered closed.
(Closed) Open Item (88-41-04):
Problems transferrin information to the Emergency Response Manager (ERM) g clear and accurate
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in the Emergency Operations Facility (E0F).
During the 1988 exercise, terms such as " core damage," " clad damage," " gap release" and " fuel melting" were used interchangeably.
In addition, there was a misunderstanding regarding the units of a direct reading measurement reported by a field team.
During this exercise, personnel were consistent and careful when discussions
involved the aforementioned terms.
Also, whenever units were transmitted, personnel were very deliberate in their attempts to make sure that the units were understood.
This item is considered closed.
(Closed) Open Item (IN-89-19):
Nuclear Division Procedure (NDP) No. 100-13, " Operating Experience Evaluation,"
is used to evaluate what actions are required to address NRC ins.
An Operational Assessment Review (OAR) Form from NDP 100-13 has been initiated for IN 89-19.
The form documents the evaluation procedure and-proposed corrective actions defined by the evaluation.
Currently, the OAR for for IN 89-19 is in the review and approval process.
0ARs and any corrective actions defined in an OAR are entered onto the Commitment
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Tracking List (CTL).
Based on IN 89-19, EP has made or planned the
following procedural changes:
l A.
Revision 3 of EP-501, " Training and Drills," has added Section i
3.4.9.2 under " Equipment Malfunctions" which includes the IN guidance on actions to take should the HPN telephone fail.
This revision is currently in the approval process.
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Section 111.27 of EP-103, " E0F" will be modified to include the-
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information from the IN on how to establish the HPN link with NRC o
Headquarters. -This modification has not yet been initiated.
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i This' item is considered closed.
- 3.
l0perational Status of the Emergency Preparedness Program Inspection Procedure 82701 A.;
Procedures This. portion of the inspection focused on the licensee's process for-submitting changes to the Emergency Plan Implementing Procedures (EPIPs).. In accordance with Paragraph V of Appendix E to 10 CFR Part 50 ~11censee's are required to submit changes to the EPIPs to the NRC within 30 days of the changes.
Prior.to the inspection, the inspector noticed that Transmittal No._ 89-010 had not been received.
This. transmittal consisted of Revision 4 (only certain pages were
" Emergency Classification." Tie licensee's revised)toEPIPEP-001'lcatethatthetransmittalhadbeensent
records appeared to ind around September 14,1989; however, the licensee did not have a receipt acknowledgement form in its possession.
The inspector discussed this, situation with the Supervisor, Administrative Services and found that the licensee does not have a formal process to track whether' receipt acknowledgement forms have been returned or to send out delinquent acknowledgement form notices within a specified period of time.
By adopting the latter aractice, the licensee would be in a better position to assure t1at the aforementioned requirements would be met.
The previously mentioned supervisor recognized that the procedure, presently being used to accomplish.this task, was not prescriptive enough to prevent this problem from reoccurring.
As a result, the supervisor deviated Administrative Procedure ADM-106 to provide for delinquent acknowledgement receipt forms to be issued within 30 days.
It should be noted that this action was taken promptly.
While investigating this matter, the inspector _ learned that a Nonconforming Activity Report (NCAR) (88-82M) was issued in September 1988 concerning-EPIPs that were not sent to the Region within 30 days of the approval dates.
The root cause of the nonconformance was determined to be the " inadequate inclusion of an RERP requirement in implementing procedures." As a result, ADM-106 was deviated to incorporate the 30 day requirement into the procedure.
The inspector concluded that the actions taken back in 1988 were not sufficient enough to prevent this problem from reoccurring.
No deficiencies or violations of NRC requirements were identified during this part of the inspection.
B.
Independent Reviews / Audits This part of the inspection was conducted to determine whether the licensee had conducted a review of its EP program in accordance with
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10:CFR50.54(t) :The inspector found that-the audit had been
F conducted during-the period of_ September 11'-15 and October 9-13,
'1989,1 and thatLthe-scope'was consistent with 10 CFR 50.54(t).- The
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I, auditLincluded observation of the October 1989 integrated drill.
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The: report, NQAD Audit of the Emergency Response Plan,"APr621, was issued on November 16,- 1989.
Eight " findings" and 15. observations"
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.'were identified as-a result of t7e audit.
NCARs were initiated for
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each of the " findings."~ The~ following '! findings" were'of particular concern to the inspector:
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. Several individuals designated as emergency-response personnel in PGE-1008A had not completed-the applicable training."
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"The Joint Information Center" (JIC) was unable to supply timely and~ accurate information to the media."
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"The notification systems do not adequately initiate rapid
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mobilization of support personnel."'
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"There was inadequate command and control in the "TSC."-
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"There was inadequate command and control in the OSC."
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In-addition to the above, the. inspector was concerned because the part of the report that addressed the interface with the offsite agencies indicated that there had been a decrease in the l
effectiveness of the interface.
The inspector verified that the part of the report dealing with the offsite interface would be-sent to each of the offsite agencies.-
Based lon the results of the audit, the inspector determined that there was a need to follow-up on the corrective actions and responses to the audit " findings." This item will be tracked as open. item 89-28-01.-
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During the interface with NQAD personnel, the inspector was informed about a situation that occurred on August 17, 1989.
The situation t
led-to the issuance'of 3 NCARs.
The following key points were-l
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1.
At 1:51 P.M. on August 17, 1989, area radiation monitor (ARM)
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ARM-22 (located at the north site boundary) indicated readings of 1.05 milliroentgen per hour (mR/hr).
Module 1, Step 4, Section 4.3 of EP-001 requires that an Alert be declared for-readings greater than ImR/hr.
2.
CR and Radiation Protection (RP) personnel were notified of the high readings and the requirements of EP-001.
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An RP technician was dispatched to the location and the resulting survey at 3:00 P.M. indicated that the actual j
radiation levels ranged from 4-7 microR/hr (uR/hr).
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~ The CR was notified of the actual readings and determined that an' Alert emergency. class-did not exist.
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No entries to the CR log.were made regarding the high ARM readings.and the EP-001 requirements; however, the Shift
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Supervisor's(SSs
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ARM-22..was~ subsequently. tagged as inoperable.
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As indicated above,'3 NCARs.were initiated.
Thesub,jectsareas follows::1) failure to implement EP-001; 2) ARM-22 high reading and-setpoint alarm greater than. emergency action level, and; 3) failure to detect and to respond to an anomalous = ARM-22' reading.
The inspector investigated the matter further and found:out that-this was;not the first time'that ARM-22 had indicated readings greater than ImR/hr.. On about three occasions during the past ye.ar,.
- ARM-22 was noted to be reading greater than 1mR/hr.
These readings were noted during routine surveillances conducted by RP.-
It ap) ears that RP did not consider these readings to be abnormal, since t.1ey
.were noted to be " background" and~no further actions were taken.
The inspector also found that the high readings on the ARM trended directly with ambient temperature readings during the same time periods.
The inspector concluded that the NQAD,had responded promptly and appropriately to this situation; however, based on the sequence of-events and the fact that a violation was issued on March 23, 1989 for failure to implement EP-001 (see Appendix A to NRC Inspection Report No. 50-344/89-04), the corrective actions and the responses to the NCARs will be tracked as open item 89-28-02.
No deficiencies or violations of NRC requirements were identified during this part of the inspection.
4.
Medical Drill This inspection included an evaluation of the onsite portion of a medical drill that was conducted on November 14, 1989.
The scenario involved a 30 gallons per minute (GPM) resin slurry spill, caused by an improperly isolated hose, during a spent resin transfer.
The resin slurry caused a worker to fall and sustain multiple cuts and injuries.
The following observations were made during the medical drill:
A.
The RP Emergency Team (RPET) arrived at'the accident scene in a timely manner.
B.
Better preparation (mock-up) of the accident scene would have enhanced conduct of the drill.
During the drill, the controller told the players that they should consider the victim to be in the actual resin transfer area.
The drill actually took place outside the contaminated area.
This situation led to confusion among
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players because not'.all players were informed and it also presented problems with simulated contamination control since no physical
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-The RPET was slow in performing the initial dose. rate survey of the
' accident scene.
The first two RPET members who arrived at the scene
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did not have any survey-instruments.
Dose rate measurements around
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the victim were not taken until 10 minutes after the RPET initially
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arrived.
No deficiencies or violations of NRC requirements were identified during
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this part of.the inspection.
-5.
Emergency Preparedness Exercise Planning (Inspection Procedure 82301)
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'The licensee's NSRD has the overall responsibility for developing, conductingandevaluatingtheEPexercise.
These activities are conducted using EP-501, Training and Drills." The scenario package was
- developed with the contracted assistance of HMM Associates, Inc.
?ersons involved in-the scenario development were not participants in the exercise.
Exercis'e o'bjectives were established as part of the scenario package and
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included general objectives, specific onsite objectives, scenario
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dependent objectives and specific offsite objectives.
NRC, Region V, and the Federal Emergency Management Agency (FEMA), Region X, were provided with an opportunity to comment on the exercise objectives and scenario I
package.
The complete scenario package: included the objectives, participant' guidelines,- controller information, scenario narrative
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summary and sequence of events, messages used during the exercise,
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initial _and subsequent plant parameters, and meteorological and radiological data.
Players did not have access to the scenario package
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L or information on the scenario events.
The exercise was intended to meet.
the. requirements of IV.F.3 of Appendix E to.10 CFR Part 50.
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Exercise Scenario The exercise scenario started with an event that was classified as.an l
Alert and ultimately escalated to Site Area Emergency (SAE) and General s
Emergency (GE) classifications.
The Alert declaration was based on a
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fire that led to a complete loss of the "B" train of the Emergency Core Cooling System (ECCS).
The scenario developers had planned the SAE declaration to be based on a loss of coolant accident (LOCA) greater than
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makeup ' ump capacity (160 GP.'t); however, the SAE declaration was made l
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based on a complete loss of any function needed for plant hot shutdown.
The condition was met as a result of the loss of the "A" train L
centrifugal charging pump (CCP), the "B" train CCP was already ino)erable
.i because of the fire, and a manual reactor trip.
The loss of the "3" train CCP occurred about the time the leak rate increased to the 160 GPM i
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The leak rate eventually increased to over 4000 GPM.
The GE was declared based on a loss of core cooling capability.
This condition was
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met because there were no reactor coolant pumps (RCPs) running, 5 core exit thermocouples were reading greater than 714 degrees Fahrenheit, and the Reactor Vessel Level Indication System (RVLIS) level dropped below
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39% full range. An unmonitored release began through a motor operated
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valve (MOV) as a: result of the high pressure in containment.
The release stopped when the pressure in containment reached zero and the'MOV was allowed to be shut.
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Federal Evaluators
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.Four NRC ins)ectors evaluated the licensee's response.
Inspectors were-
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located in tie CR, TSC, OSC and EOF.. The NRC-inspector who was assigned
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to the OSC-accompanied various repair / monitoring teams in order to evaluate their performance.
FEMA, Region X, evaluators were present during the exercise, since this was the biennial,. full scale exercise.
The FEMA team of evaluators-(approximately 50' individuals) were evaluating those portions of the exercise that involved the states and counties, as well as the interface
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occurring at the E0F.
The results of FEMA's evaluation of the offsite
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response will be described in a separate report issued by FEMA.
8.
Control Room / Simulator The following' aspects of CR operations were observed:
detection and.
classification of emergency events, mitigation, notification and PARS.
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The following are NRC observations of the CR activities.
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exception of item F below, the observations, as~ appropriate, are
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considered to be suggestions for improving the program.
A.
As a result of the fire pre plan, the CR identified the threat represented by several specific transformers containing polychlorinated biphenyls (PCBs).
B.
Prioritization of repair efforts was excellent.
C.
The CR staff noted five instances where errors were contained in the Emergency Operating Procedures (E0Ps).
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The critique held in the CR was excellent.
All players actively participated and criticisms were honest, sincere and should lead to I
improved E0Ps, EP training and EPIPs.
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'E.
Designation of the assistant SS.as the normal fire brigade leader
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significantly reduced management oversight of Emergency Plan and E0P implementation under circumstances where a fire also existed.
During the exercise, the SS degraded his E0P oversight of casualty mitigation whenever the Emergency Plan required his attention (e.g.,
f classification, notifications,etc.).
F.
It appears that both Hydrogen analyzers can bc rendered inoperable from a common mode failure, loss of the Al or A2 4160 busses.
The inspection disclosed the following information:
1)
The containment hydrogen analyzers are now normally valved out of service (closed) by " fail as is" MOVs.
All inboard valves are powered via bus Al and the outboards via A2.
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These hydrogen analyzers are a Regulatory Guide-(RG) 1.97
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category 1 variable.
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3)
TheSafetyEvaluationReport(SER),datedMay 24, 1983, appears to have approved an exception to RG 1.97 because the ability to
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isolate containment was considered to be more important than the ability to sample hydrogen. 'At the, time,_the hydrogen
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analyzers were valved in service (open).
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Section 8.1.4 of the' Final Safety Analysis Report (FSAR),
Electrical Power Design Criteria, requires " redundant power b,
and/or automatic transfer of loads to ensure ' continuous operation of equipment required under emergency conditions."
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5)
The hydrogen analyzers are required by the E0Ps.
6)
Trojan'reportPGE-1043,-datedDecember1984," Accident.
'A Monitoring Instrumentation Review," stated that the analyzers 4 -
Ldid not meet RG 1.97 requirements because they were not battery backed they had no CR recorder and both isolated on either ChannelAorBcontainmentisolation.
7)
Since the units are normally valved off service with shut,
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" fail as is" MOVs, failure to isolate is not a threat; however,
. failure to operate is due to the single bus mode failure imentioned above.
8)- Technical Specification (TS) 3.6.4.1 requires that two independent containment analyzers be operable.
This matter will be pursued furth0r to determine whether there is a u
potential for a common mode failure and whether a 50.59 review was conducted when the position of the '1ydrogen analyzer valves was changed.
Resolution of this matter will be tracked as unresolved item 89-28-03.
An unresolved item s a matter about which more
information ~is required to ascertair whether it is an acceptable item, a deviation or a violation.
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The SS directed that the operators nit be given potassium iodide
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.('KI) because he did not want to rislFToss of an operator due to the
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Technical Support Center The following aspects of TSC operations were observed:
activation, accident assessment and classification, PARS, CR support and EOF support.
The following are NRC observations of the TSC activities.
An exercise weakness is a finding identified as needing corrective action in
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accordance_with 10 CFR Part 50, Appendix E, Paragraph IV.F.5.
The other
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observations, as appropriate, are intended to be suggestions for
improving the program.
A.
The TSC did not always provide timely or adequate support to the CR and EOF.
Examples are as follows:
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The TSC' staff did not provide the ERM with a timely recommendation regarding the SAE classification. 'Section III.2 of:EP-101requirestheEmergencfCoordinator-(EC)inthe'TSCto; y'
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recommend emergency classification changes to the ERM~in the E0F when the changes are based'on plant conditions,.as opposed todoseprojections.
The SAE. initiating conditions were met at 9:36 A.M., but the recommendation from the TSC was not provided-
.until 10:09 A.M.,- 33 minutes later.
The TSC staff was focusing
!
on Module 4,' Step 8 of EP-001 for classification purposes;
_
however, they became overly concerned-about the specific wording used in-that portion of the procedure.
Module 4,-Step
~8,'makes reference to high containment pressure, high-containment sump Llevel, and high containment humidity _ The -
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- staff did not'know what constituted "high." The SAE was-
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eventually declared based on a reactor trip and the inability ~
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toestablishhigh:pressureinjection(Module 7, Step 7of
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EP-001).
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2)
The TSC staff did not identify the cause of core uncovery in a timely manner.
The TSC was focusing on alternatives to re-energize a CCP-rather than assisting the CR in determining i
the;1eak rate, leak location and repair.
3)'
The TSC did not identify the source of the offsite release in a timely manner.
The release started at 11:15 A.M., but the release path was'not determined until 1:12 P.M., almost 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later.
4)
The TSC did not ask the CR to include information about the release.during plant PA announcements.
Section III.2~of EP-101 requires ~the TSC staff to ensure notification of onsite personnel of emergency classification and PARS.
Upon activation, the TSC. implements this-portion of the procedure by providing the CR with the content of the PA announcements.
The PA announcements can only be made from the CR.
Radiological conditions, such as a release in progress, or warning of other hazardous areasito avoid,-fall under the realm of.onsite PARS.
During the exercise, none of the PA announcements made after the release started included information that a release was in progress, nor did they provide any information about the location of the plume.
Non-essential personnel were evacuated
'
(simulated) before the release started.
The findings described above generally occurred due to the TSC staff not focusing or prioritizing immediate safety issues.
Collectively,
these findings represent a breakdown in the management and control in the TSC and indicate inadequate support to the CR and EOF.
This E
matter is considered to be an exercise weakness and will be tracked as open item 89-28-04.
B.
The TSC Radiation Monitoring System was inoperable during the entire exercise.
Upon activation of the TSC, Step 3.3.4.3 of EP-101 i
recuires the RP technician, or individual assigned, to place the TSC Raciation Monitoring System in service.
While placing the the
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system in service, the' technician did~not properly sequence the exercise.ereby,- rendering the system inoperable' during the entire steps th
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Several opportunities occurred to identify the
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inoperability of the radiation monitor; however, TSC personnel
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failed to recognize the. existence:of. low flow alarms.
Althou q
habitability was not a specific concern-during this exercise'gh TSC
since t
theTSCwasnotlocatedinthepathoftheplume,portablealt samples were taken in the TSC'as a backup to the TSC Radiation p
. Monitoring Sy' stem.
The licensee's corrective action regarding this matter will be tracked as open item 89-28-05.
10.
Operational Support Center
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The following aspects of OSC operations were' observed:
activation, m,
functional capabilities and disposition of various inplant repair / monitoring teams.
The following are NRC observations of the OSC activities. -The observations, as appropriate, are intended to be-L suggestions for improving the program.
A.
The OSC Director provided frequent briefings to the OSC staff
'
(approximately every 30 minutes); however, the briefings did not
provide the reasons for the SAE or GE classifications.
B.
'At about 10:30 A.M., two teams were sent outside of the plant to obtain supplies.
Due to the deteriorating plant conditions, the
. teams ^were issued portable radios so they could be contacted in case a release occurred.
A radio check was not' performed prior to L
dispatch and radio contact could not be established once the teams
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were=in the field.
C.
The licensee's general philosophy regarding the use of protective
.
clothing (PCs) during exercises was not as conservative as observed at other facilities.
During the course of the exercise, only one team was required to don PCs.
It is important to note that i
habitability checks (i.e., grab air sampling and smear surveys) were performed by radiation protection technicians at all work locations.
None of the locations were found to be contaminated.
For training purposes, it would be advantageous to test emergency dress-out procedures as well as the use of self contained breathing apparatus (SCBA).
Suffice it to say that the scenario could have been more taxing for the OSC staff.
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11.
Emergency Operations Facility The following E0F operations were observed:
activation, functional capabilities, notifications, PARS, interface with offsite officials and dose assessment.
The following are NRC observations of the EOF activities.
An exercise weakness is a finding identified as needing corrective action in accordance with 10 CFR Part 50, Appendix E, Paragraph IV.F.5.
The other observations, as appropriate, are considered
,
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to be suggestions for improving the program.
A.
The EOF did not classify the SAE in a timely manner.
The initiating conditions for the SAE were met at 9:36 A.M. based on Module 7, Step
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The lack of plant o)erations/ engineering
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- staff to support this effort in the EOF may lave contributed to the
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This finding is considered to be an
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exercise weakness and will be tracked as open item 89-28-06.
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B.-
The'following. problems. relating to the area of dose assessment were observed:
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The Radiological Manager (RM) became so involved with the d
resolution of individual task requests that he was not able to
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manage the dose assessment activities in an effective manner.
2)
The manner--in which field team data.is plotted makes it difficult.to get an accurate and clear indication of current offsite radiological conditions.
Maps were generated with
,
measurements at different times and, therefore, did not provide a snapshot of' radiological conditions.
3)
It took a lonc ' time to get the results of an air sample.
Meaningful ioc'ine results (centerline) were not available until 12:32 ?.M., approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and 15 minutes after the release started.
The^ delay in gettin the emergency worker PAR to take KI. g an iodine sample delayed 4)
The RM held discussions and reviewed the Accident Notification / Assessment Form with offsite representatives.
before the forms were a) proved by the ERM.
The form contains the licensee's offsite
)ARs.
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5)
Unsigned (unapproved) co)ies of the Accident-Assessment / Notification porm were retained by the dose assessment staff.
On one occasion, the three copies of the form were separated and the ERM and the Alternate ERM each made additions-to two separate copies of the form.
Although the copies were eventually compiled, the licensee is cautioned against-this practice because it could result in the dissemination of different PARS.
6)
There was an excessive delay in getting the results of the deposition calculation to make ingestion PARS and to make a final dose calculation.
The Alternate ERM requested the deposition calculation at 1:02 P.M., but did not get the results until 2:45 P.M., I hour and 43 minutes later.
The final dose calculation was requested at 2:12 P.M., but was not completed until-2:52 P.M., 40 minutes later.
7)
The RM appeared to be unaware of how to get meteorological
..
information prior to the availability of the Safety Parameter Display System (SPDS).
It was approximately 25 minutes after the time the E0F was declared activated before the RM learned of the wind speed and direction.
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Collectively, the above findings represent a breakdown in the-management and control of dose assessment activities.
This matter is considered to'be an exercise weakness and will be tracked as.open item 89-28-07.-
b C.
The E0F staff was not informed that a GE had been declared until 13
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minutes after the event declaration.
1-D.-
Although the EOF was activated in a timely manner (29 minutes after the Alert was declared) and the ERM assumed the EC duties 9 minutes later, activation of the E0F appeared to be unstructured because emergency response positions were not predetermined and assignments had to be made based on the individuals who responded.
Activation could be expedited if individuals knew what positions they were called upon to fill.
This situation appeared to be most-prevalent m
in the dose assessment area.
Positionassignmentswereadjustedas
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more responders arrived.
Training qualifications may not be i
considered using this process; however, the licensee indicated that the dose assessment staff is cross trained so that everyone can fill
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any of the positions.
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E.
The security guard stationed at the entrance to the Visitor
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Information Center (VIC) (the VIC is the entrance to the E0F)
allowed one individual to enter and frisk his shoes before his j
hands.
It should be noted that this occurred prior to the release
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and there.is a notice posted next to the frisker to remind responders to frisk their' hands before their shoes.
The licensee should. consider whether it would be more prudent to have a member of the RP staff oversee this function, particularly during radiological
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releases.
c 12.
Critiques
.
Immediately following the exercise, critiques were held in each of the emergency response facilities (ERFs).
A formal critique involvin
and corporate management personnel was conducted on November 16, g site
=
1989.
The purpose of the formal critique was-to summarize the individual ERF i
critique session observations and present them to upper management.
The
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Vice President, Nuclear Operations was among those representing upper
]
management.' The following represent'some of the critique findings j
presented during this meeting-
!
A.
Although the Alert and GE were declared in a timely manner, the SAE
~
was not declared within an acceptable amount of time.
The delay occurred because the TSC did not aggressively follow-up on information that was available.
B.
The dose assessment area had data display problems and problems with c
.the timeliness of data.
I C.
The Company Support Center (CSC) may not have been utilized as much
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as it could have.
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D.1 'The TSC Radiological ~ Monitoring-System was not operable during the exercise and no-one noticed the alarm lights.
E.
The PGE: field team did not meet the 30 minute requirement to be
ready.= It took 54 minutes instead. -This is a recurring problem.
,-
F.-
Some of the modules in EP-001 have ambiguous terms relating to high
. values.'
G.
Problems were again experienced with the E0F field team radios.
'
Action will be taken to determine a_ permanent = solution to this problem.
H.
The SPDS. terminals continued to have reliability problems.
I.
The OSC failed to perform radio checks prior to team dispatch.
On i
one occasion, the radio failed.
a J.
Problems were noted with the HDT' fax to the states and counties.
Some transmissions were missed but were re-transmitted later, after the agencies notified the E0F that the copies were missed.
"
13. : Exercise Summary FEMA ~ held a briefing at 9:00 A.M. on November 17, 1989, to present its
'
findings to the offsite participants.
The NRC Team Leader attended this
'
briefing as well as representatives from Portland General Electric (PGE).
+
A aublic briefing was conducted at 1;00 P.M. on November 17, 1989.
The pu)11c briefing was held at the Red Lion Inn in Kelso, Washington.
The purpose of the briefing was_to present a summary of the preliminary exercise' findings to interested members of the general public and the media.
FEMA', NRC, representatives from each of the offsite agencies, and
.PGE made presentations.
6.
Exit Interview-(Inspection Procedure 30703)
An exit-interview was held on November 16, 1989, to discuss the-preliminary findings of the inspection.
The attachment to this report identifies the licensee personnel who were present at the meeting.
The NRC was represented by tie four members of the inspection team which included Mr. R. C. Barr, Senior Resident Inspector.
The licensee was informed that.it appeared that no deficiencies or violations of NRC recuirements were identified during the inspection.
The NRC Team Leader
.dic state that it. appeared that 4 exercise weaknesses were identified.
- The findings described in Sections 2-4 and 8-11 were discussed; however,
.the matter of the PA announcements not including information about the release was categorized, at the time, as an exercise weakness.
The NRC Team Leader expressed some concern relative to the overall level of performance.
Immediately following the exit interview, the Team Leader was informed that PGE intended to run additional drills for TSC and dose
. assessment personnel.
Subsequent to the inspection, based on further review, characterization of two of the findings was changed as follows:
1) The exercise weakness
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incorporated into.the' exercise weakness involving the TSC's-performance.
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(Section 9. A).
2) The matter involving-the-hydrogen analyzers (Section.
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ATTACHMENT
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EXIT INTERVIEW ATTENDEES'
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A.,
Licensee Personnel
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?A. R.? nkrum ' Manager,isor, Q0 AuditsNuclear' Security-
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J.:A.; Benjamin,-Superv J D. L.i Bennet,- Manager,. Maintenance Branch D.!W sCockfield, Vice: President Nuclear
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a C.-R. Cox, Emergency. Planner N.:C. Dyer, Supervisor, Health Physics J.s L Lentsch, Manager,- Personnel Protectisti i
R. M. Nelson, Manager, NSRD D.-L.'Nordstrom, Manager Q0 Branch
.J.:D.Reid,l Manager,QualityServicesBranch
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S; P. Sautter, Manager, Nuclear Energy Information Branch r
C.-K.' Seaman, General Manager, NQAD R.- P. Sheppard,-Quality Assurance Engineer J. L. Thale, Supervisor, EP
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T. D. Walti General Manager,' Technical Functions;
.W. J. Williams Regulatory Compliance Engineer C.'P.Yundt,PlantGeneralManager G..A. Zimmerman, Manager, Radiological Safety Branch B.
Other Personnel
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F. A. Casella,'HMM Associates, Inc.
S. A.L-Harlos; ATESI
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