IR 05000348/1989032

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Insp Repts 50-348/89-32 & 50-364/89-32 on 891212-15,20 & 29. No Violations or Deviations Noted.Major Areas Inspected: Annual Emergency Response Exercise,Exercise Objectives & Scenario Details
ML20011E268
Person / Time
Site: Farley  Southern Nuclear icon.png
Issue date: 01/18/1990
From: Kreh J, Rankin W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20011E267 List:
References
50-348-89-32, 50-364-89-32, NUDOCS 9002130044
Download: ML20011E268 (22)


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NUCLEAR REGULATORY.COMMISslON i
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Report Nos.:,50-348/89-32 and750-364/89-32-

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? Birmingham.-AL 35291-0400 J Docket Nos.': 50-348 and 50-364 License Nos': NPF-2 and NPF-8-

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Facility Name: 'Farley Nuclear Plant

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Inspection Conducted:, December 12-15, 20, and 29, 1989

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Inspector: MM d

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K J. L. Kreh Uate'5'gned

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Accompanying Personnel:

T. Guilfoil F. Victor-

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W. H..Rankin, Chief

'Date Signed Emergency Preparedness Section Emergency Preparedness and Radiological

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Protection Branch

. 1 Division of Radiation Safety and Safeguards

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SUMMARY Scope:

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y Thisiroutine, announced inspection involved observation and evaluation of the

. i annual emergency response exercise.

Emergency organization activation and -

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response were selectively observed in the Control-Room, Technical Support Center -(TSC),). Operations. Support Center (OSC), and Emergency Operations Facility (EOF The inspectica also ~ 1ncluded ^ a. review of the exercise

" objectives and. scenario details, = as well as observation ~ of the licensee's Tpost-exercise critique activities.

The exercise. which included partial

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= participation by State and local governments, was conducted on December 13,

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1989, between the hours of 7:00 a.m. and 3:05 p.m.

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Results:

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In the' areas inspected, no violations or deviations were identified. However,

.four Exercise Weaknesses were identified as follows:

(1) failure to follow

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applicable-procedures in making offsite notifications of the Alert, Site Area Emergency and General Emergency declarations - (Paragraph 6); (2) failure to

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(follow, applicable-procedures with respect to briefing, controlling, and tracking -2' of 7. reentry teams (Paragraph 7); (3) failure to provide adequate

.gmeans!cf communication between the reentry teams and the TSC (Paragraph 8); and

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(4) failure. to. provide a - timely-, 'and appropriate protective action--

- recommendation (PAR) to-cognizant offsite euthorities' following the General Emergency declaration' (Paragraph.10).

- On December 29..~ 1989 licensee management committed to various corrective actions (sumarized. in Paragraph 13)

intended to address the Exercise Weaknesses identified during this inspection.

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1-f-f y REPORT DETAILS-1.

Persons Contacted i

Licensee Employees

  • S. Fulmer.. Supervisor - Safety Audit and Engineering Review

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  • J. Garlington,' General Manager - Nuclear Support
  • D. Grissette Environmental and Emergency Planning Supervisor
  • R. Hill, Assistant General Manager - Operations
  • F. Jessup. Emergency Planning Coordinator
  • R. Livingston. Chemistry Foreman
  • B..McKinney, Jr., Manager - Nuclear Engineering and Licensing
  • D. Morey, General Manager - Nuclear Plant
  • C, Nesbitt, Technical Manager
  • J. Osterholtz, Manager - Operations
  • L.-Stinson, Assistant General Manager - Support
  • D. Tedin, Supervisor _- Technical Training

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  • R. Wiggins, Supervisor - Operations Training
  • L. Williams, Trainino Manager
  • J. Woodard, Vice President - Nuclear Other licensee employees contacted during this inspection included engineers. operators, security force members, technicians, and administrative personnel.

Nuclear Regulatory Commission

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  • F. Cantrell, Section Chief. Division of Reactor Projects
  • G. Maxwell, Senior Resident Inspector
  • W. Miller, Resident Inspector

-* Attended exit interview h

l 2.

ExerciseScenario(82301,82302)

The scenario for the emergency exercise was reviewed to determine whether p

provisions had been made to test the licensee's integrated emergency response capability as well as to test a major portion of the basic-elements within the licensee's Emergency Plan, as required by 10 CFR 50.54(t),10 CFR 50.47(b)(14), and Section IV.F of Appendix E to 10 CFR Part 50.

The inspector's advance review of the scenario disclosed no significant t

technical problems, although several questior.s regarding the licensee's exercise methodology were raised by the inspector and telephonically

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addressed by a licensee representative prior to the inspection.

Some i

minor inconsistencies in the scenario became apparent durino the exercise; L

however, these did not sionificantly affect exercise play,

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The scenario developed for this exercise presented a series of events which fully exercised the licensee's emeroency organization, and provided sufficient.information to the State, counties, and Federal agencies consistent with the scope of their participation in the exercise.

The licensee demonstrated adequate training of personnel through use of controllers, evaluators, and specialists participating in the. exercise.

The controllers provided adequate auidance throughout the exercise.

Neither prompting nor undue interaction between controllers and players was observed.

a No violations or deviations were identified.

e 3.

OnsiteEmergencyOroanization(82301)

The licensee's organization was observed during the simulated emergency to determine whether the requirements of Paragraph IV.A of Appendix E to 10 CFR Part 50 were met addressing the descriptions, responsibilities, and assignments of the onsite emergency response organization, i

The inspector determined that -the initial onsite emergency organization

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was adequately defined and that primary and alternate assignments for the.

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positions in the auamented emergency organization were clearly designated.

The inspector observed that specific emergency assignments were made for the licensee's emergency response organization, and that adequate staff-was available to respond to the simulated emergency.

The initial response organization was auamented by designated licensee representatives; however, because of the scenario scope and conditions, long-term or continuous staffing of the emergency response organization was not required. Review of the Emergency Plan indicated that a sufficient number

of trained personnel was available for continuous staffing of the augmented emergency organization, if needed.

l The inspector also observed activation, staffing, and operation of the emergency organization in the Technical Support Center (TSC), the Operations Support Center (OSC), and the Emergency Operations Facility (E0F).

The required staffing and assignment of responsibility at the facilities were consistent with the licensee's Emeroency Plan and respective implementing procedures.

It was noted that a number of the principal positions in the licensee's emergency organization were filled by persons who were alternates for, or recently assigned to, their positions and had not previously served in those positions during an

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exercise.

The inspector observed that the "on-call" Emergency Director (ED)

cfficially assumed the responsibilities of the ED position prior to the

l classification or declaration of any emergency.

However, there was no L

announcement made to the Control Room personnel regarding this important i

transition.

It appeared to the inspector that some of the Control Room

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staff did not know for a time that the Operations Manager had assumed the ED responsibilities.

This matter will be reviewed during evaluations of future exercises.

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-Inspector Follow-up Item (IFI) 50-348,50-364/89-32-01: Assuring that the Control Room staff is informed when the on-call ED formally assumes ED responsibilities.

No violations or deviations were identified.

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EmergencyResponseSupportandResources(82301)-

This area was observed to determine whether arranaements for requesting and effectively using assistance resources were made, whether arrangements

to acconnodate State and local staff at the EOF were made, and whether-other organizations capable of augmentina the planned response were-identified as specified by 10CFR50.47(b)(3), Paragraph IV. A of

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Appendix E to 10 CFR Part 50, and guidance promulgated in Section II.C of NUREG-0654(Revision 1).

Observation of licensee involvement and contact with Federal, State.

. county, and local support organizations was essentially confined-to initial notification and respective follow-ups attending declarations of emergency classifications via' communications links.

Only one offsite agency representative (from the State of Georgia) was present at the E0F; the licensee's interface with him appeared to be satisfactory. Operation of the News Media Center was not observed by the NRC.

No violations or deviations were identified.

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EmergencyClassificationSystem(82301)

This area was observed to verify that a standard emergency classification and action level scheme was in use by the licensee as required by 10 CFR 50.47(b)(4) and Paragraph IV.C of Appendix E to 10 CFR Part 50.

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An Emergency Action Level (EAL) matrix was used to identify and properly

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classify-an emergency and escalate it to more severe emergency classifications os the simulated accident sequence progressed.

The licensee's use of the EALs in deducing each of the emergency classifications (Alert, Site Area Emergency, and General Emergency) was consistent with the Emergency Plan and the Emergency Implementing Procedures (EIPs).

No violations or deviations were identified.

6.

Notification Methods and Procedures (82301)

This area was observed to determine whether procedures were established for notification of State and local response organizations and plant emergency personnel by the licensee, and whether the content of initial and follow-up messages to response orcanizations was established.

This area was further observed to determine whether means to provide early notification to the population within the plume exposure pathway were established pursuant to 10 CFR 50.47(b)(5), Paragraph IV.D of Appendix E

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to 10 CFR Part 50, and specific guidance promulgated in'Section II.E of NUREG-0654 (Revision 1).

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The inspector observed that notification methods and procedures were established and available for use in providing information regarding the

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simulated emergency conditions to Federal, State, 'and. local response

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organizations, and to alert the licensee's augmented emergency response

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Inspection also disclosed that the licensee consistently implemented notification of the State and countics within the 15-minute time regime following declaration of the applicable emergency classifications throughout the exercise.

Periodic updating regarding plant status via telephone and transmission of hard copies was concistently implemented durino the exercise.

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However, the inspector observed that some of the notifications to' offsite

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agencies were made in a manner inconsistent with the requirements of procedure FNP-0-EIP-26 (Revision 27),

"Offsite Notification."

Notifications to the State of Alabama and to the NRC of the Alert declaration were made without benefit of the aprropriate notification form (i.e., the communicator was conveying information from memory rather than reading from the approved message form).

Notification of the Alert was

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properly made to the State of Georgia, although the messaae form lacked the time. of the Alert declaration.

The inspector noted that the information thereby conveyed to cognizant officials of the two States was somewhat different.

- In addition, the Site Area Emergency and General Emergency notifications were made prior to completion and ED approval of the appropriate iressage form (Figure 3 of FNP-0-EIP-26).

As a consequence, a protective action recommendation (PAR), which the licensee wa's required to provide, was not issued until almost 30 minutes following the General Emergency declaration (see also Paraaraph 10).

The response problems described in this paragraph fundamentally represent a repetition of problems that occurred during the 1988 exercise (IFI 50-348, 50-364/88-30-03, Paragraph 12.b).

This problem is - therefore considered an Exercise Weakness for which corrective actions are required.

Exercise Weakness 50-348, 50-364/89-32-02:

Failure to make offsite notifications of emergency declarations in a manner consistent with

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procedure FNP-0-EIP-26.

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Activation of the prompt notification system (PNS), which consisted of I

sirens and tone-alert radios, was included as an exercise objective.

According to a licensee representative, all components of the PNS

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No violations or oeviations were identified.

7.

Emergency Facilities and Equipment (82301)

This area was observed to determine whether adequate emergency facilities i

and equipment to support an emeroency response were provided and

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maintained pursuant to 10 CFR 50.47(b)(8), Paragraph IV.E of Appendix E to l

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- 10. CFR Part. 50, and specific, guidance promulgated in Section. II.H of NUREG-0654(Revision:1).

.The inspector' observed activation, staffing and operation of the emergency response facilities, and observed the use-of equipment therein.

Emergency response facilities used by the license during the exercise included the Control Room TSC, OSC, and E0F.

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Control Room The Unit 1 Control Room was provided for the exercise Shift

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Supervisor and his staff. Required communications equipment, Control Room procedures, and other applicable documents were readily available.

The inspector observed that, following review and analysis of the sequence of accident events Control Room operations personnel promptly initiated required responses to the simulated emergency.

Emergency procedures -were readily available, routinely followed, and factored into accident assessment and mitigation o

efforts.

The Shift Supervisor and Control Room operators were cognizant of their duties - responsibilities, and authorities.

These personnel i

demonstrated an understanding of the emergency classification. system

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and the proficient use of specific procedures to determine and

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declare the proper emergency classification.

However, notification

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of offsite agencies was a problematic area; this item is discussed in Paragraph 6, above.

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~ Technical Support Center (TSC)

The TSC was activated and staffed following declaration of the Alert

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classification.

The staff appeared to be cognizant of their emergency duties, authorities, and responsibilities.

Required

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operation of the facility proceeded in an orderly manner, and the TSC

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was provided with adequate equipment for support of the assigned staff.

During operation of the TSC, radiological habitability was routinely monitored and documented, writh personnel. dosimetry distributed as L

required.

Status boards and related visual aids were located to facilitate viewing by the TSC staff.

The transfer of authority and specific responsibilities from the Emergency Director to the EOF Recovery Manager following activation L

of the E0F was consistent with the Emergency Plan and EIPs, except

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for what appeared to be an unduly lona-period for turnover of dose l'

assessment responsibility from the TSC to the EOF (approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after EOF staff began to arrive at the facility).

This matter was discussed with licensee management.

Frequent and

effective communications were maintained between the respective l

facility managers and principal staffs.

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Operations Support Center (OSC)

The OSC. team assembly and briefing area was located.at the rear of'

and adjacent to the TSC.

The facility was activated.and staffed

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following declaration of the Alert.

An inspector observed that five l

reentry teams were assembled, briefed, and dispatched from the.

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-assigned assembly area. A Health Physics (HP) Technician accompanied each of'those. teams.

However, two other reentry teams took actions which - were not in accordance with applicable procedures.

The inspector noted that FNP-0-EIP-14. (Revision 5),

"Re-entry Procedures" _ provided guidelines for reentry into plant or site areas which had. been evacuated as a result of an emeroency.

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ouidelines were not followed for the two teams (one Chemistry technicians, the other electricians) sent to restore operation of the water treatment plant. which, like the rest of the plant, had been

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ordered evacuated following the Site Area Emergency declaration. No

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records were available to indicate -that these reentries were preplanned. briefed,- or debriefed, as specified by the subject procedure.

The only documented evidence available to confirm the-required ED approval of one of these two missions was an entry.in the HP Manager's log that-stated "1027 Permission ED.for chem to go to water treatment".

Other than two further brief entries in the HP Manager's log regarding the Chemistry team (one concerning departure

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of the team from the OSC, the other documenting a report of normal background radiation levels at the water treatment plant). there were no indications that the two subject teams were tracked.

The second team (two electricians) did not include HP coverage as required by FNP-0-EIP-14, despite the fact that a radiological release was occurrino at the time of the reentry.

The problems delineated in

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this paragraph indicate a substantial repetition of a problem that occurred during the 1988 exercise (IFI 50-348, 50-364/88-30-05, Paragraph 12.d).

This problem is therefore considered an Exercise

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Weakness for which corrective actions are required.

Exercise Weakness 50-348,50-364/89-32-03: Failure to brief, control, and track two of seven reentry teams as specified by procedure

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FNP-0-EIP-14.

A related discrepancy was the fact that the ED did not complete the reentry checklist, as required by step 4.1.7 of procedure FNP-0-EIP-14, for any of the reentry teams, although, as implied earlier in this paragraoh, five of the seven teams were handled in accordance with the requirements of the checklist.

The particular discrepancy cited is failure to document actions in accordance with t

procedure. This matter will be reviewed during evaluations of future exercises.

IFI 50-348, 50-364/89-32-04:

Ensurino the completion by the Emergency Director of the reentry checklist in procedure FNP-0-EIP-14.

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d.

Emergency Operations Facility (EOF)

Consistent with the exercise scope and= objectives. -the E0F was-l staffed and activated following declaration of the Site Area

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Emergency.

A drill involving robilization of the essential ^ facility staff. including the Recovery Manager. was conducted on December 12, t

1989 to assess effectiveness of logistics and to' determine staff; augmentation time involved in transit between the licensee's

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corporate headquarters (Birmingham, Alabama) and the plant. site. The-

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subject drill, which provided the mea'ns of prestaging this aspect of the exercise, was initiated at 9:00 a.m. by a call' from the plant to

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. the corporate. office requesting activation of the EOF.

The nine required corporate personnel arrived.at the E0F at 12:25 p.m., at which time the drill was terminated.

The licensee's stated goal;of having corporate staff arrive at the EOF within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (Emergency Plan, Revision 17, page 87) was thus achieved in this drill.

Except for the matters discussed in Paragraphs 7.b and 10, the licensee's E0F operations demonstrated the capability to implement an -

adequate response to the casualty.

No violations-or deviations were identified..

8.

Emeroency Communications (82301)

This area was observed to determine whether provisions existed for prompt communications among principal response organizations and emergency personnel pursuant to 10 CFR 50.47(b)(6), ' Paragraph IV.E of Appendix E to 10 CFR Part 50, and specific guidance in Section II.F of NUREG-0654

.(Revision 1),

j The ' inspector observed comunications within and between the licensee's emergency facilities, and between the offsite-environmental monitoring

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l teams and the E0F. The inspector also observed information flow among the t

various groups within the licensee's emergency organization.

In general,

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l comunication of information occurred in an adequate manner.

j However, one significant problem in communications was observed. Reentry team 5, which was sent to.stop the containment penetration leak, had difficulty communicating with the TSC.

The team was located in a

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simulated radiation field of 1 R/hr (4 R/hr open-window reading) for-l 7 minutes while the HP technician tried repeatedly to communicate with the L

TSC (approximately 10 attempts using 'the plant telephone system and 4 l

using the plant paging system).

A total of 16 minutes transpired before the HP technician was able to communicate with the TSC.

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noted-that the licensee has determined that radio communications between

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plant reentry teams and the TSC are not reliable; therefore, such teams were not equipped with radios.)

During the referenced 16-minute period, the team decided to reenter a 20 R/hr radiation field in order to connect a gas bottle to electrical penetration B026-3 LLRT test valve even though the team had shortly before found the valve open and had closed it. This l

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4 task was performed without the knowledge or. approval of 'the-TSC.

Furthermore, this second entry into the 20 R/hr field was unnecessary and would not have been authorized by TSC managers if contact with the TSC had been established in a timely manner. Had the radiation fields described above. been 1 real instead of simulated, significant and unnecessary radiation doses would -have been incurred by three licensee personnel.

This finding is categortred as an Exercise Weakness for which corrective t

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actions are required to prevent recurrence.

Exercise Weakness 50-348, 50-364/89-32-05:

Failure to provide adequate means for plant reentry teams to communicate with the TSC.

No. violations or deviations were identified.

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AccidentAssessment(82301)

This' area was observed to detertnine whether methods, systems, and equipment for ' assessing and monitoring actual or potential offsite

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consequences of radiological emergency conditions were in use as required-by 10 CFR 50.47(b)(9) Paragraph IV.B of Appendix E to 10 CFR Part 50, and-specificcriteriainSectionII.IofNUREG-0654(Revision 1).

The accident. assessment program included an engineering assessment of plant status and an assessnent of radiological hazards to.both onsite and.

offsite personnel resulting from the accident.

In general, these assessments were adequately performed and the results properly employed in the development of mitigating actions (see Paragraph 10 for a discussion of related problems).

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The activities of onsite and offsite radiological monitoring teams were not observed by the inspector.

No violations'or deviations were identified.

10.

Protective Response (82301)

This area was observed to determine whether guidelines for protective actions during the (simulated) emergency, consistent with Federal guidance, were developed and in place, and whether protective actions for emergency workers, including evacuation of nonessential personnel, were

. implemented promptly as required by 10 CFR 50.47(b)(10) and specific i

criteria in Section II.J of NUREG-0654 (Revision 1).

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The inspector verified that the licensee had and used emergency procedures

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for formulating protective action recommendations (PARS) for the offsite populace within the 10-mile energency planning zone.

The inspector observed that protective actions were initiated for onsite emeraency workers following the Site Area Emergency declaration by conducting en accountability of those personnel inside the Protected Area.

The (simulated) evacuation of nonessential plant personnel was ordered in a timely manner.

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The procedure for formulating PARS was implemented (as stated above), but not in an adequate manner. _ As discussed in Paragraph 6', a PAR.was not i

issued to cognizant offsite officials until almost 30 minutes after the m

General-Emergency declaration.. The licensee's procedures required offsite notification of a General Emergency, along with a PAR, within 15 minutes of the declaration.

In the face of the referenced delay, the State of.

Ceorgia-(which was in the downwind direction) ordered protective actions

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for 'the public~ without benefit of the licensee's PAR.

The PAR, when i

finally. issued, was flawed because it was not formulated in accordance with procedure FNP-0-EIP-19.

The PAR was "Evacuhte Zones A,15 to 5 miles".- The' referenced procedures, as well as licensee aareements with the States of Alabama and Georgia, specified an "all or nothing" approach-

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to protective actions for a given zone.

The licensee's exclusion in the

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PAR of that portion of Zone 15 outside the 5 mile radius was not consistent with the referenced procedure or with any mode of operation

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established between the licensee and the States.

This finding is

't categorized as an Exercise Weakness for which corrective actions are

required to prevent recurrence.

Exercise Weakness 50-348, 50-364/89-32-06: Failure to provide a timely and appropriate PAR 'to cognizant offsite authorities following the General-

-Emergency declaration.

11. Exercise Critique (82301)

The licensee's critique of the emergency exercise was observed to determine whether shortcomings in the performance of the exercise were brought. to the attention of management and documented for corrective f action pursuant to 10 CFR 50.47(b)(14), Paraaraph IV.F of Appendix E.to

10 CFR Part 50, and specific guidance promulgated in Section II.N of.

NUREG-0654 (Revision 1).

The inspector observed the licensee's player / monitor critique -conducted immediately following the exercise.

The subject critique involved a

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detailed discussion and analysis of required improvements and deficiencies identified during the exercise.

All substantive findings were documented'

for review and correction.

The respective corrective actions implemented to address these findings wili be reviewed during future inspections. The significant deficiencies identified included only one of the four Exercise.

Weaknesses discussed in this report.

A formal presentation of the critique results was made to licensee management on December 15, 1989, 12. ActiononPreviousInspectionFindings(92701)

a.

(Closed) IF1 50-348, 50-364/88-30-01:

Implementing effective management and control of the TSC and E0F to ensure prompt and effective activation and routine operation.

Evaluation of the 1989 exercise indicated that suitable corrective action had been implemented in response to this finding.

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(Closed) IFI 50-348, '50-364/88-30-03:

Ensuring that offsite o

notifications ~are implemented in a manner consistent with procedure

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FNP-0-EIP-26.

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For tracking purposes, this item is closed because a similar problem

was identified.during the current inspection as an Exercise Weakness'

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(see Paragraph 6 for details),

c.

(Closed) IFI 50-348, 50-364/88-30-04:

Ensuring that' the Emergency

Director informs the plant staff of emergency declarations and provides the staff with periodic updates of' plant status durino emergency events.

The only general PA announcement made during the 1989 exercise was at 9:19 a.m. when, following the sounding of the plant emergency alarm, plant personnel were informed ~ that a Site Area Emergency had been

declared and that they should proceed to their desianated assembly areas

_ Review of the EIPs indicated that.any other announcements (e.g., upon Alert or General Emergency declaration) would be strictly at-the option of the ED.

Licensee management representatives explained that they had chosen to keep 'such announcements optional for the ED rather than require them.

There is no regulatory requirement that such announcements be made.

d.

.(Closed) IFI 50-348, 50-364/88-30-05:

Ensurino 'that all reentry teams are briefed. controlled, and tracked to preclude uncontrolled

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reentries.

For tracking purposes, this item is closed because a similar problem-

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was identified during the current-inspection as an Exercise Weakness (see Paragraph _7 for details.)

e.

(Closed)-IFI 50-348, 50-364/89-01-03:

Development of a system for periodically testing the capability to augment the onsite emergency response organization (ER0) during off-hours.

The licensee changed procedure FNP-0-EIP-15 (Revision 14), " Emergency Drills,"- to provide for a quarterly test of the ability to contact l

"on-call" personel.

The inspector reviewed documentation of drills i

conducted September 27, October 18, October 31 and November 17, 1989 (all were initiated between 7:00 p.m. and 8:00 p.m.).

A licensee representative indicated that corrective actions implemented to address _ the problems thus far disclosed have demonstrably improved y

the capability to augment the onsite ERO during off-hours.

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13. Exit Interview The inspection scope and results were summarized on December 15,'1989, l

with those persons indicated in Paragraph 1.

The inspector described the I

areas inspected and discussed in detail the inspection results listed below.

Although proprietary information was reviewed during this

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inspection, none-is contained in this report.

Dissenting connents were

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not received from the licensee.

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t Item Number Description and Reference :

50-348' 364/89-32-01 IFI - Assuring that the Cantrol Room staff

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is informed when the on-call ED formally assumes ED responsibilities (Paragraph 3).

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50-348, 364/89-32-02 Exercise Weakness - Failure to make offsite notifications of emergency declarations in a

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manner consistent with procedure l

FNP-0-EIP-26 (Paragraph 6).

'l 50-348,'364/89-32-03 Exercise Weakness - Failure to brief, l

control, and track 2.of 7 reentry teams as specified by procedure FNP-0-EIP-14

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(Paragraph 7.c).

50-348,364/89-32-04 IFI - Ensuring the completion by the ED of the reentry checklist in procedure FNP-0-EIP-14 (Paragraph 7.c).

50-348,364/89-32-05 Exercise Weakness - Failure to provide adequate means for plant reentry teams to communicate with the TSC (Paragraph 8).

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50-348,364/89-32-06 Exercise Weakness:

Failure-to provide a timely and appropriate PAR to cognizant offsite authorities following the General Emeroency declaration (Paragraph 10).

Licensee management was informed that five previous findings were reviewed and closed, as discussed in Paraaraph 12.

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On December 20, 1989, the inspector telephonically informed cognizant-licensee representativer that two additional findings (one Exercise Weakness and one IFI) discussed during the Exit Interview were being withdrawn based on further review by Region 11 management.

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During a telephone conversation on December 29, 1989, between J. Woodard, l'

Vice President-Nuclear, and D. Verre111 and D. Collins of the NRC, Mr. Woodard outlined corrective actions taken and planned as a result of

the findings during the exercise.

Actions included those already taken,

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those planned for the short term (to be completed within 14 days of e

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December 29), and long-term actions (to be completed within 90 days of L

December 29). The commitments made by the licensee are outlined below.

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F With regard to the' problems related to the' reentry teams:

All individuals who might lead such' teams will be provided with

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multiple phone numbers for contacting the TSC, and will be briefed on

the applicability-of. the procedure to situations where teams respond

to any evacuated area, including areas outside buildings (short term).

All individuals who might be the Emergency Director or a technical

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manager will be briefed on the Exercise Weaknesses and planned correctiveactions(shortterm).

Procedures-will be revised to clarify that, after an area is

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evacuated, radiological controls will be specified for teams

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dispatched to outside areas, except in limited circumstances when

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exposure to'a plume is unlikely (long term).

With reaard to protective action decision-making and communications to the

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States:

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All Shift Supervisors and Emergency Directors who have been on shift

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have been briefed on the Exercise Weaknesses and planned corrective-actions.

All such personnel who have not been on shift will receive briefings, including reminders that a protective action recommendation must be provided to the States with - the General Emergency declaration and that protective actions for partial zones are not appropriate (short term).

Procedures will be revised to clarify the above (long term).

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The licensee.will discuss with the States the use of the initial

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notification form, as well as upgrades in emergency classifications

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(longterm).

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In addition to the above, the staff will be trained in changes to procedures as the changes are made.

Also, the effectiveness of the revised procedures and training will be evaluated by walk-throughs, tests, or drills.

It is the licensee's intention to work with the States to move the 1990 emergency exercise.to a date earlier in the year.

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Attachment:

Exercise Objectives and Scenario Summary

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f 1989 FARLEY NGC1XAR FIAfff Dg3GD4CY EXERCISE CEL71lCFIVES

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December 13, 1989 q

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.I.-_ Participating organizations rull Participationt. Alabama Power Company, the State of Alabama,

-l Houston County, State of Georgia, and Early County.

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Purpose A.

To meet the requirements of 10CrR50, Appendix E, and

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NJREG-0654/rDE-REP-1, Rev.1.

J B.

To conduct-a small-scale exercise that will include the mobili-

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zation of Alabama Power Company, state and local personnel and resources adequate to verify the capability of participating j

organizations to respond to an accident scenario requiring

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response, III. Alabama Power Company Objectives A.

On-site

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1.

Demonstrate that control room staff can assess the event, classify the event, take corrective resures to control the

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event and activate emergency responte procedures.

2.

Demonstrate that plant staff can activate and staff the j

Technical Support Center (TSC) and perform accident response j

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activities including:

a.

Dose Assessment b.

Off-site notification and protective action recommendations c.

Reclassification of emergency status d.

Personnel Accountability for all personnel on-site Radiation Monitoring Team (RMT) Dispatch and Control e.

f.

Site access control and admittance of essential personnel g.

Post-Accident Sampling Activities 3.

Demonstrate the capability to turn over Ecr functions to the EOF staff when the EOF is activated and staffed.

4.

Demonstrate the capability to augment EOF staff with non-essential plant personnel.

5.

Demonstrate the adequacy of the plant's comunication system

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including: Communication links to Corporate Emergency W

Operations Center (llDC); News Media Center (NMC); interplant communications; and conmuunication links to state and local authorities.

6.

Demonstrate the capability to perform radiological monitoring.

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/,o B.- Off-Sita 1.- Denenstrate that corporate staff can be activated in a timely 7 s-fashion and dispatched to FNP.*

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Demonstrate that Corporate Headquarters Emergency Operations 2.

Center (EOC) staff.can provide initial support for:

a.

EOF activation *

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Logistics

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Support organization notification d.

Briefing of coupany management

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News release preparation 3.

Demonstrate that EOF staff cant i

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Assume the dose assessment function and a.

the RMT direction and control function from the TSC staff..

b.. Assume the logistics, manpower and engineering function from the Eoc.

Prepare and coordinate news releases and

c.

j activate * the NMC.

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4.

Demonstrate that the Public Information organization can respond to media and public inquiries, establish a rumor control center,'and issue and coordinate news releases.

A IV. - State and Local objectives

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- See Attachment 1 (Any state or local objective that cannot be

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demonstrated due to conditions inconsistent with the scenario will

be demonstrated in a separate drill.)

Joint Objectives (Alabama Power Company, State of Alabama, State V.

cf Georgia, Houston County and Early County)

1.

Demonstrate that all parties can coordinate news releases and conduct a joint news conference.

2.

Demonstrate that adequate technical information can be exchanged among involved agencies.

VI.

Exercise Limits

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2he exercise will begin prior to 8 A.M. CST and conclude by 4:00 P.M.

CST.

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This will

  • To be tested in a separate drill the day before the exercise.

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allow pre-staging of these activities on the day of the exercise.

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A'ITACHMENT 1

STATE AND IDCAL OBJECTIVES

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State Houston State Early of AL. County of GA.

County 1.

Demonstrate the ability to accitor, understand

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and use emergency classification levels (ECL)

through the appropriate inglementation of emergency functions and activities corresponding to ECLs as required by the scenario. '1he four ECLs are: Notification of Unusual Event, Alert,

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X X

X X

site Area Emergency and General knergency.

Demonstrate the ability to fully alert, mobilize 2.

and activate personnel for both facility and field-X X

X X

based emergency functions.

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3.

Demonstrate the ability to direct, coordinate, and control emergency activities.

X X

X X

n 4.

Demonstrate the ability to comuunicate with all

,-.Q appropriate locations, organizations and field X

X X

X personnel.

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Demonstrate the adequacy of facilities, equipnent,

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I dispisys-and other materials to support emergency X

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X X

operations.

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Demonstrate the ability to continuously l

monitor and control emergency worker

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exposure.

7.

Demonstrate the appropriate equipnent and and procedures for determining field radiation X

X measurements.

Demonstrate the appropriate equipment and procedures 8.

for the measurement of airbope radiciodine concentrations as low as 10~ aicrocurie per cc in the presence of noble gases.

9.

Demonstrate the ability to obtain samples of particulate activity in the airborne plume and promptly perform laboratory analyses.

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State Houston ' State Early of AL.

County of GA... County

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t A..; Demonstrate.the ability, within the plume exposure

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pathway, to project dosage to the public via v

X X

plume exposure, based on plant and field data.

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Demonstrate the ability to make appropriate Lil.

protective action decisions, based on projected

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or actual dosage, DA PAGs, availability of

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adequate ahelter, evacuation time estimates X

X X

J and other relevant factors.

12. Demonstrate the ability.to initially alert

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the public within the ICHaile DZ and begin

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dissemination of an instructional' message j

within 15 minutes of a decision by appropriate X

X X

X state and/or local official (s).

13. Demonstrate the ability to coordinate the formulation and dissemination of accurate information and instructions to the public in a timely fashion after the initial alert and X

X X

X f

notification has occurred.

I Demonstrate _the_ ability to brief the media

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in an accurate, coordinated and timely

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X X

X X

36anner.

Demonstrate the ability to establish 15.

and operate rumor control in a coordinated X

and timely. fashion.

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Demonstrate the ability to make the decision 16.

to recomend the use of KI to emergency workers based on predetermined ~ criteria, as well as to distribute and administer it once

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the decision is made, if necessitated by radiciodine releases.

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17. -Demonstrate the ability to make the decision i

to recomend the use of KI for the general public,

-based on predetermined criteria, as well as to distribute and administer it once the decision is ande, if necessitated by radiciodine releases.

Demonstrate the ability and resources necessary 18.

to implement appropriate protective actions

, OV for the impacted permanent and transient plume EPZ population (including transit-dependent persons, special needs populations, and (

X X

X X

handicapped persons).

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of AL. County ' of GA. : County

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f(d. Demonstrate the ability and resources necessary

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to implement appropriate protective actions for

~-i school' children within the plume En.

20. Demonstrate the organizational ability and

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resources necessary to control evacuation traffic flow and to control access to X

~X evacuated and sheltered areas.

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equipment and personnel for the registration, radiological monitoring and decontamination of

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. evacuees (except radiological monitoring and X

X decontamination).-

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22. Deuenstrate the adequacy of facilities, equipment and personnel for congregate care of X

X evacuees.

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23. Demonstrate the adequacy of vehicles, equipment,

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procedures and personnel for transporting con-taminated, injured or exposed individuals.

X I

(To be performed in an independent drill)

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24.- Demonstrate the adequacy of medical facilities, equipment, procedures and personnel for handling contaminated, injured or exposed individuals.

X (To be performed in an independent drill)

25. Demonstrate the adequacy of facilities, equipment, supplies, procedures and personnel for de-contamination of emergency workers, equipment

and vehicles and for waste disposal.

26. Demonstrate the ability to identify the need for and call upon federal and other outside X

X support agencies' assistance.

Demonstrate the appropriate use of equipment 27.

and procedures-for collection and transport of les of vegetation, food crops, milk, meat, a

try, water and animal feeds (indigenous to the area and stored).

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> State Houston State ~Early

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of AL. County of CA.

County

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Demonstrate the appropriate lab ~

rations'and

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.f procedures for measuring and ana yzing.s

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of vegetation, focd crops, ailk, meat,'

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water and animal feeds (iridigenous to tw area and stored).

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29.; Demonstrate the ability to project dosage to the

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determine appropriate protective asasures based

on field data, FIA PAGs and other relevant factors. _

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30. Demonstrate the ability to iglement both

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preventive and emergency protective actions for ingestion pathway hazards.

31. Demonstrate the ability to estimate total population exposure.

Demonstrate the ability to determine appropriate

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measures for controlled reentry and recovery based

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O on estimated total population exposure, available O

EPA PAGs and other relevant factors.

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33. Demonstrate the ability to implement appro-priate measures for controlled reentry and recovery.

34. Demonstrate the ability to maintain staffing on:a continuous 24-hour basis by an actual j

shift change.

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35. Demonstrate the ability to coordinate the evacuation of onsite personnel.

j 36. Demonstrate the ability to carry out emergency response functions (i.e., activate 50Cs, mobilize staff that report to the EOCs, establish connunications linkages and complete telephone call down) during-an unannounced off-hours drill or exercise.

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n 1989 EXERCISE SCENARIO - TECHNICAL EVENTS (CONT.)

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M 4.0. NARRATIVE SUMMARY The scenario will begin at-0710 central time with a gross failed fuel detector alarm. The alarm will exceed 1 x 100 cpm above background (indicate cpm equivalent to approx. 2% clad damage) and cause the operators

to connence a controlled ramp down in power per AOP-32.0. At 0745, 1B

NDAFP will trip on overload due to a short in the motor windings.

At.0755, chemistry will report the results of the RCS sample taken due to the GFFD alann.

Based on dose equivalent I-131 activity of 130 pCi/ml plant shutdown and cooldown to below 500*F will be initiated.

At 0800, the 1A S/U transformer is lost due to a voltage spike on the grid causing failure-of breaker 800 in the high voltage switchyard (will not reclose). An "A" train LO3P occurs resulting in a reactor trip.

Rod H14-will stick in the core at 150 steps.

1-2A Diesel Generator will auto start, and B1F LOSP sequencer will run. The TDAFP will trip on overspeed (can be restored) and 1A MDAFP will fail to start due to closing spring not being charged (will restore after manually charging).

Based on loss of ALL AFW an ALERT will be declared.

At 0900 indications of a control rod housing rupture (ejected rod) on rod

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H14 will be received resulting in additional fuel damage (increase to approx 5% clad damage), 20 gpm RCS leak. At this point, a SITE AREA

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EMERGENCY will be declared.

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At.1015, a large break LOCA will occur. Automatic actuation of Phase

"B" l

L will not occur at 27 psig forcing the operators to initiate Phase

"B" l

manually. Containment pressure will rise to approximately 40 psig. A containment leak of 200 CFM will occur due to failure of an electrical penetration inner (containment side) 0-ring and the associated LLRT test connection valve being left open. This will result in a radioactive

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release to the environment and the declaration of a GENERAL EMERGENCY due to the loss of all three fitsion product barriers.

By 1300, the penetration leak will be either isolated by a reentry team or will reduce to zero leakage based on CTMT pressure reduction.

The TSC will be fully staffed and radiation monitoring teams will be dispatched to perform environmental monitoring. The plant will cooldown during safety injection.

The EOF will be activated and will continue the efforts to track the plume and provide environmental monitoring and dose assessment. The EOF staff will be further challenged with licensing, public information, engineering and logistics support activities.

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1989 EXERCISE SCENARIO - TECHNICAL EVENTS (CONT.)-

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'4.0 NARRATIVE SUMMARY (CONT.).

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The News Media Center will be activated and staffed by representatives from APCo, the State of Alabama, Houston County, the State of Georgia and Early

County. _ Media and public interest will be simulated and news releases will

be prepared and released.

The exercise will terminate once the radiation monitoring teams have tracked the plume, the EOF has been staffed and is performing EOF

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activities, and the News Media Center staff has conducted a press conference. Termination will be coordinated with the State of Alabama and the State of Georgia if occurring prior to 3:00 P.M. Central.

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