ML19326E017

Forwards Scenario of Emergency Exercise Conducted on 800624 at Big Rock Point.Util Has Agreed to Critique Exercise & Provide Action Plan to Identify Deficiencies & Indicate Corrective Actions

ML19326E017
Person / Time
Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	07/11/1980
From:	Axelson W Office of Nuclear Reactor Regulation
To:	Pagano W Office of Nuclear Reactor Regulation
References
NUDOCS 8007250406
Download: ML19326E017 (44)

Text

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UNITED STATES 8 \\.,

'k NUCLEAR REGULATORY COMMISSION 5,.*

• E WASHINGTON. o C. 20555

e Jul,y 11, 1980 MEMORANDUM FOR: Frank Pagano, Chief. Emergency Planning Licensing Branch FROM:

W.L. Axelson, Team Leader, Emergency Planning Licensing Branch

SUBJECT:

OBSERVATION OF AN EMERGENCY EXERCISE AT THE BIC ROCK POINT NUCLEAR PLANT On June 24, 1980, an NRR/NRC Review Team observed an emergency exercise at.the Big Rock Point (BRP) Nuclear Plant.

The tean consisted of myself, two staff me=bers from NRC, Region III, and two staff members f rom the Los Alamos Scientific Laboratory. Team ceebers were stationed in the folloving areas: Control Room; Technical Support Center; Operations Support Group Center; offsite Emergency Operations Facility; local hospital; and the BRP offsf.te environ = ental monitor-ing station. During this exercise, the State of Michigan, Charlevoix County, and Ec=et County Ecergency Plans were also tested.

Ff.MA observed the state and local actions. The scenario is enclosed.

On June 25, 1980, a for=al critique of tie crercise wts conducted with FEMA and representatives from the State of Michig..n and Charlevoix and Ec=et Counties.

In general, FEMA felt that the exercise.<as successful and " passed" the State.

I held a similar, but much less formal,.ritique with Consumers Power Company.

In general,.I felt the Big Rock Point en reise was a t raining exercise. The plant and corporate staf f learned core f rom this exer ise than from any pre-vious exercises conducted. Several areat of concern uere identified by the NRR Review Team. These were discussed with the licensee during the critique. As a result of the exercise, Consumers Power Company agreed to critique the exercise in a letter which will be submitted to the Of fice of Nuclear Reactor Regulation.

As part of this submittal, they agreed tc provide an " action plan" which will identify the deficiencies and indicate tle corrective actions to be taken.

As you are aware, intervenors from the Ccncerned Citizens of Charlevoix were allowed to observe the licensee's actions during thi@ exercise.

Ms. Christa-Maria was stationed in the licensee's Technical Support Center and Mr. Jim Mills was stationed in the licensee's offsite Emergency Operations Facility (EOF).

After the exercise, both members provided me with their specific coc=ents.

These comments are enclosed.

In general, their observations were similar to that of the NRR team.

Mr. Mills' co==ents indicated that P&ID's were not V

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THIS DOCUMENT CONTAINS

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P00R QUAUTY PAGES 0N f s o o 't 2 5

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F. Pagano.

July 11, 1980 available at the EOF. This was noted by the NRR team also. His other comment related to the location of the EOF (approximately 10 miles from the plant).

This item is unresolved at this time. Ms. Christa-Maria's comments indicated that a status board was not available to the TSC. Her other coment iridicated that licensee personnel were not fa=iliar with the state and local plans. The team also identified both of these items and reco== ended additional training.

Ms. Christa-Maria's further co=ments were unrelated to this exercise. I asked Ms. Christa-Maria if she wanted a formal response from NRC addressing,het; con-cerns as stated in her letter. She said, "no."

I reiterated that our common concerns were addressed to the licensee during the critique.

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Er.r.rgency Planning Licensing Jranch

Enclosures:

as stated cc w/ enc 1:

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3roup asks 1 ~RC to keep Big Rockshu'xiown h present containment structure, made of Atomic Energy Commission, as was the kirwis of cladding and various kinds of (Sara Cay Dammann threcquarter inch steel plate, is NRC.

combinations," he sail. " General

" adequate to prevent off. site release of "We feel the NRC is working with Electnc, which is also a fuel supplier,is t

Another attempt to keep Big Rock radioactivity in the event of a senous ERDA. ney are knowingly allowmg a doing the same thing with ' f 2

sclerr P:wer Plant closed was made acetdent," accordmg to the release. But daneerous situation to continue at Elig Commonwealth Edison Company in 5

Y the C:ncerned Citizens of Charlevoir they added, "some radiation might be Rock because of these expertments.

Chicago."

a telegraphed intervention to the emitted directly through the steel hey are domg this because Big Rock is Blanchard alse revealed that General

'l seletr Regulatory Commission sphere and hinder activities of workers in an area af low population.

E!cetric is conducting tests at Hig Rock f:

IRC) Saturday.

at the plant site."

"ney are using local residents as on certam metals, including stainless e.1 Also on Saturday, the Concerr.ed Consumers Power spokesmen told gumea pigs for the nuclear industry,"

steel and ricroruum used m reactor fuel I$

tizens met with a coahtion of the press they are studving options "to M s.

Hier charged, referring to avemblics.

Ii rthern Mich:. a: anti nuclear groups.

mintmue radiation exposure to plant dneu m e nt ed f ailu res nf certain Speakmc personally. Ms Hier aid

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WA, to hear plarts for peaceful eml employees m the event of an accident.

expenments in 1.W. which result in the she had not decided whether she would J

sobedience at ilig Hork, May 4.

" Conceptual studies, already release of radioactivity into the become involved in the acts of civil i

ne Concerned Cituens announced completed, show that design, atmosphere at Big Rock.

disobedience planned for May 4th at d

f at chi'e they "do not endorse civil engineering, procurement and "Dus ex perimentmg mth fuets would Big Rock.

sobedience, because they are construction could take up to 24 never happen m a targe population She reported that NOVA had not 1

mmitted to followtng every legal months."

area,"she stated.-

ann unced its plans in detail except cans to close the pi.mt, mdividuais Ec Concerned Citizens argued that Accordmv, ta C.m mnr rs Power that they wouhl br ge ceful ay participate m the May 4th action if "if the workers are not protected they Company, lug hock spokesm:m Phil "It will probably involve b!ncking lk e NRC does not respond to the cannot protect the plant in the case of leomis and thg Ituk Reactor Erigineer access to flig Rock." Ms. Hier said.

I tervention." according to JoAnne an accident. and, therefore, the David Blanchard, the $15 milhon grant

" Concerned Cituens are saymg to the er. a spokesperson for the Concerned community is not protected "

involves a contract between the NRC. "she said. "Pleasc hsten to us, tizens.

according to Ms. Hier.

Department of Energy Exon Nuclear Please allow us to use legal channels to 1

he group used the present shutdown She said " workers would be expected Company Inc., Ia major fuel supplier) protect ourselves."

the plant, to complete N RC required to perfona the entical function of and Consumers Power.

She charged Consumers Power I

justments to contairunent relief bnngtng the reactor under control It is a fuel research and development Company with " blatant negbgence" for j

Ives and electrical equipment while receivtng massive doses of project aimed at studying the operatmg the plant without complete

mming from lessons learned at radtation."

interaction between fuel p Ilets and contamment shieldmg.

p iree Mile Island. to ask the NRC to ne Concerned Citizens maintain that fuel clad bng in a long run effort to ne plant is expected to go back on ep the plant closed until other if the issue of the contamment stucid is reduce the stress on cl..ddmg.

kne this weekend,accordmg to lhorms ntatnment problems are solved, senous enough for the NRC to have "The program n m its first cyc!c and j

"It is irresponsible for the NRC to ordered changes be made and workers will probably go on for eight years."

mh, g i - a m los Big Rock to go back on bne are in jeopardy of receivmg excessive leomts s9ted in a telephone interview to:ing that the contamment shield is radiation tn the case of an accident, the Monday.

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sufficient to contain gamma rays and plant should not be allowed to function

" Exon will come on. site and remove protect the workers," Ms. Bier told

.mtd the problem as solved.

rods from the fuel bundles and slup e Couner.

Ms. ther added that Ilig Rock them to the Haden Test iteactor in Our new Chamber of Consumers Power Comptiny in a rece ed a $15 amilion grant from the Sweden where they will be tested to see Commerce Boord of cent' press release stated the Big Energy llescarch and Development bcw successfully stress has been Directors:

Nellle 1

ock plant, tecause it ts one of the Ageney iERDA) in 1977 Ior reduced "

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dest m the country aopened m 19C2),

esperimentalson with different Immis w.crted that Big Rock is not Jim McGarry and hd.not require a concrete shield radioactive f uels.

caperunentmg.

itside of its containment bualu.g."

ERDA Inow part of the Department

" All w e da is pru!uce im er 1.ut with Donnis Wojon.

n.. e m tbt ii.

of Encral wa form-riv part ef the differnt 6 4 TL

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Itoactor Scram and Loss of Coolant ac.:ident at 9: 10 cpunod EOF at U.;7ne Ci ty.

Lan-cssentir.1 poot.lc 1.avo Ji; Rock i e.

tron. Class u acciden* in progress.

tato s'olico infc..cd then Class C aceidone.situatica.

Conformation call ;o Bechtel Corp. for bad v al/c plans to be found l..d chcc od'.OiG > c.11 for Goncral norn:ency -und coro sprays not ucrking.

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!!cuctor '.iator Lovel declining and con;uinment v:.1ve pecb, lot.:3.

1;o plans and di'agrams avail. from Jochtol.

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Poopic advised to sco'.c sheltor.

11:40 " Ra~ don call' to pontiac regional office.

They do not know of 31g Rock problom.

Occseicn arisos of vent valves clo inc.

.it 1/> :5$ the ca.11 came to evacuato all people within $niles of 3 Rock.

31Accidents then, of verJ scrious n.turo can happen at 9, hock.

e "Tay are aerea residents and summer population so. complacent as l

l'O,put up with dans;r 1,otentials of Big Rock just for a probable to scncral powcr grid feod-in?

i This area is to-inportant co embraco nuclear polution and, problems.

ct nt ;o.;;a.loveir. despital.

11:4., Nint. wor;::rs radiated.c. ur :

This info. came approx. i'0 min. la';e ;o

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..+tation" of n0F stenograph.r nocded fc,r nacc of 11.fc.

Jac?. son boys congra tulate each other on n " touc.a" job'well dcne a d plenty.of P.R. uns had by all.

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luns recoruonded t c

.ernonc/ 'poration Facility (.e r-Site)

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be approx. cn; mile frcn 313 ' F.o c'.c bu for roascns of convenience and publicity it uns ill-located 13 niles away in 3cyne Ci.,y.

V:sitern were ubic to ask soma quest'uonc and noted the pre-built g anc plan to go well.

.;l h rell.. net on c.lephones uus both a s tren.;th a..d u..ak..cs::.

Cen..r uas nanned mostly by imported Jt.ekson office pe:ple.

1:o 1;cdl.. people were prcsont at E.O.F.

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EMERGENCY PREPAREDI1ESS EXERCISE BIG ROCK P0lflT NUCLEAR PLAflT 4

e JULY 24, 1980 PARTICIPANTS CONSUMERS POWER COMPAfiY t-STATE OF MICHIGAN CHARLEVOIX COUNTY EMMET COUflTY CHARLEVOIX HOSPITAL REGIONAL ADVISORY COMMITTEE (NRC/ FEMA)

GEilERAL PHYSICS CORPORATION O

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g1 Exercise EXERCISE SCENARIO P2 3 Time 0700 T=@l:00 The primary system leak rate calculation tests (T1-02) a.m.

indicate a leak of approximately 12 gpm.

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The Site Emergency Director declares an Unusual Event; notifications are made to the !!RC; charlevoix Coun;y; Petosky State Police; and Power Centroller.

0830 T=-1/2 hr Plant instrumentation now reveals a leak of greater than 50 gpm from the primary coolant system.

The plant has initiated shutdown procedures.

The Sito Emergen:y Director has declared an Alert; sounded the emergency siren; initiated personnel accountability and evacuation; performs notifications; and initiated the

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Site Emergency Plan.

The county and state Ebergency Plans vill be plaged in effect uith EOC's a:t-:vated and personnel notified.

0900 T=0 LOSS OF COOLA!17 ACCIDENT (LOCA) from primary coolant system downstream of the recirculation system isolation valves; complete reactor shutdown (SCRAM) has occurred.

REACTOR INDICATIONS:

1.

Of f gas monitor alarm was at 50,000 g{/see or 2.5(E10 ) counts per second.

2.

Off gas system isolation va'.ve has closed 3.

Sphere cam Radiatica indica. ion 4.

Core Spray syatem initiation 5.

Meteorological Instrumentation-wind frcm the west at10 mph;partl, cloudy (0.7 at. 8,000 feet)

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3900

_T= 0 min Based on the LOCA and instrumentation the Site Emergency Director will declare a FITE EMERGENCY.

1.

Initiate perscnnel assembly and accountability 2.

Complete activation of Tech. Support Center-3.

Notify Plant L:ncrgency Personnel e

4.

Continue to implement the Site Emergency Plan 0905 T= 5 min Technical Support Center provides updates to charlevoix and Emmett Counties; Petoskey State Police; NRC; General Office; Boyne City t

0900 -

T=

0-Initial public notification and uarning by Charlevoi:

0925 25 min and Emett Countico; all county and state EOCa are fully activated and staffe'.

0900 -

T=

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Consumers Power Company monitoring teams dispatched to 09 0 30 min W

carry out on site monitoring and report results to TSC.

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,4 Health Physics personnel dispatched to be on alert at U g>

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Charlevoix County 1.OC.

3 Site evacuation of non essestial personnel initiated and completed.

Operations Support Center activated.

0930 T=

1/2.hr TSC provides plant update condicion report and radio-logical dose exposure calculations and projections to Charlevoix and Emmett EDCs; Petoskey State Police EOC; NRC; General Office Centrol Center; Boyne City EOC.

NOTE: Upon the Declaration. of a State of Disaster by the

- Governor and the activation of the Petoskey ECC, a.1 updates from the at Llit/ uill be to that EOC and then

' forwarded to the appropriate counties by the State EOC s

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Pa ty. 1 of 1 kLi 1000 T=1 hr CORE SPRAY SYSTEM FAILURE - A decrease in the water level in the reactor vessel; sphere radiological monitors indicate fission products are present in the containment; the ventilation valves which did not fully close at SCRAM are releasing fiss'.on products into the atmosphere. The High Stack Gas M:..i tor is reading 0.8 R/hr (800 ci/sec).

Based en this information the Site Emergency Director decla:^* a GENERAL EMERGENCY.

(Meteorological instrumentation is the same as at 0800) 1015 T=1 1/4 hr Notification to off site authorities of upgraded

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emergency condition.

Postulated dose rates of:

s 1.6 rem at 3 miles for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; rem at 5 miles k#

for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> (whole body).

1015 -

T=1 1/4 to PIRiT:

1100

,1 3/4 hr Continued environmental monitoring and assessment:

Technician in the field measuring for iodine release measures 6000 c/m for 10 minute air sample at 2 cfm (pancake probe) for a projected dose rate of 7.3P x 10" rem or 73.8 mrem. (at 3 miles distance)

Determine extent of core damage (instrumentation shews 800 R/hr for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for estimated 6.2% damage);

update dose calculations and confirm plume direction and activity concer.tration. Att:mpt to close the open sphere ventilation valves. Continae to update offsite agencies on a.15 minute interval basis.

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Page 4 of 7 1015 -

T= 11/4 to STATE AllD C0ui!TY:

1100 2 hr Receive notificatica of the cavalated condition and projected plume pacha:y and projected dose calculations.

Dete.dne the appropriate Pro ective Kction Guidelinea

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based on environmental monitoring results.

Order public evacuation up to 3 miles and cheltering in plack tlp to 5 miles; initia*e ~~ solation of c posed, areas; activate public relocation ahelters.

Approx.

A plant maintenance worker is injured in the decon-1030 tamination room (room # 121); he is radioactively contaminated and his injury is serious enough to require transportation by ambulance to a hospital for treat-ment.

The worker is found laying on his back wearing L#

a set of anti-contaminant clothing.

He is uncon-scious and reading 25 mR/hr over the upper one-half of his body.

After initial decontamination, the reading will be 0.75 mR/hr over the upper one hai: of his body with a few cuts on his left forearm' reading 5 mR/hr.

He has regained consciousness and is diagnosed as having a broken lef t ' humerus rand a dislocated left shoulder.

An ambulance from Charlevoix will be requested and the victim will be tearsported to Charlevoix Hospital for decontaminatica and treatment.

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Page 5 of 7 1100--

.T = 2

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1200 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> Carry out rescue, decontamination and first aid procedures for injured worker; continue to update off-site agencies at 25 minute in*.arvals; initiate and/or plan for dasage c,.ntrol and repair operations.

STATE A!/D CCU!.TY:

Simulate p:blic evacuation and a:tivation of relocation centers; simulate isolation pr'2cedures; the Department of P:blic Health (Div. Rad. Health) uili carry out

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confi:=ctorg off site enviror. mental monitoring.

1 Tne D::ergency Operations Centers vill continue to receive and assess plant operating conditione and enviror. mental monitoring reports.

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t Provide c.:bulance support to the plant for the injured work"an.

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GENERAL OFFICE CONTROL CENTER:

Simulate the activation of the Mutual Assistance Agreement with Detroit Edison and Toledo Edison, requesting assistance as requested by the plant; conduct comunicat. ions with the NRC, USDOE, insurance carriers, etc.

Carry out other support functions as requested.

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BOYNE CITY EOC:

Carry out support functions for the plant. Continue liaison activities with other off site EOCs and the plant.

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1200 T = 24 -

The condition is downgrad<:1 to an ALERT status by the 30 hrs of elapsed Site Emergency Director based on; time 1.

The p'reviously open reactor building ventilation valves have been closed and on and off-site monitoring indicates that off-site radioactive releases have been terminated.

2.

All off-site dose projections are now within allowable limits.

12 15 Off-site agencies are notified of the downgraded status: State EOC - Petoskey; NRC; Boyne City; General Office Control Center; counties thru State EOC 1215 -

Based on the downgraded situation the plant and off-0100 site agencies will begin planning the re-entry and I., o*

recovery procedures.

PLANT:

Health Physics and damage control and repair teams a:e insuring that:

1.

The reactor is shut down 2.

The reactor is being coaled sufficiently 3.

The containment integrity is intact.

S:' ATE AND COUNTY:

Initiate public notifigations concerning re-entry procedures; deactivate relocation centers; determine long te:m actions for protection and monitoring of the food and cater supply e

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Page 7 of 7

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After sufficient time has been given for the off-site 1:00 cm ECCs (including Boyne City and the General Office) to

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demonstrate the planning process for re-entry and recovery procedures,the exercise will be terminated.

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EMERGENCY PREFAREDNESS EXERCISE OSJECTIVES (Gene ral)

The Emergency Preparedness exercise will be an ovent that tests the intergrated capability and major portions of the basic elements within the existing emergency preparedness plans and organizations.

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The exercise will require the mobilization of State and local emergency personnel in order to verify their capability to respond to an accident.

The exercise will test and evaluate the plant's Site Emergency Plan with respect to prearrangements, directives and organizational responsibilities to assure that all emergency conditions can be effectively and efficiently resolved in order to safeguard the general public, plant personnel, and utility property.

k, The exercise scenario will be planned such that a.ajor elements of the utility, county and state plans and preparedness organizations are tested.

The:ex'ercise will be observed by qualified obserters from the utility and FedeYal, State and County Governments. A critique will be conducted the day af ter the exercise; and any deficiencies noted will form the basis for corrective action.

The exercise will be designed to familiarise the personnel assigned to all on-site and all off-site emergency response organi-

ations with the emergency plan (s) and their responsibilities in case of an emergency.

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k.8 SPECIFIC OBJECTIVES Big Rock Point Site Emergency Plan

• Test the ability of operstiers terronnel to effectively assess and respond to an abnormal operating condition which may produce an actual or potential off-sit <. radipactive release.

e To test the abilities of Hea'.th Physics personnel, operating under emergency conditions, to monitor and assess radiological dose rates; to determine s'pecific centamination levels of airborne, waterborne, and/or surface deposited concentrations; and to assess specific in-dications (including their rates of change) that may be used as thres-holds for initiating emergency measures.

.. To test the plant's site warning and evacuation plans with regards to effectiveness and operability.

\\o To test the plant's communications systems including:

e internal pla t n

communications; communications " links to of f-site company emergency centers; and communicatiens links to off-rite emergency centers for

' county and state authoritics.

The assess. Tant will cover adequacy, reliability and operability of the communications hardware; the adequacy of emergency communications plans and procedures; and the training of personnel in cperating the equipment.

• To test the operations of the Te:hnical Support Center and the ability of staffing personnel to asse s the plant :tatus and provide support to the Operations personnel.

i e To test the plant's en-site first aid capabilities with respect to caring for an accident victim.cho nay be radiologically contaminated.

The exercise will also test the interface cf the plant's emergency medical organization with that of of f-site emergoney medical service

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providers-ambulance service, hcspital.

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4 6.

' Evaluators should. offer no info 2mti'. ion, advice or assistance to the m

exercise participants.

Any,such r.: quests should be respectfully declined.

Evaluators will only in:erpose themselves if the evaluees are taking an action that will cau:;e the exercise to go far afield of th'e anticipated time schedule and/or outec.ne.

3xamples of problems requiring such interpositions may include:

a dose calculation /projec-tion that is so grossly inaccurate that an qction level other than the one postulated for the scenario wo-21d be instituted; an activit'y that is taking so much longer than predicted that the exercise scenario is in danger of not progressing as postulated. ~

z, 4J 4

8 i

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4 4

k..

h

the response capabilities of the county public safety organ-

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izations-law enforcement,. fi: e protection, emergency medical service.

To test the county's ability to keep the public informed of actual the preplans for the evacuation of the to test or potential threat; radiological release; to test the public in case of a significant planc to evacuate and shelter the public.

(MEPP)

Michigan Emergency Preparedness Plan and assess the initiation and implementation of the MEPP, e To test l

the Big' Rock Point Plant.

to a radiological emergency at with respect the ability of the State Government to assess the impact of e To test the required a radiological emergency on the public and to carry out notification plans.

h*

the Emergency Operations Center:. in Petoskey and Lansing wit k,~,

e To test respect to:

adequacy of facilities to support o!. rations under emergency con-

~

ditions

+

- interface of the varices organizaticnal components in decision making and

- adequacy of resource materials to assist in' implementing decisions adequacy of communicati:ns systems to maintain contact with other components of the emergancy response system.

the ability of the of f site radiological monitoring program e To test

,7I; to accurately determine ti e public danger and institute appropr ate i

protective actiona.

manpower and resource activation and development

f. =

adequacy of radiological-monitoring equipment

- adequacy of the ccenunications system t.

s v

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E::ERCISE EVALUATIO:i CRITERIA GENERAL PROCEOURES 1.

Ea5h evaluator has been furnished and should ba familiar with:

a.

General Emergency Preparedness Exercise Objectiver b.

The Specific Objectives to test'the Big Rock Point Plant, Emmet County, Charlevoix County, and Michigan Eme,rgency Preparedness Plans as they pertain to the area being exercised.

c.

The Exercise scenario, initiating events, and expected. courses of action to be undertaken.

2.

For each area to be surveyed the fellowing has been prepared and distri-buted to-the evaluators.

a.

A summary and description of the area's location, emergency mission, 4.-

and personnel and their emergency responsibilities.

b.

Exercise Evaluatien checklist c.

Chronological record sheet.

-3.

Evaluators will be at their assigned posts between 30 and 45. minutes prior to the commencement of the exercise, even though the area being evaluated may not be activated until later in the exercise.

4.

If evaluators are to provide information (initiating events, instru-mentation readings, environmental monitoring results, etc.) to the exercise participants. the information must be provided exactly as

prescribed and exactly when prescribed.

Failure to provide the infor-mation appropriately may invalidate the results of the exercise.

5.

A Chronological Record must be kept for areas surveyed.

The record will show the actual time, _ the event or occurrence, *he result or action taken, the elapshd drill time and 1:artinent comnents.

O e

.oa M

m-

b 6.

' Evaluators should offer no information, advice or ascistance to the r) exercise participants.

Any such requests should be respectfully.

declined.

Evaluators will onl,y interpose themselves if the evaluees are taking an action that will cause the exercise to go far afield of tha anticipated time schedule and/or outcome.

Examples of problems requiring such interpositions may include:

a dose calculation /projec-tion that is so grossly inaccurate that an action level other than the one postulated for the scenario would be instituted; an activity that is taking so much longer than predicted that the exercise scenario is in _ danger of not progressing as postulated.

i e

?

9 9

14 -

et

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f i

J PERFCR".ANCI. E'!ALUATION CRITERIA To ensure validity of the evaluation, all exercisc evaluators must 3J utiline the same grading criteria. The follow _ r.g grading standards should be utilized.

I.

Recording Times of Actions

.I a.

For grading purposes, it will be assun.cd that on-site personnel

}

have been alerted when the emergency siren is sounded.

b.

For calculating elapsed ti.mes, evaluators will be given the actual time the exercise is initiated.

Thi vill be T = 0 on all reports.

All elapsed time calculatior.s will be based on this time, 9

regardless of when the separate evaluated activities are initiated.

4 c.

An EOC or other activity will be deemed to be in service when its personnel accountabil ty check is completed and reported or when the ECC has sufficient manpower present to carry out its mission.

d.

The " Chronological Events Summary" shculd be the primary evaluation

~

A record; it is intended to be used to complete the evaluation form upon completien of the exercise. The form calls for the actual time, the initiating event, the resultant activity, evaluator cor;ments, and the elapsed drill time (T = ?).

II.

Evaluation Standards Excellent ~ Personnel and _equ..pment always functioned without error the

-first tine, every time. Thera were no prcblems encountered, and all personnel and equipment - funct.oned at a level much greater than could

4 reasonably be anticipated.

Good:

Personnel and equipment generally performed better than expecta-lbj tions.

Any errors or problems were minor, and easily correctable.

b

,q.

.q

~.

uupport the mi nion? nn:. tie area u; port. the ;.erconnel 4

asaigned to it?

2.

Resource ::aterials - flect 'here resourec matcrials readily available to assess the c: crgency situation and to plan corrective actions - maps, re ference hooks, copics of emer-gency plans and procedurer.?

3.

Communications Equipment - Was the on-alte and off-site commu-e nications equipment adequ..to in quantity, operability and availability? Did persen:.el know how to utilfze the equipment efficiently?

4.

Emergency Equipment - Was emergdney equipment' readily available, completely operable, apprespriate to the task or situation, and did personnel know hcw to use it efficiently? Emergency equipment includes:

pcrt< ble environn.cntal monitoring equip-ment; personal protective equipment, clothing, respirators:

decontamination supplies.ind equipment; first aid and fire-fighting equipment; and communications equipment.

5.

Personnel Quantity - Were there enough trained personnel to carry out the mission? 7:o few? Too many?

6.

Area Access Control - Li(- all assignec persor.nel respond to their areas prcmptly.v.d

tay in assiy ned area for the dura-tion of the exercise?

Wc, the area s(cured against unauthorized persons being present? Uas there an identification system develcped and used that ef fectively identified authorized personnel and their duti(n?

7.

Recordkeeping - Was all data accurately recorded and maintained in a systematic readily retrievable manner for future reference?

C.

Interface with Other Areas an;l Groups Although this is not specifically addressed on all evaluation forms, obviously it is an item of.x:reme importance.

An area that performs j

its own mission satisfactorily but that does not interfere adequately with other areas, has not performed in an overall satisfactorily

o

' Satisfactory:

Personnel.and/or equipment performed according to h.ai expectations, with few minor exceptions.

Any errors noted were not severe and could be corrected without undue labor and/or expense.

4 Poor:

Personnel and/or equipment generally performed below expecta-tions and/or there were several significant deficiencies noted.

The area's ability to carryout its miusion was diminished.

Fail:

Personnel and/or equipment :onsistently failed to perform as required and/or there were serious deficiencieg noted khich severely impaired the ability of the area to carry out its mission.

t III.

Categories for Evaluation A.

Mission Perfornance 1.

Command Functions - did th area carry out its mission of k,

directing the activities of other compc nents?

2.

Assessment and' Evaluation - was information promptly and correctly received, assessed and evaluated?

3.

Personnel Functions - Did personnel know and carry out their duties with efficiency and without undud direction?

4.

Communications - Did the area establish and maintain ec=muni-cations with other components? Was the information received and/or transmitted. accurate, concise, appropriate, and timely?

5.

Records - Was the recordkeeping system designed and implemented to record significant events ar.d actions for future use?

B.

Facilities and Equipment 1.

Physical Pacilities - Was he area utiliced appropriate by

+

virtue of its' si:e ar.d _ loca tion? Was there enough furniture, adequate ventilation, rest rooms, office supplies, etc. to

- M F-

~

5"

- manner.

Any deficiencies not d ir..an area interfacing with another area should be noted.

cuch deficiencies n y be due to inadequate communicaticns hardware, orga :i ctional de ficiencies, or inadequacies in plans and procedures. '

IV.

Summary A.

Describe any problems noted by the area being evaluated, a descrip-tion of the problem, its outcome or effect, and any recommended corrective courses of action to mitigate or. correct the deficiency.

B.

After completely filling out the evaluation fonn total up the

~

actual number of points the area was awardc:d.

s 1

C.

The evaluator (s) is'to sign the evaluation form and promptly return it as directed.

A critique of the exercise will be held the following day with D.

all participants, evaluators and NRC/ FEMA cbrervers present.

t I

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4 9

,m

C4ERGENCY CPERAT3DNS CLSTCR

- g BOyNE CITY LOCATION: Consumers Power Ccmpany S'ervice Center Boyne City, Nichigan MISSION:

(1) Support function to the plant (2) Serve as a contact /locaticn point for the NRC field team (3) Serve as a mustering point for vendors, contractors, and plant relief personnel. Such personnel will be briefed and trained as necessary to minimize radiological exposure when they go to the plant site.

~

(4) Serve as the location for Consumers Pcwer media relations persennel who are not assigned to the nedia center at the Holiday Inn, Petoskey.

(5) serve as a liaison point for state and local government.

PERSCNh*EL AND DUTIES: '

(1) Licensed Training Instructor / Training Instructor (EPIP 3c & 4z)

(a)

Proceed to facility as directed by SED (b)

Arrange furniture, plug in additional telephones, energize

• the radio equipment, and verify the communications links with the NRC and General Office Control Center.

~

(c)

Assist responding Ger.eral Office Personnel.

(d)

Appoint /r.rrange for an emergency recorder (2)

Other' Facility Support Personnel

• (a)

Vice President of Nuclear Operations

• (b)

Engineering and Health Physics Personnel (c)

Vendors, contractors,:ensultants (d)

NRC Emergency Response Team (e)

DOE - Interagency Radiological Assistance Team

• (f)

Other General Cf fice Support. Persennel s

==e

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EMERGENCY O'PEMTICNS CENTER av (BOYNE CJTY)

Evaluator-BIG ROCK POINT NUCLEAR PIJd1T EXERCIS5 EVALUATICN 9"

Time Ended I.

Establishment of Boyne City Facility:

Af ter the emergency was declared:

a.

When was the designated individual dispatched:

b.

When did the individual arrive:

c.

When was the facility physically ready for operations:

d.

When were the communications checks completed:

EXC GOOQ SATIS PCOR FAIL II.

How did the facility carry out its:

a.

. Plant support functions 25 20 15 10 0

4 b.

Communications functions 25 20 15 10 0

c.

Liaison functions 25 20 15 10 0

(

III.

Assess and evaluate a.

Adequacy of physical facilities 10 7

4 1

0 b.

Resource materials r0 7

4 1

O c.

Communications equipment 10 7

4 1.

O d.

Personnel resources 10 7'

4 1

0 e.

Area access control 10 7

4 1

O f.

Recordkeeping 10 7

4 1

0 IV.

Mission performance a.

Operation of facility 20 15 10 5

0 b.

Did assigned personnel know and 20 15 10 5

0 carry out their duties c.

Were communications established 20 15 10 5

0 and maintained adequately V.

Describe any problems noted with recs. mended corrective actions s

e

BIG ROCK POINT NUCLEAR PLANT

~

TECHNICAL SUFFCRT CENTER k.,

Location:

Third floor, across from Control Room Mission:

(1)

Used in support of Control Room for the assessment of plant status and any potential offsite impact.

(2)

To provide control of all plant activities during the emergency including:

firefighting; first aid; danage assesement and control; on and off-site communications.

(3)

To provide direction to re-entry and recovery operations Personnel and Duties:

(1)

Site Emergency Director - TSC Coordinator; the Pl' ant Super-intendent or alternate (a)

Provide overall direction (b)

Request General Office control center activation (c)

Assure primary notifications (d) Direct liaison with offsite agencies (e)

Procure / request sece ssary personnel and/or equipment

~

~

(f)

Assure complete and accurate recordkeeping (g)

Assure personnel accountability (h)

Direct evacuation / recovery actions (i)

Assure continued plant security (2)

Operations and Maintenance Superintende.f t - (first alternate TSC director) cirect plan: operations and maintenance; damage control teams.

(3)

Technical Superintendent - coordinates activities of the engineering emergency team (4)

Technical Engineer - dedicated offsite communicator (5)

Plant Health Physicist - advise on health and safety of plant personnel; provide necessary dose predictions.

(6)

Operations Supervisor - assist in determining accident classi-fication and control measures; control access to Control Room, k,

w y

3

(7)

Nuclear Safety Technical Engineer - assist in planning the re-entry and recovery operations.

kw (8)

Reactor Engineer -

(9)

Emergency Recorder - maintain log of activities and assure that notifications are made.

e e

0 0

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=

=

EVfdUATOR BIG ROCK POINT WCCLEAR PLM3T EXERCISE IVALUATION TIME BEGAN TECHNICAL SUPPORT CENTER I.

Establishment of T.S.C.

0-5-

10-(MINUTES).

5 10 15

+15 A.

After the emergency was sounded how long did it take before:

1.

Site Emergency Director 15 10 5

0 arrived 2.

Other personnel arrive 15 10.

5 O

(personal acct.)

3.

Recordkeeping established 7

5 3

0 4.

Offsite communications 7

5 3

0 established (Jackson, NRC, Charlevoix, State) 5.

Onsite communications 7

5 3

0 established (control, security, O.S.C.)

I.,

6.

Personnel dispatched to 7

6 5

3 Charlevoix and Petoskey

(+20 = 9)

E.O.C.

B.

TSC Activation l '. Was personnel acccuntability Yes No check performed and reported (5)

(0) 2.

Was radiological survey made of Yes No the aree (less than 10 mr/hr)

(5)

(0)

II. How did the TSC carry out its:

EXC GOOD SATIS POOR FAIL 1.

Overall command functions 10 7

4 1

0 2.

Assessment and evaluation 10

-7 4

1 0

functions 3.

Control rcom support functions 10 7

4 1

0 4.

On-site _communicatione 10 7

4 1

0 5.

Off-site communications lu 7

4 1

0 6.

'First aid coordination c

4 3

1 0

. n x

III. Facilities h

Rate of the adequacy of:

EXC GOOD SATIS POOR FAIL A.

Physical facilities 10 7

4 1

0 B.

Resource materials 10 7

4 1

0 C.

Connunications equipment 10 7

4 1

0 D.

Emergency equipment 10 7

4 1

0 E.

Personnel resources 10 7

4 1

0 F.

Area access control 10 7

4 1

0 t

G.

F4cordkeeping 13 7

4 1

0 IV. Mission Performance EXC GOOD SATIS POOR FAIL A.

Did Site Emergency Director 25 20 15 5

0 take and maintain control?

B.

Did all assigned personnel 25 20 15 5

0 k-know and carry out their duties?

C.

Was information promptly and 25 -

20 15 5

0 correctly assessed?

D.

Were the corrective actions 25 20 15 5-0 ordered prompt and appropriate?

-E.

Were communications established 20 15 10 5

"O and maintained with offsite agencies-adequate updates at 15 minute intervals?

V.

Describe any problems noted with recce.r, ended corrcetive actions

~

VI, sity,3 ry:

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...., u,,O r, c_.

4I:: 3 CORE

,TCTUAL y.

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I

'S 51 II 55 23 III 70 28 IV 120 70 Overall 313 172 4

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. BIG ROCK PQINT **: CLCAR T LANT OPERATIONE SUI'10RT CENTER Location:

Air Compressor Room (Alternate:

Screenhouse)

Mission:

(1). Assembly Area II for porconnel not assigned to Control R6om or Technical Support Conter.

(2)

Assembly location also for centractors, vendors, and plant visitors.

(3)

Monitoring (a)

Area radiological monitors (b)

Extent of core damage monitor (c)

Stack gas release rate monitor Personnel and Duties g'

to

.(1)

Chemical and Radiation Pr:tection Sup.rvisor - OSC Director (acts as alternate Platt lealth Physiciut?

-(a)-

Dispatch on-site and off-site monitoring teams (2)

Maintenance Director - (alternate Assembly Area II director) -

Team leader for team #8 composed of naintenance ' repair personnel.

(3)

Instrument and Control Su;ervisor - Team leader for team #7 composed of instrumentati:n and technical personnel.

(4)

Maintenance Supervisor (5)

Chemical and Radiation Protection Technicians (6)

Instrument Technicians (7)

Other plant personnel and off duty per sonnel reporting back to work.

(8)

Other rersons on site - v..sitors, contractors, vendors 1

o E

.m_.

.m_

Y EVALUATOR

- BIG ROCK POINT NUCLEAR PLANT OPERATIONS SUPPCRT CENTER TIME BEGAN EYERCISE EVALUATION TIME ENDED I.

O.S.C. Activation A.

How long did it take af ter om. rgency was sounded for the O.S.C.

to beceme functional - i.e. on-site pers onnel present 0-5, min (20) 5-10 min (10) 10-15 min (5)

+15 min (0)

B.

How long after notification did it take the OSC director to be on location and assume duties 0-10 min (10) 10-20 min (5) h,,

+20 min (0)

C.

Activation Procedures I.

Was radiation / survey performed Yes (5)

No (0)

~~

2.

Was personnel _ accountability Yes (5)

No (0) check performed and report-ad i

l to the Property Prot. Supervisor II.

EXCELLENT GOOD SATIS POOR FAIL A.

Did assigned personnel know 20 15

,10 5

0 and carry cut-their assigned responsiDilities?

B.

' How did the CSC carry out its:

- 1.

Support runctions 10 7

5 3

0 2.

Assestment and Evalua-10 7

5 3

0

• ions 4

O e.

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En ELLE ZT CXD SATIS FOOR FAIL l

3.- Onsite comunications 10 7

5 3

0 4.

Personnel control anct 10 7

5 3

0 account. ability III.

Rate the adequacy of:

E::CELLE:;T G.MD SATIS FOOR FAIL

-A.

Physical facilities 5

4 3

2 0

B.

Resource documents 5

4 3

2 0

C.

.Co=nunications equipment 5

4 3

2 0

D.

Emergen:y equipment 5

4 3

2 0

E.

Personnel resources 5

4 3

2 C

F.

Area access control 5

4 3

2 0

G.

Recordkeeping 5

4 3

2 0

IV.

Describe any problems noted ' ith recorxnended corrective actions.

. 4.. s.

SUM.v.ARY :

AREA MAX MIN ACTUAL I

40 25 II 60 30 III 35 21 TOTAL 135 76 ese d

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RIsDIC:,0G1CAI, ". TOI:!! 0 TEA"Jt

" f.!:AR PLANT IllG LOCK PO!!JT 73 J

4 LCCATION :

Assembly Area II/Operatichs Support Center MISSION: (1)

On-site environmental monitoring (2)

Off-site environmental mon toring (3)

Support other emergency operations - personnel egress screening,

.first aid and monitoring of injured / contaminated personnel, assist in firefighting/ rescue operations PEFSONNEL AND DUTIES:

(1) plant Health Physicist -(located in TSC) - has overall rerpon-sibility for providing advice on health and safety matters (a)

Provides dose predictions based on instrumentation, meteor-ological data, and environmental rr.onitoring results (b)

Assures accurate recor 3 keeping of !!ealth Physics data (2)

Chemical and Radiation Prottetion Supervisor (located in OSC)

(a) Director of Operations Support Center, Alternate Plant

(,

Health Physicist

,s>

Direct supervision of c. and off-si*.e monitoring teams (3)

Chemical and Radiation Prot:ction Technicians (a) Perform-envirennental v.an'itoring (b) Assist ir. decontamination procedurer s

!. o.

e A

F' RADIOLOG1 CAL, !Vi!!! TORI.'G TEA *M:

BIG ROCK POIt.r tit'cLLu PL7d;T EXERQISE EVALUATION Time Begun i

i Time Ended I.

Activation - How long after the 4

emergency was sounded did it take for:

0-5 5-10 10-15

+15 minutes a.

Chen & Rad Pro Supervisor on scene 15 10 5

0 b.

Rad. monitoring teams assembled 15 10 5

0 c.

Other personnel present &

accountability performed l '.

10 5

O II.

At what time were in plant surveys l orformed? O - 20 min 10

=

20 - 30 min 7

=

30 - 40 min 3

=

+ 10 min

=

0 At what time were the first perimotcr fence' surveys performed?

O - 20 min 10

=

( '

20 - 'L -in 7

=

40 - 60 min 3

+ 30 min 0

=

III.

Evaluate the adequacy oft EXC GOOD SATIS POOR FAIL 1

a.

Physical facilities 5

4 3

2 0

j b.

Resource materials 5

4 3

2 0

1-c.

Cn-site communications 5

4 3

2 0

I' d.

Off-site communications 5

4 3

2 0

e.

Portable instrumentation 5

4 3

2 0

f.

Fixed instrumentation 5

4 3

2 0

g. _ Personnel resources 5

4 3

2 0

h.

Recordkeeping 5

4 3

2 0

I l

i 4

a

)

e e

-r

.+--

,--+--e-x

-3 COCD SATIS POOR FAIL IV.

MISSION PETTOTd4ANCE -

' A'.

~ Appropriate direction and

' supervision 17 Plant Health l

Physicist 20 15 10 5

0 B.

Appropriate direction and supervisien by Chem & Rad Protection Supervisor 20 15 10 5

0 C.

Did personnel know and carry out their duties 20 15 10 5

0 i

d.

Was informution promptly and accurately transmitted to appropriate parties 20 15 le 5

0 e.

Coordination with~off-site radiological monitoring teams 20 15 10 5

0 I

f.

Did personnel know location and use of equipment 10 7

4 1

0 g.

Did personnel adequately support other emergency operations - first aid, egress screening, etc.

20 15 10 5

0 4

1 4

V.

Note any problems encountered and recommended course of action:

e l

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._.__..._,7.

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k ;e EIG FO:n POINT nt ' LEAR PLI,:iT 1:XEECISC LV/.UATION FIRST AID TEAM 2.

At what time was first aid team nutified?

(T = 0 for first aid team)

II.

At what time was first aid team dispatched:

T + 5 = 10 S - 10 = 7 q

10 - 15 = 4 4

+15 = 0 I

III.

At what time did first aid team reach victim?

]

IV.

First Aid Procedures:

L.,

4 A.

Was ' radiological survey conducted prior to Y

N trea tment?

q

.B.

W'as primary body survey conducted Y

N 4

immediately?

C.

Was decontamination conducted prior to Y

N trea tment?

D.- Was secondary body survey cond seted prior Y

N to treatment?

E.

Were injuries ' correctly diagne::ed and trea ted? Y N

i V.

. Transport Procedures A.

.Was' ambulance requested prcmptly?

Y N

B.

Was ambulance emergency kit utilized to pro-Y N

i tect crew and. vehicle?

C.

Was -contamination control maintained on way Y~

N to hospital?

i l'

.D.

Was portable air sampler picked up at access Y

N control (Health Physics) ?

-s.

y

1-VI.

!!ocpital Proceduros:

4 A.

Callback for additional poru+:.ncl Y

N

.B.

Evacuate treatment area Y

N C.

Remove / cover equipment in roon Y

N D.

Assemble needed equipment Y

N E.

Assemble contamination control Y

N supplies e

F.

Cover floors between entrance and Y-N i

trea tment

]

G.

E.D. personnel in protective clothing Y

N H.

Decontamination procedures Y

N VIII. Evaluate EXC GOOD SATIS POOR FAIR A.

Plant personnel knew 20 15 10 5

0 and carried out their responsibilities B.

Performance of first aid 5

4 3

2 0

trea tment C.

Performance of contamina-4 3

2 0

tion centrol T

D.

Performance of decontamina-4 3

2 0

tion procedures E.

Adequacy.cf equipment, 5

4 3

2 0

F.

Adequacy of communica-5 4

3 2

0 tions' G.

Interface with ambulance 10 7

4 1

0 crew h.

Interface with hospital 10 7

4 1

0 SUvJtARY:

Maximum Points - 65 Minimum Points - 33 Actual Points - ---

1 e

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s 2

FIRST AID FCENARIO Elapsed Drill Actual Time Time Ti::ic T+

T+

1.

Time injured person intro-duced I

2.- Time first aid team alerted 3.

Time first aid team dispatched 4.

Time first aid team on scene 5.

Ambulance requested 6.

Hospital notified 7.

Victim moved to gate 8.

Victim loaded in ambulance 9.

Victim arrives at hospital 10.

Treatment initiated 11.

Treatment completed 12.

Decontamination initiated 13.

Decontamination completed 14.

All clear Note any problems encountered and recommended ccrrective actions:

r.

EVALUATOR

s BIG ROOK POII;T ::UCLEAR PLANT

' I

,SECUR TY l'ORCE Location: Main Guard House Missions (1)

Site access control (2)

Notify and evacuate any nearby fishermen or boaters onshore and offshore of plant.

(3)

Direct personnel exiting the plant in~ case of a site eva cuation.

(4)

Perform personnel account ability checks as required.

(5)

Interface with responding off-site emergency responders -

screen, escort, direct, assist.

Forsonnel and Duties:

(1)

Property Protection Supervisor (a)

Receive personnel ac.:ountability information and report to Site Emergency Director.

(b)

Direct Security Force " activities (i)

Security Officers to Assenbly Arcas II and-III (ii)

Security Officers to Main access road (iii)

Security Officers to chec): for fishermen, boaters, or trespassera in immediate area.

(2)

Security shift Leader - as necessary in the absence of the Property Protection Supervisor.

(3)

Security Officers f.

t g,

4*

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EVALUATOR BIG ROCK FOINT in'CIIAR PLANT

+

EXERCISE EVT.LUATION TIME PEGUN

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SECURITY FORCE TIM.F ENDED I.

.How long after the 0-5 5-10 10-15

+15 emergency was sounded did it take for:

(minutes)

A.

Property Protection Super-7 4

1 0

visor to station B.

Security Shift Supervisor 7

4 1

0 to station C.

Security Force assembled /

7 4

1 0

accounted D.

Site Access Control 7

4 1

0 established E.

Immediate area checked for 7

4 1

0 fishermen, etc.

P.

Security Officer dispatched 7

4 1

0 to Assembly Area II G.

Security Officer dispatched 7

4 1

0 k,

to Assembly Area III i

y H.

Security Officer (s) dis-7 4

1 0

l patched to access road I.

.II.

Did Security Force personnel EXC GOOD SATIS POOR FAIL know and correctly carry out their duties 1

.A.

Overall 20 15 10 5

0 B.

Access centrol 15 10 7

3 0

C.

Persennel accountability I 's 10 7

3 0

checks D.

Site evacuaticn procedures 23 15' 10 5

0 E.

Coordination with of fsite 13 7

5 2

0 emergency response personnel 93 e

• t.

e-III.

Rate tho adequacy of:

LJC

. GOOD SATIS POOR PAIL A.

Physical Facilities.

5 4

3 2

0 B.

Resource Materials 5

4 3

2 0

C.

Communications equipment *

'5 4

3 2

0 1

D.

Personnel resources 5

4 3

2 0

E.

Recordkceping 5

4 3

2 0

e IV.

Describe any problems noted with recor. mended corrective action..

s i

SUMMARY

AREA MAX MIN ACTUAL I

56 32 II 80 39 III 25 15 TOTAL 161 86 J.

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i-MODIA CI::TER k'"

hIG ECCK POINT N'. CLEAR PLANT IDCATION :

Holiday' Inn, Potoskey, Michigan l

MISSION:

1.

To serve as a joint media center 2.

To serve as a central poir.t for public infomation 3.

To assist media representatives with the preparation of news

{

releases, including technical briefings on a regular basis i

e PERSONNEL AND DUTIES:

1.

Vice President - Public Affairs (Director) i 2.

General Supervisor, Public Information 3.

Public Affairs Director, Big Rock Point Plant 4.

Executive Vice President, Energy Supply 5.

Technical briefers frem Consumers Power Company 6.

Public Information Officers from Charlevoix and muett Countias; l

the State of Michigan; and the Federal Governmen W.,.

}

I

- !:OTE:

No fomal exercise evaluation criteria has been developed due to the 1

actual press briefing taking place before the exercise.

A general evaluation will be performed on the basis of adequacy of facilities, interface of the various PIOS, and the coordination and direction of

- activities.

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