ML20073J393

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Responds to Generic Ltr 82-33, Emergency Response Capabilities, (Suppl 1 to NUREG-0737) Requesting Implementation Schedules for Identified Requirements
ML20073J393
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 04/15/1983
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Clark R
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, LIC-83-093, LIC-83-93, NUDOCS 8304190281
Download: ML20073J393 (17)


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Omaha Public Power District 1623 Hamey Omaha, Nebraska 68102 402/536-4000 April 15, 1983 LIC-83-093 Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Operating Reactors Branch No. 3 Wash'ing ton , D.C. 20555

Reference:

Docket No. 50-285

Dear Mr. Clark:

Generic Letter 82-33, Supplement 1 to NUREG-0737,

" Emergency Response Capabilities" The subject letter asked all utilities to define their imple-mentation schedules for the requirements identified in that letter. Accordingly, attached is Omaha Public Power Dis-trict's response.

Si _ rely, W. .

fkUb Jones Divis ion Manager Production Operations WCJ/TLP:jmm Attachment cc: LeBoeuf, Lamb,'Leiby & MacRae p 1333 New Hampshire Avenue, N.W. b Washington, D.C. 20036 )

Mr. L. A. Yandell, NRC Senior Resident Inspector 8304190281 830415 PDR ADOCK 05000285 PDR p

45 5124 Employmen h qual Opportunity

m UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )

) l Omaha Public Power District .) Docket No. 50-285 (Fort Calhoun Station, )

Unit No. 1) ) ,

AFFIDAVIT

. . . . . being duly sworn, hereby deposes and says that he is Division Manager - Production Operations of Omaha Public Power District; that he.is duly authorized to sign and file with the Nuclear Regulatory Commission the attached response to Generic Letter 82-33; that he is familiar with the con-tent thereof; and that the matters set forth therein are true and correct to the best of his knowledge,-information and belief.

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'4. C. Jones DivisNon Manager Production Operations STATE OF NEBRASKA)

) ss COUNTY OF DOUGLAS)

Subscribed and sworn to before me, a Notary Public in and for the State,of Nebraska on this /(n/ day of April, 1983.

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i l J.T. GLEASON

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Enclosure i.

OMAHA PUBLIC POWER DISTRICT'S RESPONSE TO GENERIC LETTER 82-33 Generic Letter 82-33 forwarded NUREG-0737, Supplement 1, p

which details the Commission's 'osition on 5 TMI related tasks; all related to improved capabilities for responding to plant emergencies. These 5 tasks are:

(1) Implementation of a Safety Parameter Display' System (SPDS). .

(2) Performance of a Detailed Control Room Design Review

( DCRDR) .

(3) Evaluation of Compliance with Regulatory Guide 1.97, Revision 2 (R.G. 1.97).

(4) Implementation of Upgraded Functi'on Oriented Emergency Operating Procedures (EOP's).

(5) Development of Emergency Response Facilities (ERF's) .

The District has reviewed the above requirements and Attach-ments 1 through 5 detail the present status and final com-pletion schedules for each of the 5 tasks. It should be noted that each of these 5 tasks are interrelated to one or uare of the other tasks and, as such, these schedules have been integrated. The District has made significant progress in the development of the SPDS, EOP's, and ERF's and these

_ tasks will be completed concurrently with the 1985 refueling outage. For DCRDR and R.G. 1.97, the initial stages of the planning effort were only recently initiated and will lag the other tasks in full implementation.

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Attachment 1 SAFETY PARAMETERS DISPLAY SYSTEM SCOPE:

The basic hardware. installation and computer programming for Safety Paraneters Display System (SPDS) is currently in pro-gress. The SPDS is part of 2 major modification efforts:

(1) the Emergency Response Facility Computer System (ERFCS) and (2) the Inadequate Core Cooling System (ICCS).

The ERFCS will be the real time data processing system which will present plant parameters to the operator in such a fashion as to be able to determine the safety status of the plant.

The ICCS is being installed in response to Generic Letter 82-28 and consists of 3 major components: (1) the Heated Junction Thermocouple (HJTC) system to monitor reactor ves-sel liquid inventory, (2) accident qualified Core Exit Thermocouples (CET's) for reactor temperature monitoring, and (3) a Qualified Safety Parameter Display System (QSPDS) which acts as a Class lE data processing system for the HJTC, CET's, and other lE signals. The QSPDS, in turn, pro-vides the lE data to the ERFCS via a fiber optic serial data link.

The scope of the project also includes: (1) the install-ation of mineral insulated cable and new electrical pene-trations to link the HJTC and CET's to the control room, (2) cabling necessary to provide plant parameter to the ERFCS and QSPDS, (3) displays of the information in the EOF, TSC, and control room, (4) primary system pressure boundary modi-( fication to accommodate the HJTC probes, and (5) the quali-fled CET's.

PROJECT STATUS:

To date, the following work has been accomplished:

(1) HJTC probe holders are installed in the reactor.

(2) The new incore detectors (CET's) and their modified ICI reactor flanges are installed and operable through the existing plant computer.

(3) Approximately 60% of the mineral insulated cable in containment is installed (100% of the seismic hangers

! are installed).

l l (4) Approximately 75% of the cable outside containment is in place. This cable is approximately 20% terminated.

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(5) The 2 new electrical penetrations are installed in con-tainment. \

l (6) The ERFCS power distribution system is about 65% com-plete.

.(7) The ERFCS signal junction cabinets are installed in the cable spreading room.

(8) The Sigma II computer has been removed and the com-puter room floor core drilled for the ERFCS data acqui-sition system.

(9) The QSPDS panels have been installed in the control -

room.

PROJECT SCHEDULE FOR COMPLETION:

The completion of the project scope is hinged around a suc-cessful factory acceptance test of the ERFCS, its delivery and installation, site testing, and operational availability 1

testing.

The schedule, as provided by the ERFCS vendor, calls for a factory acceptance test (FAT) from May 23, 1983 to June 8, 1983; installation from June 20, 1983 to July 8, 1983; site testing from July 11, 1983 to July 22, 1983; and the oper-ational availability testing from August 8, 1983 to

February 8, 1984. NOTE: During the 6 month operational availability testing, no hardware or software changes which would impact the computer operation (i.e., the entry of a new program which could cause a software failure) will be permitted.

i For the SPDS to be completed on a schedule which would pro-l vide the earliest possible operation, the operational avail-l ability testing must be complete by the beginning of the 1984 refueling outage (February 27, 1984). This allows only l 3 weeks for contingencies to complete computer installation l and testing. If any slippage were to occur, there may not be enough outage time available in 1984 to accomplish all outage related work necessary for an operable SPDS. Based upon the District's experience, it is normal to allow much more than 3 weeks for contingencies in a year long project;

! thus, we believe the probability of the operational avail-l ability testing being completed prior to the 1984 outage to be extremely low. Accordingly, the District expects the l

SPDS to be completed during the 1985 refueling outage, al-lowing for an operational date of November 30, 1985.

SAFETY ANALYSIS SCHEDULE:

The selection of parameters for the SPDS has been completed

! based upon the present generic Emergency Procedure l

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r Guidelines (EPG's). However, other projects (such as imple-menting the plant specific EOP's or R.G. 1.97) can and are expected to result in changes and/or refinements to this parameter set. The District's ERFCS will allow the flexi-bility to incorporate such changes as the need arises. How-ever, consistent with the present guidance provided in NUREG-0737, Supplement 1, the District intends to proceed with the development of the SPDS based upon the EPG's, without waiting for these other projects to be completed.

By October 31, 1983, the District will provide a safety analysis justifying the set of SPDS parameters presently selected for the SPDS. Any subsequent changes to this parameter set will be evaluated in accordance with the criteria of 10 CFR 50.59. .

TRAINING:

Training on the SPDS will be in at least 2 parts. Part 1 will consist of training on the operation of the SPDS computer (i.e. , how to retrieve information, call up dis-plays, trend points, etc.). This will require each shift and other appropriate emergency response personnel to be trained for 1 week.

The other training will be part of the new emergency pro-cedures. In order to maintain system reliability, several weeks of I&C technician training will be required on both the ERFCS and QSPDS.

VERIFICATION AND VALIDATION:

The physical capabilities of the ERFCS and SPDS will be veri-fled through the operational availability testing and sub-sequent District performance demonstrations. The validation of the SPDS parameter set will be included as part of the V&V effort for the new plant specific EOP's, as detailed in Attachment 4.

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Attachment 2

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DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)

The District will develop and implement the DCRDR program along the guidelines provided by the industry-supported Nuclear Task Action Committee (NUTAC) on DCRDR. Currently, the District is developing a draft program plan. The draft plan will be completed by May 30, 1983 and will be used as the specification for selecting a contractor to support the District in implementing the DCRDR.

DCRDR activities and tasks are expected to be integrated with other NUREG-0737, Supplement 1, issues in the following ways:

(1) EOP's - One basis for the DCRDR will be the systems review and task analysis conducted as part of the development'of the plant-specific.EOP's. DCRDR verification of task performance capabilities and validation of control room functions shall be integrated with EOP Verification and Validation (V&V) activities. Procedural modifications / enhancements shall be considered as a solution to identified Human Engineering Deficiencies (HED's).

(2) SPDS - The DCRDR survey and verification of task performance capabilities shall include an evaluation of the SPDS. SPDS enhancements shall be considered as a solution to identified HED's.

(3) R.G. 1.97 - The R.G. 1.97 design packages will require man-machine interface reviews as part of the human factors requirement. CR improvements emanating from the DCRDR shall be integrated with R.G. 1.97 based improvements.

(4) Integrated Training - Recommendations, based on oper-ator interviews and walk-throughs/ talk-throughs of procedures, for improvements resulting from the DCRDR shall be incorporated in training programs. Training shall be considered as solutions to identified HED's.

In planning the implementation of the DCRDR, the District has established the following milestones and completion dates:

Milestone Completion Date Develop Draft Program Plan May 30, 1983 Define Manpower Requirements May 30, 1983 Select Contractor August 15, 1983 2-1

Milestone- Completion Date

- Start Review Sep'hember 1, 1983-Submit Final Program Plan to the NRC October 15, 1983 Review Operation Experience February 1, 1984 Conduct CR Survey April 1, 1984 Verification of Task Capabilities August 1,,1984 Validation of CR Functions October 1, 1984 HED Assessment Februar y 1,1985 Submit Summary Report April 1, 1985 Implementation and V&V of CR improvements have not been 3

scheduled since it is r:ot possible to develop a specific implementation schedule until completion of the review and .

assessment activities. The summary report will contain V&V and implementation schedules for correction of HED's.

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Attachment 3 SCHEDULE FOR IMPLEMENTATION OF REGULATORY GUIDE 1.97, REVISION 2 In accordance with our letter dated June 1, 1981, the District submitted a conceptual design for construction of Emergency Response Facilities (ERF's) and installation of the new ERF computer. In this conceptual design, the District committed to connecting some of the presently available instrumentation to the ERF computer and/or SPDS.

The installation of this ERF computer and the SPDS is in progress and is expected to be completed during the 1985 refueling outage. Several available inputs, including some of the instrumentation installed per the requirements of NUREG-0737, are also in the process of being connected to the ERF/SPDS computer. The operational ERFCS/SPDS will provide indication of selected Fort Calhoun accident monitoring instrumentation; however, a preliminary review of the available inputs indicates some deviations from the recommendations of R.G. 1.97 as they presently exist.

The District plans to continue with the present installation plans and simultaneously do a detailed study to fully identify deviations from R.G. 1.97 requirements. This study will have to be closely coordinated with other NUREG-0737 Supplement I requirements; such as control room design re-views, emergency operating procedures, etc. The schedule for this study is, therefore, dependent upon timely com-pletion of other items.

This study will constitute Phase 1 of R.G. 1.97 imple-mentation and will provide information as requested in section 6.2 of NUREG-0737, Supplement 1. This will also provide justification for any deviations and schedule for upgrading and modifications of the existing instrumentation (Phase 2).

Various steps required for this study and the time required for each step are as follows:

(1) Preparation of the plant specific Types A, B, C, D, and E variable list - This will initially require review of the generic Emergency Procedure Guidelines to prepare a Type A variable list, preparation of review criteria. and the actual review of Types B, C, D, and E variab as to identify deviations from the R.G. 1.97 criterion, environmental qualification, redundancy, instrunent ranges, power source and seismic qualification. With regard to the quality assurance requirements, it is the District's under-standing that for the existing instrumentation, the QA 3-1

requirements applicable at the time of issue of the construction permit or as detailed in the USAR will be applicable. The completion of this step is expected to take approximately 34 weeks.

(2) Justification of deviations - Any deviations from the recommendations of R.G. 1.97 will be resolved by per-forming additional analysis to justify existing equip-ment, proposing Technical Specification or procedural changes or qualifying the existing instrumentation.

If justification ~is not possible, the District will propose modifications .and upgrading if required. This step is estimated to take approximately 20 weeks.

(3) Preparation of the conceptual designs and modifi-cations schedule - In order to propose a realistic schedule for upgrading of the existing instrument-ation, the District plans to do_ a conceptual design to fully define the scope of work and establish equipment delivery schedules. In preparation of the conceptual design, an iterative process will.be used that con-siders changes associated with EOP's, control room de-sign reviews, and the operable ERF/SPDS for proper integration of all requirements. It is expected that this step will take approximately 12 weeks.

(4) Preparation of the final report - The results of the preceding 3 steps will be summarized in a report to be submitted to the NRC. Preparation of this report and the internal reviews are expected to take approxi-mately 16 weeks. The final report will provide inform-i ation as requested in section~6.2 of NUREG-0737, Sup-plement 1, and will be available'for NRC review by April 1, 1985.

, The above schedule is summarized in the attached block diagram (Figure 1).

NUREG-0737, Supplement 1, also calls out a specific ex-ception from R.G. 1.97 related to meteorological instru-mentation. The District has evaluated these revised re-quirements. The results of this evaluation are provided below.

The 110M meteorological tower is equipped with a redundant primary power supply, fed from two separate power sources, and instrumentation. Reliable indication of-the meteor-ological variables (wind speed, wind direction, and atmos-pheric stability) is provided by the tower instrumentation, via various equipment, in the control room. The available instrumentation and the level of redundancy are provided on the attached Table 1. A cross-comparison of the specifi-cations for the currently installed instruments with ones indicated in R.G. 1.97, Revision 2, is also provided in Table 1.

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Real time meteorological data is available in the control room from the plant computer by calling up the specific computer addresses. Historical meteorological data may be accessed by use of a magnetic tape which records one minute scan values from all instruments. Historical data is also available from the control-room's computer log where hourly and 24-hour average data is available. Visual indications

-for wind speed, wind direction,.and delta temperature are provided in the control room to provide real-time data and to immediately detect the failure of data recovery. In fo rm-ation on the meteorological conditions for the site vicinity can also be obtained via voice communication with the National Heather Service.

Meteorological instruments are inspected and serviced at a frequency that ensures an annual 90% joint data recovery for the meteorological variables per Regulatory Guide 1.23. No changes in the existing meteorological monitoring system are proposed as it has been historically prov,iding reliable indi-cations of the meteorological variables. The most recent annual joint data recoveries for 1980, 1981, and 1982 were 94.9%, 99.7%, and 97.6%, respectively.

Therefore, the District presently meets the criteria for the meteorological data. These parameters will be incorporated into the ERFCS for radiological assessments and will be available in the control room, TSC, and EOF.

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SCD(DLLE 10 WEEKS S ' ASSIGN REVIEC .

RESPONSTEFLITY 2____ __ ______ - .---- ..

EST ABLISH REVIEW /

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DESIGN TEAM p

RETAIN OUTSIDE CONE >LLTANT IF RE0 0 tRESPONSIBLE DEPT. MANAGER) o ESTABLISH REVIEW 12___e _ ___________ __ -_ ,

CRITERIA i,

COMPAhE AVAILd:6LE INSlHUf'.ENT ATION WITH TYPE 3. C.0 APO E R.G.1.97

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VARIABLE LIST IN THE AREA 0F REQUNDANCY.RANCE. ACCURACY Are f IINA'LI[E EMERIEtTV- OUALIFICATION

24. - _L OPERATING PROCEOURE - - - - - - - . _ _ _ _ _

E0P TEAMP ESTABLISH TYPE A g_, VARIABLE LIST 4

REVIEW TYFE A VARIABLE LIST g 34.

i b i t IhSTRUMENTS FOR INSTRUMENTS FOR VHICH ALL REQUIRE- VHICH ALL REcuIRE-M NTS ARE MET MENTS ARE NOT MET

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JUSTIFY THE ADEOUACY OF _ ADDITIONAL EXISTING INSTRUMENTATION ACCIDENT ANALYSIS WITH i,

g PROPOSED PENDING TECH SPEC EQUIPMENT CHANGES ,

y-- CHANGES OUALIFICATION PROPOSE ADDIT,IONAL gp g THE EXISTING 54________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

t PREPARE CONCEPTUAL DESIGN / ----i - e ESTABLISH MODIFICATION CON 1ROL ROOH I ISPOS/ERF i SCN h E LDESIGN REVIEW,3 JISPLAYg 66 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ , _____ ___ _

PREPARE PRELIMINARY 4 }-

REPORT

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4 INTERNAL REVIEWS

78. . _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

4 FINAL REPORT TO NRC 82.- _ - _ _ _ - - - - _ - _ _ .

REG GUIDE 1.97 IMPLEMENTATION

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_T_ABLE 1 Instrument Specifications, locations and Level of Redundancy l Instrument Location

! Meteorological Parameter Instrument Specification and Level of Redundancy Reg. Guide 1.97 110M Met. Tower Location Quantity l

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1. Wind Direction Azimuth (Degrees) O to 360 0 to 540 110M 1 a

j Accuracy (Deg.) 15 15 45M 1 Damping Ratio 0.4 to 0.6 0.6 10M 2 w

E Distance Cons. (m) f2 1.2

! 2. Wind Speed Range (mph) O to 67 0 to 100 110M 1 l

j Accuracy (mph) 1 0.5 1 0.5 45M 1 Starting Thres. (mph) 1.0 0.9 10M 2 I

3. Atmospheric Range (*C) -5 to 10 -5 to 15 110M-10M 3 Stability (Delta Temp) Accuracy (*C) 1 0.15 1 0.1 1

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Attachment 4 SCHEDULE FOR UPGRADED EMERGENCY OPERATING PROCEDURES (EOP'S)

Reference 1 transmitted the Combustion Engineering Owners Group's (CEOG's) latest report and revisions to Emergency Procedure Guidelines (EPG's).

Reference 2 stated that the guidelines contained in CEN-152, Revision 1, are applicable to the Fort Calhoun Station and will serve as the technical guidelines for the development .

of EOP's for the Fort Calhoun Station.

The Dictrict's process for developing EOP's will include the organization of a Procedures Writing Group to translate the technical guidelines contained in CEN-152, Revision 1, into EOP's; the use of workshops to verify the guidelines; the validation of the EOP's; and a training program for the EOP's. The District plans to implement the upgrade of EOP's following a refueling outage. The training for the upgraded EOP's must be completed prior to a refueling outage because the level of participation required of operations personnel in a refueling outage prohibits trnining during the outage.

The District intends to use the Procedures Writing Group to develop the EOP's from the EPG's. This group will consist of plant operations personnel and selected technical support personnel familiar with plant operations, transient re-sponse, and plant design. The product produced by the work-ing group will be the upgraded EOP's. It is estimated that approximately 4 months will be required to develop the new EOP's.

l The District intends to use workshops similar to those used by the CEOG to verify the EOP's. Participants in the work-shop will include Fort Calhoun operations personnel and Dis-trict engineers who are f amiliar with plant design and the transient response of the Fort Calhoun Station. These per-sonnel will not have been involved in the Procedures Writing Group. In addition to considering the EOP's, the workshop participants will also consider the interface between EOP's and the SPDS. The current SPDS displays will be reviewed for their applicability to the EOP's. The product of these l

workshops will be a validated set of EOP's and the associ-l ated SPDS displays. It is estimated these workshops will require 2 months to complete.

The District will perform an EOP validation which will evalu-ate the EOP's for usability and operational correctness.

The District anticipates using control room walkthroughs in this process. It is estimated the validation process will require 2 months to complete.

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The' District currently utilizes'6 operating shifts at the Fcrt Calhoun Station. Each shift is in training 1 week out-of every 6 weeks. It is estimated that 2 weeks of formal training, per individual, will be require ~d for training on the upgraded EOP's. Therefore, 3 months will be required to train all operations' personnel at the Fort Calhoun Station on the upgraded EOP's.

The attached table shows that'a total of 11 months will be required to implement the upgraded EOP's at the Fort Calhoun Station. The Fort Calhoun Station has recently completed a 4 month refueling outage. The next refueling is scheduled to start in late February or early March of 1984. Fort

, Calhoun operations personnel will be at simulator training

  • during the months of May and June, 1983 and will not be 1

available at that time to participate in a Procedures Writing Group. The District feels that it is absolutely necessary to have operations personnel in the Procedures Writing Group. Since there are only 9 months available from the time at which the operations personnel complete their simulator training to the start of the 1984 outage, it will not be possible to implement the upgraded EOP's following the 1984 refueling outage.

The next refueling outage is currently scheduled for September of 1985. The upgraded EOP's will be implemented following the 1985 refueling outage in December, 1985.

REFERENCES:

(1) Letter from R. W. Wells, CE Owners Group Chairman, to D. G. Eisenhut, NRC, " Transmittal of CEN-152, Revision 1, Combustion Engineering Emergency Procedure Guide-lines", November 22, 1982.

(2) Letter from W. C. Jones to R. A. Clark (LIC-82-414),

December 30, 1982.

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DEVELOPMENT OF UPGRADED FORT CALHOUN STATION EOP'S Months Required to Complete Total Task Task Months Procedures Writing Group Develops EOP's from EPG's 4 4 Verification Using a Work-shop Process 2 6 -

Validation 2 8 Training 3 11 i

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Attachment 5

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EMERGENCY RESPONSE FACILITIES (ERF'S)

The ERF's for the Fort Calhoun Station consist of a. Tech-nical Support Center (TSC) and Operations Support Center (OSC) physically located within the plant's security bound-ary and an Emergency Operations Facility (EOF) located at the North Omaha Station 17 miles south of the Fort Calhoun Station. The TSC and portions of the OSC are physically located in the same building which is designed for continued occupation throughout all design basis accidents. With the exception of the data acquisition and radiological assess-ment to be provided by the ERFCS/SPDS, the ERF's are consi-dered fully operational and meet the requirements of NUREG-0737, Supplement 1. As discussed in Attachment 1, the data acquisition capability will be available by November 30, 1985.

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