IR 05000483/1985011

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Insp Rept 50-483/85-11 on 850604-06.No Noncompliance, Deficiencies or Deviations Noted.Major Areas Inspected: Emergency Preparedness Exercise Involving Observations of Key Functions & Locations During Exercise
ML20127P479
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/26/1985
From: Phillips M, Ploski T, Snell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
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ML20127P457 List:
References
50-483-85-11, NUDOCS 8507020428
Download: ML20127P479 (28)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/85011(DRSS)

Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Nuclear Power Plant Inspection At: Callaway Plant, Reform, M0 Inspection Conducted: June 4-6, 1985

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Inspectorg: W. Snell Team Leader Date' h4 Date I

Approved B :

/Y M. Phillips, Chief 8/4/6 Emergency Preparedness Section Date'

Inspection Summary Inspection on June 4-6, 1985 (Report No. 50-483/85011(DRSS))

-Areas Inspected: Routine, announced inspection of the Callaway Nuclear Power Plant emergency preparedness exercise involving observations by seven NRC representatives of key functions and locations during the exercise. The inspection involved 143 inspector-hours onsite by two NRC inspectors and five consultant Results: No items of noncompliance, deficiencies, or deviations were identified; however, weaknesses were identified as summarized in the Appendi O ,,j8

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DETAILS 1. Persons Contacted NRC Observers and Areas Observed W. Snell, Control Room, Technical Support Center (TSC), Emergency Operations Facility (EOF)

J. Will, Control Room B. Haagensen, TSC J. Jamison, Operational Support Center T. Lonergan, Health Physics Access Point, Medical Drill J. Stephan, Offsite Radiological Monitoring Teams T. Ploski, E0F '3 Union Electric Personnel E. Dille, Executive Vice President D. Schnell, Vice President, Nuclear R. Shukai,. General Manager, Nuclear Engineering S. Miltenberger, Manager, Callaway Plant M. Stiller, Manager, Nuclear Safety and Emergency Preparedness A. White, Supervisor, Emergency Preparedness R. McAleenan, Manager, Nuclear Information T. Dehner, Supervisor, Public Information M. Cleary, Supervisor, Nuclear Information P. Appleby, Assistant Manger, Support Services G. Randolph, Assistant Manager, Technical Services A. Bonino, Consultant D. Young, Consultant ,

W. Otto, Consultant J. Gearhart, Supervising Engineer, Quality Assurcace E. Andes, Engineer, Quality Assurance H. Bono, Assistant Engineer, Quality Assurance G. Poteat, Nuclear Scientist W. Hinchic, Assistant Engineer, Emergency Preparedness M. Faulkner, Administrator, Nuclear Affairs M. Evans, Senior Training Supervisor J. Price, Superintendent, Training M. Williams, Principal Health Physicist G. Huges, Supervising Engineer R. Daming, Assistant Engineer, Emergency Preparedness D. Ray, Engineer, Emergency Preparedness S.' Harvey, Administrator, Nuclear Affairs P. Suonak, Administrator, Nuclear Affairs

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All. personnel listed above attended the exit interview on June 6, 198 . General An exercise of the licensee's Callaway Nuclear Power Plant Emergency Plan was conducted at the Callaway plant on June 5, 1985, testing the response of the licensee to a hypothetical accident scenario resulting in a major

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release. Attachment 1 describes the Scope and Objectives of the exercise and Attachment 2 describes the exercise scenario. The exercise was

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integrated with a test of the Callaway, Osage, Gasconade, and Montgomery Counties' emergency plans; the State of Missouri emergency plan; and the Nuclear Regulatory Commission Region III Incident Response Supplement to NUREG-084 This was a full participation exercise for the State of Missour . General Observations Procedures This exercise was conducted in accordance with 10 CFR Part 50, Appendix E requirements using the Callaway Nuclear Power Plant Emergency Plan and Emergency Plan Implementing Procedure Coordination The licensee's response was generally coordinated, orderly and timely. If the events had been real, the actions taken by the licensee would have been sufficient to permit the State and local authorities to take appropriate actions, Observers Licensee observers monitored and critiqued this exercise along with seven NRC observers and a number of Federal Emergency Management Agency (FEMA) observers. FEMA observations on the responses of State and local organizations will be provided in a separate repor Critique A critique was held with the licensee and NRC representatives on June 6, 1985, the day after the exercise. The NRC discussed the observed strengths and weaknesses during the exit interview. A public critique was held later that day in Fulton, Missouri, to present the preliminary onsite and offsite findings of the NRC and FEMA exercise observers, respectivel . Specific Observations Control Room The Control Room portion of the exercise was conducted from the simulator, which enhanced the realism of the events and enabled tne players to more effectively demonstrate their capabilitie The Control Room was well organized and operated efficiently. Noise level was kept low. The filling out of forms and logkeeping in the Control Room was excellent.

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The Control Room operators worked well together and were tenacious in pursuit of the solution to the problems presented. In so doing, they made effective use of their procedures and system schematic The Shift Supervisor was particularly well supported by the Control Room /TSC Liaison, Control Room Supervisor and the Shift Technical Advisor. The Shift Supervisor, both as the Emergency Coordinator and subsequently as the Shift Supervisor, provided excellent periodic status updates for the personnel in the Control Roo The Control Room operators showed consideration for the effect of radiation in the plant on the Control Room. For example, they issued pocket dosimeters. However, there were no airborne or swipe surveys taken in the Control Room and no action taken to establish a contamination control point (with at least a frisker) for people coming into the Control Roo b. Technical Support Center (TSC)

Technical Support Center activation was conducted promptly and effectivel Check-off sheets were used and the Emergency Coordinator (EC) relieved the Shift Supervisor of EC responsi-bilities 35 minutes after the ALERT was declare Information flow between TSC coordinators and the Emergency Coordinator was excellent. The periodic briefings for the TSC staff and separate briefings for the TSC coordinators were thorough and concise. TSC personnel functioned properly as a team throughout the exercis The TSC staff took exceptional care in documenting decisions and recommendations in logs and on interoffice memorand There was no health physics (HP) control point established at the TSC entranc Emergency response personnel were observed entering the TSC without checking for personnel contamination after the radioactive release had started. The potential for contamination in the TSC was discussed, and a frisker was provided at the TSC entrance, but there were no provisions for standard control point radiological controls. No surface contamination surveys were taken in the TSC despite a large radioactive release and personnel arriving in the TSC did not frisk themselves. This is Open Item No. 483/85011-0 The Emergency Coordinator (EC) was reluctant to start the hydrogen recombiners in containment despite the recognition of a hydrogen buildup problem early on in the scenario. The decision to start the recombiners was not made until after the hydrogen explosion occurred inside containment at 1238. Concern over hydrogen buildup existed since 1012 when incore thermocouple temperatures first showed a rapid rise and later confirmed at 1156 by a rapid rise in containment hydrogen concentratio , .

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The existence of radioactive iodine in the offsite release was not confirmed until after 1400 despite numerous opportunities to obtain an iodine analysis at an earlier point. Shelter factor differences were never considered for protective action recommendation The Emergency Coordinator did not realize that there was an offsite release from containment (due to the hydrogen explosion at 1238)

until informed by the Recovery Manager in the Emergency Operations Facility (E0F) one hour and 43 minutes after the release starte At that time, offsite monitoring results had been posted on the status board in the TSC for 41 minutes, but nobody directed the Emergency Coordinator's attention to the existence of offsite radiation readings. The Emergency Coordinator was reluctant to believe these readings and did not inform the TSC Coordinators that a release was in progress for an additional 12 minutes after being advised by the EO As a result, TSC efforts to identify the release path did not get started for one hour and 55 minutes after the release first occurre TSC status board data were not updated with key values in a timely manne Examples of this problem included the following:

. Protective action recommendations were never updated after the initial recommendations at the Site Area Emergency classificatio . Protective actions implemented by the counties were never properly posted or updated to show which counties had implemented recommended protective actions, although there were status board provisions for posting such informatio . Reactor coolant system (RCS) temperatures were posted as reading greater than 500 F for over an hour after temperatures had actually decreased to less than 200 . RCS pressure continued to be posted at 1500 psi for well over an hour after the RCS had depressurize As a result of the above inaccuracies, the communicator in the TSC responsible for providing data to the NRC over the ENS phone did not have access to accurate data. This probably contributed to the communications weakness described in paragraph Trending of key parameters was not done adequately by the TSC staff and was not available to the Emergency Coordinator. Trending of data would have allowed earlier identification of the release path and would have provided earlier indications of the LOC Dose assessment was effectively established and actively pursued in the TSC. Protective action recommendations were adequately discussed prior to any recommendations being given to offsite authoritie . .

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c. Operational Support Center (OSC)

The Maintenance OSC was manned and operational within minutes of the Alert declaration. Personnel promptly logged in on the status board and were directed to waiting areas to stand by for assignment The OSC demonstrated the ability to assign and control a large number of inplant teams. As many as five teams were deployed at once. In all, a total of 13 inplant teams were #signated and given assignment Status board keeping in the Maintenance OSC was generally goo The board served as the main tool for tracking team assignments and movement However, briefings in the Maintenance OSC were sometimes inadequat Some teams were dispatched with an inadequate understanding of their mission and without being informed of their team designatio Plant drawings and references were not used effectively in briefing In addition, the OSC and inplant repair teams were not always kept informed of major developments and changes in plant conditions. Some information on the status of core cooling would have helped the OSC staff focus and prioritize their effort For example, at 1200, after learning the nature of the shaft coupling failure, the OSC Coordinator gave up on the attempt to repair the B Safety Injection (SI) pump. He apparently did not understand fully the urgency of restoring some SI capnilit The Maintenance OSC provided a significant amount of t:chnical input to the solving of plant equipment problems. Knowledge.ble staff members suggested means of restoring vital equipment ta service and used drawings and references well. However, at one t'me, virtually all discussion in the Maintenance OSC for a period of about ten minutes focused on relieving one of the field team drivers who could not work overtime due to union consideration The OSC Coordinator demonstrated concern over the habitability of the OSC. He promptly requested that a HP Tech be sent to the Maintenance OSC to establish habitability, and continued to ask for this support at regular intervals until the HP Tech arrive Health Physics practices observed in the plant were generally very goo Briefings, debriefings, emergency dose authorization, access control and use of protective clothing were all demonstrate However, personnel returning to the OSC from outdoors were not frisked. There was no frisker station in the Maintenance OS Additionally, plant staff members did not consistently follow the Callaway Plant guidelines for wearing badges and dosimeters., Many wore their badges and/or dosimeters at or below the waist. Some wore the TLD at or below the waist with the self-reading dosimeter on the upper chest. One HP tech dropped both his self-reading dosimeters on a hard floor from a height of about two feet while dressing out in protective clothing. He then put them on without checking the readings and entered the Radiation Control Area (RCA).

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i Also, two repair team members did not follow the prescribed plant procedure for removing protective clothing. They were accompanied by and observed by an HP Tech who did not correct them. These health physics weaknesses will be tracked as part of Open Item 483/85011-0 Some significant communication problems were note Occasional loud interference occurred on the OSC Coordinator's telephone, particularly while talking with the HP Access Control Point. The Gaitronics was the in plant teams' primary means of communications with the OSC, however the Gaitronics pages were often not very audible in the OSC and had to be repeated several times before someone in the OSC answered. Radios were not used effectively for communications with in plant teams. Overall, the OSC communications observed during this exercise needs to be improved. This will be tracked as Open Item No. 483/85011-02 and examined again during the 1986 annual exercise, d. Health Physics Access Control (HPAC)

The HPAC was observed to operate smoothly and effectivel Briefings and debriefings of individuals and teams required to enter the facility during the exercise were thorough. In general, Health Physics personnel emphasized and operational personnel implemented actions designed to minimize personnel exposure Health Physics personnel demonstrated thoroughness and patience in requesting and cautioning volunteers who might receive radiation doses in excess of normal limits while attempting to mitigate or terminate releases of radioactive materials. However, the HPAC status board was sometimes inaccurat On one occasion, two teams did not have the time of entry into the RCA recorded on the status board. The exit time was not shown for several teams that had finished their work and withdrawn from the RC Although the inspector was not present in the HPAC during the entire exercise, at no time was the Emergency Director or Coordinator observed providing a statement of plant status. Individual participants were overheard voicing their concern as to "What is tne total picture?" or "Why are we doing this?" In addition, the status board in the OSC indicated the classification of the event as a Site Area Emergency for at least 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after it had been upgraded to a General Emergenc During the exercise, the Radiation Control Coordinator directed the placement of a "fris,ker" device at the entrance of the HPAC as a control measure, to prevent tracking of contamination into the facilit However, it was observed to be ineffective as no posting of instructions or instruction of the HPs to enforce self-frisking were provided, therefore, it was ignored by most participant Additionally, although not observed by the inspector, HPAC Health Physics personnel indicated that habitability surveys of that facility were made. However, no documentation of such surveys could be produced, nor was there any posting of results observed in the HPA This will be tracked as part of Open Item No. 483/85011-0 '

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e. Medical Drill The initial actions of the coworker of the injured electrician were appropriate and effective, as was the timely reporting of the injury. The Medical Emergency Response Team (MERT) determined the extent ~of the injury and provided expeditious first aid treatment upon arrival. Positive communication between the MERT members and the injured was established and maintained until the injured party was turned over to the ambulance cre Contamination control measures at the site and at the hospital were adequate and timely. Security personnel accompanied the ambulance crew while onsite, which helped expedite their movement. The dispatch and utilization of a second HP Tech to the hospital provided for expeditious treatment rf the injured party and improved contamination control capabilitieF at the hospita Medical personnel appeared to be well triined in the exercise of contamina-tion control during the treatment of the radiation accident victi At one point, there appeared to be a difference of opinion between a HP Tech and a MERT member on whether the personnel monitoring devices of the injured should remain with the injured party or be collected and remain onsite. It is recommended that an accepted procedure for items of this nature be established and personnel trained, to avoid confusion that could potentially delay the transport or treatment of an injured perso f. Fire Brigade Drill Fire brigade members were well briefed enroute from the OSC to the fire scene. All members responded well to onsite directions by the brigade leader who was decisive in his actions. Although the team members did not connect their SCBA masks to the air tank (in order to conserve airtanks) they did don, test and wear the masks as required, thus demonstrating realism in communication Although generally well done, two errors were noted during the fire dril The first was that the fire brigade initially set up the smoke ejector and, upon energizing the ejector, noted the fans were moving air into the room instead of exhausting air out of the roo The brigade members noted this immediately and corrected the situation. This could be prevented in the future by painting arrows on the smoke ejector indicating the direction of air flo Second, a team member dispatched from the OSC who normally wears prescription eyeglasses was observed to remove them and don an SCBA which did not contain a prescription lens adapter. When questioned the individual indicated he had a prescription lens adapter for use in the SCBA masks, but he did not have them with him. The importance of having available and using prescribed corrective lens in SCBA masks should be emphazied, particularly by emergency response personne ..

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g. ~Offsite Radiological Monitoring Teams (RMTS)

The assembly and coordination of the initial RMT was prompt and efficien The inventory of equipment prior to departure was comprehensive and complete. However, the dispatch of the RMT from the OSC was not well coordinated. The team leader was required to explain his need for a vehicle and driver to several OSC supervisory personnel before he could obtain the needed support. In addition, the team leader determined during checkout of equipment prior to leaving the EOF that the Dual Analyzer Model 2218 was defective and attempted (in succession) to: replace the battery; locate a screwdriver; consult with the OSC; and consult with another HP Tec This activity consumed some 40 minutes before the technician finally replaced the defective unit with an operational one from another ki The total time required to dispatch the first team was one hour and 43 minute Communication with the OSC, TSC and E0F was effective, and properly proceeded and ended with "This is a drill." However, control of the field teams was not properly transferred from the TSC to the E0F, and at times teams received instructions from both the TSC and EO Sound radiation monitoring and protection practices were demonstrated throughout all off-site surveys. Instruments were properly used for monitoring dose rates above and on ground (window open and closed),

and for obtaining and evaluating air sample Requests by the OSC, TSC or E0F for monitoring data were frequent and well coordinated between the two offsite teams. Evaluation of sample data was timely. Reporting of evaluated data to the OSC, TSC or E0F was timely. The team leader displayed an adequate knowledge on use and advisability of protective clothing. Vegetation samples were

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properly obtained, bagged and labelled. Contaminated filters and gloves were properly bagged as radwaste. The teams demonstrated good monitoring practices with personal dosimeters and reporting of readings as well as good logging practices of monitored and evaluated data. However, the use of a single HP Tech per team appeared to be too demanding for the spectrum of monitoring and evaluation functions required. The team's driver should be procedurally required to assist the HP Tech in appropriate tasks, besides just driving the vehicl Vehicles used by the teams appeared to be adequate for both on and off road travel. Teams had an adequate knowledge of access roads to designated monitoring locations, and readily inquired about additional road details by contacting the OSC when uncertai The teams demonstrated an adequate knowledge in tracking the radioactive plume centerlin Emergency Operations Facility (EOF)

Personnel responded quickly to set up the E0F. The Offsite Liaison Coordinator (OLC) did a good job in preparing the E0F for the Interim Recovery Manager and the rest of the EOF organization. The

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OLC monitored PA announcements, offsite notifications and arranged for licensee Technical Representatives to be sent to the various county Emergency Operations Centers.

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The turnover of overall responsibility for emergency response activities from the TSC to the EOF was slow, and did not occur until almost 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after the Site Area Emergency was declared. Some of the delay was the result of both licensee corporate E0F and NRC Site Team personnel arriving at about the same time. However, the Corporate Recovery Manager had relieved the plant Interim Recovery Manager within about 50 minutes after the Site Area Emergency declaration, but it took about 30 to 35 minutes more for the Recovery Manager to receive concurrence from the various EOF Coordinators that they were ready to assume their responsibilitie The turnover could have been carried out faster had the Recovery Manager been more forceful in his pursuit to take contro Also, several coordinators should have reported to the Recovery Manager that they were ready to assume their responsibilities in a more timely manne The Radiological Assessment group in the E0F did a good job 0; controlling the RMTs and obtaining data that was useful to thL E0 Dose calculations were frequently made based on existing plant conditions and comparisons made with offsite data. However, the flow of information between the radiological assessment group and the rest of the EOF was weak. Although it may in part be dce to the physical separation of the Radiological Assessment group's workspace from that of other groups in the EOF, there was a significant amount of useful information being generated and discussed that could have been useful to the Recovery Manager or others that was not forwarded in a timely manne Discussion on protective action recommendations were thorough and appropriate, although not very well coordinated with the TSC. The Protective Action Decision Flow Chart (Attachment 1 of EPIP-ZZ-00212)

was constantly referred to and effectively utilize Meteorological information was updated throughout the exercise and the meterological forecast was considered when making protective action recommendation The Recovery Manager and OLC did a good job in keeping aware of the status of protective actions being implemented offsite. At one point, the Recovery Manager appropriately called the Gasconade County Presiding Judge to urge him to implement the recommendations that the neighboring counties were already implementin Long delays were observed within the EOF and between the TSC and EOF in informing all personnel of when the major release had begun. For example, the Dose Assessment Coordinator's logbook indicated that the release began at 1235, but 15 minutes later, when questioned, the Technical Assessment Coordinator was not sure if a release was in progress or not. Additionally, although the Recovery Manager told the Gasconade County Judge at about 1255 that evidence of a release had been received by the E0F, the Emergency Coordinator in the TSC

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was unaware that the field teams had confirmed this until about 15 to 20 minutes later. Informing all the counties and the State about the release was also very slow. With the exception of the Gasconade County Judge, who was informed of the release by the Recovery Manager at 1255, the other counties and the State were not informed until the Initial Notification Form was transmitted at 132 The Recovery Manger and Emergency Coordinator did a good job of discussing the aspects of authorizing exposures in excess of

.10 CFR Part 20 limits before sending teams into potentially high radiation areas. The Administrative and Logistics staff demonstrated the ability to arrange for additional Rad-Chem Tech support from Wolf Creek and other assistance from INP0. Although the Recovery Manger periodically assembled his key staff and NRC personnel in a conference room for worthwhile discussions, it was unclear who was in temporary charge of the various work groups during these conferences. At times, it appeared that efforts by various workgroups diminished while group leaders were away from their workstations and in conference with the Recovery Manage Status baards in the E0F were generally kept up-to-date. However, the status board listing emergency response facility activation status could contain more useful information such as the times the facilities became operational, the persons in charge, or the names of any Union Electric personnel at the various county E0Cs. In addition, it would be helpful if there were provisions on a status board in the Recovery Center room of the E0F for listing information on plant components out of service, the reasons, and the estimated repair times. During the exercise, some later arriving Corporate EOF staff and the NRC Site Team seemed to be unaware or lost track of the fact that certain components were out-of-service since the beginning of the exercise, as well as what had failed during the exercise, and when equipment might be fixed. No attempts were made in the E0F to graphically trend (either on a status board or graph paper) key plant parameters such as vessel level, pressure, containment hydrogen concentration or release rate. By trending key plant parameters on a graph, incoming personnel such as corporate staff, relief shift or NRC Site Team can become more easily aware of historical data and trends, while not impacting with ongoing wor The OLC informed the Recovery Manager by message at about 1440 that the State had recommended to the counties that emergency workers in the effected sectors could be given potassium iodide (KI). However, when a FEMA observer later asked E0F Security whether persons leaving the E0F required any special instructions, guards were unaware of the KI issuance recommendatio The Recovery Manager shouM have acted on this information provided by the OL Public Information (PI) activities in the E0F were very goo The PI staff was well organized and demonstrated good teamwork during the exercise. All press releases were reviewed by the Interim Recovery Manager and later the Recovery Manager before release. In general, the contents of the press releases were accura +.e and sufficiently detailed, without being too technica '

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5. NRC Interface The interface between the licensee and the NRC was smooth and effective in the Control Room and TSC. However, for about the first ten minutes after the NRC Site Team was in the E0F, no exercise players made any real efforts to see that Site Team people were directed to their Union Electric counterparts' werk stations, or even to tell the NRC Site Team whether the E0F was in charge of emergency response. This lack of interface between the licensee and NRC in the E0F continued for much of the exercise. For example, between about 1120 and the General Emergency declaration at 1140, little attempt was made by the Recovery Manager to inform the NRC Site Team Leader and his aides in the Recovery Center Room of the fact that important decisionmaking was going on regarding declaring a General Emergency and formulating a protective action recommendatio Until late in the exercise the NRC was not provided an adequate opportunity to input into the decisionmaking process in the E0F. Some of the neglect in this regard appeared to be the result of the licensee's determination that decisionmaking on utilization of equipment such as the hydrogen recombiners and containment spray constitute onsite activities and therefore resides in the TSC. However, the licensee should realize that any activity that can have a bearing on core integrity or containment performance has a direct impact on offsite consequences, and should, therefore, be part of the E0F decisionmaking proces A number of communication problems were also identified during this exercise. For example, the locations of the NRC Emergency Notification System (ENS) telephone in the TSC does not permit the ENS communicator to see the plant and radiological status board In addition, data displayed on the boards was erroneous (see paragraph 4.b). As a result, technical data transmission to the NRC Base Team was delayed or erroneous while the data was copied onto separate sheets of paper. The ENS phone should be relocated to a central position in the TSC to allow the ENS communicator to directly read information off the status board display In addition, although two telephone lines were available to the NRC in the E0F Recovery Center room, they both went to the same telephone, so only one line could actually be used at a tim . Exercise Scenario and Control The scenario used during this exercise presented a challenging series of events that kept most of the players busy throughout the duration of the exercise, in addition to presenting enough events to allow the players l to demonstrate their capabilitie In most cases, the role playing by the l players was good as was the control of the scenario by the controllers.

l However, a number of unrealistic actions were taken by the licensee. In one case, three communicators reported to the Control Room about ten minutes prior to the declaration of the Unusual Event. Since the Callaway Emergency Organization identifies only one communicator for the Control Room, with a second communicator available at the discretion of

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the Shift Supervisor, having three show up that early in the exercise was totally inappropriat In the future, if additional communicators are necessary, these should be requested by the Shift Supervisor and not be automatically assigne Also, apparently due to the expediency of the exercise and the physical distance of the simulator from the plant, certain short cuts were taken in procedures which, if actually done, could have caused dangerous situations. One was the removal of hold-off tags and operation of equipment without following all the steps prescribed to do so. Another was the shifting of valves and pumps from normal positions and or jury-rigging systems without following all the specific administrative procedures to do so. Since it is a poor policy to practice the incorrect way to carry out activities, simulation of these activities should be eliminated in future exercise Exercise scenario data deviated from expected data trends on several occasions during the exercise and this deviation was not promptly corrected by the controller In one case, simulator values for incore thermocouple temperatures showed fuel damage conditions in the core very shortly after the loss of coolant accident (LOCA) occurred but were not confirmed by area radiation monitor readings and process monitor readings. These deviations degraded exercise realism and caused some confusion to exercise participant Due to the interactive nature of the plant parameters, the exercise scenario " bugs" should be worked out on the simulator, if possible, with possible operator actions to be able to anticipate parameter abnormalities. Better controller briefings and preparations should improve coordinatio Also, the simulator should contain a status board and phones identical to what is available in the Control Room if it is to be used during exercise This hampered NRC participation in the exercise since the Resident had to leave the simulator to use a phone, although this would not have been the case in the Control Roo . Exit Interview The inspectors held an exit interview the day after the exercise on June 6, 1985, with the representatives denoted in Section 1. The NRC team leader discussed the scope and findings of the inspection. The inspectors also discussed the content of the report to determine if the licensee thought that any of the information was proprietary. The licensee responded that none of the information should be proprietar ,

Attachments:

1. Callaway Exercise Scope and Objectives Callaway Exercise Scenario Outline

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1985 FIELD EXERCISE UNION ELECTRIC OBJECTIVES v General Demonstrate the capability of the Emergency Response Organi-zation to implement the Radiological Emergency Response Plan and associated procedure I Classification Demonstrate the ability to accurately identify exceeded Emergency Action Levels and correctly classify the emergenc III. Accident Assessment and Response Demonstrate the ability of the Control Room and TSC to identify methods for mitigating the accident, terminating or limiting releases of radioactive material, and placing the unit in a safe, stable conditio . Demonstrate the ability to analyze current plant conditions, projected trends and potential consequence . Demonstrate the ability to form and dispatch teams to perform emergency repaifs.

i' I Notifications Demonstrate the ability to notify.and mobilize the Union Electric Emergency Response Organization ip_a.. timely manne . Demonstrate the ability to notify offsite agencies (county, State, NRC) within the required time limit . Demonstrate the ability to efficiently transfer notification '

responsibilities from the Control Room to the TSC and ultimately to the EO . Demonstrate the ability of the Control Room, TSC and EOF to update appropriate Union Electric, State, local and Federal emergency response personnel regarding emergency statu . Protective Response 1. Demonstrate the ability to perform timely assessments of on-site and offsite radiologica7 conditions to support the

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formulation of Protective Action Reco'mendation m Demonstrate the ability to formulate and communicate Protective Action Recommendations to State and local agencies.

[' . Demonstrate the ability to formulate protective actions for plant personnel including evacuation, use of protective r devices and administration of potassium iodid .-

    • Protective Rasponse (Cont 'd. ) Demonstrate the ability to control exposures of emergency

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response personnel both on-site and offsite.

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, Demonstrate the ability to select volunteers for receiving exposures in excess of 10CFR20 limits and demonstrate knowledge of actions to be taken following such exposure . Demonstrate the ability to respond to a medical emergency involving a contaminated victi . Demonstrate the ability to account for all personnel within the protected area and maintain accountability of emergency response personne V Emergency Response Facilities and Equipment 1. Demonstrate the ability to activate emergency response facilities in a timely manne . Demonstrate the functional adequacy of the TSC, OSC, EOF and JPI . Demonstrate the operability and effective use of communica-tions equipment and the adequacy of communications proce-dure .

VII. Direction and Control E

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l. Demonstrate the ability of the Emergency Coordinator and Recovery Manager to maintain overall control over the UE emergency response effor , Demonstrate the ability to gather, assess and disseminate information regarding plant conditions and emergency response activitie ~ Demonstrate the ability to transfer command functions from -

the Control Room to the TSC and from the TSC to the EO . Demonstrate the ability of facility staffs to initiate and

, coordinate activities in an efficient and timely manne . Demonstrate the ability to call upon additional Corporate and

outside assistance as deemed appropriat . Demonstrate the ability to correctly complete all forms and documents, and maintain these records for post-emergency

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dispositio VII Radiological Assessment 1. Demonstrate the ability to perform offsite dose assessment in

,.. a timely manner, kk[) . Demonstrate the ability to mobilize and direct field

, monitoring team ,

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VII Radiological Assessment (Cont'd.)

, , Demonstrate the ability of Health Physids personnel to J

s- conduct on-site and field monitoring activities including dose rate surveys, and collection and analysis of radio-

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logical sample , Demonstrate the ability to obtain and analyze samples utilizing the Post Accident Sampling Syste . Demonstrate the ability to coordin' ate dose projections and Protective Action Recommendations with SEMA and BRH personne '

I Recovery -

, Demonstrate the ability to de-escalate or close-out the

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emergency based upon current plant conditions or trend , Discuss appropriate recovery activities based upon current or projected plant condition . Conduct a post-exercise critique identifying areas requiring improvemen X. Public Information

. Demonstrate the ability to coordinate preparation, review and release of information with Union Electric emergency manage-(C

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ment personnel and, as necessary, Federal, State and local governmental agencie . Demonstrate the capability to provide timely 'nda accurate information to the press and general publi . Demonstrate the ability to identify and control rumor '

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X NRC Interface

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1. Devanstrate the ability to coordinate emergency response activities with the NRC on-site emergency response tea /

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SCENARIO FORM ME ME SEQUENCE OF EVENTS MBERS D.- Initial Plant Conditiens Personnel on-site are limited to the normal weekday complement. The unit is operating.at 100 percent power with rod control in the " automatic" mode. All plant parameters are normal and stable with the unit just completing a 30 day run at 100 percent powe Residual Heat Removal (RHR) Pump PEJ01B is tagged out for pump bearing replacement wor This work commenced at 1700 on June 2 and is expected to be completed by 1200 on June Refer to Mini-Scenario 7.3 for further informatio Turbine Driven Auxiliary Feedwater Pump PALO2 is tagged out for rebuilding of the speed governor. This work commenced at OTOO on June 5 and is expected to be completed by 2100 on June 5. Refer to

Mini-Scenario 7.4 for further informatio The Train "A" Fuel Building Emerg,ency

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Exhaust System is tagged out. Fuel Building HVAC to Unit Vent Isolation

' Damper GG-D045 is being replaced. This damper was damaged during recent backfit construction activities. The damper shaft is bound and the adjacent ductwork -

is creased, resulting in restricted flow. This work commenced at 1600 on June 4 and is expected to be completed by 1600 on June .-

The Reactor Vessel Level Instrumentation System (RVLIS) has not yet been installed and is therefore not availabl The ERFIS computer system'is down for repairs due to a recent fire in the processor cabinet. The SPDS is undergoing hardware modifications and is unavailabl (-.

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SCENARIO FORM SCENARIO MESSAGE REAL p,- TIME

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TIME SEQUENCE OF EVENTS NUMBERS

,1 NOTE: In addition to the above initial conditions, the Simulator Operator shall include the following items to the initici Simulator conditions:

1) Freeze out all UNS function ) Main Feedwater Line Break inside l

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Containment on Steam Generator "D" (MALF FWM 8, Delay = 7200, Leak Rate = 30E6, Ramp = 60)

3) Rod Ejection (MALF CRF 5, Rod =

M-12, Break Size = 2000.0 gpm, Delay = 7230)

4) " Stick" the Train "B" Containment Spray Pump Discharge Valve EN-HV-12 closed (MALF RHR 6, Pump = B, Delay = 0.0)

5) failure of Safety Injection Pump PEM01B (MALF RHR 5, Pump = B jf ?) . Delay = 7500)

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6) Failure of Engineered Safety Feature (ESF) Bus NB01 (MALF EPS 5,, Bus =

NB01, Delay = 11,500)

7) Failure of Turbine Driven Auxiliary

Feedwater Pump PALO2 (MALF FWM 12, Pump = TD, Delay = 0) ~

8) Failure of RHR Pump PEJ01B (MALF RHR 1, Pump = B, Delay = 0)

j Initial Meteorological Conditions Winds are from the northwest (315') at 8 miles per hour. Ambient air temperature is 80*F. It is a partly cloudy, windy da .

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SCENARIO FORM REAL SCENARIO MESSAGE

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TIME TIME SEQUENCE OF EVENTS NUMBERS Detailed Scenario Timeline 0800 H+00:00 Initial Conditions establishe I and 1 Sim NOTE: All plant parameters and operational information will be supplied to Control Room personnel by the Simulator with the exception of the following:

1) Any radiological information that would normally be supplied by the RRIS or RM-ll computer system ) Miscellaneous Balance-of-Plant (BOP)

parameter ) Fire Detection Alarms Additionally, depending upon the Simulator performance, the following information may be manually provided:

r 1) Incore thermocouple temperature ) Containment hydrogen concentratio '~ '

3) Containment pressur The above information will be supplied by a Control Room Controlle One of the electricians working in the 2 -

0815 H+00:15 Train "B" RHR pump room falls and is injured. The individual has a 3 inch laceration above his left eye and a closed fracture left ankle. He is conscious but in considerable pai Refer to Mini-Scenario 7.1 for further informatio '~

Message to be The Shif t Supervisor should declare an 2c passed 15 minutes Unusual Event (Transportation of post Control Room Externally Contaminated Injured /Ill -

notificatio Individual from Site to an Offsite Hospital) and initiate the appropriate actions per Procedure EIP-ZZ-0010 f 5-3

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SCENARIO FORM REAL SCENARIO MESSAGE k' TIME TIME SEQUENCE OF EVENTS NUMBERS 0845 H+00:45 The weld connecting the drain line to 3 and the Waste Evaporator Bottoms Tank has 3g partially failed allowing liquid radwaste to spill on the room floo Gaseous iodine is released from the spil These events result in an increase in area and airborne activity level Appropriate annunciators are received in the Control Roo H+00:45 A Health Physics Technician performing 4 his routine surveys of the Radwaste Building hears local area radiation monitors alarming. Upon proceeding to the area of the monitors and reading his survey instrument , he verifies that an abnormal radiological hazard exist Message to be The Shif t Supervisor should declare an 4c passed 15 minutes Alert (Area Radiation Levels or High post Control Room Airborne Activity greater than 1000 confirmation times normal) and initiate the contac appropriate actions per Procedure EIP-ZZ-0010 (i 1000 H+02:00 Main Feedwater Line 071-ELB-14" ruptures 5g at the downstream weld of Check Salve - .

V122. The unit reactor trips on LoLo Steam Generator Level and is followed by a turbine trip. As the rods insert during the reactor trip, Rod Cluster Control Assembly M-12 is ejected '

resulting in a Loss of Coolant Acciden Upon receipt of a Containment Spray Actuation Signal, the Train "B" Containment Spray Pump Discharge Valve EN-HV-12 fails to open due to control

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fuse failure and subsequent circuit breaker trip. Refer to Mini-Scenario 7.6 for further informatio NOTE: The Control Room status indicator light for this valve is no'w los H+02:05 Safety Injection Pump PEM01B flow and 6g 1005 discharge pressure drop to zero due to motor-to-pump shaft coupling spacer

failure. Refer to Mini-Scenario 7.5 for

! further informatio .

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SCENARIO FORM

,. REAL SCENARIO MESSAGE l TIME TIME SEQUENCE OF EVENTS NUMBERS Message to be The Emergency Coordinator should declare 7c passed 15 minutes a Site Emergency (Loss of Coolant post recognition Accident greater than Charging Pump that LOCA exceeds Capacity) and initiate the appropriate charging capacity, actions per Procedure EIP-ZZ-0010 NOTE: Message 7c-1 directs the Emergency Coordinator to initia.te activation of the Interim EOF Staff if not already accomplishe H+02:18 The Accumulators begin to discharge to 8g the Reactor Coolant System as system pressure continues to decreas + H+02:20+ If not already accomplished, the O&M 9c Coordinator should direct dispatch of an Emergency Repair Team to repair RHR Pump PE J01 + H+02:25+ If not already accomplished, the O&M 10c Coordinator should direct dispatch of an Emergency Repair Team to repair Safety Injection Pump PEM01 (>

1030+ H+02:30+ If not already accomplished, the O&M 11c Coordinator should direct dispatch..of an Emergency Repair Team to open discharge valve EN-HV-1 H+03:15 ESF Bus NB01 sustains arcing.. fire and 12 and smoke damage due to "B" phase bus bar 12g

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splice failure. Alarms sound on the Fire Protection Panel KC008 in the Concrol Roo The area Halon system operates as designed and the feeder

, breaker trips on ground faul The fire is extinguished but NB01 is rendered

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inoperable. Refer to Mini-Scenario 7.2 l

for further informatio NOTE: A Fire Brigade shall be formed and dispatched to the ESF switchgear room.

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SCENARIO FORM

REAL SCENARIO MESSAGE N TIME TIME SEQUENCE OF EVENTS NUMBERS Message to be The Emergency Coordinator should declare 13c passed 15 minutes a General Emergency (Loss of 2 out of 3 post appropriate fission product barriers with a parameters being potential of losing the 3rd) and exceeded initiate the appropriate actions per Procedure EIP-ZZ-0010 NOTE: Lead Controller should concur with a. Control Room Controller to verify Simulator parameters before passing this messag H+04: 30 A hydrogen burn takes place inside 14 and Containment. The containment pressure 14g trend recorder indicates a high pressure transient (spike) has occurred. The burn and pressure transient damage penetration assembly V161 (Containment purge supply line) causing it to lose integrit The above events allow the Containment atmosphere to vent to the 2047' level of the Auxiliary Building.

(1 1235 H+04:35 The pressure on the 2047' level of the 15 Auxiliary Building has become s.p,fficient to establish a radiological release through the open ductwork (line 026-SNP-32") where damper GG-D045 was located and, subsequently, out the unit ven ,

1300 H+05:00 Safety Injection Pump PEM01B is returned 16 to servic H+05:30 RHR Pump PEJ01B is returned to servic H+06:30 The Train "B" Containment Spray 18 Isolation Valve EN-HV-12 is opene With the initiation of the Containment Spray System, Containment pressure begins to decreas .

1500 H+07:00 Containment pressure has equalized with 19 atmospheric pressure. The release through the unit vent has terminate gr

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SCENARIO FORM REAL SCENARIO MESSAGE IR TIME TIME SEQUENCE OF EVENTS NUMBERS

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1530 H+11:30 It is now 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> later. Plant 20 parameters, conditions and trends are such that recovery operations are warranted and that a transition to a recovery organization can begi NOTE: Messages 20-1, 20-2, 20-3, 20-4, and 20-5 provide operational and radiological data to appropriate Control Room, TSC and EOF personne The data should provide a basis for recommendations to the Emergency Coordinator and Recovery Manager for initiating recovery discussion H+11:45 The Recovery Manager and Emergency 20c Coordinator should initiate actions to transition to a recovery organizatio H+12:15 Emergency response facility managers are 21 1615 now directed to initiate deactivation of their respective facilities and organization (i 1630 H+12:30 Exercise activities are terminated as 22 directed by the Lead Controlle gency Commence critiques response facility at each and amongemer,fd'

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personne N/A N/A An additional message is provided to N/A relay meteorological information to the -

Health Physics Coordinator from the National Weather Service. This message will be passed when the information is requested by the Health Physics Coordinato ._

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SCENARIO FORM INITIATING MESSAGE AT INITIATING REAL SCENARIO MESSAGE i TIME TIME SEQUENCE OF EVENTS NUMBERS

~ Offsite Response Action Suutary 0815 H+00:15 The Shif t Supervisor notifies the 2 Callaway Community Hospital and the ambulance servic Shift Supervisor notifies Callaway County /Fulton ECC Dispatcher, Missouri State Highway Patrol and the NRC Region III that the plant is in an Unusual Even The~Callaway County /Fulton ECC

. Dispatcher records the message, verifies the message and makes the following notifications:

1) Other Counties (if ringdown line is not available)

2) County Commission / Mayor

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3) Local Emergency Management Director

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4) Chief of Police 5) Sheriff , ,

State Emergency Management Agency (SEMA)

verifies notificatio The other County ECC Dispatchers make

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the following notifications:

1) County Commissioner 2) Local Emergency Management Director 0845 H+00:45 Shif t Supervisor notifies Callaway 3

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County /Fulton ECC Dispatcher, SEMA and the NRC Region III that the plant is in an Aler No protective action recommendations are

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made by the utility at this time. The UE Public Information Coordinator and the Offsite Liaison Coordinator proceed to the EO .

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SCENARIO FORM INITIATING MESSAGE AT INITIATING REAL SCENARIO MESSAGE ja NJ TIME TIME SEQUENCE OF EVENTS NUMBERS The Callaway County /Fulton ECC Dispatcher records the message, verifies I the message and makes the following notifications:

1) County Commission / Mayor 2) Local Emergency Management Director

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3) Chief of Police 4) Sheriff 5) Establish contact with SEMA 6) Establish contact with EOF The Callaway County Commission / Mayor authorizes partial activation of the County EO The ICC Dispatcher notifies the Osage, Casconade and Montgomery ECC Dispatchers of status (if ringdown line is not (4

available).

EBS is placed on standb ,,, ,

The ECC Dispatcher initiates the call tree for key county EOC personne The State EOC and the Forward Command Post (FCP) are activated at this tim .

State and County EOC personnel locate and review appropriate procedures, and assess resources. Rumor Control Center established in the JPI H+02:00 The TSC Communicator calls Callaway Sg County /Fulton ECC Dispatcher, SEMA and the NRC Region III with the message that the Emergency Coordinator has declared a Site Emergency. No protective action ~ '

recommendations are made by the' utility at this tim The Callaway County /Fulton ECC Dispatcher records the message, verifies the message and makes the required

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SCENARIO FORM INITIATING MESSAGE AT INITIATING

. REAL SCENARIO MESSAGE i& TIME TIME SEQUENCE OF EVENTS NUMBERS The EOF and JPIC are activate Resources are placed on standby, and operational checks are performed on equipmen Protective action procedures are reviewe SEMA confirms the Site Emergency status, and BRH dispatches Field Monitoring Team H+03:15 General Emergency may be declared 12 or shortly after this time. Emergency 12g Coordinator will recommend sheltering withir. a two mile radius and within five miles in downwind sector The EOF Communicator would then inform Callaway County /Fulton ECC Dispatcher that.the Emergency Coordinator has declared a General Emergency.

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k' The Callaway County /Fulton ECC Dispatcher records the message, verifies the message and makes the appropriate

notification The following actions may be initiated, as appropriate, at this time:

1) Implement Protective Action -

Recommendation ) EBS activated, and message released; station broadcast should be monitored for correctnes "~

3) Public Alert System activated and confirme ) Access / traffic control determine ) Access Control Points establishe ) Radiological exposure controls for emergency workers assigned to the field initiate '

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SCENARIO FORM INITIATING MESSAGE AT INITIATING REAL SCENARIO MESSAGE

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TIME TIME SEQUENCE OF EVENTS NUMBERS 1145 H+03:45 General Emergency should be declared by 13c this time, if not previously don EOF Communicator informs Callaway County /Fulton ECC Dispatcher, if not previously done, that a General Emergency has been declare ,

Actions initiated by Counties would be the same as previously identified at 1115, messages 12 and 12 SEMA calls Counties and communicates offsite data from BR H+04:35 Protective Action Recommendations from 15 Emergency Coordinator may be upgraded at this time based on a release of large amounts of radioactive materials to the environmen Emergency Coordinator may recommend full two mile evacuation and five* mile downwind evacuation based on release rate, release duration and projected doses offsite.

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Protective action decision is made by the Callaway County Commission /hayor as ,

follows:

1) Develop appropriate EBS messag ) Coordinate EBS message with other '

organization ) Release EBS message, monitor station broadcas ) Activate Public Alert System and

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confir ) Dispatch resources required to implement protective action .

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SCENARIO FORM INITIATING MESSAGE AT INITIATING REAL SCENARIO MESSAGE

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\LE TIME Coordinate with SEMA as follows:

1) Implementation of-rad monitoring suppor ) Implementation of contamination control / decontaminatio ) Implementation of reception and care center Refer emergency workers to decontamination centers, if necessar l Implement control of radiation dose records and general records maintenanc H+11:30 Based on start of plant recovery and 20 termination of release, county officials may consider downgrading protective actions in effect at this tim .

Develop plan for reentry / recover "p

' 1) Continue to receive radiological data from State and plant field monitoring team , ,

2) Contact SEMA to coordinate recovery assistanc H+12:30 Exercise terminated, critique by 22 1630 -

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