ML20132F898

From kanterella
Jump to navigation Jump to search
Draft Ltr Forwarding NRR Draft SALP Input for Review. Comments Received by 830826 Will Be Considered in Final Rept
ML20132F898
Person / Time
Site: 05000000, Waterford
Issue date: 02/27/1985
From: Joshua Wilson
Office of Nuclear Reactor Regulation
To: Eisenhut D, Mattson R, Vollmer R
Office of Nuclear Reactor Regulation
Shared Package
ML082320156 List: ... further results
References
FOIA-84-206 NUDOCS 8510010430
Download: ML20132F898 (6)


Text

.. -..

w =7 n' n ~ - -. a - ;;;

M WJ

~

rh:nx. --= :;& ;- MgK=_~ - =5%gx (n&Q.uM3+ 1&+3 %f =' ~ =iz & ~ Aw rmL. ~W: = mm:&vecA=QM J-

/psM **9g'o, UNITED $TATEs NUCLEAR REGULATORY COMMISSION

)

y

{

Yr ASHIfeGTON. D. C. 2006s i

~#f M

J

\\p%... /

gis si I

MEMORANDUM FDR: Darrell G. Eisanhut Dirwetor Division of Licensing Roger Mattson. Director Division of Systems Integration Richard Vollmer, Director Division of Engineering Hugh Thompson, Director afvision of Human Factors Safety Edward Jordon, Director Wision of Emergency Preparedness & Engineering Response Thomas M. Novak, Assistant Director THRU:

for Licensing Division of Licensing FROM:

Jauras Wilson Project Manager Liceesing Branch No. 3 Division of Licensing t

SUSJECT:

i" Attache ts a draft of the NRR input for the SALP for Louisiana Power and TMs draft report is based par'tly upon input solicited from IJ.gic Company.

selected staff personnel who have had substantial contact and involvement Please review the draft evaluation and i:.

wfth LP&L's licenstag activities.

provide any comments you feel appropriata. All coments received by August 26, l

1983 will be considered in the final report.

To assist you with review and coment, the following persons were contacted l

R. Benedict, L. Sender, LQB; D. Kubicki. CNEB; J. Clifford.

for input:

M. Goodaan, PSRB; M. Garg, J. Jackson, EQB; G. Hsii. T. Huang, CPS; and D. Perrotti, EPL8.

3 s

James H. Wilson, Project Manager I

Licensing Branch No. 3 Division of Licensing

{

5.closrues: Evaluation Matrix

$ 00Q @ e50227 en 2.

Input for SALP Report BERNABE84-206 PDR cc:

R. Senedict M. Goodman D. Kubicki H. Garg p/A/Y-20(

D. Perrotti J. Jackson L. Sender.

G. Hssi g

L

e

.:...~

p== <.u'*

UNITED STATES

,i j $.e/-,,h NUCLEAR REGULATORY COMMISSION WASHING TOM. D. C. 20046 8

7*

'/ E g...../

8a Facility Name: Waterford 3 Licensee: Louisiana Power & Light Company MRR Project Manager: James Wilson 1.

Introduction This report. presents the results of an evaluation of the applicant, Loutstana Power & Light Cospany,in the functional area of licensing it is intended to provide NRR's input to the SALP review actlYttler, The review covers process as described in NRC Manual Chapter 0616.

the period July 1, 1982 to June 30. 1983.

The beste approach used for this evaluation was to first select a number of licensing issues which involved a significant amount of staff Comments were then solicited from the staff.

Finally, this information was assembled in a matrix which allowed an overall evaluat manpower.

This evaluation is based on staff input

(

of the applicant's perfomance.

N from eight review activities.

II.

Surparv of Results NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a perfonnance category based on a number of factors.

j The single final rating was determined thourgh integration of the opinions g

received from the MRR reviewers and the judgement of the project manager.

ach, the perfonnance of Louisiana Power & Lijht Company Based on this l

in the functiona rea " Licensing Activities" is rated category 2.

.l III.

Criteria l

Evaluation criteria, as given in NRC Manual Chapter Appendix 0516 Table 1,were used for this evaluation.

t IV, Perfonnance Analysis The applicent's performance evaluation is based on a consideration of For most of the seven attributes as given in the NRC Manual Chapter.

I licensing actions considered in this evaluation,only three or four of l

the attributes were of significance. Therefore, the composite rating is heavily based on the following attributes.

(1) Management involvement (2)' Approach to resolution of technical issues (3) Responsiveness j

t l

1

~'

=m

, - -- h v

' t g

g dith the exception of Enforcement History ano Reportable Events for which there was no basis within MRR for evaluation, the remaining ctributes of Staffing and Training were judged to apply only a few 5

licens a g activities. Both training and staffing were considered as

=

unigee licensing activities, under licensatoualifications.

4 s

g k-

}

The perfomance analysis was based on our evaluation of the following liceesing activities:

}

C Fire Protection 4

Training Procedures

-7

[

On-site E:ergency Plans p

Emirtarental Qualification f

5 Seismic Qualification

)

Licensee Qualification 2

Core Performance c

I The level of licensing activities during the review period was used d

as a writerion in choosing the functional areas considered in this M

(evaldation.

Management Involvement and Control in Assuring Quality A.

a3 6

The overall rating for this criterion is category 2.

There is s

evidence of planning and assigreent of priorities and decision p

eakirng seems to be at a level that ensures c:anagement review.

=

Managemeret involvement was particularly evident in meeting the a

regzh -..ts of Appendix R. Emergency Planning and Licensee However in the area of procedures, the rating is Qualtitcation.

category 3 because the applicant's approach to writing E0Ps r

a facked prier planning. The approach to writing E0Ps changed

^

several times during the course of the review, resulting in

==

onr:ecessary delays. Lack of proper management direction has E

resulted in the plant staff resisting changes of any kind in e

order to take licensing exams sooner than would have been A

r possible of E0Ps were adequate.

m

-3 The overall rating for this criterion was category 2.

In the B.

2 technical area of Fine Protection the applicant's perfonnance es rated category I because they use technically sound approaches in cost cases and display sufficient conservatism when potential il for safety significance exists. However, in the case of Procedures.

t-the rating is category 3 because the applicant has not appeared as to use an analytic approach to E0P development. Many engineering s

p judgements appeared to be made on the spot, without references or 3

g consideration of supporting documentation. Also, the applicant d

appeared to be extremely reluctant to use existing industry guidance (NSSS,IMPO.MRCdocuments).

i

=

a i

L z

5 h,,

3-C.

Responsiveness tb NRR Initiatives The overall rating for this criterion was category 2, but in t)#e area of core performance the rating was category 1.

In general the applicant's responses are timely with very few long standing The resolutions regulatury issues attributable to licensee.

However ir. the proposed by the licensee are usually acceptable.

area of Procedures, a rating of 3 is assigned because af,ter more f ne applicant T

than two years of review involving two sets of E0Ps,licant has still does not he.ve a set of approved E0Ps. The app demonstrated a continuing inability to discern technical errors identified during the review by Regional and NRR reviews.

D.

Enforcement History There is no basis for an MRR evaluation of this criterion.

E.

Repwtable Events j:

4 There is no basis for an flRR evaluatier, of this criterion.

F.

Staffing This criterion was not broadly evaluated, but did receive an e

l overaf f category 2 based largely on LP&L's performance in the l

area of the licensee qualification. During this SALP review period, the applicant overcame a large deficiency in staffing.

Mthemsk same key positions were still vancant and overall staffing fell short of stated goals at the end of the period, the etfort displayed by the licensee earned them a category 2.

! ena of environmental qualification, as well as other La the technical areas, the applicant is relying heavily on job

Jwyy=as, rather than LP&L staff.

G.

Training This criterion was given a rating of category 3.

Althou3h training department has been given greater authority in the organization, this organization has not been as corporate effective as it should have been at this stage of the licensing There is an apparent lack of coordination between the 4

process.

applicakt's organization that develops procedures and the training organization which could lead to problems in the applicant's approach to accident mitigation during operation.

,,.,_,m..

~. _. - -,, _.,. -.. _., _.,,

k

,,d)L Y I A. "

- V.

Conclusion Based on the evaluation of five of the seven attributes listed in the NRC Manual for a number of significant licensing activities, an overall rating of category 2 was given to Louisiana Power & Light Company.

Specifically, management attention and involvement with matters of nuclear safety is evider.t and satisfactory perforinance with respect to safety is beeing achieved. The applicant's responses are usually timely and reascnable resolution to licensing issues are offered.

H:hever, for one of the sigt.t technical areas evaluated, Procedures, significant deficiencies in all categories resulted in unsatisfactory ratings for the applicant's perfo:v.ance during this rating period.

s ps e

t 8

a l

i l

l

G N

A 3

2 A

A A

A I

3~

N N

N N

N I

N A

R T

GN I

F 2

A A

2 3

A 2

A F

N N

N N

AT S

e E

LBS AT TN A

A A'

A A

A A

OV N

S' N

N N

N N

N RE A

PE 3

E R

D R

O T

F N

R EY MR t

W CT A

A A

A A

A A

A TA EO RS N

N N

N N

N N

N R

OI O

FH F

N A

E W

I E

R I

E V

T E

E I

V R

R I

P C

SNS L

3 2

2 2

2 1

A N

OS 2

2.

S O

'P E I

SH T

E A

R X

U I

L O

R A

TN T

V O

A E

HI M

CT AU 3

1 3

2 2

2 2

2 N

hL O

RO I

PS T

PE A

AR e

U TQ LA E '

NE V

EM ME 2

2 2

3 2

2 2

A EV GL H

AO NV l

A i Ml.

t d

i R

r i

rn t

n c

g E

e) k)

oa t

o i

in)

W dO c8 fm) o)

g) s)

d) i E fdB rB r8 k6 e8 t aB oR rL aQ cQ nQ suP E

nQ B(

uC 1 oS eP GE aE eL HHC eL bH 1

I

(

V K(

CGP PE

(

J(

B(

E

(

(

.H' GT

^

R L

D JM D

J R

s n

na n

o m,

i o

l t

i P

M t

a a

c E

y n

n i

e T

c c

f c

1 I

n n

l

/

o e

o f

a.

i l

N g

li i

e O

t r

at l

t a a

u r

I c

e

_ nc u

Q o

T e

s m

f C

t e

E

_ et Q

e r

A g

o r

mf n

r u

e nt c

e e

s P

i P

d t

bl i

N n

e i

r a m

n G

I i

e c

S iu s

e e

i c

r a

r o

vQ o

S

.__ r t

r n

e i.

h C

E S

l N

u ll.

Jl;j).

!ljlJ

)ijilJlj!.

i

6 l

l LOUISIANA POWER and LIGHT COMPANY WATERFORD-3 STEAM ELECTRIC STATION EMERGENCY PREPAREDNESS EXERCISE 25 MAY, 1983 PARTICIPANTS LOUISIANA POWER and LIGHT COMPANY STATE OF LOUISIANA ST. CHARLES PARISH ST. JOHN THE BAPTIST PARISH U.S. NUCLEAR REGULATORY COMMISSION U.S. FEDERAL EMERGENCY MANAGEMENT AGENCY N

g i

l t

f*M -ff-1**

,,7y 3y <,a;'

aLg.

o/35-

o WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 e

TABLE OF CONTENTS I.

INTRODUCTION II.

OBJECTIVES III.

GUIDELINES A.

General B.

Safety Precautions C.

Drill Monitor and Caserver Instruction D.

Performance Evaluation Standards IV.

NARRATIVE

SUMMARY

V.

DRILL SCENARIO SEQUENCE OF EVENTS VI.

CUE CARDS Part I

- Participant Message Part II. - Monitor Guide A.

Anticipat.d Response B.

Comments C.

Instructions VII.

CHARTS, GRAPES AND TABLES VIII.

REFERENCES IX.

DRILL MONITOR / OBSERVER TASK ASSIGNMENT SHEET I

\\

f

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 SECTION I - INTRODUCTION In the interest of assuring that the health and safety of the general public in the surrounding area is protected in the event of a radiological emergency at the Waterford-3 SES, Louisiana Power & Light conducts exercises jointly with the State and Local agencies on an annual basis.

The role of the Federal government at such an exercise is to evaluate the capabilities of the utility, State and Local governments to provide the accessary protection for ensuring the health and safety of the public in the event of an emergency at the Waterford-3 f acility.

In this respect, the Exercise will be observed and critiqued by the Federal Emergency Management Agency (FEMA)'at the State and Local level and the Nuclear Regulatory Commission (NRC) at the utility level.

This Exercise, which is to be conducted on May 25, 1983, is the first of the annual exercises which will be observed by the Federal Govarnment and as such plays an important part in the licensing process for Waterford-3.

The Exercise will include the mobilization of LP&L, State and Local agencies such that the capability to respond to a simulated emergency at the Waterford-3 SES may be assessed and verified.

Exercise " players" will have no prior knowledge of the sequence of events including radiological release information.

The exercise itself will allow those individuals and agsncies assigned responsibilities in a radiological emergency to demonstrate their ability to perform according to current emergency preparedness plans and procedures.

To assist the Exercise Controllers, evaluators and observers in

~

the conduct and evaluation of the Exercise, this manual has been provided.

This manual contains all of th9 informr. tion and data accessary to properly conduct the Exercise in an efficient and coordinated manner, and is broken down as shown in the Table of Contents.

The scenario itself is a mechanism by which selected monitors can initiate and evaluate the activities of the participants in the exercise.

The exercis; will be initiated at the Waterford-3 Steam Electric Station at 6:00 a.m. on May 25, 1983 and is expected to last approximately ten hours.

The following organizations will participate in this exercise:

1.

LP&L Personnel a.

Station Management b.

Control Room c.

Emergency Response Organization i

d.

General Office Support e.

Media Relations 1

f.

Corporate Staff

.he6Bh&.'?^ "'+

L

,G.anvuu rxvM PUBLIC DISCLO5URE '

I-l

I-WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 2.

Parish a.

St. Charles Parish Sheriff's Office b.

St. Charles Department of Emergency Preparedness c.

St. John the Baptist Of fice of Civil Defense d.

St. John the Baptist Parish Sheriff's Of fice e.

Jefferson Parish Office of Civil Defense f.

Orleans Parish Office of Civil Defense 3.

State a.

Louisiana Office of Emergency Preparedness b.

Louisiana Nuclear Energy Division c.

Fixed Facility Response Team Members d..

Louisiana State Police To ensure that the exercise is conducted properly and that the participants understand and learn from this experience, copies of this manual will be provided to the exercise controllers, evaluators, and observers prior to the Exercise.

Also, following the exercise, copies of the manual will be distributed to key exercise " players" for their review.

Controllers will be utilized for this Exercise and will be the i

only individuals having authority to alter the scenario.

In order to achieve in-plant realism and provide data for testing off-site response actions.

The following assumptions are made:

1.

For in-plant radiation levels, it is assumed that limited core damage occurs.

This allows for an in-plant (and near-plant) response to occur with more realistic area radiation levels.

2.

For off-site- (greater than 1/4 mile from W-3 complex) dose l

projections, it is assumed that major core damage occurs.

This allows for a radioactive plume that will require off-site protective actions to be taken.

l l

I-2

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 LOUISIANA POWER AND LIGHT COMPANY WATERFORD 3 STEAM ELECTRIC STATION 1983 EMERGENCY PREPAREDNESS. FIELD EXERCISE SECTION II. OBJECTIVES As a result of discussions between Louisiana Power and Light Company (LP&L), the Nuclear Regulatory Commission - Region IV (NRC), the Federal Emergency Management Agency - Region VI (FEMA), the Louisiana Nuclear Energy Division (LNED), Louisiana Of fice of Emergency Preparedness (LOEP), St. Charles and St. John the Baptist Parishes, general objectives and guidelines have been developed for the 1983 Emergency Preparedness Exercise at Waterford 3 Steam Electric Station, which is scheduled to be conducted on May 25, 1983.

A.

Exercise Objectives 1.

For the LP&L (Licensee) Emergency Response Organization:

a.

Demonstrate proficiency in classifying the emergency condition.

b.

Demonstrate prompt notifications, c.

Demonstrate the ability of the LP&L Emergency Response Organization to establish command and control and maintain continuity of command and control throughout the exercise.

d.

Demonstrate adequate and effective use of emergency l

communications equipment, and communications l

procedures and methods.

e.

Demonstrate the capability to develop and disseminate timely and accurate public information releases.

f.

Demonstrate the ability to obtain appropriate l

medical care for simulated injured or contaminated j

personnel.

l g.

Demonstrate the ability to perform radiological monitoring and assessments, and off-site dose l

assessment projections necessary to provide advance warning to Parish, State and Federal agencies.

oomu nrer,- meer,ne"#E II-l

-- ;, 7 7 um meo+, _ ww.mone n

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 h.

Demonstrate the adequacy of the LP&L emergency response facilities for personnel to perform their designated functions.

i.

Demonstrato recovery techniques in the ability of the LP&L Emergency Response Organization to de-escalate (deactivate) corporate and site emergency response activities.

j.

Demonstrate the ability of the Emergency Response Organization to disseminate information to other participating emergency response organizations (Parishes, State and Federal).

k.

Demonstrate accountability using a select group of Louisiana Power and Light employees.

1.

Demonstrate adequate security measures at each of i

the Louisiana Power and Light Emergency Facilities.

m.

Demonstrate the ability to conduct a post-exercise critique to determine areas requiring additional improvements.

2.

For the various off-site emergency response organizations (Parish, State, Federal and private).

1 a.

Demonstrate that participating organizations can i

alert, notify and activate emergency response personnel in a timely and effective fashion.

b.

Demonstrate State and Parish capability for alert / notification of the public, institutions and industry within tha plume exposure pathway (EPZ).

c.

Test and evaluate the activation and adequacy of external communications systems and procedures between facility, State and Parish.

d.

Test and evaluate the activation and adequacy of communications between the various emergency response organizations and their respective field operations.

e.

Demonstrate the activation of emergency operations centers and the effectiveness of security, internal procedures, displays and information systems.

f.

Evaluate the adequacy, capabilities and personnel of emergency operations center staffing.

g.

Evaluate State and Parish effectiveness in the direction and control of emergency operations.

av r - nerm ?

II-2

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 h.

Demonstrate LNED's capability for accident assessment and protective action recommendation.

i.

Demonstrate that timely and coordinated protective response decisions can be made for both plume and ingestion exposure pathway EPZ's.

j.

Test and evaluate capability of State and Parish emergency staffs to carry out radiation exposure control measures.

k.

Test and evaluate State and Parish capability for implementing access control and traffic control procedures.

1.

Demonstrate State and Parish capability for disseminating instructions and emergency information to the public.

m.

Test and evaluate utility, State and Parish capability for coordinating the release of information to the media and the general public.

n.

Demonstrate the capability of special facilities within the plume exposure pathway EPZ to implement protective measures.

o.

Demonstrate the capabilities to provide support to risk Parish from designated local and State agencies.

p.

Test and evaluate the implementation of reception center and ' shelter operations in support Parishes, q.

Demonstrate capability for implementation of I

recovery operation.

l 1

I l

l l

)

rumutu v.._:: TEE II-3 1:2... 7:: Ji ZZ Z ? I "'-" : :

..un

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 Section III - Guidelines To define the " extent of play" by the exercise " participants" meetings were held on the aforementioned exercise objectives and the following exercise guidelines were developed:

A.

General 1.

The full-scale exercise will be conducted on May 25, 1983.

Since exercise " players" will not possess prior knowledge of the exercise start time, all personnel should follow their normal routines for that day.

2.

The Exercise will commence with a postulated plant condition necessitating a declaration of a notification of an Unusual Event and escalate through the four emergency classifications to a General Emergency.

3.

The postulated accident conditions will result in a simulated radiological release which necessitates the consideration of protective actions for the general public.

4.

The exercise will include the actual movement of selected vehicles from within the plume exposure pathway EPZ for the purpose of testing procedures for processing, monitoring and placement of simulated evacuees within participating support Parishes.

Traffic control plans will be implemented along main evacuation routes with the actual employment of limited equipment and personnel.

5.

Participants shall inject as much realism into the exercise as is consistent with its safe performance, however, caution must be used to prevent over-reactions, since maintaining public protection is a key aspect of the exercise.

l 6.

Exercise participants will perform, as appropriate, radiological monitoring and dose assessment activities.

7.

Radiological monitoring field teams will be dispatched in order that response time, communications, and monitoring procedures may be' evaluated.

8.

All emergency communications that relate to the exercise shall be identified as part of the drill.

Verbal communications during the exercise shall be initiated and closed by the statement, "This is a drill".

III-l h a.,sv nn.atnu ni.uuvuv inun,vuuAu unwww

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 1

NOTE:

Care shall be taken to assure that individuals who may overhear or see exercise activities are not misled into believino that an actual emeroency exists._

9.

All communications that relate to an actual energency shall be unequivocally identified as such.

If at any time a real acergency occurs, all actions relating to the exercise shall cease and response shall be directed to the actual emergency.

10.

All onsite and offsite emergency response facilities, including the State and Parish EOC, will be manned and perform their prescribed functions.

11.

Utility, State and Parish media centers will be staffed and activated.

Members of the media will be invited to participate at specific media centers.

Press releases will be made which depict simulated exercise events.

However, no exercise press releases will be made to the public.

12.

As appropriate, Emergency Broadcast Station (EBS),

announcements should be prepared and passed to the appropriate stations, but not released to the general public.

13.

The offsite notification siren system will be activated as part of this Exercise.

14.

Procedures will be tested for the treatment of a simulated injured onsite worker.

This will involve the movement of the individual to the support medical facility.

15.

The postulated accident conditions may warrant the assembly and simulated evacuation of non-essential sits personnel.

If required by the exercise scenario, the Station Alarm should be sounded and personnel assembled.

However, once onsite assembly and accountability procedures have been completed, non-participating personnel should be allowed to return to their normal work stations.

Onsite construction workers will be excused from participation in the exercise.

Site employees will not be moved or evacuated to offsite assembly areas.

Participation by LP&L onsite personnel directly involved in responding to an emergency shall be carried out to the fullest extent possible, including the deployment of radiological monitoring teams, emergency maintenance teams. and other emergency workers.

III-2

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 16.

If the exercise scenario requires that any organizations and/or officials be contacted, they shall be contacted for the purpose of checking communications only.

17.

Activities, Functions or Operations to be simulated:

Security Computer Accountability a.

b.

Post-Accident Sampling Panels c.

Volunteer Fire Department Response 18.

If required by exercise scenario, alternate means of accessing the plant shall be simulated and not actually implemented.

However, onsite security personnel should exercise their procedures for restricting normal access to the site without actually redirecting incoming or cutgoing personnel.

19.

The observers /monitort shall issue cue cards to key players to simulate the sequence of events.

Drill observer's input may be used where necessary to provide an element of realism and spontaneity into participant response.

If problems occur with the sequence of events, the drill coordinator shall be notified to obtain a resolution.

20.

The following systems will not be considered part of this exercise.

a.

Computerized Emergency Planning and Data Acquisition System (CEPADAS).

b.

Safety Parameter Display System (SPDS).

Due to the existing stage of construction, the unavailability of SPDS will not be considered as meeting Unusual Event criteria.

(EP-1-001, Unusual Event, EAL #3.)

c.

Radiation Monitoring System (RMS).

d.

Post Accident Sampling System (PASS).

Backup methods will be utilized for CEPADAS and SPDS.

For drill purposes the RMS must always be simulated.

PASS will also be simulated.

l III-3 L

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 B.

Safety Precautions 1.

valves, breakers and controls shall not be manipulated in response to this drill.

2.

Portable fire extinguishers or other sealed canisters or equipment shall not have the seals broken or safety pins removed.

3.

Specific precautionary notes have been given in the body of the scenario.

C.-

Drill Monitor and Observer Instructions 1.

Monitors shall follow the specific guidance given in the Monitor Guide,Section VI, Part II.

D.

Performance Evaluation Standards To ensure validity of the evaluation, all Drill Monitors must utilize the same grading criteria.

The following grading standards should be utilized:

Recording Times of Actions For calculating elapsed times, evaluators will be given the actual time the drill is initiated.

This will be T = 0 on all reports.

All elapsed time calculations will be based on this time regardless of when the separate evalauted activities are initiated.

An emergency center will be deemed to be in service when its personnel accountability check is completed and reported or when the center has sufficient manpower present to carry out its mission.

NOTE:

A formal announcement should be made.

Monitors shall use the forms provided during the course of the drill to take notes on the time and events.

It is intended to be used to complement the evaluation forms used to grade the exercise.

Grading Methodology The sequence below should be used by the Moni-tor to evaluate assigned areas pertaining to the emergency response.

A dual purpose will be served by this rating system.

First, the capability of each facility or response area will be evaluated.

Second, the system will provide a vehicle for guiding and directing improvement.

The rating scale is as follows:

1 III-4

WATERFORD-3 SES ANNUAL EXERCISE iaY 25, 1983 0.

Not Observed - Through no fault of the exercise.

\\

1.

Excellent - Personnel and equipment always performed without error the first time, every time.

There were no problems encountered and all personnel and equipment functioned at a level much greater than could reasonably be anticipated.

2.

Good - Personnel and equipment generally performed better than expected.

Any errors or problems were minor and easily correctable.

3.

Satisfactorv - Personnel and equipment performed according to expectations, with few minor exceptions.

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

4.

Poor - Personnel and equipment generally performed below expectations and there were several significant deficiencies noted.

The area's ability to carry out its functions was diminished.

5.

Failure - Personnel and equipment consistently failed to perform as required and there were serious deficiencies noted which severely impaired the ability of the area to carry out its functions.

Categories for Evaluation A number of areas have been designated for monitor evaluation.

Each monitor will be required to rate pertinent response actions in the following areas:

Activation and Response Communications / Dissemination of Information Procedures Direction and Control Material and Equipment Protective Measures Access Control III-5 u.

w m u m........ -

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 The drill itself is provided only as an aid to develop the integrated response capability of LP&L organizations to protect the public should an

" actual" event occur.

Thus, all Monitors / Observers should make necessary explanations as required to both participants and personnel witnessing this event, such that tney are not misled into believing that this Scenario was developed in anticipation of events such as those described within the Scenario.

The sole purpose of the Scenario is to aid in the continued development of a coordinated approach to Emergency Response.

l e

t l

[

ggy_g m m

m. m m an u

-nne,,

,,,mnnnen nnen nnn,,n n e e n, n nne m

9 WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 SECTION IV - NARRATIVE

SUMMARY

This exercise is provided to test the integrated response capability of the orgsnirations established to protect the public should an " actual" event occur.

As such, the plant sequence of 4

events in this exercise is not evidence of che possibility of such an actual event.

It is conceived on worst case or extremely unrealistic assumptions necessary to force degradation of support l

systems that would place the plant into an unstable condition.

In order to achieve a sequence.of events that will lead to a significant plant problem, the exercise scenario must contain an incredible plant situation, an unlikely series of equipment failures, or an improbable operator error combined with equipment failures.

Thus, off-site personnel (e.g.,

the public) should not be misled into believing that an event of this nature could occur based on the assumptions used to generate the events in this scenario.

The following is a summary of these events:

The plant is operating at 100% power with a.1 gpm primary to secondary leak in the #2 S/G.

B Containment Spray Pump is out of service and one HP Technician and Mechanic have been called in early to work on it.

During his on-the-job training period, a reactor operator trainee is given the task of starting the containment air removal system.

He inadvertantly selects " Purge" on the containment purge system initiating a containment purge.

The On-Shift NPO, when he discovers the error, has the trainee shutdown the system.

The purge exhaust valves fail to close and manual attempts to close the valves f ail.

The NOS-SS dispatches a Nuclear Auxiliary Operator (NAO) to investigate the cause and declares an Unusual Event, Tab D, EAL #7, due to a technical specification required shutdown because of a loss of containment integrity.

The time is approximately 0600.

A notification of the Unusual Event will simultaneously be transmitt*d to State and Local emergency preparedness organizations via the Operational Hotline.

Additional emergency personnel will be notified as per standard operating procedures.

At approximately 0700, a reactor trip occurs because of low flow in loop 2B.

Simultaineously, the trip alarm for 2B RCP, and motor overcurrent trip alarm for 23 RCP activate.

The Letdown Process Radiation Monitor activity levels increase.

The "A" Diesel Generator starts when the "A" Feeder breaker from the startup transformer malfunctions.

IV-1

.. ~

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 The NOS-SS classifies the event an Alert based on EP-1-001, Recognition and Classification, Tab C, EAL #3.

The Emergency Coordinator directs his Control Room staff to take action to mitigate the incident and directs the STA to begin failed fuel analysis.

The Emergency Coordinator directs the NAO appointed Emergency Communicator to begin making the required notifications to plant management, State, Local and Federal agencies.

The Emergency Communicator activates the Emergency Pager System to call in the Technical Support Center (TSC) and Operational Support Center (OSC) staffs.

The NOS-SS directs the On-Shif t Chemistry Technician to.take primary & secondary chemistry samples to determine the amount of f ailed fuel.

The TSC and OSC begin arriving and staffing their respective facilities (the time is approximately 0745).

Emergency Communicators transmit additional information to the State, Local and Federal agencies as it becomes available.

The TSC technical assessment staff continues to evaluate the extent of failed fuel and core damage.

At this time there is no radiation release.

At 0830, the Chemistry Technician reports the results of the primary and secondary samples.

The NOS-SS requests additional samples.

At 0845, sroke and heat alarms on "A" Diesel Generator activate.

The NOS-SS dispatches a NAO to verify the alarms.

The OSC dispatches a Fire Brigade Team to the fire.

The Diesel Generator shuts down.

The Emergency Coordinator declares a Site Area Emergency based on EP-1-001, Recognition and Classification, Tab E, EAL $1.

The Emergency Coordinator contacts the EOF Director and requests that the EOF be staffed to support the on-site emergency organization.

The Emergency Communicator notifies the State, Local and Federal agencies of the changing plant status and degrading plant conditions.

The protected area is simulated as being evacuated of all non-essential personnel.

The non-essential designated PAD personnel assemble in the parking lots and await further instructions.

The plant security force performs accountability in accordance with PS-16-103 and EP-2-190.

Due to the construction force present, this evacuation will be limited to a select group of (PAD Holders) administrative staff members in the Administration Building.

At this time, traffic control points will be set up and manned.

Access will be limited to the affected area.

i Preparations for possible escalation of emergency status will I

be undertaken should the situation degrade.

IV-2

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 The EOF is staffed and the TSC begins transferring the appropriate responsibilities from the TSC to the EOF (the time is approximately 0945).

At about 1045, Safety Injection occurs.

Pressurizer pressure is rapidly decreasing, containment pressure is increasing and containment airborne radiation monitors alarm.

CIAS and MSIS A large scale release occura at this time.

The occur.

Emergency Coordinator declares a General Energency based on EP-1-001, Recognition and Classification, Tab D, EAL #1.

The Emergency Communicator notifies the State, Local and Federal agencies of the changing plant status.

The OSC dispatches Field Monitoring Teams.

The EOF commences dose assessment and makes protective action recommendations.

At 1300, a weather front moves through and the wind changes toward Norco and Bahnville.

The release, continues, dose assessment activities continue and efforts to terminate the release are on-going.

A member of the OSC repair team falls in a contaminated area and is severely injured.. The OSC dispatches a first aid team.

The EOF makes off-site notifications for medical assistance using West Jefferson Hospital and Aircare Helocopter Service.

At 1500, the OSC recair team repairr the Containment Purge Exhaust Valve.

The release is termi.ated.

The EC declassifies to a Site Area Emergcoc! based on EP-1-001.

At 1530, the OSC repair team repairs Lt.7 feeder ireaker from the startup transformer.

This restores nermal At cower and the EC declassifies to an Alert based on EP.'-001.

Field monitoring teams begin to send back repot s of decreasing off-site radiation.

The emergency matagemest team evaluates the changing plant situation and initiat.s recovery actions.

The exercise is terminated at approximately 1700.

l IV-3

i

}

f WATERFORD-3 SES ANNUAL EXtRCISE MAY 25, 1983 SEQUENCE OF EVENTS The Waterford-3 SES is under construction, the following conditions are simulated for the purposes of this exercise.

The plant has been operating at power continuously for the past 300 days and is presently operating at 100% power with no restrictions.

A slight primary to secondary leak in #1 Steam Generator has been experienced over the past several days.

The leak has been determined to be approximately 0.1 gpm and is constant.

"B" Containment Spray Pump is out of service with two mechanics currently working on the pump.

The weather forcast indicates steady southeasterly winds during the early morning hours with a shift to westerly with the passing of a cold front during mid-day.

TIME OF DAY ON-SITE SCENARIO EVENT 0600 The participating shift personnel are given the T=0:00 guidelines and briefed of the initial plant CC-1 conditions.

CC-2 An announcement is made by the NOS-SS informing the station that an emergency preparedness exercise is beginning.

EVENT 0605 A Reactor Operator trainee inadvertantly starts the T=0:05 Containment Purge System.

When attempts are made to CC-3 secure the system, the purge exhaust valves fail to l

close.

Additional attempts to close the valve also l

fail.

ANTICIPATED RESPONSE Upon determining that the purge exhaust valves will not close, the NOS-SS declares an Unusual Event l

based on EP-1-001, Recognition and Classification, Tab D, EAL #7.

The NOS-SS implements EP-1-010, Unusual Event, and assumes the role of the Emergency Coordinator (EC).

i The Plant Manager - Nuclear is notified, the station alarm is sounded and the emergency classification announcement is made to the station.

The emergency on-shift organization is activated.

Meaak V-1

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 EP-2-010, Notifications and Communications, is implemented and initial notifications are made to the State, Local and Federal agencies.

The EC dispatches a NAO to the purge valve to investigate the reason for its failure to close.

EVENT CC-4 Upon arrival at the purge valve, the NAO attempts to manually shut the valve.

While doing so, the valve is damaged preventing all attempts to close it at this time.

ANTICIPATED RESPONSE The EC may call in maintenance personnel to attempt to repair the valve before a technical specification shutdown is required.

EVENT 0700 A reactor trip occurs due to low flow in loop 2B.,

T=l:00 Indications of a reactor coolant pump failure and CC-5 failed fuel are given.

The "A" Diesel Generator also starts supplying power to 3A3-S buss.

ANTICIPATED RESPONSE The EC reclassifies the event to an Alert based on EP-1-001, Recognition and Classification, Tab C, EAL

  1. 3 and implements EP-1-020, Alert.

The Emergency Communicator, following EP-2-010, l

Notifications and Communications, informs State, Local and Federal agencies of the reclassification.

i The emergency pager response system is activated and I

the On-Site Emergency Organization is mobilized at this point.

A NAO is dispatched to the switchgear room.

l l

The On-Shift Chemistry Technician is directed to take RCS samples.

I i

V-2 l

l 1

~

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 EVENT CC-6 The NAO discovers that the feeder breaker from the Startup Transformer has malfunctioned.

ANTICIPATED RESPONSE The NAO will report his findings to the Control Room.

EVENT CC-7 Upon initiating activities to take the sample from the normal RCS sample point, the area radiation monitor alarms.

ANTICIPATED RESPONSE The Chemistry Technician will secure the valve lineup and inform the Control Room.

He will request EP assistance and implement PASS procedures to draw the sample.

EVENT Upon arrival, the Emergency Coordinator will receive a briefing from the NOS-SS who has assumed the role and responsibilities of Emergency Coordinator.

As the TSC and OSC continue to activate the Emergency Coordinator keeps the staff informed of plant and equipment status.

Upon full functional capability of the TSC, the Emergency Coordinator will relieve the NOS-SS of the responsibilities of the Emergency Coordinator declaring the TSC activated and functional.

When the OSC has formed all of the required emergency teams, the OSC Supervisor will inform the TSC that the OSC is activated.

From this point the OSC emergency teams will provide initial response to medical and fire emergencies.

As the Operational Support Center becomes capable, Emergency Repair Teams will be briefed and dispatched to the feeder breaker and the Containment Purge Exhaust Valve.

i i

l I

E V-1

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 EVENT CC-8 Upon investigation at the Purge Exhaust valve, the OSC repair team will discover that replacement parts are required to repair the valve.

CC-9 Upon investigation at the feeder breaker, the OSC repair team will discover that replacement parts are required to repair the breaker.

ANTICIPATED RESPONSE Effective communications should be established and maintained between the OSC repair teams and the OSC.

The OSC should keep the TSC informed of any potential safety or radiological h.szards to the team and the prognosis for repair of the valve and breaker.

EVENT 0830 The Chemistry Technician reports the results of the T=2:30 RCS samples to the Control Room.

CC-10 ANTICIPATED RESPONSE The NOS-SS will request that the Chemistr-J Technician take additional RCS samples.

The TSC Technical Assessment staff will make detailed failed fuel and core damage calculations based on the chemistry results.

EVENT 0835 The NPO receives heat and smoke alarms from the "A"

T=2:35 Diesel Gere:rator room.

CC-ll ANTICIPATED RESPONSE The NOS-SS dispatches a NAO to investigate the alarms and informs the EC.

i 12...,4.

i ; ;

..;._.Ill "I"""^'n FROM PUBLIC DTCF'^"?..;

V-4

}

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 EVENT CC-12 The NAO discovers the "A" Diesel Generator room is engulfed in flames.

ANTICIPATED RESPONSE The NAO informs the Control Room of the fire.

The EC directs the OSC to dispatch a fire brigade team to the "A" Diesel Generator room.

NOTE:

Once the Diesel Generators have automatically started, they can only be shutdown from inside the room.

Because of the fire, this is not possible at this time.

EVENT 0845 The "A" Diesel Generator shuts down.

T=2:45 CC-13 ANTICIPATED RESPONSE The EC reclassifies the event to a Sito Area Emergency based on EP-1-001, Recognition and Classification, Tab E, EAL #1 and implements EP 030, Site Area Emergency.

The EOF Director is contacted and requested to activate the EOF.

The Emergency Communicator, following EP-2-010, Notifications and Communications, informs State, Local and Federal agencies of the reclassification.

The station alarm is sounded and a protected area esacuation is conducted in accordance with EP-2-070.

The winds are from the southwest and are passing over the assembly area.

The EC may direct the site evacuated based on the prevailing weather conditions and the prospect of worsening conditions.

Accountability is performed in accordance with EP 190, Personnel Accountability.

I EVENT 0910 The fire in "A" Diesel Generator room is out.

T=3:10 CC-14 ANTICIPATED RESPONSE l

l A reflash watch will be stationed and the OSC will assess the damage to the "A" Diesel Generator.

l l

6 V-5

C WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 NOTE:

The "A" Diesel Generator will be so severely damaged that it cannot be fixed for the remainder of the exercise.

EVENT Upen arrival, the EOF Director will receive a briefing from the Emergency Coordinator.

As the EOF continues to activate, the TSC staff will continue to keep them informed of plant and equipment status.

Upon full functional capability of the EOF, the EOF will accept responsibility for off-site communications, Dose Assessment and Protective Action Guideline recommendations.

EVENT 1045 Safety injection occurs.

Pressurizar pressure T=4:45 decreases rapidly, containment pressure increases CC-15 and containment airborne radiation monitors alarm.

CIAS and MSIS occur.

2B RCP shaf t seal pressure decreases.

A large scale release occurs at this time.

ANTICIPATED RE5PONSE The EC reclansifies the event to a General Emergency based on EP-1-001, Recognition and Classification, Tab D, EAL #1 and implements EP-1-040, General Emergency.

The Emergency Director is contacted and requested to activate the CCC.

The Emergency Communicator, following EF-2-010, Notifications and Communications, informs the State, Local and Federal agencies of the reclassification.

The station alarm is sounded and a site evacuation is performed in accordance with EP-2-071.

NOTE:

This may have been performed earlier at the EC's discretion.

EVENT l

1145 Plant personnel continue their actions to mitigate T=5:45 the accident and to assess failed fuel and core damage.

The off-site field teams track the plume and dose assessment continues.

00 220_'0:...;

- = =MM FRN DMa m e ";_,,5 v.6

I WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 EVENT 1200 Exercise players and observers will eat lunch T=6:00 between 1200 and 1300, however, the exercise will not be interrupted.

EVENT 1305 A strong moving weather front enters the area and T=7:05 the wind shifts towards Norco and Bahnville.

ANTICIPATED RESPONSE The EOF Dose Assessment personnel will steer the off-site field teams to continue tracking the plume.

EVENT 1330 A member of the Emergency Response Organization haa T=7:30 an accident resulting in a life threatening injury CC-16 and contamination.

Treatment at an off-site medical CC-17 facility will ce required.

ANTICIPATED RESPONSE The second member of the team will assess the injuries and provide details to the OSC and perform first responder first aid.

The second member of the team will, if qualified to do so, assess the injuries as life threatening and include this in his notification to the OSC.

The OSC will dispatch an Emergency First Aid Team to the scene.

Upon their assessment, if not already accomplished, the OSC will be notified that the injuries are life threatening.

Emergency transportation is summoned and the support medical facility notified.

EVENT 1500 The OSC repair team completes repairs to the T=9:00 Containment Purge Valve.

The release is terminated.

CC-18 ANTICIPATED RESPONSE The EC declassifies to a Site Area Emergency.

The Emergency Communicator, following EP-2-010, notifies State, Local and Federal agencies of the i

I declat:ification.

V-7

1 l

WATERFORD-3 SES ANNUAL EXERCISE MAY 25 1983 EVENT 1530 The OSC repair team completes repairs to the feeder T=9:30 breaker from the Startup Transformer.

Normal power CC-19 is restored to the 3A3-S buss.

ANTICIPATED RESPONSE The EC declassifies to an Alert.

The Emergency Communicator notifies State, Local and Federal agencies of the declassification.

EVENT The EOF Director and Emergency Coordinator assemble a recovery team based on EP-2-071, Recovery.

EVENT 1700 The exercise is terminated.

T=ll:00 e

l

{

l l

l V-8 40 m * ::^

."J.T _-.:..

-t ian a u c o m..

.. _ =

WATERF01D-3 SES ANNUAL EXERCISE HAY 25, 1983 TABLE I-l abbreviations Atmospheric Dump Valve ADV Corporate Command Center CCC Containment Isolation Activation Signal CIAS CEPADAS -

Computerized Emergency Planning and Data Acquisition System Departure from Nucleate Boiling Ratio DNBR Exclusion Area Boundary EAB Emergency Action Level EAL Emergency Coordinator EC Emergency Command Center ECC E=ergency Core Cooling System ECCS E=ergency Feedwater Actuation Signal EFAS Emergency Operations Center EOC

' Emergency Operations Facility EOF Federal hergency Management Agency FEMA Fixed Facility Response Team FFRT High Pressure Safety Injection HPSI Louisiana Nuclear Energy Divisida LNED Louisiana Office of Emergency Preparedness LOEP Louisiana Power & Light Company LP&L Low Pressure Safety Injection LPSI Main Steam Isolation Signal MSIS Main Steam Isolation Valve MSIV Nuclear Auxiliary Operator NAO Nuclear Operations Supervisor - Shift Supervisor NOS-SS 1^'""'

'?: nawsx1AL-nAwanvuv r.,vn ruouiu -

VII-l

WATERFORD-3 SES ANNUAL EXERCISE MAY 25, 1983 Nuclear Regulatory Commission NRC Operations Support Center OSC Radiation Monitoring System RMS S/G Steam Generator Safety Injection Actuation Signal SIAS Safety Injection System SIS Shift Technical Advisor STA Technical Support Center TSC Waterford 3 Steam Electric Station W3SES e

e l

1 VII-2 l

t e

4 State of Louisiana /St. Charles Parish /St. John the Baptist Parish OFF-SITE SEQUENCE OF EVENTS OFF-SITE SCENARIO May 25, 1983 Approx Planned Time Exercise Cue of Day Time Card 6:05 T+0:05 Unusual Event declared.

Off-site notifications made to St. Charles and St. John Sheriff dispatchers and to the LOEP duty officer.

l 6:10 T+0:10 Sheriff's dispatchers notify EP and CD Director in St. Charles and St.

John Parish respectively.

The LOEP Duty Officer notifies LNED.

7:00 T&l:00 St. Charles EP, St. John CD, LOEP and LNED notified of the declaration of Alert.

7:10 T+1:10 State and Parish cutrgency organizations initiate notifications as per procedures.

j 7:40 T+1:40 off-site emergency operations centers are activated.

Additional State and Parish notifications initiated as per appropriate procedures.

NOTE:

When Parish Media Centers are activated, releases to the media will be made as appropriate.

8:45 T+2:45 Site Area Emergency declared.

Off-site Emergency Response Organizations notified.

State and Parish Organizations initiate activities as per procedures.

l 8:50 T+2:50 Due to the close proximity of Killona Elementary School, evacuation of this school will be considered and may be i

simulated.

l

-w- - - -- - - - -,

,e---

,- m e,,

n. e-~

.-e,-w,--,,

-,,w~,,,,~.-w---

t Approx Planned Time Exercise Cue of Day Time Card In the event that any on-site evacuation should occur, industries in close proximity to the site will be notified in order that non-essential personnel can be sent home, if the individual industry chooses to do so.

10:45 T+4:45 off-site emergency response organizations receive notification of General Emergency declaration.

11:00 T+5:00 Information from W-3 is evaluated jointly by risk parishes and appropriate information is relayed to local radio station and to LOEP for EBS dissemination.

(Message is for general public to shelter in two mile radius of plant and 5 miles downwind at minimum).-

Access control is initiated. in all affected areas.

Sirens sounded in appropriate areas jointly by both parishes, accompanied by information disseminated by the i

media.

Based upon information received from W-3 and LNED, the 2ollowing l

activities should occurs a.

Access control initiated for j

affected areas.

b.

Evacuation of areas as indicated l

by dose projections and field sampling data.

c.

Activation of selected reception centers.

1:40 T+7:40 off-site authorites notified of injured, contaminated victim.

i l

Request from St. Charles EOC medical transport assistance.

1:50 T+7:50 West Jefferson Hospital apprised of victims condition.

a IM AGE EV ALU ATION

\\

!/

TEST T ARGET (MT-3 i

  • h&

s\\

7@

v o'

su s' k.

\\

/,,

g N.-

'c; i

]i, ___

l.0

!.l m

I.25

1. 4 i 50mm 4

/>

,\\

gig s

..x s

<nlir T

i Approx Planned Time Exercise Cue of Day Time Card 2:20 T+8:20- Ambulance arrives and is aided by security to obtain access to the location of the victim.

Health Physics personnel support ambulance service personnel and hospital personnel.

2:50 T+8:50 Ambulance arrives at the hospital with the injured victim.

Medical treatment is provided by the hospital staff.

3:00 T+9:00 Off-site agencies notified that emergency has been downgraded to Site Area Emergency.

3:30 T+9:30 Downgrade to Alert.

Reentry and Recovery efforts should be initiated at or near this time.

This effort should continue for no more than 1 1/2 hours.

t i

k 1

-s r.

-u..s!

' M4 l.OUISIAA1A iemmassen$

P O W E A & L I G H T/ INTE A-OFFICE CO A A ESPONOENCE MtOOLE SCUN NES SYSTEM February 13, 1984 W3AS4-0008 To: All Shift Supervisors and Licensed Cperators THROUG3:

L.F. Storz O.D. Hayes TRCM:

R.P. Barkhurst SC3JIO"':

Emergency Classification and Initial Notificatien iring the course of the ongoing emergency appraisal by the NRC, discussions with scoe of our supervisors in Cperations have apparently indicated the lack of understanding as to how to utilize our procedures on Emergency Classification and Nctification. Some personnel have given the NRC the impression that if the steps in procedure, EP-1-030, for example, say to classify an emergency, call the Outy Plant Manager and nctify the off-site agencies, that this means they are not to call the Plant Manager before they classify the emergency and that they are not to call the off-site agencies and. notify them until they have called the Cuty Plant Manager. Neither of these assu=ptions are true. We write cur procedures with the steps in the order in which they are nor= ally and routinely carried out.

Per this philosophy, these procedural steps are not required to be performed in the exact crder in which they are laid out under all circumstances. It is to be our philosophy that procedures should be written with the steps in the usual and routine order and that these steps need not be performed exactly in that order unless there are circumstances which definitely require this. In procedures where circumstances dictate that steps shculd always be performed in the exact order listed, our procedures will state this.

Unless we do this, there would never be roca for judgement in performing important steps of all of our procedures.

All Shift Supervisors and Senior Reactor Cperators should understand that time permitting, they would be expected to call the Outy Plant Manager and discuss the developing proble with him.

Should a clear cut event occur which requires 1:=ediate classification, then classification would take place before anyone eff-site was called.

Similarly, prier : making notification to off-site agencies, it is desirable that the Shift Supervisce call the Outy Plant Manager a ' ' '- kis of the circu=s ances.

fe/A-ff-204 6 3y

s Shift Supervisors Li:ensed Operators Page 2 ebrcary 13, 1964 If :=pleting such a call is cbviously going to take enough ti=e that notification to off-site agencies would he hampered, then notification to Off-site agencies will be made by the Shift Supervisor (E=ergency C0erdinator) without centacting the Cuty Plant Manager.

In s'--= y, we have succeeded in staffing this plant with a goed nu=ber of qualified capable =anagement and supervisory personnel. We have confidence in the Judge =ent of these persennel and their ability to use this Judgement in erder to -.ake the best decisiens possible and =ake notifications and other eff-site actions within the ti=e allotted. Our procedures are not intentionally written to preclude the valuable advice and censultation of experienced manage-i

=ent personnel with Shift N arvisers when proble=s occur.

I k

l l

On the Other hand, should tc.nro not be time for such advice and censultations then the Shift Supervisor :.s never to be in a position where he is relieved of his responsibility of =aking the classification and not:.fication within 15 rinute i'-4 ts prescribed.

I 1

l e

y y N

}i.' ~.h r.u \\

R.P. Barbarst RPS:agh

Gr:up & Cepar ent Heads R.S. Laddick P. Backes

-