ML20202A707
| ML20202A707 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 11/24/1997 |
| From: | Modes M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20199M090 | List: |
| References | |
| 50-245-97-81, 50-336-97-81, 50-423-97-81, NUDOCS 9712020199 | |
| Download: ML20202A707 (38) | |
See also: IR 05000245/1997081
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U. S. NUCLEAR REGULATORY COMMISSION
REGION 1
Report Nos. 50 245,336,423/97-81-
License Nos. DRP-21, DRP-65, NPF-49
Licensee: Northeast Nuclear Energy Company
P. O. Box 128
Waterford, Connecticut 06385-0128
Facility: Millstone Nuclear Power Station
Dates: August 20 through September 8,1997
Inspectors: John H. Lusher, Lead, Emergency Preparedness Specialist, RI
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William A. Maier, Emergency Preparedness Specialist, RI
Daniel M. Barss, Emergency Preparedness Specialist, NRR/PERB
Edwin E. Fox, Jr., Sr. Emergency Preparedness Specialist, NRR/PERB
David M. Schultz, COMEX
Gary W. Bethko, COMEX
Approved by: Michael C. Modes, Chief
Emergency Preparedness and Safeguards Branch
Division of Reactor Safety
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9712O20199 971124
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TABLE OF CONTENTS
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PAGE
EXE CUTIV E SU M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii
R E PO RT D ET AI LS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
P4 Staf f Knowledge and Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
EMERGENCY PREPAREDNESS PROGRAM REVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
P1 Conduct of EP Activitic s ....................................11
P1.1 Emergency Detection and Classification . . . . . . . . . . . . . . . . . . 11
P1.2 Notifications and Communications . . . . . . . . . . . . . . . . . . . . . 12
P1.3 Protective Action Decision Making . . . . . . . . . . . . . . . . . . . . . . 12
P1.4 Dose Calculations and Assessment . . . . . . . . . . . . . . . . . . . . . 13
P2 Status of EP Facilities, Equipment, and Resources .................. 16
P3 EP Procedures and Documentation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
P5 Staf f Training and Qualification in EP ...........................25
P7 Quality Assurance in E P Activities .............................28
MANAGEMENT MEETINGS . . . . . . ......................................29
X 1 E xit M e e ti ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 9
PARTI AL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30
INSPECTION PROCEDURES USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
ITEMS OPENS AND CLOSED ...........................................31
LIST O F ACRO NYMS U SED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .... ....... 32
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EXECUTIVE SUMMARY
MILLSTONE NUCLEAR POWER STATION
Full p:rticipation Emergency Preparedness Exercise Evaluation
August 20 through September 8,1997
Inspection Report 50-245,336,423/97 81
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EMERGENCY PREPAREDNESS EXERCISE
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- Overall the licensee site emergency response organization (SERO) performance -
was good,
- No exercise weaknesses were identified,
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- Good command and control were demonstrated in all ernergency response >
facilities,
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- Communications within and between facilitie:, and with the State of
Connecticut were good.
- The licensee adequately demonstrated its ability to implement the emergency
plan However, during the exercise a concern was identified that the Unit 1
emergency action levels CNB4 aad CNBS as phrased could cause a possible over
classification of emergency events from a Site Area emergency to a General
Emergency.
EMERGENCY PREPAREDNESS PROGRAM INSPECTION
I During the emergency preparedness program inspection for restart the inspectors identified
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activities which apparently were not conducted in accordance with your license
requirements Problems included:
- (1) Instances of failure to maintain emergency response facilities in accordance
with the emergency plan.
- (2) Failure to provide adequate dose assessment training procedures suffi:ient to
assure that personnel could perform radiological dose assessment activities in
- the timely manner,
. * (3) Emergency Plan Revision 22, implemented in June 1997, decreased the --
effectiveness of the emergency plan and that pian revision was implemented
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without receiving the required prior approval by the NRC,
- Additionally, the NRC team was concerned that these discrepancies were not
- identified at Millstone Station by the required audit program.
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- An additional concern of the NRC team was that the audit conducted did not
appear to include all elements of 10CFR50.54(t)such as evaluation for
adequacy of emergency preparedness program cacabilities and procedures.
Although your emergency response personnel, facilities and equipment, self assessment,
and the corrective actions, implementeo at Millstone as a consequence of the Haddam
Neck exercise problems, adequately demonstrate the ability to implement your emergency
plan during the exercise, the review of the emergency preparedness program indicates
that some elements do not support restart.
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REPORT DETAILS
EMERGENCY PREPAREDNESS EXERCISE
P4 Staff Knowledge and Performance
a. Exercise Evaluation Scopa
The NRC inspectors evaluated the performance of the licensee's emergency
response organization (ERO) during the biennial, full-participation exercise. The
inspectors assessed various aspects of emergency response, including
recognition of abnormal plant conditions, classification of emergency conditions,
and notification of of fsite agencies. The inspectors evaluated the licensee's self-
assessment of the exercise,
b. Emeroency Resp _gnse Facility Observations and Critioue i
b.1 Simulator Control Room (SCR)
The control room crew promptly initiated accountability procedures for the Plant
Equipment Operator (PEO) at the scene of the emergency diesel room fire,
concluding that search and rescue was not required. The crew conservatively
requested fire and ambulance support from offsite in the event conditions ,
worsened.
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The Shift Manager (SM), af ter consultation with the Shift Technical Advisor
(STA), promptly and properly recognized the adverse effect of the diesel
generator fire on safety functions and correctly classified the event as an Alert
within four minutes of event notification.
The Shift Technician (communicator) and Station Duty Officer promptly
integrated their efforts into the control room crew structure, and effectively
relieved the Shift Manager of many administrative details such as notifications
and tracking of health physics and chemistry technicians dispatched by the SM
l into the plant, while keeping the SM appropriately informed as activities were
accomplished. As a consequence, correct notifications for the Alert were
initiated ten minutes after classification for local authorities and to the NRC
within thirty minutes.
The SM properly implemented EPOP 4411," Dire for of Station Emergency
Operations (Rev 5,5/5/97)," utilizing the procedure as a checklist for
accomplishing required activities. The sequence prescribed by the procedure
resulted in the SM not ordering the station public address system announcement
concerning EDG fire location, classification, and ERO activation until eighteen
minutes after the event initiation. ONP 505, Fire (Rev. 4,1/1/97), specifically
requires the CR Operator to make a plant page announcement concerning the
fire location and activation of the Fire Brigade, but the page announcement was
not made due to controller-indr 'd, exercise artificialities. A public address
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system announcement to warn emergency response personnel was not made at
1310; when the CR staff became aware of the radiological release to the
environs. As a consequence, ERO members may not have been aware of
adverse changing plant conditions in a timely manner.
The Unit Supervisor and SM performed frequent briefings for CR crew members
as occasioned by changes in plant conditions that kept all membess of the CR
response team fully aware of plant status and significant response actions. The
CR crew demonstrated a strict discipline of closed loop communications for
reports and orders. Control room protocol maintained a noise-free environment.
b.2 Technical Support Center (TSC)
The TSC was activated exactly one half hour after the Site Emergency Response
Organization (SERO) pager activation. The additional team responders assigned
to the unaffected units quickly assumed support roles that enhanced the
response. Assigned responsibilities of all responders were unambiguous, and
the team performed well together. There was adequate staff present to conduct
all the tasks prescribed by the emergency plan.
The ADTS made two decisions without adequately assessing the consequences
of the decisions. In one case, he ordered the relocation of the OSC assembly 4
area personnel to the refueling outage building (ROB) without assessing the
radiological conditions of the destination. The radiation levels at the ROB were
greater than the area the personnel were being evacuated from. The ADTS
discovered this from his discussion with the Director of Station Emergency
Operations. The evacuees learned this from a returning radiation monitoring
team, and the evacuation was redirected to a safer location.
In another case, the ADTS ordered the stopping of the main stack exhaust fan
af ter the pressurized drywell was vented via the main ventilation exhaust duct.
The eccident management team leader (AMTL) reported in an earlier briefing that
the vent ducting, having been pressurized, may have exceeded its design
pressure and had been breached. The AMTL mentioned that this cor.dition could
result in an unmonitored ground release. The ADTS ordered the exhaust fan
stopped without considering the effects of this action on increasing the potential
unmonitored release rate through such a breach in the vent duct. He did not
coordinate his intended action with the radiological consequence or dose -
assessment personnelin the EOF to allow for their increased surveillance of any
possible ground releases resulting from this action.
General Emeraency (GE) Classification
The ADTS made two classifications during the exercise. He classified events
i using input from the Manager of Control Room Operations (MCRO) and the
Senior Reactor Operator (SRO) phone talker in the TSC. The ADTS classified the
i Site Area Emergency condition quickly and accurately. He classified a GE
I condition shortly after the loss of reactor coolant accident (LOCA) occurred, but
the basis for the classification was erroneous.
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The ADTS classified the GE based on the loss of all three fission product
barriers, although the primary containment barrier was stillintact. The Director
of Site Emergency Operations (DSEO) in the EOF questioned this classification,
and the ADTS later modified his basis for the GE declaration. The GE
classification was not changed because, in the judgement of the ADTS, the
containment barrier was potentially lost.
Emergency action level (EAL) CNB5 permits this judgement classification if
conditions, such as, area radiation monitor readings in alarm or offscale high are
present. Reactor building radiation monitors were allin alarm after the LOCA
occurred. The ADTS concluded, based on this determination, that plant
conditions resulted in the loss of two of the three fission product barriers with a
potentialloss of the third barrier. These conditions satisfied the criteria for a GE
declaration.
The updated GE classification, while satisfying the EAL requirements of the
barrier failure reference table, was stillincorrect since the containment barrier
was not degraded due to release of radioactive material from the containment.
The inspectors concluded that inadequate procedures were the cause of the
ADTS making an inappropriate classification.
EAL CNB5, in EPlP 4400, " Event Assessment, Classification and Reportability,".
allows the classifying official to conclude that the containment barrier is lost or
potentially lost based on certain plant conditions which may exist. One such
condition, as mentioned before, is area radiation monitor alarms or offscale high .
readings. During the exercise, these conditions existed in the reactor building
following the release of radioactive material to the drywell, but the radiation
levels resulted from the radioactive materialinventory that was being contained -
in the drywell, not from a release of radioactive material, in such a case, no loss
or potentialloss of the containment barrier existed although the ADTS concluded
otherwise from the EAL.
This problem also exists with EAL CNB4, which recognizes a Icss of the
containment barrier from unisolable primary system leakage outside the drywell.
This EAL also lists area radiation monitor alarms as an indication of the
condition. Although this EAL closely follows the guidance given in the NRC-
accepted generic EAL guidance upon which EAL CNB4 is based, applying this-
EAL in such conditions as existed during the exercise would erroneously give
indications of a loss of all three barriers when, in fact, only two barriers were
lost.
The inspector discussed the expec(ed reactor building radiation readings with
the licensee's Radiological Assessment Branch management, who informed them
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that the radiation readings simulated in the exercise would be expected for the
level of cote damage simulated in the exercise (approximately 5% of the fuel
gap activity). EALs CNB4 and CNB5, as currently worded, could result in
overclassification of an event in which the RCS barrier was lost with a moderate
amount of core damage even with the containment barrier intact. The potential
overclassification of events associated with EALs CNB4 and CNB5 is classified
as an inspector follow item. (IFl 50-245,336,423/97-81-01)
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b.3 Operations Supoort Center (OSC)
The OSC was staffed and activated within 22 minutes of the Alert declaration
by the necessary positions for minimum staffing. Shortly thereafter, additional
personnel reported to the f acility so that full staffing level was accomplished.
Early in the exercise a determination was made to relocate the OSC Assembly
area to the Refuel Outage Building (ROB)if dose rates in the OSC-Assembly area
caused habitability problems. The OSC Assembly Area Supervisor received
conflicting information when the time came to relocate. Better evaluation and
coordination between facilities of available information was needed. Dose rate
information available in the EOF indicated the ROB was not acceptable as a
relocation point due to high radiation levels. The relocation was initiated
without regard to the dose rate information available in the EOF. In route to the
ROB, the OSC staff encountered a repair team returning from a job assignment
which informed the OSC staff of unacceptable dose rates in the area they were
moving to. Subsequent communications with the OSC resolved the issue and
relocated personnel were correctly directed to a low dose rate area and
eventually moved to the EOF.
Some procedures and EP user guides were beyond the two year review period.
EPIP 4405, " Response to Personnel Injures," was past the review date and -
identified with a "Do Not Use Page." Procedure EPOP 4413, Revision 1,
" Potassium lodine Tablet Control and Use" was past the review date but was
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not identified with a "Do Not Use Sheet." The evaluators also identified two -
different revisions of the Onsite Field Monitoring Map, and a 9/88 dated revision
of the Millstone Onsite Monitoring Points listing in an emergency equipment
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cabinet.
Dosimetry supplies, TLDs and finger rings, are maintained in the emergency
cabinets, However, no control TLD or finger ring was identified to be stored
with or in the adjacent area. Respirators stored in the equipment lockers were
labeled with a sticker that read "(mask #) has been approved for use (date)."
When questioned, neither controllers nor players were able to provide an answer
to how long the respirators were good for to be issued, or where control
dosimeters could be found.
Overall, the response actions of the OSC staff successfully demonstrated the
licensees ability to staff the OSC and form, dispatch, control and account for
multiple field repair teams to take actions inplant to mitigate emergency
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- situations. Minor focility supply concerns and out of date procedure copies
detracted from an otherwise good demonstration of emergency response
capabilities.
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b.4 Ememency Operations Facility (EOF)
The EOF was minimally staffed 38 minutes af ter the Alert declaration and
declared fully operational 7 minutes later. With the transfer of DSEO EOF
functions 2 minutes later. EOF SERO personnel appropriately established
communication with their respective counterparts. Personnel used procedures
throughout the exercise and maintained status boards as data was received and
as new or updated information was provided or obtained. During the activation
of the EOF, the assigned DSEO was relieved by the affected unit DSEO;
however, the relieved DSEO remained in the EOF as the back up DSEO. The -
DSEO exhibited very good command and control throughout the entire exercise.
Timely briefings were conducted and personnelin the EOF were kept informed
of changing plant conditions as they occurred and the DSEO was informed.
There was a very good turnover between the DSEO at the EOF and the Control
Room DSEO.
Security was promptly provided at the EOF to control access. The DSEO
considered additional security issues throughout the exercise. At the Alert, the
Manager of Security (MOS) was requested to determine if the emergency diesel
had been sabotaged. The MOS provided a timely assessment which concluded
that the damage had not resulted from sabotage. Additionally, in planning for the
evacuation of non-essential personnel from the site, the DSEO and MOS
effectively coordinated the egress of personnelleaving the site prior to the
evacuation being ordered.
Personnel used procedures throughout the exercise and status boards were
adequately maintained and updated. However, Controlled Copy 126, " Director
Station Emergency Operations EOF /EOC," had not been updated to include
Change Number 23. Additionally, it contained both Revision 21 and Revision 22
to Appendix D, " Supporting Procedures List." Following the exercise, it was
noted that Administrative Control Procedures, ACP 8.02, " Fire Fighting Training
Program," which is identified in Appendix D as a supporting procedure, is now a
Nuclear Training Procedure, NTN-7.207," Millstone Site Fire Protection Training
Program."
Although Protective Action Recommendations (PARS) were provided in a timely
manner, there was confusion regarding the basis for the General Emergency (GE)
declaration The Assistant Director Technical Support (ADTS), located in the
TSC/OSC, indicated that the GE was based on the loss of all three fission
barriers at 1249 hours0.0145 days <br />0.347 hours <br />0.00207 weeks <br />4.752445e-4 months <br />. The TechnicalInformation Coordinator, located in the
EOF, demonstrated an excellent working knowledge of the Emergency Action
Levels by reviewing and indicating to the DSEO that plant conditions, at that
time, did not support the loss of all three barriers. The ADTS re-evaluated tne
classification and changed the basis to loss of 2 barriers with the potentialloss
of the third. The GE classification remained appropriate, however, this delayed
the development of PARS, which were subsequently issued at 1303 hours0.0151 days <br />0.362 hours <br />0.00215 weeks <br />4.957915e-4 months <br />.
Shortly thereafter, the third barrier was loss and revised PARS were provided at
1312 hours0.0152 days <br />0.364 hours <br />0.00217 weeks <br />4.99216e-4 months <br />.
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Dose Assessment .
The EOF Radiological Dose Assessment Team (RDAT) members demonstrated
good teamwork throughout the exercise. The RDAT ioutinely discussed ,
potential release pathways as plant conditions deteriorated. They carefully
tracked Radiological Monitoring Team (RMT) past and current doses, and took .
early action to extend administrative limits and to invoke higher legal exposure
limits for activities in progress.
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The Radiological Assessment Engineer (RAE), who is operator of the Accident -
Dose Assessment Model (ADAM) computer, was very fast and efficient in
performing his duties of calculating source term, performing dose projections,
and correcting projections based upon field menitoring data. ADAM system
printer output speed became the limiting factor in his generation of updated dose
projections. -
The EOF Radiological Dose Assessment Team (RDAT) had difficulty obtaining
accurate plant system status upon which to base radiological release
assumptions (e.g., heating ventilation and air conditioning (HVAC) damper
status, HVAC f an operating status, Containment pressure, reactor building and
l turbine building ares radiation monitor readings, and plant drawings depicting the
release pathway). Accurate plant system status was not available in the -
emergency operations center area of the EOF. Better liaison with the TSC
and/or the CR m the icture should provide the necessary plant system
information and status.
RDAT personnel did not have the systerbs knowledge, or the benefit of a
technical advisor to help them understand that the Standby Gas Treatment
System (SBGTS) operational status (i.e., on/off) would have had neglig'ble effect
on the filtration of the release simulated. RDAT personnel should receive
refresher training on the major plant systems in release pathways.
The use of the term TEDE (Total Effective Dose Equivalent), by RDAT members,
as an hourly number, and the use of a TEDE to DDE (Deep Dose Equivalent) ratio
terminology, rather than just computing and discussing TEDE as defined in EPA-
400 and 10 CFR 20, created unnecessary confusion.
The overall performance of the EOF Radiological Dose Assessment Team
(RDAT), under the direction of the Manager of Radiological Dose Assessment
(MRDA), was good. This positive statement is within the context of the teams'
use of their existing procedures and equipment, and the scenario data presented.
Mathematical, terminology, and underlying assumption errors and questions in
the dose assessment procedures and computer codes are summarized separately '
in the appraisal section of the report.
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b.5 Scenario and Exerciss Control
' Some exercise scenario radiological and meteorological data was either lacking
- or not representative of the accident sequence simulated. Examples include: No a
detailed meteorological forecast data was provided; all radiological isopleth plots
were in disagreement with the tabular radiological monitoring point (RMP) date
by as much as a factor of 10, thus rendering the isopleth plots unusable by the
RMT controllers; main steam line monitor data was erroneously reduced to
10 mr/hr, for the remainder of the exercise, following the anticipated transient-
without scram (ATWS) event (i.e., no accounting for direct shine from
containment); no data scatter was introduced for instruments having two
channels (e.g., Containment high range monitors); and, in plant radiological data
was " prompt jumped" to maximum levels at the very outset of the LOCA event,
and then reduced throughout the remainder of the scenario timeline (i.e., the i
radiological data was increased prior to any core uncovery, fuel gap release, or
release of significant inventory from the reactor vessel to containment).
b.6 Licensee Interface at State Emeroency Operations Center (SEOC)
Following the declaration of the Alet, the Northeast Utilities (NU) Executive
Spokesperson (ES) and supporting NU representatives arrived at the State EOC
at about 1030. The ES oversees the actions of all NU representatives at the -
SEOC including the Nuclear News Manage:*and staff. The ES immediately
established communications and began getting information on the plant status
and conditions by speaker phone from the DSEO in the EOF as well as from the
NU Technical Assistant (TA)in the SEOC via the OFiS.
The ES interacted very effectively with the State emergency response
o 9anization (ERO) staff, in particular the Office of Emergency Management
(OEM) and Department of Environmental Protection (DEP) Directors. The ES
presented information on plant status and protective action recommendations in
a clear and confident manner at SEOC staff meetings, briefings of the mock
Governor, and at Joint Media Center (JMC) briefings. The State decision makers
relied to a great extent on the information provided by the ES in developing their
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understanding of the situation and in determining protective actions.
The SEOC was informed that a GE - Alpha had been declared as of 1249 based
on tha loss of three fission product (FP) barriers. Because of questions which
arose in the SEOC concerning why there was no apparent radiation release with
the loss of three FP barriers, the ES and staff attempted to verify the status of
the FP barriert. Information was received from the EOF at 1304 that the GE
was classified based on the loss of two FP barriers and the potentialloss of the
third barrier, the containment. The Assistant DSEO also informed the ES that
the protective action recommendation (PAR) was still being developed. (Note:
The licensee allows 15 minutes to develop a PAR following the declaration of a
GE.) At 1306 a PAR was received to evacuate all communities in Zones 1 and 2
and to shelter Zone 3. (Evacuating all communities in Zones 1 and 2 is
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equivalent to' evacuating a 5 mile radius.) Based on this information, the ES
briefed the Governor that a GE - Alpha had occurred based on the loss of two FP
barriers and potentialloss of the third, and that the NU PAR was to evacuate a
5 mile radius and shelter 5 to 10 miles. The State DEP concurred in the PAR. At ,
1316 the Governor authorized the emergency alert message (EAS) to be issued
informing the public of the protective action decision. (The Governor's
authorization to issue the EAS message is the initiation of the 15 minute
- notification requirement, as evaluated by FEMA.)
At 1316 information was received in the SEOC that the licensee was revising
the PAR, that additional communities in the downwind direction between 5 and
10 miles (East Lyme, Old Lyme, and Lyme) were being included in the
evacuation PAR. The ES received information from the EOF that the PAR had
been revised because the third FP barrier had been lost. Based on the revised
licensee PAR, the State decided to revise its PAR to evacuate all of Zone 3, the .
5 to 10 mile radius, despite the concern that revising the PAR in such a short
time would cause a loss of credibility with the public. (The Governor's Press
Secretary felt that this would not be a loss of credibility problem because the
State was reacting to changing plant conditions.) At 1329, the Governor
authorized the EAS message to be issued informing the public of the change in
protect're actions.
Another information issue at the SEOC concerned the radioactive material
release pathway. The ES received conflicting information from the EOF
concerning whether the release was filtered or unfiltered. As a result, the SEOC
staff considered the release to be filtered in their dose calculations and in their
decision-making, in particular, in the decision concerning potassium iodide for
emergency workers. The EOF also did not provide meteorological forecast
information in response to requests f4um the DEP staff in the SEOC.
The NU Director of Corporate Communications, who is in training to fulfill the ES
position, provided critical assistance to the ES especially during periods of
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rapidly changing plant conditions. The E3 assistant or deputy position is not
identified in the ES procedure, NUC EPOP 44558, Rev.1.
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The ES performed very wellin concisely summarizing the plant conditions and
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responding to questions in briefings at the Joint Media Center (JMC). However,
the visual aids available to the ES in the JMC could be improved to assist in the
presentation.
The ES also reviewed and concurred in the NU news releases before they were
issued. Six news releases were issued during the course of the exercise. The
inspectors noted that none of the news releases contained protective action
information. While it is understood that the issuance of protective action
information to the public is the responsibility of the State of Connect l cut, it
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would be helpfulif the NU news releases contained a referenco to the State of
Connecticut releases for protective action information.
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The overall performance of the ES in the SEOC and JMC was very good. The
ES effectively interacted with the SEOC decision making staff and provided
invaluable information and support which enhanced the performance of the
SEOC staff.
b.7 Licensee Exercise Critiaue
The licensee's critique was very comprehensive and identified all of the
concerns identified by the NRC inspection team,
c. Overall Exercise Conclusions
Overall the licensee site emergency response organization (SERO) performance
was good. No exercise weaknesses were identified. Good command and
control was oemonstrated in all emergency response facilities. Communications
within and between facilities, and with the State of Connecticut were good.
The licensee adequately demonstrated its ability to implement the emergency
plan.
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EMERGENCY PREPAREDNESS PROGRAM REVIEW
An inspection of the emergency preparedness program was conducted during the period of
August 25- 29,1997.
The inspection team utilized the guidance of Inspection Procedure 82206," Knowledge and
Performance of Duties (Training)," in conducting interviews and scenario (tabletop)
walkthroughc to determine whether emergency response personnel understand and can,
perform their assigned functions. Functions focused on during this inspection included:
- emergency detection and classification cccording to Emergency Action Level
(EAL) schemes for plant emergency conditions;
- notifications and communications with on site personnel and off site .
authorities;
- on-shift dose calculations and assessment; and
- formulation of on-site protective actions and off site protectiva action
recommendations (PARS).
The scope of the walkthroughs included five of six control room (CR) crews from Millstone-
Point Unit 3 (MP3), and two management groups of the Emergency Operations Facility '
' (EOF) and Technical Support Center (TSC) Staff. The CR crew " staff" consisted of the
Shift Manager (SM), the Shift Technician (ST) performing communications, and the
Chemistry Technician (CT) performing on-shift dose assessment. Absent were the Unit .
Supervisor (US) and the Shift Technical Advisor (STA) who would normally provide
recommendations concerning classification to the SM. All table top interviews were
performed in the EOF due to simulator use and control room activity.
The management groups ware members of the Site Emergency Response Organization
(SERO) that would be activated by the SM in event of an Alert classification or higher. For
the table tops, the groups consisted of the Director of Site Emergency Operations (DSEO)
and Assistant Director Emergency Operations Facility (ADEOF) normally stationed in the
EOF, the Assistant Director Technical Support (ADTS) normally stationed in the TSC, and
the EOF Shift Technician (communicator). The Millstone site Emergency Plan and
implementing procedures require the ADTS to relieve the SM of classification
responsibilities after SERO activation.
Scenarios for each of the seven groups interviewed were selected from a pool of ten
licensee-prepared scenarios, Two scenarios were presented to each group by licensee
personnel representing disciplines of operations and radiologica; assessment; plant specific
conditions and parameters not included in the written portions of the scenarios handed out
to participants were available by questioning the licensee facilitators. Most response
actions were simulated except dose calculations and notification computer operation.
Guidelines for conduct of the interviews were discussed with the groups before starting.
Each scenario "run" consisted of a description of deteriorating plant conditions over a
simulated period of 15 to 30 minutes, read to the interviewees, and then handed out, by
the licensee operations f acilitator. An initial classification of Alert or Site Area Emergency
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11
was required; the inspection team observed and timed the response activities. After
completing initial response activities, an additional description of further plant deterioration
resulting in radiological release necessitating a General Emergency (GE) classification, dose
assessment, and formulation of PARS was delivered to the interviewees for observation of
continued response. Each scenario required approximately one hour to complete for a total
of two hours per group. The following sections summarize the observations and
conclusions in e'ach of the listed areas.
P1 Conduct of EP Activities
P1.1 Emergency Detection and Classification
a. Scope
To determine that the licensee's standard emergency classification and action .
level scheme, the bases of which include f acility systems, effluent parameters,
and projected offsite doses, is clear and unambiguous,
b. Observations and Findinas
in eighteen of twenty classification (or re-classification) opportunities among five
shift managers, SMs correctly classified events in an average of 5.5 minutes, in
two of twenty classification opportunities, the SM conservatively classified at
one class higher than expected due to information provMed by facilitator
verbalizations filling in with requested information. On one occasion, it was -
unclear from facilitator information what color the critical safety function would
have been when viewed on the Safety Parameter Display System (SPDS). On ,
the second occasion the facilitator stated that the dose rate observed at one
foot from a one liter primary sample was 35 mR/hr. The interviewee
misunderstood or misinterpreted the verbal information and implemented the
associated EAL of " Dose Rate at One Foot from Unpressurized RCS Sample
.>_ 30 mR/hr/ml".
In nine classification opportur" ties among two ADTSs, eight correct
classifications were performcd within fifteen minutes. The ninth opportunity
consisting'of evaluation and interpretation of adverse plant conditions was not
able to be classified within fifteen minutes, The DSEO was then provided
alternative information of field radiological data which was promptly recognized
by the DSEO and ADTS, resulting in a correct classification,
c. Conclusion
Shift Managers from MP3 were able to correctly detect and classify postulated
events in a timely manner. Due to the small sample size and uncertain method
of presentation of scenarios to ADTSs, the team did not asses the ADTS
classification responsibilities.
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P1.2 Notifications and Communications
a. Scope
To determine whether the licensee is maintaining a capability for notifying and
communicating among licensee personnel, offsite authorities and supporting
agencies, and the population within the emergency planning zone (EPZ) in the
event of an emergency.
b.- Observations and Findinos
During nineteen of twenty notification opportunities (associated with
classifications performed by the SM), Shif t Technicians (ST) " completed"
notifications, including obtaining real time meteorological data, filling appropriate
incident Report Forms, obtaining DSEO approvals, and utilizing the Emergency
Notification and Response System (ENRS) correctly in an average of seven
minutes. One ST did not complete the notification in a timely manner due to
non f amiliarity with a Time Sharing Option (TSO) terminal networking the Off-
site Facilities information System (OFlS) for meteorological data.
-
During nine of nine notification opportunities (associated with classifications
performed by the ADTS), the ST " completed" notifications utilizing the ENRS
correctly in a timely manner,
c. Conclasion
Licensee personnel performed their notification responsibilities correctly in a
timely manner; however, one ST may require additional training to ensure timely
notifications in the event watch rotation necessitates use of equipment located
in the EOF.
P1.3 Protective Action Decision Making
a. Scope
To determine whether the licensee maintains a 24-hour a day capability to
assess and analyze emergency conditions and to make recommendations to
protect the public and onsite workers,
b. Observations and Findinas
in ten of ten opportunities among five shift managers for determining protective
actions for onsite personnel, appropriate actions of assembly and accountability
were initiated in accordance with procedure.
For four correctly computed, on shif t dose assessments performed by the
Chemistry Technicians, Shift Managers correctly interpreted the results and
correctly modified the " understood" (default) PAR that is initially transmitted
,
with a GE declaration.
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One of one Shift Managers specifically questioned did not understand what
demographic zones were af fected with what public action (evacuation, shelter)
upon issuance of a GE, Posture Code Alpha, classification. In particular, the SM
did not realize the declaration would result in evacuation of a five mile radius.
One Shif t Manager did not properly implement an upgraded PAR af ter
consideration of on shif t Dose Assessment results. NUC EPOP 4428G, Rev. 2,
Protective Action Recommendations, requires transmission of PARS to the 24
hour Department of Environmental Protection (DEP) dispatcher in Hartford prior
to State Emergency Operations Center (EOC) activation. The SM was prepared
to notify each local jurisdiction of his revised PAR.
One of two Shift Managers was unable to revise the " understood" (default) PAR
accompanying a GE, Posture Code Alpha, declaration when thme fission product
barriers were " lost" subsequent to the initial declaration. NUC EPOP 4428G,
Rev. 2, " Protective Action Recommendations," requires an upgraded PAR to
five mile radius, ten miles downwind,in event of " Loss of 3 fission product
barriers".
Upon receipt of dose assessment results necessitating upgrading of the
" understood" PAR accompanying the GE declaration (four opportunities), the
ADEOF correctly interpreted the results and recommended a revised PAR to the.,
EOF DSEO for implementation,
c. Conclusion
Control Room Director (s) of Site Emergency Operations (CR DSEO) and EOF
SERO staff demonstrated a capability to make recommendations to protect the
public and initiate protective actions for onsite workers. However, additional
training may be werranted for Shif t Managers in PARS affecting the public.
P1.4 Dose Calculations and Assessment
a. Scope
To determine whether the licensee has the ability to perform dose assessment
under accident conditions,
b.1 Observations and Findinns (for on shif t Chemistry Technicians)
Among five Chemistry Technicians (cts), four of ten dose assessment
computation opportunities were performed correctly in an average of nine
minutes. Six of ten computation opportunities were performed inecarectly.
Of six incorrect dose assessment computations, one Shif t Manager detected the
errors made by the CT when presented the calculation for review.
Several Shif t Managers have not integrated the efforts of the cts into the shif t
organization. As a consequence, cts frequently had little direction concerning
their activities.
.
14
Specific examples of problems encountered and errors committed in the
performance of on shift dose assessment include the following:
- The Chemistry Technicians generally had difficulty accessing radiological and
meteorolc.gical data on the OFlS data terminals. Access to OFIS data
typically took greater than 5 minutes, with some cts taking over 10
minutes.
- Some cts used the wrong attachments to EPOP 4432 Rev. O, On Shif t Dose
Assessment, for the release being simulated in the walkthroughs (e.g.,
Attachments for Steam Dumps used when the release path was via Auxiliary
Feed Water Terry Turbino exhaust).
- Some cts and SMs mistakenly believed that EPOP 4432 contained methods
for dose assessn.ent utilizing inputs from water chemistry samples and
containment high range radiation detectors. Most Chemistry Technicians
believe a " release" must be in progress to begin utilization of EPOP 4432.
- Approximately half of the cts made substantial human factors and math
er; ors in using the attachments to EPOP 4432, including entering the wrong
stability class (+ / convention poblem for delta temperature), converting
millitem per hour (mr/hr) to Rem per hour (R/hr), and use of exponential
values (e.g., E 3,108, converting ur/hr to tur/hr, etc.).
- Some cts and SMs had a misconception that releases via steam relief and
dump valves were "unmonitored releases," causing them to select the
"unmonitored relsass" attachment (9) versus one of the attachments
costomized for the monitored release path (e.g., Attachment 6). This
misconception appeared to be related to materialin radiation monitor
handbooks and associated lesson plans that describe the inability of the main
steam line monitors to detect a release of normal reactor coolant following a
steam generator tube break and the decay of nitrogen 10 following a reactor
trip.
c.1 Conclusion (for on shif t Chemistry Technicians)
Shif t Chemistry Technicians (cts) had great difficulty using EPOP 4432. Shift
Managers (SMs) f amiliarity with EPOP 4432 was insufficient to assure their
ability to perform a quality assurance check of the CT's work. Pro'alems noted
during the walkthroughs are attributed to a comt'ination nf poor human f actors
design of EPOP and lack of training on the EPOP for cts and SMs.
b.? Observations and Findinas (for RDAT members)
The inspection team also conducted scenario walkthrougns and problem solving
interviews for core members of the SERO Radiological Dose Assessment Teamo
(RDAT). Personnelinvolved in the two hour long sessions were the Manager of
Radiological Dose Assessment (MRDA), the Assistant Manager of Radiological
Dose Assessmer.t (AMRDA), and the Radiological Assessment Engineer (Rt.E).
Three ressions were conducted for the RDAT teams not involved in the
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August 21,1997 Exercise. The first two sessionc involved a walkthrough of ;
the scenario used during the August 21,199*/ Exercise, with minor additions ;
and corrections to the basic scenario being provided by the inspect;on team. l
The third session involved the presentation of three discrete dose assessment +
t
problems. These three problems were, (1) Computation of the lodine
concentration, based upon a field air sample using a silver zeolite cartridge, (2)
Computation of Unit 1 Stack lodine release rate using a silver zeolite cartridge
removed from the Kahman stack monitor, and (3) Performing a "What If"
.
projection based upon probable use of the MP2 Terry Turbine following a steam'
'
generator tube rupture. The sessions were conducted in the RDAT room in the
Millstone EOF, with open access to all available references and computers. The
inspection team played the role of all personnel with whom the RDAT members
communicated. Results of these walkthroughs are summarized below.
- RDAT members had difficulty selecting among the assessment options _ ;
available in EPOPs 4428E (Post Accident Release Rates),4428F (Refined
Dose Assessment),4428H (Rsdionuclide Deposition and Dose Calculation),
4429 (Radiation Monitoring Team Deployment and Control),4435
(Drywell/ Containment Curie Level Estimate),4439 (Unit 1 Core Damage
Estimate),4445 (Unit 1 RX Coolant and Liquid PASS), and 4446 (Unit 1
Stack and Drywell Air PASS).
- Various attachments from the above family of EPOPs are required to be
completed as a prerequisite to performing a dose projection using the ADAM ,
'
computer system (e.g., to estimate release rste). The two groups involved in
the walkthrough took different alternate paths to determine release rate (e.g.,
using stack monitor readings versus using containment radiation readings 3
'
and containment hole size /pressurc tables).
- The August 21 RDAT completed dozens of required furms in the course of
two hours. The walkthrough teams successfully completed less than 5 each
'
over the course of about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. While satisf actory ADAM dose projections
were ultimately obtained, the time required would not support protective
action decision-making during an actual event similar to the 21 August
exercise scenario. Attachments such as those for "TEDE Limit Reduction !
Factor Based on DDE" (Attachment 3 of EPOP 4425)were not completed.
During the problem solving session, the following problems were noted:
- RDAT members had difficulty locating the proper attachments (e.g.,
Attachment 1 to EPOP 4428E, and Attachment 5 to EPOP 4429)for use
(problems 1 and 2)in converting iodine sample cartridge counts per minute
(cpm) or mr/hr into concentrations and release rates.
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- One computation of release rate contained an error of E6.
-_
m- m.- c m m ww-- -vw' e-p-- w-w -
,---.--se-> ---o-r- g -.-m -rt - r--i.q%y-.y-mp--3- ---ww+- r.--.-,v-y- e e t v y-98-r->+-w=r ww y-p-y awy+-+r ew-a-. yyw---+ + - - a---ge+vevw
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16
All RDAT team members involved in the sessions were unsure of the existence
'
and content of detailed preedures for performing gross and/or isotopic iodine
estimates based upon use of solver reolite cartridges installed in the Kahman air
sample monitors, or used in a grab sample of stack er drywell atmosphere.
Based upon a review of the associated procedures with RDAT members, and
later reviews by the inspection team, no detailed procedure for counting " hot" -
silver roolite cartridges could be found. Procedures reviewed included:
EPOP 4446 (Unit 1 Stack and Drywell Air PASS) and CP 801/2801/3801 AT
(Gamma Spectroscopy Counting System Maintenance and Operatio.4. Expected
lovel of detail which could not be found included: A chart or discussion of cpm ,
< or mr/hr versus shelf height, calibration or reference source number, location and :
configuration of increased height shelf supports, and procedures for obtalning a >
" grab sample" using an air sampler (versus installed Kahman system).
c.2 Rgnclusion (for RDAT members) i
s
Personnel weto not sufficiently familiar with the f amily of dose assessment
procedures to perform radiological dose assessment in the timely mannor ,
necessary to support emergency management decision making.
Later discussions with NU_ Radiological Assessment Branch (RAB) management
provided insight as to the lack of f amiliarity with the dose assessment
procedures demonstrated by RDAT members interviewed. Many personnel
formerly trained and experienced in the use of the procedures have been
transferred to offsite locations, and romoved from the SERO. Replacement
personnel have not taken the repetitive training and drill / exercise programs
necessary to utilize the complex set of procedures proficiently.
P2 Status of EP Facilities, Equipment, and Resources
a. hgpa
Gmemine whether key facilities and equipment are adequately maintained and
determine whether changes made since the last inspection are technically
adequate., meet NRC requirements, licensee commitments, and are appropriately
incorporated into the emergency plan and implementing procedures.
Determine whether changes to emergency facilities, equipment, instrumentation,
and supplies have adversely affected the licensee's emergency preparedness
'
program,
b, Observation and Findinali ,
The inspectors toured the Emergency Operations Facility (EOF), Technical
"
Support Center / Operational Support Center (TSC/OSC) and the Operational ,
Support Center Assembly Area (OSCAA). Table 71, " Locations of Emergency
Response Centers," of the Emergency Plan for Millstone Nuclear Power Station
(EPMNPS) list the locations of Emergency Response Facilities (ERFs). However,
not all key facilities or their locations, such as the laboratory at the EOF, are
. _
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listed. Additionally, the locations are given in general terms and not as ;
discussed in Section 7 of the EPMNPS. !
l
The inspectors identified that emergency f acilities and equipment to support the
emergency response were not being maintained, an apparent violation of l
5 50.47(b)(8). (VIO 50 245,336,423/97-08101). Examples are as follows:
- During the tour of the EOF, it was noted that Figure F 3, Appendix F,
EPMNPS, " Diagrams and Arrangement of Emergency Facilities,"
indicates the typical layout for the EOF which is consistent with the
actual f acility. However, maps, status boards, diagrarns, and the
" Minimum Staffing Chart" were not described or referenced in the
EPMNPS and were not controlled. Additionally, the phone at the
Director of Site Emergency Organization (DSEO) desk labeled (203-
437 2743)is no longer in service. The licenuee indicated an updated
version of the telephone directory for the Millstone NPS is on the
computer system. However, that system is not backed up with
emergency power and upon loss of power, the phone book, which is
dated Summer 1995, would be used.
- At the TSC, the inspectors noted that the TSC/OSC reference library
contained uncontrolled drawings ( S&W DOC NU 12179 ESK 4AA 5
and 12179 ESK 14).The inspectors also noted that both EPIP 4405,
" Response to Personal Injuries," and EPOP 4413, " Potassium lodide
(Kl) Tablet Control and issue Agent," Revision 1, effectivs June 1,
1995, had a sheet over them which indicated "Do Not Use," because
both procedures had not met the two year review requirement, if a
personal injury occurred or Kl consumption was directed, licensee
personnel could not respond. The inspectors noted that there was no
control over other documents and the facility.
- The inspectors inventoried emergency equipment used by OSC teams
dispatched from the TSC/OSC. This equipment is stored in lockers
located in the " penthouse" of the TSC. The TSC/OSC Filtration
System is located here and some protection to OSC repair teams is
provided. However, having workers obtain equipment from these
lockers in a radioactive field is not ALARA. The inspectors verified
that the equipment, as specified on the inventory form, was in place.
However,it was not indicated on these forms which locker (s) were
designated to contain which equipment. There were four lockers:
two contained the prescribed equipment and two contained other
material, equipment, etc., which the licensee indicated would be used
in the response. None of this equipment was identified in the
EPMNPS or implementing procedures. Additionally, these lockers are
not controlled in that they may be accessed by licensee personnel not
directly involved in the emergency response program. Consequently,
personnel could remove, replace or alter a locker's contents without
! the know! edge of emergency response personnel. Although the
equipment and instruments were in place to support the emergericy,
there was no control of the lockers to assure that the equipment
would be there when needed for an emergency.
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- Oversight, inventory, and calibretion of emergency equipment,
although under the purview of the Director, Nue'ur Emergency
Planning Services Department, is within the res;>onsibilcy of Health
Physics, Chemistry, or other NU departments, liiventoros are to be
conducted quarterly and after use. Although the halui Physics
Departrnent conducts inventories quartarly and after use, emergency
preparedness equipment inventories were only being performed
quarterly. The breathable a;r portion of Self Contained Breathing
Apparatus (SCDA)is maintained under another department. This
equipment is neither inventoried or maintained such that the Millstone
Emergeacy Preparedness is aware of its condition to support the
emergency resporue.
- Laboratory equipment at the EOF is under the Chemistry Department ,
for inventory r.ad calibration. However, the f acility is used by health
physics department personnel. At the time of this inspection, it
appeared this equipment was calibrated, however, it was not possible
to determine if the emergency preparedness department had been
inforrred.
- During the tour of the eme.gency response f acilities, it was noted that
none of these f acilities contained a copy of the EPMNPS. -
The inspectors toured the OSCAA which provides space for additional SERO
personnel outside the TSC/OSC and is located in the William Ellis Tet;hnical .
Support Center (B475), Conference Room C-102. This f acility is in the
protected area approximately 50 yards west of the TSC/OSC. During the tour of
the f acility, it was noted that equipment and telephnnes as specified in the plan
and procedures are in place such that additional support personnel needed by
the OSC could be obtained.
c. C_poclusion
As a result of ERF tours, inspection of emergency response equipment / kits, and
a review of the EPMNPS and it implementing procedures, it was determined that
information required by 10 CFR Part 50 to assure that the maintenance of these
emergency response facilities and equip nent would be adequately maintained
was not contained in the plan. An apparent violation of 650.47(b)(8)was'
identified concerning control of information, documents, and equipment in
emergency response f acilities and for the failure io inventory equipment
following use.
19
P3 EP Procedures and Documentation
a. S_qspg
If significant or major changes have been made to the emergency preparedness
program, assess whether these changes have adversely affected the licensee's
overall state of emergency preparedness and have been appropriately
incorporated into the licensee's emergency plan and implementing procedures.
Verify that major or significant changes to the emergency plan and implementing
procedures have been reviewed, approved, and distributed in accordance with
approved licensee procedures and NRC requiremi,nts before implementation,
b.1 Observation and Findinas
The licensee's emergency plan is titled the " Emergency Plan, Millstone Nuclear
Power Station." The licensee impismented Revision 22, of the Emergency Plan
in June 1997. Prior to implementing the revision the licensee conducted a
review and determined that the reviolons being implemented did not decrease
emergency plan effectiveness. Revision 22 was issued as a complete revision
and replaced all pages of previous ernergency plan revisions. In August 1997
the licensee implemented Revision 23 of the Emergency Plan.
The inspectors reviewed selected portions of Revision 22 and 23 of the
licensee's Emergency Plan and compared the current plan content with that of
the previous revision. The inspectors also evaluated selected portions of the
emergency plan using the guidance provided by NUREG 0654," Criteria for
Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants," and the standards found in
10 CFR 50.47(b), and the requirements 'f Appendix E to 10 CFR 50.
The inspectors identified the following specific changes that were implemented
by Revision 22 th91 decreased the emergency plan effectiveness.
- With the implementation of Revision 22, the licensee removed
Figure 5 2, " Normal Station Organization Millstene Station," page
5 26, of Rev. 21 from the emergency plan. The removal of this figure
from the plan resulted in deleting required information from the plan
concerning the plants normal operating organization. The inspectors
noted that with the implementation of Revision 23 the licensee has
restored this information to the emergency plan.
- In Revision 21, the licensee identified the ability to evacuate
personnel to an assembly area in 30 minutes, (Section 6.4.1.D. page
611), as one of the protective action that would be implemented
when needed, in Rev. 22, this has been changed to a 45 minutes.
This is a decrease in the licensee emergency response capability.
Guidance in NUREG-0654, Section J.5, established a time frame of
_ _ _._._ _ _ _ _ _ _ _._ _ _ _ _ _ _._.._ _.___ _
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30 rninutes for licensees to be able to account for individuals onsite
and ascertain the names of missing individuals. The change from 30 l
to 45 minutes is a decrease in the licensee response capability and is ;
!
not consistent with established guidance.
With thu ;mplementation of Revision 22, the licensee has altered
many of the response capabilities previously identified in Rev. 21. ,
- In Rev. 21, the licensee had committed to provide four (4)
individuals in about 30 minutes to provide for radiation protection
access control functions. In Rev. 22, this commitment has been ,
'
revised to a 60 minute time frame. This is a decrease in the
licensees response capability. This change also falls outside of
the guidance established by NUREG-0654 for 2 individuals to be
available in 30 minutes and 2 additionalindividuals to be available i
in 60 minutes.
- Additional review of the licensees commitments for
coverage of health physics functional areas in Rev. 21
and 22 identified that no specific provision is made for
- onsite (out of plant) and inplant surveys capabilities to
! be augmented at 30 and 60 minute intervals from
declaration of events. The licensee also omits the
function of access control from onshif t capabilities.
- In Rev. 21, the licensee identified a number of position ;
l'
that were committed to be filled within 60 minutes and
additional positions to be staff within 75 to 90 minutes.
With Rev. 22, the licensee has adapted a new
approach to meeting response capability commitments.
These changes include identifying a number of
,
positions that are identified as minimum staffing and
'
other positions as augmented staffing. The licensee
has not clearly identified the response time for the
'
positions now considered to be augmented staffing.
!
The following are specific examples of funct;onal areas
and associated augmented staff positions that no
longer have a specific response commitment clearly
identified in the emergency plan: Technical Information
Communication, Technical Data Communication,
Offsite Radiological Dose Assessment, Radiological
Radio Communications, Unit System Engineering, Plant
Systems Engineering Repair and Corrective Actions ,
(Core Thermal Hydraulics), Operational Support, and
Resource Acquisition & Personnel Dispatching. Not
specifying a response time for the augmented staff
positions results in a decrease in the response
capability.
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The inspectors identified several concerns when selected portions of the !
licensee's emergency plan was evaluated using the guide lines found in !
NUREG-0654. This review identified the following concerns: ,
- The Licensee's Table 5-1 omits the onshif t capability for Mechanical
Maintenance and Electrical Maintenance. Table 51 also omits
identification of coverage for the Rad Waste Operator. The Manager- ;
'
of Security Forces is the only security position mentioned in the
Table 51, the licensee has omitted the balance of security force i
capabilities from the emergency plan. [
- The position of Station Duty Officer is omitted from the list of on-
shift /onsite positions as part of the normal station organization on
page 51. In Table 51, the Station Duty Officer is identified as ri i
position for which one person is available for each unit, when actually -
there is only one individual identified inr the site.
,
- The cross reference developed by the licensee to correlate NUREG-
'
0654 criteria with specific emergency plan sections that !mplement
.the criteria has omitted several sections which more completely
address the established evaluation criteria. Several of the reference
are inaccurately identified.
- The licensee emergency plan fails to address in a significant and
meaningful way the emergency action levels required by 10 CFR
50, Appendix E. Section 4 and Appendix I of the licensee plan
provides only minimalinformation on the existence of the EALs
and directs reference to EPIP 4400 for specific details. Appendix i ,
of the licensee emergency plan is essentially a set of pages
fortnatted with boiler plate columns and lines to form a matrix but -
no details are provided concerning the EALs. The content of
Appendix I is inconsistent with information provided in ,
, Section 6.2.3.b., "Use of Emergency Action Levels," page 6 6 of
Rev. 22, which states that Appendix I contains effluent monitor
radiation levels which correspond to precalculated doses, this
information has been omitted from Appendix 1.
,
- The list of supporting procedures provided in Appendix D omits
several procedares which are referenced in the plan and relied on for
complete implementation of the emergency plan. Specific examples
include the Emergency Preparedness Departmental Procedures,-
Emergency Preparedness User Guides, and Radiation Protection ,
'
1 Manual chapters 4.8.5, 2.3.4 and 2.3.5.
l
l * Appendix C, EPZ Maps and Monitoring Locations, has omitted several
! maps utilized by responders. These maps are not identified by the
'
emergency plan nor controlled in any specific programmatic way
.
associated with the emergency plan. Examples of maps included,
Millstone Point Onsite Field Monitoring Map, (Revisions 8/98,10/94,
and 8/97 were identified by the inspectors to be in use), Millstone
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Nuclear Power Station Overwater EPZ Monitoring Map as supplement j
to the EMT Procedures, Rev. O, dated 1/3/96, Millstone Station !
Emergency Response Facility Map, DWG No. SK:RH110896, Rev.1, .
dated 3/24/97, As Built, and State of Connecticut Official Millstone
Nuclear Power Station EPZ Base Map for RERP, dated 8/85. !
1
- The list of supporting plans and sources in Appendix L omits
reference to the emergency plans developed for each local
governmental jurisdiction, such as the Town of Waterford. The
resources of the Seabrook Station which are relied on by the licensee
are not listed, nor is the Northeast Utilities Production Operation
Servicss Labor; tory included in the resource list. -(Both of these
facilities are also omitted from Table H 2, "Offsite Assessment
Equipment.")
- Several positions identified in the licensees emergency response
organization are not clearly described in the emergency plan. Some i
specific examples include the Accident Management Team (AMT)
Leader, AMT Mechanical Engineer (Core Thermal Hydraulics), and
Generation Test Specialist.
- In Section 6.2, Initial Assessment, page 6 3 of Rev. 22, the licensee e
made the statement, "Real time dose estimates are not performed for
f ast moving events." This statement is inconsistent with current
duties and responsibilities assigned to onshif t Chemistry Technician to
provide initial dose assessments.
c.1 Rgpclusion
,
in accordance with conditions of license,10 CFR 50.54(q) states, in part: "A
licensee authorized to operate a nuclear power plant shall follow and maintain in
effect emergency plans which meet the standards in 650.47(b)and the ,
requirements in appendix E of this part...The nuclear power reactor licensee may
make changes to these plans without Commission approval only if the changes
do not decrease the effectiveness of the plans and the plans as changed '
continue to meet the standards of 150.47(b) and the requirements of appendix E
to this part..."
The inspectors concluded that with the implementation of Revision 22 the
licensee made changes to the emergency plan which decrease the emergency
plan effectiveness. The changes were made without commission approval, in '
some instances the plans as changed no longer meet the standards of 10 CFR-
50.47(b), and the requirements of Appendix E. This is an apparent violation of
NRC requirements. (VIO 50-245,336,423/97 81 03)
-
6
- '
-
y'FT"*Nv'f'W'- "-'Y*'
- _ ~ . - - . . - - - - _- - - . . --- --- __-._ .- .
.
.
23
i
b2 Qhtgrvations and Findinas Dose Assessment Procedures
The inspection team performed a detailed review of twelve of the dose
assessmer.t related EPOPs during the course of the inspection. The examples
provided below are those for which no onsite resolution was satisfactorily
,
completed. ,
- The Or- Shif t Dose Calculation Procedure (EPOP 4432) had the following
problems:
t
4432 included only DDE and is on Per/ Hour basis). !
- Thyroid CDE (which is neehd in the Protective Action Procedure EPOP. .
4428G)is not computed, t
- Plant Chemistry Technicians had great difficulty using the procedure in the
walkthrough environment (average time to complete a calculation was about
12 minuter major errors were generated in over 50% of the calculetions
performed), ,
- Mathematicalinconsistencies were found in conversion f actors among the ;
various attachments to EPOP 4 432; and EPOP 4432 did not include a means ,
~
for computing releases via Unit 2 Terry Turbine or Unit 1 Hard Vent.
The ADAM Dose Assessment Code had the following problems which detract
from use of the system in a timely manner to compute TEDE:
- ADAM does not compute ground deposition or the giound depositlen
contribution to TEDE (As defined in EPA 400).
- ADAM does not compute the CEDE values for nucliaes released (Another
TEDE contributor).
- The data entry forms (4428 series procedures) are cumbersome and overly
,
complex.
General use and definition of the term TEDE, across several procedures and
training lesson plans, is not consistent w;th EPA 400 or 10 CFR 20. Examples
include:
i
- EPOP 4428F stated that TEDE includes ingestion pathway and resuspansion
of ground deposition (Not part of EPA defined TEDE).
- TEDE was defined in hourly terms in most procedures, versus being defined
as total dose over the projected duration of a release.
__ _ _ _ _ _ . . . _ _ _ . __ . _ _.-_ _ _ _ _ _ _ _ , _ _ , _ . _ . . . _ _ _ _ _ _ , , _ _ _ _
_
24
Procedures contain f ar too many disclaimers and warnings that TEDE will
essentially always consist of only whole body plume exposure dose, and that
other contributors are too difficult or unreliable to estimate and project; and the
related lesson plan " Radiological Assessment Engineer" (EP-G013 RAE) contains
totally falso and technically inaccurate guidance such as "... DDE and the f actor
of CDE thyroid will be sufficient to calculate TEDE".
The f amily of 4400 series procedures contained f ar too many redundant options
for the average Radiological Dose Assessment Team (RDAT) member to
assimilate and use reliably to arrive at hand and computer based dose
projections. All RDAT groups interviewed had difficulty selecting among the
options, and in using the options in a sufficiently rapid manner to support
emergency management decision making.
4
Extensive discussions were held with RDAT members and RAB personnel
concoming converW. factors used in the large family of dose assessment
procedm ' POP 4400 series). Questions remain on conversion f actors for
using a frisker or gamma dose rate instrument to obtain a rough estimate of
silver lodido cartridge gross lodina content, and consequently ucl/cc
concentration, or release point Ci/sec values. This unresolved question applies
to field samples, Kahman Monitor samples, and HVAC/ Containment grab
samples. Similar questions remain concerning the basis for conversion factors
for installed process monitors (e.g., Main Steam Line Radiation Monitors). A
technical basis for most of the above types of conversion factors was not
contained in the basis documents for individual procedures, and was not
delivered from the radiological assessment branch (RAB) reference files to the
inspection team during the period of thu onsite inspe : tion.
Many calculations in the EPOP 4400 series procedures were understood only by
the original authors, based on interviews where interviewees interpreted the
procedures at face value, as did the NRC inspection team (because underlying
assumptions are not clearly stated). Examples include:
- Containment release rates through varying size holes, at various pressures,
were being interpreted as Cubic Feet per Minute (CcM) at Standard
Temperature and Pressure (STP), versus the authors' intention of the CFM
values representing " Cubic feet of the portion of pressurized containment
atmosphere abovt. atmospheric pressure"
- Terminology for amounts and concentrations of iodine varied from procedure
to procedure, and within procedures, among " Gross lodine" and " Dose
Equivalent lodine 131" terminology and underlying assumptions
l
l * Procedures contained far too many footnoted uses of the term TEDE which
l couH, and did, lead the users to apply the term TEDE to dose projection
j results communicated to both internal and external recipients, when the
results computed were not really TEDE.
.
. - _. . . _ .
- - -
25
Procedures allow users to apply decontamination f actors (DFs) to potential
iodine releases which are three orders of magnitude below current NRC and
industry techniques for unfiltered releases. These DF factors are applied to an
assumed starting lodine to Noble Gas (1/NG) ratio in the fuel gap and coolant of
3.7% (Lower than any authoritative text ever estimates). The topic of the
beginning assumptions for iodine to noble gas ratio in the coolant, for gap and
beyond accident scenarios, was still under discussion and unresolved as the
onsite portion of the inspection ended. The August 21,1997 scenario data
assumptions, and the assumptions by the RDAT exercise team, were in the
range of E 4 to E 61/NG ratio for an unfiltered release. The NU RAP reviewed
those assumptions with the NRC Team, without reaching closure,
c.2 Conclusion
The combination of rnisuse of the term TEDE, lack of a rapid means to compute
TEDE, mathematical errors, complex options, questionable assumptions, and
typographical / human factors problems in the dose assessment procedures
warrants a complete review and upgrade program. Licensee Emergency
Preparedness management concurred in this conclusion at the end of the onsite
inspection period. This along with the inability to perform dose assessment in a
timely manner to provido protective action recommendation upgrades, as
discussed in Section P1.4 is an apparent Violation of 10 CFR 50.47(b)(9) which
states: " Adequate methods, systems, and equipment for assessing and ,
monitoring, actual or potential offsite consequences of radiological conditions
are in use." (ViO 50 245,30,423/97-081 04)
P5 Staff Training and Qualification in EP
al. Eg_qp_u
The inspectors assessed whether emergency response personnel have received
training, whether they understand their emergency response roles and
authorities, and whether they can perform their assigned functions,
b1. Observations and Findinas
The inspectors learned, through their discussions with the EP training staff, that
the licensee's entire training program had been subjected to a ret,ent review.
Adverse results from both external and internal audits resulted in the suspension
of training penuing the revision of the training product at the lesson plan level.
The EP training curriculum was included in the training programs that needed to
be " restarted".
The restart offort for an individual training program required the completion of an
explicit review methodology to ensure that the program adhered to the orinciples
to the Systematic Approach to Training (SAT). All of the SAT principles were
covered in the methodology except the incorporation of long term feedback from
job performance into revision of the subject program. The licensee had deferred
the formal development of this feedback process to a later date.
__.
_ _ _ _ _ _ _ _ ____ .
_. - - - -. . . - . - . -- .-
26
At the time of the inspection, the EP training staff had revised 13 of 37
programs in the EP training curriculum for Millstone Station. Five of these
13 programs had been implemented af ter their restart. The inspectors reviewed
three of these 13 programs to determine the acceptability of the training. The
training progran1s reviewed had all the restart certification documentatico
appropriately fi' led out and were consistent with the principles of SAT bated
training. The inspectors noted that there was no defined method of ensuring
that changes to EP procedures and equipment was reflected in changes t s the
training programs. The licensee does, however, use Curriculum Advisor',
Committees (CACs) extensively to provide a liaison between the line
organizations and the training department. These CACs would provide the 1
necessary feedback to the training department of changes to the procedures or
equipment.
The inspectors reviewed the task list for SERO positions and noted some
positions did not have lesson plans listed in which the tasks were covered. EP
training stofI stated that this was due to the applicable lesson plans not being
restarted. 'The inspectors found several examples where the training specified
for members of the ERO did not meet the tasks they were expected to perform
either as specified on formal task lists or conventional practice. For example,
the inspectors reviewed the task list for STAS for Unit 3, which specified such
EP related tasks as classifict. tion of emergency conditions, offsite dose
calculations, protection of on-site personnel and emergency plan implementation
as those irs which the STA would participate. Two of three shif t managers
interviewed stated their expectations that the STA would assist in the
classification of emergency events. The inspectors noted the STA who
performee in the August 21,1997 exercise was intimately involved in the
emergency action level classification of degrading plant conditions.
The training expectatiens for the STA, however, do not require specific training
in these areas. The emergency plan and the training procedure only require that
the STA receive overview training. The same training requirements exist for the
Station Outy Of ficer (SDO), who is listed in Revis!on 23 of the emergency plan
as responsible for assisting with NRC notifications, communications, and
evacuation of onsite personnel. The SDO, having discrete emergency duties,
involvirg operation of communication equipment, should be given specialized
traininpl i n the use of this equipment.
Also, Revision 23 of the emergency plan does not require radiation worker
training for certain ERO positions, although such training is appropriate. For
example, the Shif t Technicians, who make of fsite notifications of emergency
- events from the control room, are not required to be radiation worker qualified,
although other control room staff members are required to be qualified. EP
Department staff informed the inspectors that radiation worker training was in
fact ' required for Unit 3 Shif( Tecnnicians by plant r.lanagement. Similarly, the
health physics technicians in the EOF, likewise are not required to be radiation
,
worker qualified although their duties center around radiation surveys and
l
decontamination of personnel.
l
._
_. _ _ _ . _ _ _ _ . _ _ . _ _ .. _ _ _ - _ _ . . _ _ _ _.. _ _ . _ __ . __
\
l
.
27
The performance of some SERO members during the table-top walkthroughs (see
Section P1.4) indicated that there were some Shif t Managers who were ,
unfamiliar with the procedures for on shift dose assessment and protective
action recommendations. The inspectors interviewed three Shift Managers who ,
stated their complete unfamiliarity with the oneshift dose assessment procedure.
Two of the three also stated that they felt somewhat unfamiliar with the latest
protective action recommendation procedure, which they had only been exposed
to once,
c1. Conclusion
The inspectors concluded that there were some problems with the EP training's
adherence to a SAT based model since the tasks ascribed to be performed by
certain positions in the SERO were not adequately reflected in the training ;
requirements specified for those positions. The inspectors could not !
conclusively state that the training program was adequately preparing SERO
membors for their I ;sitions since the task list to-lesson plan tie was still
undeveloped for son.e positions. Finally, the inspectors concluded that the
performance of the personnel during the walkthroughs, combined with
interviews of those persons, indicated that additional training was needed for
certain tasks performed on shif t.
b2. Maintenance of SERO Qualifications
a2, Scope
The inspectors checked the qualification training status of a random selec'. ion of
SERO members to determine if they were receiving the EP training specified by
the emergency plan and procedures.
b2. Observations and Findinas i
The inspectors checked the qualification records of 63 SERO members, including
,
Unit 3 SERO members on shift. They found only five examples of SERO
members who did not have the proper training, and three of thess members
were inadvertently lef t on the SERO list af ter being removed from an on shif t
status. The other two exampics were plant equipment operators who had not
had respirator training since calendar year 1995. EP Department personnel,
af ter being informed of these problems, stated their intent to improve the
mechanism for tracking the qualification status of on shif t SERO members,
c2, Conclusions
The inspectors considered the program for tracking and maintenance of SERO
qualifications to be wellimplemented.
!
_
>
l
28
P7 Quality Assurance in EP Activities
a. Sggge -
Examine independent and internal review and audit reports for the licensee's
emergency preparedness programs since the last inspection to determine
compliance with NRC requirements and licenseo commitments.
Evaluate the licensee's corrective actions for audit identified deficiencies and
those ihntified during dritls and exerciscs,
b. Observations and Findinas
The licensee has committed ii Section 8.3 of the Millstone Emergency Plan that
annual reviews per 10 CFR 50.54(t) of the Emergency Preparedness Program are
performed by the licensee oversight group. Appendix D of the Emergency Plan,
Supporting Procedures list, reflects EPAP 1.15, Management Program for
Maintaining Emergency Preparedness, as the reference for Emergency Plan
Section 8. The team reviewed EPAP 1.15 Rev. 2, and noted that the procedure
addressed subjects of on-going maintenance of the program, but was silent on
the subject of independent and internal audits.
The team noted hat EPDP 12 Rev. O, Self Assessment Program, became
effective January 15,1997. EPDP 12 stated that the first two levels of
assessment, " Individual" and Management," were the only assessments
considered to be "self assessments". Third and fourth level assessments were
described as independent internal and external oversight audits, and not covered
by EPDP-12.
The team was provided a copy of Audits and Evaluations Audit Report No.
A25113, entitled " Connecticut fankee/ Millstone Station Emergency Plan Audit
and 10 CFR 50.54(t) Review for 1996", dated January 24,1997. The audit
was conducted between January 25,1996 through January 15,1997. The
Executive Summary of the report reflected, "No discrepancies were identified at
Millstone Stabon".
The NRC inspectors were concerned that no discrepancies were:idenCfied at
Millstone Station during the year long audit period by a team of nine auditors.
This situation was different than the experience of the NRC inspection team. An
additional concera of the NRC team was that the audit did not appear to include
all elements of 10 CFR 50.54(t) such as evaluation for adequacy of emergency
preparedness program capabilities and procedures.
In addition to the above report, the NRC team was provided several other
reports of audits and assessments, for example, "97107.wpd, Self
Assessment: NU Dose Assessment for Emergency Planning Facilities," dated
June 19,1997. Many of the areas for improvement and deficient performance
and practices of the report were noted by the NRC team, but were not
. .. .. . . . . . . _ . .
_. _ . _ _ . _ . _ . _ _ _ _ . . _ . . _ _ _ . _ . _ _ . _ _ _ _ _ _ _ . . _ _ , _ _ _ _ . ___.
i
.
- 29
verbalized by Radiological Assessment Branch staff as previously identified <
,
concerns at the tirne of the NRC inspection. No evidence was presented to the
NRC inspectors that corrective action was being considered for the report
concerns. *
c. Conclusion
Based upon the extent of concerns identified by the inspectors review of
oversite in the EP area, the inspectors concluded that inadequate audits
,
constituted another apparerit violation of 10 CFR 50.54(t). (VIO 50-245,336, -
4
423/97 081 05)
, MANA91MENJ_MEEIllMA
i
X1 Exit Meeting
The inspector presented preliminary inspection results to members of licensee management
1
at the conclusion of the inspection on August 29,1997. The licensee acknowledged the .
Inspector's findings.
The inspector presented the inspection results to Mr. N. Carns, Senior Vice President and
Chief Nuclear Officer, and other members of your staff at the public exit meeting
conducted on September 8,1997, at 6:00 p.m. The licensee acknowledged the
i inspector's findings.
.
4
4
I l
1
_ _ _ _ _ _ _ _ . - . . _ _ . _ _ _ _ . _ _ _ . _ _ . . - _ _ . - _ _ . _ _ . _ . _ _ . _ , _ _ _ . _ _ _ _ _ , . . . _ . _ , _ . _ .. ~
. _ _ . _ . _ _. _ _ . _ _ _ _ . _ . _ . _ _ _ - _ _ . __ _ . . _ . _ _ . .- -_
1
.
l
30 i
PARTIAL LIST OF PERSONS CONTACTED
Mllistone Station Personnel
W. Buch, Emergency Planning Coordinator
E. Maclean, Emergency Planning Training
J. Rigatti, Emergency Planning Training i
A. Vomasick, Emergency Planing Training Supervisor
B. Nevelos, Director Nuclear Services
D. Gerber, Oversite
M. Covell, Director Corrective Actions
M. Keyes, Emergency Preparedness Coordinator
D. Embrosky, Emergency Preparedness i
D. Goebel, Vice President, Oversite .
D. Hicks, MP3 Director
J. McElwain, MP1 Recovery Officer
M.- Bowling, MP2 Recovery Officer
J. Thayer, Vice President, Nuclear Engineering and Support
M. Brothers, MP3 Recovery Officer ,
P. Stroup, Director, Emergency Preparedness Services Department
N. Carns, SerAr Vice President and Chief Nuclear Officer
T. Blount, Mt - ger, Emorgency Preparedness Services Department
J. Morlino, Exercise Manager, Emergency Preparedness Services Department
l
.
l-
. ~. . _, .. _ . , - . ,.. .._-_- . .- __ .. . . - - _ - . _ - _ _ . - . - - _ _ . -
- -_.. .-_ _ ~ _ _ . _ _ . _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ ____ ..__.__ _ _-- _ . ._ _ ._ - -
!
,
31
INFPECTION PROCEDURES USED
iP 82206: Knowledge of Performance of Dutiec
IP 82301: Evaluation of Exercises for Power Reactors
IP 82302: Review of Exercise Objectives and Scenario for Power Reactors ,
IP 82701: Operational Status of the Emergency Preparedness Program
ITEMS OPENS AND Ct.OSED
l
poened
(IFl 50 245,336,423/97 8101): Potential over classification beer,use of EALs CNB4 and
CNB5. -
(VIO 50 245,336,423/97 08102): Failure to maintain emergancy preparedness facilities.
(VIO 50-245,336,423/97 08103): Improper implementation of dose assessment -
standards, EPA 400, and 10CFR20 requirements.
(VIO 50 245,336,423/97 08104): Decrease in effectiveness of the emergency plan with
prior NRC approval.
- (VIO 50-245,336,423/97 08105): Adequacy of oversite review of 10CFR50.54(t)and -
oversite requirements.
-
G9 lid
None
,
h
e
-c,
,e---- - , -e,-- av, mv,s.m--.ww. -v., ,m v-n..n,--e-ere- e .,v.wn- en- wuv,,,e,n -r-e>w-- , ,-.xww sg - , ,~an e t- --w -
--
. _ _ _ .
.
N
32
l
LIST OF ACRONYMS USED i
AC Alternating Current
ADAM Accident Dose Assessment Model
ADEOF Assistant Director Emergency Operations Facility
ADTS Assistant Director Technical Support
AMRDA Assistant Manager of Radiological Dose Assessment
AMTL Accident Management Team Leader
ARM Area Radiation Monitor
ATWS Anticipated Transient Without Scram
BWR Boiling Water Reactor
cc cubic centimeter
CDE Committed Dose Equivalent
CEDE Committed Effective Dose Equivalent
CEPG Central Emergency Preparedness Group
cfm cubic feet per minute
CFR Code of Federal Regulations
Ci Curie
cpm counts per minute
CR Control Room
CT Chemistry Technician
DEP Department of Environmental Protection
DF Decontamination Factor
DSEO Director Site Emergency Operations
EAL Emergency Action Level
EAS Emergency Alert System
EDG Emergency Diesel Generator
CNRS Emergency Notification and Response System
EPA Environmental Protection Agency
EPMNPS Emergency Plan for the Millstone Nuclear Power Station
EOC Emergency Operations Center
EOF Emergency Operations Facility
EPAP Emergency Plan Administrative Procedure
EPDP Emergency Plan Depar*. mental Procedure
EPIP Emergency Plan implementing Procedure
EPOP Emergency Plan Operating Procedure
EPZ Emergency Planning Zone
ERF Emergency Response Facility
ERO Emergency Resoonse Organization
ES Executive Spokesperson
FEMA Federal Emergency Management Agency
FPB Fission product barrier
GE General Emergency
gpd gallons per day
gpm gallons per minute
.- - _. - - . - - . - - - . - _ - - - - . =
,
.
33 ;
I
nr hour
HP Health Physics ,
HVAC Heating, Ventilation, and Air Conditioning
1/NG lodine to Noble Gas (ratio)
lRF Incident Report Form ;
JMC Joint Media Center '
LOCA Loss of Coolant Accident
MCRO Manager of Control Room Operations
MNPS Millstone Nuclear Power Station
MP1 Millstone Point Unit 1
MP' Millstone Point Unit 2
P' Millstone Point Unit 3
v maximum permissible concentration
.' milli-liter ;
rn milli Roentgen
u C,. micro-Curie
MOS Mar,3ger of Security
MOSC Manager of Operational Support Center
MRDA Manager of Radiological Dose Assessment
NRC Nuclear Regulatory Commicsion
NU Northeast Utilities
NUREG 0654 Criteria for Preparation and Evaluation of Radiological Emergency
Response Plans and Preparedness in Support of Nuclear Power Plants,
NUREG 0654 FEMA REP 1, Revision 1
! OEM Office of Emergency Management
OFlS Off site Facilities information System
OSC Operational Support Center
PA Public Address system
PAR Protective Action Recommendation
PASS Post Accident Sample System
PEO Plant Equipment Operator
l P&lD Piping and Instrument Drawing
l QA Quality Assurance
RAB Radiological Assessment Branch
RAE Radiological Assessment Engineer
RDAT Radiological Dose Assessment Team
l RERP Radiological Emergency Response Plan
!
RMP Radiological Monitoring Point
PMT Radiological Monitoring Team
. HOB Refueling Outage Building
SAE Site Area Emergency
SBGTS Standby Gas Treatment System
SCR Simulator Control Room
SDO Station Duty Officer
SEOC State Emergency Operations Center
SERO Site Emergency Response Organization
SM Shif t Manager
. . . . _ _ _ _ _ _ _ _ - _ . _ _ . _ , _ _ _ _ _ _ . _ _ _ - . __ _ __ _ __
1
Y
o
34
SPDS Safety Parameter Display System
SRO Senior Reactor Operator
ST Shif t Technician
STA Shift Technical Advisor
stp Standard temperature and pressure
TA Technical Assistant
TEDE Total Ef fective Dose Equivalent
TLD Thermoluminescent dosimeter
TSO Time Sharing Option
US Unit Supervisor