4.0 Summary of Major DCISC Review Topics, 17th Annual Report - July 1, 2006 thru June 30, 2007
4.7 Emergency Preparedness
4.7.1 Overview and Previous Activities
An Emergency Preparedness Program has been in-place since the beginning of the nuclear power industry; however, the accident at Three Mile Island brought substantial changes. Prior to Three Mile Island, Emergency Operating Procedures (EOPs) were primarily event-based, requiring the operator to know which event was taking place. Afterward, the EOPs became symptom-based, making it easier for the operator to decide what actions to take. The five major facilities used in an actual emergency situation (and used for practice in an emergency drill) include
- the Control Room (simulator in practice) where operators respond to the accident,
- the station Technical Support Center (TSC) where engineering, computer, radiological assessment, NRC, and operations, as well as documents and procedures, are located,
- the offsite Emergency Operations Facility (EOF) where the Recovery Manager and administrative and technical staff are located,
- a station Operations Support Center (OSC) provides a location to stage and dispatch operations, maintenance, firefighting and radiation protection personnel, and
- the Joint Media Center (JMC) where DCPP and San Luis Obispo County interface with the media
The DCISC reviews Emergency Preparedness at DCPP on a regular basis. Past Committee activities have included observations and reviews of drills and full, graded emergency exercises each year and related issues from the observations.
During the previous reporting period, the DCISC reviewed the following specific items:
- Plant Simulator Models and Codes
- Emergency Preparedness Equipment Reliability
The DCISC concluded in the last reporting period that the DCPP Emergency Preparedness Program has undergone extensive reviews, and a recently-developed Strategic Plan will bring about needed improvements, two of which are to further improve the way it conveys radiation release projections and data to the media and public, including improved coordination with the County. This aligns with recent DCISC positions and recommendations, and the DCISC will closely follow PG&E’s progress in this area.
4.7.2 Current Period Activities
The DCISC reviewed the following Emergency Preparedness items during the current period:
- October 25, 2006 Emergency Exercise
- Emergency Preparedness Update
- Emergency Classifications and Activation for Security Events
- Emergency Evacuation Plan
October 25, 2006 NRC-Graded Emergency Exercise
The DCISC Fact-finding Team met with Steve Hamilton, Regulatory Services Engineer, at its October 25-26, 2006 Fact-finding Meeting (Volume II, Exhibit D.3, Section 3.1) to observe the October 25, 2006 NRC-Graded Emergency Exercise. The DCISC also received a DCPP presentation on this exercise at its January 31 – February 1, 2007 Public Meeting (Volume II, Exhibit B.6).
The exercise scenario was developed in coordination with SLO and the State Office of Emergency Services. Its objectives which included testing the emergency response plans and procedures learned from the June 14, 2005 tsunami warning; testing the new California Warning Center Notification System; and evaluating response to radiological release including testing the coordinated efforts to mitigate consequences and protect public health and safety. The exercise scenario included loss of offsite power, a large break loss of coolant accident (LOCA) and fuel damage which led to a radiological release.
The DCISC Fact-finding Team (FFT) began its observation in the Control Room Simulator (CRS) which was acting as the Control Room for the exercise; the Technical Support Center (TSC); the Emergency Operations Facility (EOF; and the Joint Media Center (JMC) to observe media briefings and receive event news releases.
The News Releases appeared accurate and well-worded. The DCPP and County news releases appeared informative, accurate and timely. DCPP’s news releases concentrated on plant status, mitigation efforts, and radioactive releases. The county provided information on protective actions, emergency broadcasts, schools, and agricultural actions.
As it has stated in previous reports on DCPP emergency drill observations, the DCISC FFT believes that the use of a single spokesperson, preferably an officer, would improve providing messages to the media. This is because officers are generally more experienced at providing information in a concise, mostly non-technical, and contextual manner. DCPP has agreed with this approach on an "as needed" basis (see DCPP response to DCISC recommendation above). Jim Becker, Vice President and Plant Manager, appeared at the JMC but in a limited role.
The FFT observed the JMC critique following the end of the event. The critique focused on whether DCPP met its previously-stated objectives. Generally, all objectives were met or “met with comment”. In the latter case, DCPP participants believed that
- some information on radiation releases and levels was not timely,
- spokespersons didn’t consistently respond to media questions or provide promised follow-up information, and
- at times too much technical information was provided.
Following the exercise, DCPP reported that NRC concluded that DCPP "effectively demonstrated the ability to implement its Emergency Plan" and did not identify any issues not already identified by DCPP. FEMA provided favorable comments regarding DCPP, State, and County performance.
DHS and FEMA’s team of 25 evaluators concluded at a post-exercise public meeting there were no deficiencies or open areas requiring corrective action, emergency response personnel were focused on actions to protect public health and safety. and PG&E personnel worked closely with SLO and State personnel in response to the scenario. There were no Areas Requiring Corrective Action (ARCA) identified.
The October 25, 2006 DCPP emergency preparedness exercise appeared to have been well-designed and challenging. DCPP effectively implemented its Emergency Plan during the exercise and performed a good critique. Two areas of DCISC concern were (1) difficulty in providing timely, accurate and understandable information on radiation releases to the media and public and (2) little or no use of a DCPP officer to represent the organization to the media and public.
Emergency Preparedness Update
The DCISC Fact-finding Team met with Mike Meko, Director Station Services, at the October 25-26, 2006 Fact-finding Meeting (Volume II, Exhibit D.3, Section 3.5) and at the December 14-15, 2006 Fact-finding Meeting (Volume II, Exhibit D.5, Section 3.4) for an update on DCPP Emergency Preparedness (EP).
Because of perceived low priorities, Emergency Preparedness (EP) was having difficulty obtaining engineering and maintenance support to improve its equipment reliability, except for Technical Specification and other similarly important items; however, EP is working with Security, which is having similar problems, to develop a joint solution. There have been no results to date. EP is developing leads for its facilities (e.g., Technical Support Center, Emergency Offsite Center, Joint Media Center, etc.) to assure attention to their needs. Overall, EP equipment and facilities are in a stable condition but not improving.
EP will continue its normal drill schedule in 2007 and work on improvements for 2008. It is developing a five-year comprehensive EP plan in late 2006 or early 2007. The plan will address all open EP issues and needed improvements and, along with DCPP, work toward becoming the best in the industry. Included in the plan will be actions to address the recent biennial EP assessment. The DCISC should continue to follow DCPP EP plans and actions.
The DCISC Fact-finding Team reviewed the Emergency Planning Health Report for the Third Quarter 2006. Overall health (scored at 68) had declined to Red (Score < 76) since the First Quarter 2006. The individual cornerstones contributing to the overall program health were as follows:
| Monitored Parameter | Criteria | Color | Comments |
|---|---|---|---|
| EP Personnel | Right personnel with the right skills in the right positions to manage the program. | Yellow | - EP leadership lacks experience & knowledge - EP staff vacancies - No clear succession plan |
| EP Program Infrastructure | Quality of infrastructure to support EP Program | Red | - Many Emergency Response Organization (ERO) vacancies - No Long-Term Plan for equipment health - Drill development & implementation needs improvement - Drill Director position vacant |
| EP Program Implementation | How well programmatic requirements executed | Yellow | - Drill performance issues NCR- actions still open |
| EP Equipment/Related Plant | Health of EP components | White | - Equipment health |
Each of the above Cornerstones has three or more sub-cornerstones which are monitored and measured. Their scores roll up to cornerstone scores which in turn roll up to the overall program score. This health measurement tool appears appropriate.
To drive improvement on the above program DCPP has developed a comprehensive "Emergency Services Long Term Plan." The LTP is a three-year plan (Mitigation [2006], Stabilization [2007], and Improvement [late 2007 and beyond]) to take EP into the top quartiles and deciles in the nuclear industry. The LTP contains an EP Action Plan comprised of 26 action items (many with sub-items) with responsibilities, estimated completion dates and progress indicators. The action items align to the above Program Health Cornerstones. The plan appears comprehensive, aggressive and actionable.
DCPP Emergency Preparedness appeared generally satisfactory through the First Quarter 2006. Third Quarter 2006 through Second Quarter 2007 Emergency Plan Health showed unsatisfactory (Red) health. DCPP has developed a comprehensive three-year Long-Term Plan with actionable, aggressive, and measurable action plans for dealing with the health issues. The DCISC will continue to follow these plans.
Emergency Classification and Activation for Security Events
Note: due to the sensitivity of nuclear plant security, information classified as “Safeguards Information” cannot be presented in this report, thus limiting the breadth and scope of the report.
The DCISC Fact-finding Team met with Bob Waltos, Manager of Emergency Services, at the October 25-26, 2006 Fact-finding Meeting (Volume II, Exhibit D.3, Section 3.5) to review the Emergency Preparedness classification and activation process for security-type events.
Following the September 11, 2001 terrorist event, the NRC issued a number of orders requiring upgraded security measures and features at domestic nuclear power plants. The DCISC has reviewed these orders and DCPP’s responses in previous Fact-finding meetings and has found DCPP’s responses satisfactory.
One NRC Order required nuclear plant operators to incorporate security events into their Emergency Preparedness classification and activation plans. DCPP implemented that requirement by revising its Emergency Classification and Emergency Plan Activation Procedure. The procedure describes accident classification guidelines and Emergency Plan activation responsibilities. It identifies the four Emergency Action Levels (EALs) of emergency classification (Unusual Event, Alert, Site Area Emergency, and General Emergency) based on the severity of such events as fires, fuel or reactor vessel damage, fuel handling accidents, release of radioactive material, loss of control room, loss of engineered safety features, loss of off-site electrical power, natural phenomena, primary or secondary system leaks, reactor protection system failure, and other hazards.
The added security event EAL classifications of security threats are as follows:
1. Unusual Event
- Security threat or attempted entry or attempted sabotage, or
- A credible site-specific security threat notification, or
- A validated notification from the NRC providing information of an aircraft threat.
2. Alert
- Ongoing security compromise, or
- A validated notification from the NRC of an airliner attack threat < 30 minutes away, or
- A notification from the site security force of an armed attack, explosive attack, airliner impact, or other “hostile action” within the owner controlled area.
3. Site Area Emergency
- Imminent loss of physical control of the plant, or
- A notification from the site security force that an armed attack, explosive attack, airliner impact, or other "hostile action" is occurring or has occurred with in the protected area.
4. General Emergency
- A “hostile force” has taken control of plant equipment such that personnel are unable to operate equipment required to maintain safety functions.
The procedure includes definitions of a number of security terms used, such as hostile action, explosion, intruder, sabotage, etc.
The procedure appears satisfactory for determining the EALs for various security events. Other Emergency Preparedness actions, activities, and responsibilities are included in the remainder of DCPP’s Emergency Plan and implementing procedures.
DCPP also developed three new casualty procedures for site specific security threat responses and actions. The DCISC will review these procedures in a future Fact-finding meeting.
DCPP’s procedure revision for determining Emergency Action Levels (EALs) and activating their Emergency Plan for security events appears satisfactory.
Emergency Evacuation Plan
The DCISC Fact-finding Team met with Bob Waltos, Manager Emergency Services, at its March 21-22, 2007 Fact-finding Meeting (Volume II, Exhibit D.7, Section 3.7) to discuss emergency evacuation plans for DCPP. The purpose of this review was to follow up on an evacuation concern expressed by a member of the public at the January 31 – February 1, 2007 Public Meeting (Volume II, Exhibit B.6).
DCPP has had an Emergency Plan (EP) since initial plant operation. The plan includes actions to be taken at the plant and offsite facilities in the event of an emergency. It also includes notifications to and cooperation with San Luis Obispo (SLO) County, the State of California, and the Nuclear Regulatory Commission and others. The DCISC has determined that implementation of the emergency plan has been satisfactory, based on its observations of drills and exercises. The NRC is responsible for nuclear plant EP standards and for reviewing the EP and its implementation. DCPP’s EP and its implementation have been approved by the NRC.
SLO County is responsible for the protection of public health and safety outside the plant boundary, including planning, designing and implementing population sheltering and/or evacuation. The plan is reviewed every ten years in order to account/adjust for physical and population changes, as well as other demographic issues. The County Office of Emergency Services annually distributes to all residents an updated booklet titled "Important Emergency Information about Diablo Canyon Power Plant for San Luis Obispo Residents and Visitors."
The concern expressed at the Public Meeting was that the County or State is planning to replace the bridge leading from Avila Beach to Highway 101 thereby removing a major evacuation pathway for about a 10 month period. The Avila Beach resident questioned whether this had been incorporated into the evacuation plan and what alternate routes would be available.
Highways 1 and 101, running North-South, are the main routes away from the plant area. The bridge in question is on San Luis Bay Drive between Avila Beach Drive (leading from Avila Beach) and Highway 101. This is one of two major roads leading to Highway 101. There are an additional two residential streets (Ana Bay Road to Blue Heron Drive to Lupine Canyon Road in two directions) leading from Avila Beach to San Luis Bay Drive and to Highway 101. These alternate routes are discussed in the three documents below.
There are three pertinent documents produced or initiated by SCO County. These are
- San Luis Bay Drive Bridge Replacement Project (February 2007 Update) – This report describes the bridge work to be completed and addresses alternate emergency evacuation routes from Avila Beach. There is a county contact provided in the report
- San Luis Bay Drive Widening Project Detour Plan (map showing alternate evacuation routes from Avila Beach)
- 2006/2007 Grand Jury Report “Diablo Canyon: San Luis Obispo’s Katrina?” – this is a comprehensive study requested by the SLO County Office of Emergency Services (OES) to review the adequacy of the County Emergency Plan in light of the Hurricane Katrina event. It looked specifically at alternate evacuation routes from Avila Beach and recognized two additional routes (as described above). It also recommended that the County upgrade a dirt road, Cave Landing Road to Bluff Road, as a third alternate. The Grand Jury described SLO County as being “widely recognized as one of the best [emergency preparedness organizations] in the State of California and western region.”
The DCISC Fact-finding Team reviewed whether alternate evacuation routes were considered for the temporary bridge removal on part of the main evacuation route from Avila Beach. Both the County and Grand Jury identified alternates which both currently exist or could be made available. The Fact-finding Team recommended to the DCISC that it respond to the person with the concern, include the pertinent documents, and direct that person to the corresponding County contacts. A response dated May 17, 2007 (Volume II, Exhibit G.2, Page G.2-48) was sent to the member of the public with the evacuation concern.
QPAR Measures of Emergency Preparedness Program Health
DCPP Emergency Preparedness (EP) Program Health declined to Unsatisfactory (Red) performance in the second quarter 2006 and continued Red through the first quarter 2007. Prior NRC Performance Indicators also showed declining performance. The second quarter Quality Performance Assessment Report (QPAR) indicated positive steps had been made, but that it was too early to see the full results of changes because a significant amount of improvement is needed to regain program health. The DCISC is monitoring these initiatives but is concerned about DCPP’s attaining and sustaining satisfactory health.
4.7.3 Conclusions and Recommendations
- Conclusions:
- The DCPP Emergency Preparedness Program appeared unhealthy (as evidenced by Quality Performance Assessment Report (QPAR), equipment issues, and other DCPP measures), but improving due to a successful emergency exercise, improvements specified by a Long-Term Plan, and NRC evaluation results. The DCISC has a concern about this program and will closely follow PG&E’s progress in this area.
- Recommendations: None