ML20004E248
| ML20004E248 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 06/08/1981 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| GL-81-10, TAC-12428, TAC-12429, NUDOCS 8106110405 | |
| Download: ML20004E248 (37) | |
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Northem States Power Company 414 Nicoilet Mall Minneapons. Minnesota 55401 Tewonone(612)330 5500
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1 Director of Nuclear Reactor Regulation l2; JUN 111981
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- _. i PRAIRIE ISLAND NUCLEAR CENERATING PLANT Docket No. 50-282 License No. DPR-42 50-306 DPR-60 Post-TMI Requirements for the Emergency Operations Facility (Generic Letter 81-10)
Our letter of April 8 furnished certain information for the subject requirement and further indicated that by June 1 we would be in a position to supply additional conceptual design information for your pre-implementation review. We also indicated that our June 1 submittal woula include expanded descriptions of the phased installation of emergency response f acilities to include 1981 installations.
Attached is the document package that constitutes our June 1 response information under the following format:
(1) General Description Emergency Resnonse Facility Implementation (2) Appendix A Technical Support Cent (
Phase I Detailed Description (3) Appendix B Emergency Response Facility Task Functions (4) Appendix C Generic Safety Assessment System-Conceptual Design Description For certain emergency response facility requirements, NUREG-0696 references the data sets presented in Regulatory Guide 1.97 (Rev 2) and our designs will be based on this guidance where practicable. However this action should not be construed as an NSP blanket commitment to all other aspects of that Regulatory Guide.
As indicated in the item (1) att nhment material under Phase III, we will furnish by December 1,1981 the balance of the conceptual design information for the upgraded emergency response facilities.
Also included will be an update on a realistic implementation schedule in lieu of the October 1,1982 date specified MOS 8106110 F
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i NORTHERN STATEO POWER COMPANY l
l Director of NRR June 8, 1981 Page t in Mr Eisenhut's February 18 letter (generic letter 81-10). Apparently the specified date is based on hardware equipment delivery lead times only and does not allow for design development and testing of new systems for backfit applica-tions, which activities must be included in our projection, h*
L 0 Mayer, PE Manager of Nuclear Support Services LOM/jh i
ec J G Keppler NRC Resident Inspector G Charnoff Attachment 1
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o NORTHERN STATES POWER COMPANY EMERGENCY RESPONSE FACILITIES PRAIRIE ISLAND NUCLEAR GENERATING PLANT CONTENTS (1)
General Description of Emergency Response Facilities Implementation Figure 1 - General Arrangement Plant Operating Floor Figure 2 - Technical Support Center Layout Figure 3 - Property Plot Plan Figure 4 - General Layout of Training Center Figure 5 - Classroom / EOF Section of Training Center Figure 6 - Routing from Prairie Island to General Office (2)
Appendix A - Technical Support Center Phase I Detailed Description (3)
Appendix B - Emergency Response Facility Task Functions j
(4)
Appendix C - Generic Safety Assessment System Conceptual Design Description l
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NORTHERN STATES POWER COMPANY POST-TMI REQUIREMENTS FOR THE EMERGENCY RESPONSE FACILITIES PRAIRIE ISLAND NUCLEAR GENERATING PLANT I.
General Description of Emergency Response Facilities Implementation In order to insure an integrated approach to the Emergency Facilities upgrade, a multi-phased program is being pursued.
The phases are broken up in a logical manner that balances needs for upgrading in a timely manner against uncoordinated additions of hardware and software to the facility which may satisfy individual narrow requirements, but in reality, may be detrimental to the overall safe operation of the facility.
The following is a general description of the phases.
De-tailed descriptions are contained in various sections of the report.
Phase I This phase will complete the upgrading of the physical portion of the Tech Support Center including habitability, HVAC, power supplies and an upgraded interim data acquisi-tion and display system.
Phase II This phase will complete the installation of a computer based dose assessment system that will include on-line availability of meteorological data and radiation release data.
This phase will also see the construction and ac-tivation of the permanent Emergency Operations Facility.
Phase III This phase wi.U include the completion of a complete data acquisition and display system in a final configuration for the control room and emergency response facilities.
This phase will include the replacement of the plant process computer and installation of a plant multiplexing system and computer driven control room enhancement system.
This phase will also include implementation of the results of the control room review that will be done in response I
to NUREG 0700.
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Phase I Detailed Description Attached in Appendix A is a detailed description of the It ir Phase I upgrading of the Technical Support Center.
intended that Phase I will result in a final configuration of the TSC in the functional areas of:
tiVAC, structural, shielding, power supplies and communications.
Ongoing studies may result in modifications to the facilities as described in this report.
Phase II Description Phsse II of the Emergency Response Paciliry upgraJe will consist of the installation of a computer based Dose This system will allow dose assess-Assessment System.
ment based on real time meteorological data and up-to-date The system will have CRT displays plant release data.
allowing access to dose assessment data in the control room, TSC, and EOF.
This system will meet the intent of NUREG 0654 and Reg Guide 1.23.
Also, as part of Phase the construction of a Training Center - Emergency II, This building Operctions Facility will be completed.
will house the permanent EOF for the plant.
Emergency Response Facility Task Functions II.
Attached as Appendix B are the task functions for the per-sonnel that will report to the various emergency response These task functions will be used to arrive facilities.
at a deteiled matrix of facilities required in the various By use of these matrices, it will be insured that ERF's.
the proper equipment and facilities are available for the individual to perform their functions.
Response Facility Design Description III.
Emergency A.
Technical Support Center The location and general layout of the facility is shown on attached Figures 1 and 2.
The TSC is loca-ted directly across the turbine hall from the plantThe control room entrance and on the same elevation.
description of the facility is as described in Appen-dix A.
B.
Operational Support Center The Operational Support Center is located in what is called the. Plant Operating Records Room.
It is loca-ted immediately adjacent to the main Control Room on the same operating level.
Its location is shown in attached Figure 1.
Communications between the Opera-tional Support Center, the Technical Support Center and Control Room will be handled by two extensions of the present plant telephone system.
The Operational Support Center will also be served by a multi-channel intercom system that will allow enhanced communication between the TSC, the OSC and the Control Room and all other stations served by this intercom system.
This room, while not as heavily shielded as the Control Room, is contained in a substantial structure that has significant concrete shielding.
C.
Emergency Operation Facility The permanent EOF
- will be located on site as shown on attached Figure 3.
This multi-use building will contain the plant simulator, plant training section, display, visitor center and administrative offices for the Training Department.
The general layout of the building is as shown on Figure 4 with the detailed laiout of the classroom - EOF section shown on Figure 5 with room square footages as indicated.
The portion of the building shown in Figure 5 is the s3ction c5 the building that meets the requirements for the EOF.
This section of the building is a concrete structure that contains sufficient shielding to meet NUREG 0696.
The ventilation system has an emergency mode of opera-tion that wi.1 pressurize the building with a HEPA filtration system.
The general layout of the build-ing's entrances and exits have been given consideration for operation of the building in an emergency mode.
Radiological monitoring and alarming will be provided for the EOF portion of the building.
Extensive commu-nications equipment will be installed in the building to provide primary and backup means of communicating with outside agencies, Headquarters Emergency Center, TSC and the Control Room.
1 For the EOF data displays, it is intended to provide the full capability of the computer based Dose Assessment System, and as part of Phase III, selected plant data displays will be available in the EOF.
The EOF portion of the building will be served by a dual Until this permanent EOF can be made operational an interim facility is now in use.
This interim facility is located 6.9 miles southeast of the plant in the city of Red Wing and is equippea to meet the functional requirements of an EOF.,
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source power supply for those services necessary to make the EOF functional.
Records for the use of the EOF will be contained in the administrative section of'the Training Department.
These records, while not in the habitability envelope of the EOF, will be I
accessible at all times through use of available pro-tective' measures and clothing.
e D.-
Headquarter Emergency Center - Backup EOF As indicated in Table 2 of 0696, a backup EOF is suggested if the' primary EOF is located within 10 miles of the plant.
As part of the Corporate Emer-l gency Response Plan, a Headquarters Emergency Center is provided for.
This HQEC will be manned for those I
emergency classes that require manning of the EOF.
Therefore, the HQEC is atrailable and functional during j
those times that the EOF is activated.
For those un-likely circumstances that could result in abandonment of the primary EOF, the HQEC.would function as the 1
backup EOF and would be able to assume the responsi-bility and functioning of the primary EOF. Because the purpose of the HQEC is to provide a corporate focal i
point for. monitoring of emergencies, the correct deci-sion making authority would be available L.n the backup EOF at any time the primary EOF would need to be aban-d doned.
The. location of the HQEC is on the 8th' floor of i
Northern States Power's corporate offices which are-located in downtown Minneapolis, Minnesota.
As shown on attached Figure 6, the location of the corporate offices are approximately 55 miles from Prairie Island and is one-half.the distance between our Monticello and Prairie Island plants. While this location exceeds the 10 to 20 miles suggested in'0696, it is felt that this additional i
distance is not a significant deviation.
It is antici-pated that the backup-EOF will be equipped with a output device from the plant Dose Assessment System.
i This will allow the backup EOF to perform the monitor-(
ing of the Dose projections 11f it is necessary to l
assume the role of the primary EOF.
Dedicated commu-i nications systems are-available in the HQEC.
Also a controlled set of the most significant plant l
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drawings is available in the Corporate Headquarters.
The location of'the HQEC is on'the same floor in the j
corporate headquarters as our System Dispatch Center.
i This location allows access to extensive primary and backup communication systems.
For'those cases where rapid transportation between the EOF and the HQEC may be necessary,. arrangements are being made for the use of a helicopter pad on an adjacent building to the J
Corporate Headquarters.
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IV.
Safety Parameter Display System Northern States Power is a member of a group of utilities who are jointly funding the development of a generic safety parameter display software system.
This system is described in detail in Appendix C and was presented to the NRC staff on May 14.
This system is being developed for implementation on the Emergency Response facilities data acquisition and display computer which will be part of Phase III.
The final version of SPDS that is implemented at Prairie Island will depend on the resuAts of the development, testing and veri-fication work that will take place with the generic SPDS system.
It is anticipated that final acceptance of the sys-tem will depend upon testing and verification performed at a simulator.
Northern States Power is evaluating and keep-ing abreast of other SPDS systems that are being developed to fully assess the overall status of various systems.
A final review and determination of the actual system to be implemented at Prairie Island will not be able to be com-pleted until late 1981.
The generic SPDS system presented in Appendix C is intended to be a status report on the present stages of development of this system.
The final configuration of the SPDS that will be installed could vary from the described system due to changes implemented during systen reviews.
It is intended for the final configuration of the ERF data display system that some version of the SPDS display will be available in the TSC and the EOF.
V.
Schedules Phase I The implementation of this phase is underway at this time.
Completion of the major portion of this phase is expected l
to take place by the end of 1981.
Phase II Detailed apecifications for the Dose Assessment System are being completed at this time.
As indicated in the regional meeting on NUREG 0654 and 0696, final NRC guid-ance on Dose Assessment and Meteorological Data Systems are being completed at this time.
In anticipation of these final NRC requirements being issued late this fall, we would plan on purchasing and installing a complete computer based Dose Assessment System in 1982.
We would anticipate having the system operational in late 1982 dependent on hardware and software availability.
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The construction of the Training Center - permanent EOF is underway at this time.
Completion of this facility is sche-duled-for Spring of 1982.
Therefore, is it anticipated that full operation of the permanent EOF should be available late in 1982.
The backup EOF (HQEC) is now functioning as a part of the upgraded Emergency Plan.
Dose Assessment for the primary EOF and backup EOF will be installed as the complete Dose Assessment System is implemented.
Phase III Phase III which consists of the permanent Data Acquisition and Display System for the Emergency Response Facility and the Control Room is dependent on many factors.
Because of the significance of placing new displays, output devices, printer, plotters, etc. in che Control Room, the approach to implementation of this phase must be carefully planned.
Our plans, at this time, are to proceed with specifying and procuring a replacement plant process computer that will have capabilities for supporting Co trol Room enhancements, including SPDS, possible safety system status monitoring and annunciator enhancement features.
To adequately specify, engineer and testout such a system is a long term undertaking.
The formal NRC requirements for the overall Control Room re-view are undergoing review and modification at this time.
As soon as these reviews and changes are made and the re-quirements and/or guidance are published, we intend to under-take the complete Control Room review.
The output of this review should provide final guidance for possible control Room changes.
Because of the complexities and long lead hardware items which are required for the final implementa-tion, we are unable to supply a complete schedule at this time for Phase III.
We do intend to provide updated status reports and clarification of our intended implementation method at six month intervals.
By December
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1981, we will be able to supply additional information on the final Data Acquisition and Display System including a update on schedule considerations.
To help us determine if our Control Room contains any serious deficiencies, we cooperated with an EPRI sponsored effurt to have a review completed on the plant Cont rol Room.
This review is completed at this time and we have received a preliminary report.
As we had anticipated, there are no major concerns associated with the Prairie Island Control Room.
Because of the demonstrated adequacy of the present Control Room layout and information display system, together with a lack of formal regulatory guidance, we are reluctant to commit to a schedule for control room modifications.
In order to give careful consideration to control bocrd modifications and additions, a full scale mockup is now being designed with construction to follow.
This tool will allow complete review and verification of changes before actual implementation.
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O APPENDIX A PRAIRIE ISLAND NUCLEAR GENERATING PLANT TECHNICAL SUPPORT CENTER PHASE I DETAILED DESCRIPTION I.
Interim Technical Data System The Technical Support Center interim technical data system is comprised of three systems:
A.
Unit 1 and Unit 2 process computer acquisition and display systems (Engineers Console)
B.
Babcock and Wilcox Transient Monitoring System (TMS)
C.
Offuite Dose Calculation System A.
Engineers Console The Engineers Console has access via a keyboard and output typer to all data points accessed by the plant processors.
In addition a " slave" CRT is provided to display a dedicated group and alarm group of parameters as selected by the control room operator.
B.
Transient Monitoring System TMS is comprised of two independent subsystems:
RECALL' and the Real Time Display System (RTDS).
RECALL is a dedicated " flight recorder" type data acquisition and recorder that captures initial plant data.
The TRDS subsystem provides instantaneous real cime plant informa-l tion at the technical support center.
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The display system provides the capability for real-time l
display or delogging of the Recall Recorder system tapes l
for off line historical analysis.
A " work-station" l
concept has been developed such that data is displayed l
using integrated peripheral devices suitable for detailed diagnostics and includes an alph-numeric CRT, graphic plotting CRT with hard copy output, a line printer, and two 3-point recorders. Standard displays include alph-numeric CRT display of parameter valves by system group-(
ings and graphic plots of parameter valves versus time l
with hard copy printout.
A printer is also svailable to provide hard copy of display parameter group..ags on the alph-numeric CRT.
In addition up to six points can be recorded on the two dedicated recorders.
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The RECALL data acquisition and storage function (RECALL Recorder System) obtains its inputs directly from the plant sensor interface and not the real time display system. The RECALL Recorder System continuously acquires and records plant data, and monitors for a defined event once per second.
An event is defined as a reactor trip.
Once an event is recognized, the system will not record over data that has been recorded one hour before the event, but will continue to record data after the event until manually stopped or the storage medium is unavail-able. The data is stored on two dual drive digital cart-ridge tape recorders.
The total storage capacity is approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of plant data.
If no fresh tapes are inserted the system will automatically protect data for one hour before the event and eleven hours afterwards.
Minimal operator attention is required except for periodic replacement of tapes after an event.
By periodic insertion of new tapes, data can be stored continuously.
Once an event has occurred, the tapes will sequentially and auto-matically eject and a Label Printer will eject appropriate labels with tape encoding. The system has an auto restart capability upon loss of power and uses a battery backed Real Time Clock.
Alarm contacts provided include " EVENT DETECTED", " TAPES NEED ATTENTION", "ONE HOUR OF TAPE REMAINING", and " RECALL STOPPED".
Steam Release Monitoring Computer Provided as a component of the TMS is a steam release monitoring computer which will compute upon initiation of an event signal radiation releases from the secondary steam system. The following steam release paths will be monitored:
1)
Steam Generator Safety Relief 2)
Turbine Driven Auxiliary Feedwater Pump Turbine Exhaust 3)
Steam Generator Power Operated Relief Valves 4)
Steam Dump to Atmosphere Valves The following data is plar.ned to be available through the Transient Monitoring System and Steam Release Monitor-ing Computer.
Unit 1& 2 Analog Points Primary Parameters 1)
T-Hot A 2)
T-Hot B 3)
T-Cold A A-2
4)
T-Cold B 5)
Przr Lev A 6)
Przr Lev B 7)
RX Pwr A 10)
RX Pwr B Reactor Parameters'A 1)
Rx Pwr A 2)
Rx Pwr B 3)
INCORE T/C 1A 6)
INCORE T/C 3A 7)
INCORE T/C 1B 8)
INCORE T/C 3B Containment Parameters 1)
CONTMT Pres A 2)
CONTMT Pres B 3)
CONTMT Lev WR A 4)
CONTMT Lev WR B 5)
CONTMT Lev NR A 6)
CONTMT Lev NR B 7)
RTR VEL Lev WR A 8)
RTR VSL Lev WR B 9)
H2 Monitor A 10)
H2 Monitor B RCS Leak Evaluation 1)
SI Flow A 2)
SI Flow B 3)
CONTMT Pres A 6)
CONTMT Pres B 7)
T-Hot A 8)
T-Hot B 9)
CONTMT HI RNG RAD 10)
H2 Monitor A A-3 t
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INCORE 1)
INCORE T/C 1A 2)
INCORE T/C 2A 3)
INCORE T/C 3A 4)
INCORE T/C 4A 5)
INCORE T/C 1B 6)
INCORE T/C 2B 7)
INCORE T/C 3B 8)
INCORE T/C 4B 9)
Rx Pwr A 10)
Rx Pwr B Steam Generator 1)
SG Pres A 2)
SG Pres B 3)
AUX FW Flow A 6)
AUX FW Flow B Radiation / Environmental 1)
CONTMT HI RNG RAD 2)
SHLD BLDG RAD 3)
LPA Stm Line RAD 4)
LPB Stm Line RAD Unit 1 & Unit 2 Steam Release Monitor Outputs 1)
Steamline Radiation Level l
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Total Steam Flow i
3)
Radiation Release Rate l
(only calculated after a Rtr Trip) l 4)
Integrated Steam Release l
(Manual Reset) 5)
Integrated Radiation Release l
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C.
Offsite Dose Calculation System The projected offsite dose rates at various distances from the plant can be calculated by two methods.
1) computer method and 2) hand calculation method when the computer or meteorological tower is unavailable.
Computer Method The computer method utilizes radioactivity release data from the Transient Monitoring System and meteorological data from a dedicated printer located in the Technical Support Center.
The following information is used to develop the dose projections:
TMS:
Steamline Radiation Level Total Steam Flow Radiation Release Rate Integrated Steam Release Integrated Radiation Release l
Met Tower Data:
Wind Speed Wind Direction Elevation Delta T Temperature Hand Calculation Method If the computer system or meteorological system is not available, hand calculation of offsite dose rates can be performed.
Meteorological data can be obtained direct-ly at the tower, additional backup data for wind speed and direction, and deviation of wind direction (for stability class information) can be obtained from instrumentation located in the control room.
I NOTE:
This method of offsite dose calculation will be replaced by the on-line computer based dose assess-ment system of Phase II.
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II.
Power Supplies Power supplies for the Technical Support Center peripherals j
are divided into two types:
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1)
Normal AC with a manual backup to a separate load center.
2)
Non-Interruptable AC Power, Normal AC Normal AC is supplied from a 480 volt bus powered from Unit 2 Station Auxiliary Transformer.
Trouble in the turbine main generator, main transformer or station auxiliary trans-former calling for isolation from the system would initiate a dead transfer of this bus from the station auxiliary trans-former to the Reserve (Startup) Transformer to provide power to this bus. Trouble on the bus causing loss of power to the Technical Support Center would require manual action to position a manual transfer switch to an alternate backup supply power from Unit 1 Station Auxiliary Transformer with automatic transfer to the Reserve (Startup) Transformer.
The following Technical Support Center equipment is powered from the normal AC supply:
1)
Ventilation System 2)
Humidification System 3)
Heating System 4)
Air Conditioning System 5)
Lighting 6)
Power Receptacles 7)
Real Time Display System Non-Interruptable Power Non-interruptable power is supplied by instrument bus /com-puter inverters.
Each inverter contains an associated rectifier permitting the inverter load to be normally fed from a 480 volt safety features A-C source with instantaneous non-interrupted trannfer to a battery on loss of the rectifier or A-C supply.
Ir.verter loads can also be transferred to an A-C minimum in-terruptable 480 volt safety features bus if the inverter fails or is removed for maintenance.
The following Technical Support Center equipment is powered from the non-interruptable power supply:
1)
Plant Telephone System 2)
Recall System 3)
Steam Release Monitoring Computer 4)
Intercom 5)
Multi-channel Radio Phone A-6
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III.
Records Availability As-built plant records that include general arrangement drawings, piping and instrument diagrams, piping system isometrics, electrical schematic wire and cable lists, and single line electrical drawings are available in the office area adjacent to the Tech Support Center.
These drawings are in the-form of aperture cards, microfiche, or hard copy.
Equipment for reading and printing the micrographics media are also included in this area.
Plant Operating Procedures, Plant Technical Specifications and Safety Analysis Report Operations Committee Minutes, and design change packages are also located in the area and can be immediately brought into the Technical Support Center.
If access to the area is prohibited because of radioactive airborne, suitable protec-tive gear is located in the Tech Support Center to allow retrieval of the desired information.
IV.
Communications Communications capabilities of the Technical Support Center will include several diverse systems.
These include:
a)
Multi-channel radio phone:
State and local offices, and survey teams b)
" Hotline" phones:
Dial telephones:
Onsite and offsite Communications NOTE:
Some of the lines will be part of NSP's micro-wave communications system and do not depend upon the plant telephone systen or the local telephone system.
d)
Intercom System:
Communication between several plant areas including the TSC, Control Room, OSC and several work stations throughout the plant.
e) 2-way and 3-way telephone networks:
Provides direct communication (auto-ring) for EOF-TSC-State, EOF-TSC-HQEC, etc.
V.
Structure The structure housing the Technical Support Center is an existing building constructed of concrete block and pre-A-7
cast concrete panels.
The entire structure is located inside the outside walls of the Turbine Building.
Protection is therefore afforded from the effects of high winds.
The TSC structure is located on the Turbine Operating Floor, which is some 40 feet above grade, so flooding presents no problem.
Additional modification may be necessary to afford better pro-tection from earthquake forces.
Further analysis of the struc-ture is continuing.
VI.
Habitability Sufficient protection from direct radiation has been provided by filling of the concrete block cells of TSC wall facing the i
containment buildings to meet the guidance of 0696.
l Airborne radioactivity protection will be provided by install-l ation of a pressurization type ventilation system which in-cludes particulate and charcoal filtering.
In addition, radiation monitoritig systems will be provided to indicate radiation dose rates and airborne radioactivity j
concentracions inside the TSC.
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s PRAIRIE ISLAND NUCLEAR GENERATING PLANT EMSRGENCY RESPONSE FACILITIES APPENDIX B TASK FUNCTION ANALYSIS This report has been written to delineate the function of, and tasks performed by, individuals who will normally report to the Technical Support Center, Emergency Opersting Facility, Operational Support Center and the Headquarters Emergency Center (Backup EOF) upon the activation of these emergency centers.
The Emergency Organization (both plant and corporate) is not mobi-lized during " Notification of Unusual Events", therefore the emer-gency facilities are not activated during events that come under this emergency classification.
Each of the tasks in this report are specified in various Northern States Power Company Emergency Plans and Implementing Procedures.
This report is intended to be a general discussion of the functions of individuals who will report to the ERF's.
This report will be used to assist in the design of the physical facilities to ensure that the design will support the neede of the emergency response organizations.
As a regulatory requirement we have implemented upgraded Emergency Plans and Procedures.
Efforts have been expended to make this descriptive report consistant with the above mentioned documents.
However, if differences are found, our commitment is to the Plan and Procedure documents.
TECHNICAL SUPPORT CENTER Emergency Director The Emergency Director is the overall coordinating authority for Northern States Power Company at *.ne affected plant.
He has the responsibility and authority for managing the emergency effort within the piant.
He also manages the emergency effort outside the confiner, of the site until *.he near-site Emergency Operating Facility (EOF) is activated, and the corporate Emergency Organiza-l tion relieves him of his external tasks.
When notified of a problem, and after he familiarizes himself with the situation, the Emergency Director determines the classification of the emergency to be declared.
He directs the Emergency Plan to be activated and initiates the appropriate notifications for the class of emergency declared.
During Alert classifications, he l
assists the Emergency Manager in determining the necessity of mobi-lizing the sister plant's Health P'ysics personnel to act in the
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capacity of offsite survey teams.
If releases occur from the plant, offsite dose rate projections will l
be made.
If the results of the projections warrant sheltering or j
immediate evacuation of an area, the Emergency Director notifies the proper authorities and provides them with protective action recommen-t dations.
In all other circumstances, he ensures that radiological information is transmitted to state level authorities as soon as practicable, with periodic informatica updates.
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He determines the need for, and initiates the monitoring of onsite and offsite areas.
When the EOF is activated, he transfers responsi-bilities for offsite surveys to the Emergency Managar.
Regarding plant matters, the Emergency Director periodically consults with NRC personnel.
If the conditions of the emergency continue to deteriorate, he directs the escalation of the eme gency to the next higher classifi-cation and notifies the proper authorities.
If conditions warrant, he initiates onsite protective actions, from the use of anti-conta-mination clothina up to evacuation of the plant or site.
With the recommendation of the Superintendent, Radiation Protection, he can direct the use of a thyroi s blocking agent for Northern States Power personnel.
He is responsible for personnel accountability during the emergency, and initiates Search and Rescue operations as necessary.
The Emergency Director is responsible for the authorization of in-creased exposure for Search and Rescue personnel up to the maximum limits for the protection of life and property.
Utilizing all available pertinent data, he determines the conditions of evacuated plant areas and makes decisions as to the re-entry of affected areas.
When the emergency is stabilized and as conditions dictate, after review with the Emergency Manager the Emergency Di-rector de-cscalates the classification of the emergency and noti ies the appropriate offsite author. les.
TSC Coordinator The TSC Coordinator is a member of senior plant management and is responsible for the general operation of the TSC.
He establishes and maintains communications in the TSC and designates a communi-cator.
He is responsible for the monitoring of TSC habitability through the usc of equipment to measure direct radiation and airborne contamination.
He apportions office space in the TSC for all Emergency Organization personnel.
The TSC Coordinator is the interface with non-company personnel and coordinates the activities of plant and non-plant personnel at the TSC.
He is responsible for the maintenance and updating of the status boards in the TSC and periodically briefs personnel on the current status of the emergency effort.
He obtains technical assistance to support control room operations and controls the use of equipment in the TSC emergency locker.
Superintendent, Radiation Protection The Superintendent, Radiation Protection directs the efforts of the Radiation Protection Group.
This group is responsible for surveys (onsite and initial offsite), chemistry, contamination / radiation control, exposure control and the use of respiratory protection B-2
equipment.
He is responsible for making offsite dose projections as soon as possible in the event of a release from the plant, and any subsequent offsite dose assessments until the corporate organization at the EOF assumes this responsibility.
He makes recommendations to the Emergency Director concerning the authorization of additional exposure for Search and Rescue team members and in the use of a thyroid blocking agent.
Shift Technical Advisor The Shift Technical Advisor is on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day coverage, and is available to consult with the Shift Supervisor within a 10 minute period at all times.
He reports to the control room immediately when notified and assists the Shift Supervisor and Emergency Director in assessing the accident and other emergency conditions.
He advises the Emergency Director on the safety related aspects of the situation and on ways to improve the plant's capability for response to off-normal situations.
Communlcator The Communicator is responsible for the functioning and coordina-tion of the various means of communication in the TSC.
He trans-mits and receives information over the communications systems.
He records pertinent data transmitted to him and routes all other information to the appropriate person.
This position is filled by a person designated by the TSC Coordinato'..
Other Personnel The remaining Northern States Power Company personnel in the TSC consist of the Duty Engineer and other members of the Operations Committee.
The balance of the Operations Committee in the TSC is comprised of the following positions:
Superintendent of Maintenance
& Operations (who directs the Maintenance Group), Superintendent of Engineering & Radiation Protection (who directs the Engineering Group), Superintender. of Technical Engineering, Superintendent of Maintenance, and Supurintendent of Nuclear Engineering.
With the addition of administrative support, technical specialists and 5 NRC personnel the maximum staffing of the T.S.C.
should not exceed twenty.
It is the responsibility of these individuals to assist the Emergency Director and apply their expertise in their specific disciplines to support the emergency effort.
Although they may not be required to remain in the TSC, they report to the TSC and familiarize themselves with the needs of the Emergency Director.
They may then report to their work space to direct the efforts of their respective support groups if environmental conditions are satisfactory.
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EMERGENCY OPERATING FACILITY (EOF)
Emergency Manager The Emergency Manager position is staffed by a corporate call list of qualified individuals.
He is responsible to direct the corporate emergency response effort.
He manages the overall offsite support ef fort and supervises the Northern States Power Company personnel at the Emergency Operating Facility (EOF).
The Emergency Manager provides resources to the Emergency Director as he requests them.
Upon notification of an emergency at a nuclear plant, the Emergency Manager contacts the Eme:.gency Director to determine the extent of the emergency.
If the Emergency Director classifies the emergency as an Alert, the Emergency Manager determines the necessity of mobilizing the sister plant's Health Physics personnel to conduct offsite surveys.
He then proceeds to the affected plant's EOF and assumes control of the Corporate Emergency Organization.
He assigns personnel to fill positions in the Emergency Organization at the EOF.
He coordinates the efforts of the sister plant's Health Physics persc'nel and directs the gathering of offsite survey data.
If necessary, he requests the implementation of the Emergency Radiological Environmental Monitoring Program.
Using the data gathered by the offsite survey teams, he ensures offsite dose projections are performed.
He reports the results of the local pro-jections to Northern States Power management and state EOCs.
If projection estimates warrant, he provides recommendations to state and local agencies on the potentiel need for sheltering or evacuation of offsite areas.
The Emergency Manager supervises the logistic ef fort to supply the plant with personnel and equipment as required.
He provides technical support to the TSC and plant as the Emergency Director requests it.
The Emergency Manager is the interface with Northern States Power corporate management to obtain the necessary resources to support the emergency ef fort.
He obtains the services of outside vendors or consultants as is necessary and coordinates their assistance to i
support the plant during the emergency.
He advises Power Production Management at the Headquarters Emergency Center (HQEC) on emergency related matters at the plant.
He provides routine status reports to Power Production Management, state and local officials at the EOCs and the NRC.
He provides the technical i
input and review of press releases by public information personnel.
When directed by Power Production Managerant he provides technical l
support at t ess conferences called by the Communications group.
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In the event that the situation deteriorates to the point that EOF habitability warrants protective actions, the Emergency Manager directs the evacuation of non-essential personnel and the use of protective actions by personnel remaining in the EOF.
If radiation or contamination levels continue to increase, the Emergency Manager directs the evacuation of the EOF to the HQEC.
He notifies the proper authorities (HQEC, state and local EOCs) of his change in location.
If long term recovery needs dictate, through discussions with Power Production Management and the Recovery Manager, the Emergency Manager determines the need for mobilizing the Recovery Organization.
When conditions at the plant have stabilized, he and the Emergency Director discuss the reclassification or close out of the emergency.
If a i
recovery is dictated, he directs the turnover of the EOF to the Recovery Organization.
EOF Coordinator The EOF Coordinator-is responsible for the general operation of the EOF.
It is anticipated that he will be the first Northern States Power Company corporate representative to arrive at the EOF when notified.
As such, he is responsible for the initial startup of the EOF.
After the EOF has become functional, he acts as the Emergency Manager and may direct all offsite activities until a designated Emergency Manager arrives and relieves the Coordinator of those duties.
In starting up the EOF, he directs other personnel available to test the communication systems at the EOF and the habitability of the facility.
He directs the activities of the Security Force personnel and the recordkeeping personnel at the EOF.
The EOF Coordinator assists the Emergency Manager in obtaining vendor services.
He directs the activities of the Logistics Coordinator in providing logistical support for the plant and the EOF and sets up a shift rotation to keep the EOF manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day.
When the Emergency Manager declares the need for evacuating the EOF, the EOF Coordinator oversees and coordinates the actual evacuation of the facility.
He supervises the assembly of material to be re-moved to the HQEC (Alternate EOF).
The EOF Coordinator prepares reports to the Emergency Manager concerning the status of the EOF and any problems concerning EOF operations.
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1 Radiation Protection Support Supervisor He is a member of the sister plant's Health Physics Organization.
He directs the Radiation Protection Support Group that carries out all offsite radiological tasks requested by the Emergency Manager.
The Radiation Protection Support Supervisor advises the Emergency Manager on radiological matters, including data from the Radiological Environmental Monitoring Program.
Upon arriving at the EOF, he contacts the Radiation Protection Superintendent at the TSC and familiarizes himself with offsite activities in progress.
When this is done, he assumes control and coordination of the offsite survey teams, determining the necessary radiation protection equipment for all field personnel.
He dispatches survey teams to perform appropriate surveys to confirm dose projection results and to map the plume of any released radioactive material.
The Radiation Protection Support Supervisor provides the interface with state health officials to coordinate state and Northern States Power Company sirvey teams.
He directs the activities of the dose projection team and assists in calculations of offsite dose estimates.
He informs the Emergency Manager of the results of the projections and makes recommendations to the Emergency Manager on offsite protective actions.
He prepares status reports of operations in progress for the Emergency Manager.
If events at the site deteriorate to the point where a site evacua-tion is necessary, the Radiation Protection Support Supervisor recommends evacuation routes for plant personnel.
He supervises the monitoring of the EOF and routinely updates the EOF Coordinator on the habitability of the facility.
He directs the distribution of personnel dosimetry equipment to all personnel in the EOF and protective clothing, as necessary.
When the results of EOF monitoring are reported to him, he informs the Emergency danager when radiation or contanination levels in the EOF are above normal.
Based on this information, the Radiation Protection Support Supervi-sor makes protective action recommendations for EOF personnel.
If radiation levels reach the point that the Emergency Manager decides to evacuate the EOF, the Radiation Protection Support Supervisor determines evacuation routes to be used to lim..t personnel exposure and supervises teams for monitoring evacuated personnel.
Technical Support Supervisor l
l He supervises the Technical Support Group at the EOF.
The Technicc.
(
Support Supervisor supplies publications and prints nececsary for l
analysis of plant conditions and provides technical analysis as l
requested by the Emergency Manager.
He advises the Emergency l
Manager and Power Production Management on technical decisions l
affecting the emergency effort and performs other technical tasks as l
requested by the Emergency Manager.
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The Technical Support Supervisor is the interface between the Emergency Organization and the vendors and NRC techt:1 cal personnel at the EOF.
He provides information and direction for Technical Support Group personnel located at the HQEC.
Communications Coordinator The Communications Coordinator is responsible for establishing communications in the EOF and the overall coordination of all communications systems at the facility.
He verifies all methods of communications are functioning and arranges for the repair of any equioment as necessary.
He distributes and updates Communications Info:mation sheets, containing pertinent phone numbers.
Logintics Coordinator The Logistics Coordinator is responsible for coordination of tLe logistics effort necessary to support the plant, the EOF and the
,overall emergency effort.
As directed, he initiates and expedites the procurement process to obtain needed goods and services.
He notifies the affected plant's Nuclear Steam Supply vendor and Architect / Engineer of the emergency and provides the vendor response centers with t's information necessary for them to formulate their level of response.
If the vendors are needed for longer than three days, the Logistics Coordinator initiates procedures to procure their long term services.
He is also responsible for making the necessary living arrangements (food, lodging and transportation) for personnel at the EOF who are not able to commute to the EOF from their homes.
He arranges for food and other habitability items for personnel while working at the EOF.
Records The Records position is responsible for keeping complete and accurate logs at the EOF during an emergency.
As the logs are completed, he consolidates and files them to provide a permanent record of events and decisions taken at the EOF for the duration of the emergency.
He is also responsible for updating the EOF status boards as informa-tion is received from the plant.
Public Information Specialist The Public Information Specialist supervises the collection of information at the EOF for news releases.
He prepares news releases and obtains the Emergency Manager's approval of their technical content.
He then provides drafts of the releases to the Supervisor, B-7 l_
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i Media Information at the corporate headquarters.
He is the inter-face with media personnel at the facility and coordinates any news releases given to the press at the EOF.
(This news release point is not a normal interface and will only be used if unusual circum-stances dictate. The normal interface point with the press will be at corporate headquarters in Minneapolis.)
He also keeps the Emergency Manager informed of media activities in and around the EOF.
OPERATIONAL SUPPORT CENTER Operational Support Center Coordinator The Operational Support Center (OSC) Coordinator is responsible for the general operation of the OSC.
The senior Operations per-sonnel present (that is not in the control room) or a person designated by the Emergency Director will function as the OSC Coordinator.
The OSC Coordinator initiates the operation of the portable Area Radiation Monitoring equipment.
He verifies radiological monitoring of the OSC and control room environs is begun by the Radiation Protection Group.
He ensures continuous monitoring of the area monitoring equipment and establishes routine sampling of j
the OSC and control room atmosphere.
He coordinates the activities of plant personnel at the OSC to support plant operations as requested by the Emergency Director and shift supervisor.
The OSC Coordinator requests and notifies additional personnel as the need arises.
During evacuations, he directs the OSC accountability check and informs the Emergency Director of all personnel present.
He checks and maintains communications systems between the OSC, the TSC and the control room.
He controls the use of the reentry equipment in the OSC emergency equipment locker.
He also keeps personnel in the OSC informed of the current status of the plant and emergency effort by means of periodic information updates.
Radiation Survey Teams Emergency radiation survey teams are normally' composed of about.4 people.
Therefore, there is at least one person per team available at all times for each of the 3 teams that report to the OSC.
When the Emergency Director feels offsite surveys are warranted, two of uhe teams are delegated for offsite surveys.
They continue their offsite surveys until relieved by sister plant health physics personnel.
The remaining survey team begins onsite duties as necessary.
These consist of radiation safety, personnel and material decontamination, air or liquid sampling and analysis of onsite and offsite samples.
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Other Personnel The remaining personnel in the OSC have the responsibility to assist the Emergency Director and use their knowledge or direct their groups in such a manner as to support the emergency effort.
The remaining personnel consist of standby Operations personnel (any shift operators not presently on shift) who assist the Operations Group in all plant operationb and the assessment of operational aspects of the emergency.
The Maintenance Supervisor directs Mainte-nance Group personnel in damage control and emergency repairs.
The Instrument & Control Group Supervisor / Coordinator directs I & C Group personnel who are responsible for instrument damage control, repair and calibration.
The Chief Station Electrician also reports to the OSC, where he supports the emergency effort in any electrical aspects of the situation.
(BACKUP EOF)
HEADQUARTERS EMERGENCY CENTER (HQEC)
Power Production Management When notified of an emergency classified as Alert, Site Emergency or General Emergency, Power Production Management Personnel report to the Headquarters Emergency Center (HQEC).
The person in charge is responsible for the overall coordination of the corporate emergency response effort.
He serves as a focal point for relaying corporate rolicy decisions to the corporate emergency organization and provides plant status information to upper management.
He insures corporate resources are available to the plant in support of the emergency effort.
He coordinates EOF operations with the HQEC, Communications Department and the Environmental Regulatory Activities Department (ERAD).
He provides managerial support to the Emergency "anager as necessary and serves as a sole interf ace between the company executive management and the corporate emergency organization.
i The person in charge selects appropriate members of NSP management l
for advisory support.
He provides direction for the HQEC Technical Support Supervisor as to long term engineering analysis.
He assigns personnel to serve as interface between vendor representatives and the power production management organization.
The power production management organization procures funds to support Site, EOF and HQEC operations.
Also involved is the point of contact with the Institute of Nuclear Power Operations; authoriza-tion of information release to the Notepad system, and contacts j
with American Nucle Insurers.
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e Communications Supervisor This position is filled by the Director of Communications or his designee.
He coordinates the NSP public information efforts and advises Power Production Management.on public affairs related items.
He is the sole media representative for corporate manage-ment communication with the various media channels, although he may delegate this responsibility.
When notified of an emergency, the Communications super. visor insures the Communications procedure is activated and function-ing.
He provides a staff of Communications Representatives to prepare news releases and conduct press conferences.
Although the major NSP interaction with the media will be at the Media Information Facility, he directs a Communications Representative to report to the EOF to interface with any media that might arrive at that facility.
He coordinates the efforts of NSP Communications Representatives at the state Emergency Operations Center, the EOF and the Media Information Facility.
The Communications supervisor provides Communication Department support to Power Production Management at the HQEC.
He submits draf ts of news releases to Power Production Management for review and approval, and insures that requests by Power Produc-tion Management in the communications field are promptly acted on.
The Communications Supervisor directs the dissemination of news releases and situation reports and coordinates with Power Production Management to prepare for and conduct formal news conferences.
Technical Support Supervisor The Technical Support Supervisor directs personnel in the Technical Support Group to assist in engineering analysis as requested by Power Production Management.
The Technical Support Group is staffed from a call list of Northern States Power Company non-plant techni-cal personnel.
The Group advises Power Production Management on technical decisions and perform other tasks as required.
j The HQEC Technical Support Supervisor is the technical liaison with the EOF Technical Support Group.
He oversees the efforts of vendor engintaring groups retained by Power Production Management at the corporate offices.
He provides the technical information to Power i
l Production Management for release on the Notepad System.
When j
directed by Power Production Management, the Technical Support l
Supervisor interf aces with the Logistics Coordinator at the EOF to l
facilitate processing material or service requests from the EOF.
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Environmental Regulatory Activities Department (ERAD) Supervisor The ERAD Supervisor provides a NSP liaison with state and local government representatives.
He supplies timely information to Power Production Management about actions taken or planned by either of these government's agencies.
Advisory Support Groo, The Advisory Support Group is staf fed by appropriate management personnel as requested by Power Production Management.
This Group supplies a pool of knowledgeable management personnel to support the operations of the HQEC.
They advise on management and policy decisions concerning the emergency effort.
They also provide assistance and perform selected tasks as directed by Power Production Management.
Backup EOF For the unlikely occurren:e when the primary EOF is evacuated the HQEC will serve as the backup EOF.
As directed by the Emergency Manager, personnel from the EOF shall report to the HQEC.
Key personnel functional responsibilities shall remain as presented.
For the interim period during evacuation, Power Production Management and his staff have complete responsibil-ities for offsite activities regarding the emergency.
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APPENDIX C GENERIC SAFETY ASSESSMENT SYSTEM CONCEPTUAL DESIGN DESCPIPTION 1.0 GENERAL CONSIDERATIONS The Safety Assessment System (S AS) was designed to meet the requirements of the Safe'.y Parameter Display System (SPDS).
It provides a centralized, flexible, computer based data and display system to assist control room personnel in evaluating the safety status of the plant.
This assistance is accomplished by providing the operator and other Emergency Response Facilities (ERF) a high level graphica) display containing a minimum set of key plant parameters representative of the plant safety status.
More de-tailed plant information is provided by several secondary displays.
All graphical displays are presented to the Control room operator on high resolution multiple-color CRTs.
All data displayed by the SAS is validated if practical, by comparing redundant sensors, checking the_value against reasonable limits, calculating rates of change, and/or checking temperature versus pressure curves.
All displays of the SAS have been carefully designed by per-sonnel with plant operating experience and evaluated against human factors design criteria.
The concepts used in the SAS design will be validated by direct observation of licensed operators at a power plant simulator after extensive verification testing has been completed using data recorded from a similar power plant simulator.
The intent of the SAS is to present to the control room personnel a few easily understandable displays which use color coding and pattern recognition techniques to indicate off-normal values.
These displays are updated and validated on an I
l essentially real time basis.
The SAS will be operable during normal and abnormal plant operating conditions.
The SAS will operate during all SPDS re-l quired modes of plant operation.
Normal operations will encom-pass all plant modes above intermediate shutdown.
When the reactor coolant system is intentionally cooled belaw normal operating values the operator will select the heat up-cooldown mode which alters the limit checking algorithm f: : the key parameters.
An additional mode may be provided to address concerns of cold shutdown plant conditions.
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2.0 DISPLAY HARDWARE LOCATIONS AND OPERATION The SAS display system consists of a primary CRT and a support-ive CRT.
The primary CRT will contain the high level display during normal conditions and for the first few minutes during abnormal con-ditions.
A dedicated function button panel controlling the primary CRT will allow the operator to select from several predetermined supportive displays at any time.
This CRT is located in a central location of the control room neer the emergency operating station of the control room Senior Reactor Operator (SRO).
It will be dis-tinguished by its display content und central location.
l The secondary CRT can display any information available to the primary CRT.
This CRT may be located away from the primary CRT but within viewing distance of operators stationed at the aain control board.
This CRT will provide supportive displays or act as a backup device if the primary CRT should fail.
The SAS has been designed such that control room personnel can utilize its features without requiring additional operations personnel.
3.0 DISPLAY CONTENTS The primary display consists of bar graphics of selected para-meter values, digital status indicators for important safety system parameters and digital values.
The parameters indicated by bar graphs and digital values include:
RCS pressure, RCS temperature, pressurizer level, steam generator levels and steam generator pressures.
Items indicated by status and digital values include containment environment and secondary system radiation.
Inadequate Core Cooling indication (if available), core exit temperature, amount of subcooling and containment radiation are indicated by digital values.
In addition there is a small message area which will be used l
to indicate that an appropriate secondary aisplay provides further information in case an of f-normal val;e is detected or an event is occurring.
Each of the bar graphs indicatr.s. normal parametric wide-range values.
If a parameter's value is outside the normal range the bar color will turn red.
Arrows next to the bar will indicate the trend direction (increasing or descreasing) based on data smoothing algorithms.
The value for "RCS subcooling" will be titled with the word "Subcooled", " Saturated", or "Superheat" as appropriate.
During normal operation the message area will be used to dis-play average power, reactor core average temperature, date, time, and unit name.
These messages may be displaced by higher priority messages as required.
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i Secondary displays may be selected by the operator.
One group will contain trend graphs of groups of selected parameters, showing the last 20 minutes of plant operation.
These groups were chosen to keep like parameters or related parameters on one display "page".
Another group of secondary displays includes the alphanumeric values for each parameter and an arrow indicating the direction of change.
All of the secondary displays maintain the message area which noti-fies the operator of off-normal values on other "pages".
4.0 HUMAN FACTORS CONbaddRATIONS Human factors engineering and industrial design techniques have been effectively combined to establish man-machine interface ' aign requirements, maximize system effectiveness, reduce training and skill demands, and minimize operator error.
The CRT color graphic formats and functional key board designs have been developed through an interdisciplinary team of senior operational, human factors, industrial design and computer inter-face personnel.
Mimimum use of color combined with simplified form throughout the CRT presentation have been key design features to provide both normal and off-normal pattern recognition.
The operator, who is the end user, ha; 5een directly involved from the conception to insure that man-machine interface goals of SAS have been satisfied.
Human factor engineering standards and testing verification have been used which are consistant with accepted practices as recom-mended or specified by the NRC (NUREG/CR-1580; Supplement NU3EG-0659, AND NUREG-0700), Military (MIL-STD-1472 B, Human Engineering Guide to Equipment Design), aerospace, and participating individual utilities.
5.0 QUALITY ASSURANCE CONSIDERATIONS The SAS is implemented on a digital computer system which includes a peripheral display generator computer for color graphic displays.
The software that controls the sensor data validation, key parameter construction, and display formats has been developed under strict quality assurance procedures similar to those defined in Position 19 of NUREG-0388, " Safety Evaluation Report Related to Operation of Arkansas Nuclear One, Unit 2",
Rev. 1 and supplements.
The original development of the SAS software began with a functional specification that was developed over a period of 18 months by a technical committee comprised of members from a number of utilities and consultants.
These functional cpecifications will be transformed into a design specification that will be reviewed by an independent set of qualified utility personnel not involved in the original definition.
These reviews will assure conformance of the SAS to those functions of the SPDS discussed in NUREG-0696.
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selection of the primary display parameters will be a part of the final documentation.
During the course of software development, a set of static test cases will be developed which test the key features of each software module.
Furthermore, stati system test cases will be developed and used to verify the correct operability of the total system.
A set of dynamic test cases will be generated by capturing nuclear reactor simulator data on magnetic tape from a number of different plant transients which test the dynamic behavior of the system under "real" conditions.
Finally, an operator testing phase on a simulator is scheduled to validate the correct operability of the software and the man-machine interface.
A design review that compares these test results to the original functional and design specifications will be performed.
A selected number of the static test cases will be
" frozen" such that they could be used to verify future changes to the software.
In sur.imary, quality _ssurance was addressed and de-signed into the SAS software from the beginning to provide a highly reliable product and a mechanism for identifying and controlling future changes.
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