ML20033B555
| ML20033B555 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 11/16/1981 |
| From: | Lundvall A BALTIMORE GAS & ELECTRIC CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8112010518 | |
| Download: ML20033B555 (7) | |
Text
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B ALTIMORE G AS AND ELECTRIC COMPANY P.O. BO X 14 7 5 gd h
h B A LTI M O R E, M A RYLAND 21203
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0 1981
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November 16, 1981 f6 3
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U.S. Nuclear Regulatory Commission Docket Nos. 50-317 Office of Inspection & Enforcement 50-318 Region 1, 631 Park Avenue King of Prussia, PA 19406 ATTENTION:
Mr. Ronald C. Haynes, Director
REFERENCE:
Letter dated November 6,1981, to Mr. A. E. Lundvall, Jr.,
from Mr. R. C. Haynes; NRC Emergency Preparedness Implementation Appraisal Gentlemen:
In response to your referenced letter concerning emergency preparedness, please be advised of the following:
Item 1 Commitment:
Review and revise the appropriate Abncrmal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs) to include a clear description of Emergency Action Levels (EALs), so that operating personnel will recognize the emergency situation and can effectively and expeditiously implement appropriate Emergency Response Plan Implementiag Procedures (ERPIPs).
This will be accomplished by November 1, 1981.
l
Response
Following a review of all appropriate procedures, AOPs Nos. 6, 8, and 10; and E0Ps Nos. 3 and 7 were revised to incorporate references to the Calvert Cliffs ERPIPs. These revisions vere reviewed and approved by the Plant Operations and Safety Review Committee (POSRC) on October 28, 1981.
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4 Mr. Ronald C. Haynes November 16, 1981 Item 2 4
i Commitment:
8 Determine which emergency response and other necessary Operations personnel must perform essential duties in locations where significant airborne radio-active contamination can be present during emergency conditions.
Determine the availability and storage locations of appropriate respiratory protection equipment (self-contained breathing devices).
Insure that the personnel are j
- provided with the appropriate respiratory protection.
This will be accomplished by November 16, 1981.
3 Respense:
1 On November 1, 1981, we completed an evaluation of the Self-Contained Breathing Apparatus (SCBA) requirements to support our emergency preparedness plan. A copy of that evaluation is available for your inspection. Based on the evaluation we have determined that it is necessary to purchase 44 additional BIOPAK-60P SCBA units and 277 additional spare air bottles. We have also determined the proper storage locations for the additional SCBA's and spare air bottles.
A supplier has been contacted who can provide the additional respiratory protection equipment. These particular SCBA units and spare air bottles are available from the supplier upon receipt of a purchase order and we
. could expect to receive this equipment within the next forty-five (45) days.
Item 3 Commitment I
Complete training / retraining of all emergency response organization personnel (including the Plant Superintendent and Shift Technical Advisors) using qualified instructors and formal lesson plans, and ensure that they are able to perform their assigned duties effectively.
t This will be accomplished by November 16, 1981.
Response
The Calvert Cliffs Nuclear Power Plant's ERPIPs have been revised to be consistent with the training requirements detailed in the Emergency Response l
Plan (ERP). A review of training records has determined that emergency response personnel were trained by qualilled instructors. These instructors have now been certified.
In the future, emergency response training will be conducted by certified instructors and approved lesson plans will be used for initial and annual requalification training.
Appendix A.1 of the ERPIP will be revised to include only fully trained personnel. Provisions will be added to the ERPIPs for the periodic update of listing the team members.
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Mr. Ronald C. Haynes November 16, 1981 Item 4 Commitment:
Until your permanent post-accident sampling systems are operational in accordance with NUREG-0737 by January 1,1982, improve your present post-accident reactor coolant, containment atmosphere, and gas and particulate effluent sampling by performing the following:
Determine the plant conditions and resultant radiological conditions under which the post-accident sampling can be safely performed.
Revise the interim sampling procedures and modify the sampling equipment so that representative samples are obtained with as low personnel exposure as practicable.
Revise the interim sampling procedure to ensure that they are applicable to emergency conditiens as well as normal operating conditions.
Assure that analytical capability exists for handling high activity post-accident samples.
This will be accomplished by November 16, 1981.
Response
A.
Containment Air Sampling Permanently installed post-accident contamination sampling systems per NUREG-0737 should permit sample acquisition and analyses for hydrogen and gaseous radioactivity within acceptable personnel exposure limits.
The Baltimore Gas and Electric Company commitment date for this modification, including testing and training, is described in our October 23, 1981, letter to Mr. Darrell G. Eisenhut.
As an interim post-accident containment atmosphere sampling measure, the Chemistry Technician will enter the Auxiliary Building under an approved Emergency Work Permit (EWP) and grab an air sample from the gas analyzing panel on Auxiliary Building Elevation -10'.
While the sample will be handled in accordance with accident procedures, the obtainment of the sample would be by normal procedures. Post-accident sampling kits have been assembled and their storage location specified.
The EWP will restrict the exposure to the Chemistry Technician such that 3 rem per quarter will not be exceeded and entry will be denied where radiation levels ara greater than 300 R/hr since this function has neither live-saving, nor accident mitigation significance.
Mr. Ronald C. Haynes November 16, 1981 A.
Containment Air Sampling (Continued)
Post-accident radiation studies performed for Baltimore Gas and Electric indicate that in a worst-case-accident scenario, containment air sampling under the above stated criteria would not be possible.
It is expected, however, that the sampling and analyses could be performed by this interim procedure under most accident scenarios.
B.
Reactor Coolant Sampling Separate post-accident reactor coolant sampling and analyses procedures have been generated which incorporate floor plans and system drawings.
Conditions and prerequisites have been revised and special EWPs have been prepared as an administrative means of maintaining dose ALARA. The format of the sampling procedure was altered to synchronize the activities of the Emergency Reentry Monitoring Team member and the Liquid Release Monitoring Team member with the intention of maximizing sampling efficiency, health physics coverage, and communication with the Radiation Protection Director while minimizing time spent, and the dose received during sampling. A shielded quick-disconnect sample collection analysis device has been fabricated and tested. Analytical capabilities were considered. Reactor coolant sampling using these interim measures will not be possible under all accidet. scenarios.
Completed installation, testing, and qualification of modified permanent, post-accident sampling system is anticipated as described in the October 23, 1981, letter referenced supra.
Item 5 Commitment:
As you indicated in your August 10, 1981, letter to Mr. Robert A. Clark, there is a question on your part as to your capability to achieve the 30 and 60 minute staff augmentation times described in the February 18, 1981, letter to all licensees from D. G. Eisenhut, Director, Division of Licensing, U.S. Nuclear Regulatory Commission (Generic Letter 81-10). The NRC Staff is actively reviewing your proposed interim action in this area and has identified the need for additional documentation.
In this regard, conduct an evaluation or drill that assesses your capability to achieve the 30 and 60 minute staff augmentation time goals of Table B-1 of NUREG-0654, after the declaration of an emergency. The results of this evaluation or drill shall be forwarded to the NRC for review along with a description of planned compensatory measures for any augmentation goals not met.
This will be accomplished by November 16, 1981.
o Mr. Ronald C. Haynes
-S-November 16, 1981
Response
To evaluate Calvert Cliffs Nuclear Power Plant's capabilities to achieve emergency response staff augmentation times, travel times from home to the station were obtained from approximately two-thirds of our staff designated for response under the emergency plan. Additional time was added for preparations to leave home and security entrance procedures.
Travel times for the balance of those designated to respond under the emergency plan were estimated based on telephone exchange numbers. The results of this evaluation (included on the attached, modified Table B-1 of NUREG-0654) indicates that Calvert Cliffs Nuclear Power Plant could achieve a 30 minute staff augmentation time with a.30 probability following the notification of a declared emergency. Similarly, the evaluation indicates that we could achieve a 60 minute augmentation time with a.96 probability. To improve the speed with which notification can be made, a recall paging system and procedures were implemented October 30, 1981. Analysis of travel times will be used as an additional consideration when making emergency response staff assignments.
Very truly youps, f)
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Vice President - Supply AEL/DWL/gla cc:
J. A. Biddison, Esquire G. F. Trowbridge, Esquire D. H. Jaffe R. E. Architzel
e table B-1 titFEG-Of>54 tindified MINIMUM STAFFING R[ JIRIMINTS FOR NRC LICENSEES
~IMlNCIYAR7 OtTMANT TsuTnif r4CIIT-(Se7 n.S.)
q Position Title Capability for Additions Major Functional Area Location Major Tasks _
or E gertise 30 min 60 nin Totn18/ tianpower Y Plant Operations and Assessment of Shift Supervisor (SRO) 1 (1.00)
Shift foreman (SRO) 1 (1.00)
Operational Aspects temtrol Ro<nn Operators 2 (1.00)
Auxiliary Operators 2 (1.00)
[mergency Direction and Control (Emergency Shift Technical Advisor.
1 (1.00)
Shif t Super visor or Coordina tor)* *
- designated facility nuna ger Nntification/
Notify licensee, State 1 (0.20) 2 4 (1.00) 10 Conmm i c a t t ore * *
- local end Federal personnel & maintain conemmica tion Radiological Accident Emergency Operations Senior Manager
(*
1 Assessment and Support Facility (E0r) [,trector of Operational Accident Offsite Cose Senior Health Physics Assessment Assessment (IIP) Expertise 1 (0.30) 1 (0.86) 7 I
Offsite Surveys 2 (0.30) 2 4 (0.95) 22 El Onsite (out-of-plant) 1 (0.27) 1 3 (1.00) 22 E/
In-plant surv,eys it? Technicians 1 (0.27) 1 3 (1.00) 22 El Chemistry / Radio.
Rad / Chem Technicians 1
2 (1.00) 7 chemistry Plant System Technical Support Shift Technical Advisor Engineering, Repair and Corrective Actions Core / Thermal Hydraulics 1 (0.00) 1 (1.00) 8 Electrical Mechanical 1
1 (1.00) 8 I
1 (0.89) 18 Repair and Corrective Mechanical Maintenance /
Actions Rad Waste Operator 3 (0.97) 30 l
Electrical Nintenance/
1 (0.35) 1 2 (1.00) 17 Instrument and Control fl&C) Technician I (0.38) 2 (0.91) 34 a/ Coltum entitled "rotal" indicates probability of achieving full staff augenentation in 60 minutes for each Ibsitim Title or Fyrtise.
E/ nwr is defined ns the ntr+er of individuals assigned a Ibsition Title and/or possess specified exper+1se.
-] Team menbers may supplopent other teams.
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Table n-1 (contd) hWm-0654 thlified Position ilt'le Capabflity for Additions t Qor f unctional Area n Qor lasks or Expertise 30 min 60 min Total a_/
tt,nptwer b/
J Protective Actions Radiation Protection:
IfP Technicians 2 (1.00) 2 6 (1.00) 44 (In-Plant) a.
Access Control b.
IIP Coverage for repair, corrective af.tlons, search and rescue first-afd & firefighting r,
c.
l'ersonnel monitoring
' d;
,, Dosimetry 3s Firefighting local Support
- i.
Rescue Operations
-4 and First-Aid,
Local Support
$lte Access Control Security, firefighting Security Personnel and Personnel corminications, personnel Accountability accountability Total 11 (0.3) 15 41 (.96)
Notes:
For each unaffected nuclear unit in operation, maintain at least one shif t foreman, one control room operator and one auxiliary operator except that units sharins a control room may share a shif t foreman if all functions are covered.
May be provided by shift personnel assigned other functions.
Overall direction of facility response to be assumed by EOF director when all centers are fully manned. Director of minute-to-minute facility operations rem.ilns with s nlor manager in technical support center or control room.
"" flay be performed by engineering aide to shif t supervisor, n/ Coltum entitled ' Total" indicates probability of achieving full staff angnentation in 60 minutes for each Position Title or Fyrtise.
[/ thnpmer is defined as the ntrnier of individuals assigned a Position Title or possess specified expertise.
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