ML20039B589
| ML20039B589 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/07/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20039B584 | List: |
| References | |
| NUDOCS 8112230275 | |
| Download: ML20039B589 (17) | |
Text
c-TENNESSEE VALLEY AUTHOR!TK!90 PF'r CH ATTANOOGA. TENNESSEE 374o1
.N'tA 400 Chestnut Street Tower II S I 0 ' C it! A O: 53 December 7, 1981 Mr. James P. O'Reilly, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region II - Suite 3100 101 Marietta Street Atlanta, Georgia 30303
Dear Mr. O'Reilly:
This is in response to your letter to H. G. Parris dated November 6, 1981, Report Nos. 50-259/8*-19, -260/81-19, -296/81-19, Emergency Preparedness Appraisal, concerning activities at the Browns Ferry Nuclear Plant which appeared not to be in full compliacce with NRC requirements.
Enclosed is our response to Appendix A, Notice of Violation; Appendix B, Emergency Preparedness Deficiencies; and Appendix C, Appraisal Improvement Items.
If you have any questions, please call Jim Domer at FTS 858-2725.
Based on the enclosure, continued operation of the Browns Fcery Nuclear Plant is justified, and the operating licenses for Browns Ferry units 1, 2, and 3 should not be modified, suspended, or revoked.
To the best of my knowledge, the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY
.N>w
.M. Mills,hanager Nuclear Regulation and Safety Enclosure yDRADOCK112230275 811216 05000259 g
PDR An Equal Oooortunity Emplo, er
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3 ENCLOSURE RESPONSE TO NRC INSPECTION REPORT NOS.
50-259/81-19, 50-260/81-19, AND 50-296/81-19 L
JAMES P. O'REILLY'S LETTER TO H. G. PARRIS I
BROWNSFERRYNULEkRPANT i
i APPENDIX A Notice of Violation (50-259/81-19-29, 50-260/81-19-29, 50-296/81-19-29)
Technical Specification 6.3.A.8 requires that written procedures be established, implemented and maintained covering Site Radiological Emergency Plan. implementation.
Contrary to the above, the Technical Specification requirement for written procedures that implement the Site Radiological Emergency Plan was not met in that:
a.
There was no written procedure for use by the plant's Emergency Offsite Monitoring Tear. to provide initial offsite environmental assessment following an accident as required by Section 6.2.2.1 of the Browns Ferry Emergency Plan.
b.
There was no written procedure addressing implementation of exercises and drills required by Section 9.2.2 and 9.2.3 of the Browns Ferry Site Emergency Plan.
This is a Severity Level V Violation (Supplement I).
- Admission or Denial of the Alleged Violation a.
TVA admits the violation occurred as stated.
b.
TVA admits the violation o:xurred as stated.
Reasons for the Violation if Admitted a.
It was TVA's intent that offsite monitoring teams would all use the same procedure provided in the Muscle Shoals Emergency Control Center (MSECC) implementing procedures.
b.
A procedure to provide internal tracking for this and other Radiological Emergency Plan (BCP) commitments was in draft form at the time of the emergency preparedness appraisal but had not been completely implemented.
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h Corrective Steps Which Have Been Taken and 'Results Achieved
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a.
A procedure has been developed to direct the activities of the plant's emergency offsite monitoring team.
b.
A procedure for informing each plant of commitments and required performance dates has been developed. TVA contends that this cracking system will provide adequate notice to the plant of necessary drills and exercises. - The radiological emergency planning coordinator has been designated at each plant to provide coordination for commitments involving the plant.
Corrective Steps Which Will Be Taken To Avoid Further Violations The procedure for p. ant offsite monitoring teams will be implemented a.
and training will be provided to users, b.
The pr 2cedure for commitment tracking has been issued. The procedure provides for alerting the responsible organization 6-12 weeks in advance of the required performance date. If performance is not verified, automatic follogups are made until verification is received.
j Date When Full Compliance Will Be Achieved TVA will be in compliance by February 1, 1982.
a.
b.
Full compliance was achieved on October 2, 1981.
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. APPENDIX B
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Emergency Preparedness Deficiencies Item 1 (50-259/81-19-02, 50-260/81-19-02, 50-296/81-14-02)
The Browns Ferry onsite emergency ceganization had not been specified, in detail, down to the working level, and the functional responsibilities of onsite personnel were not well defined below the supervisory level. Due to the lack of apecific functienal responsibility assignments, specific training in radiological response had not been provided to all emergency organizational personnel. This deficiency is d!.scussed in paragraphs 2.1 and 3.1 of the enclosed report.
Steps Which Have Been Taken In an informal presentation made to NRC staff members from Region II and I&E headquarters in TVA offices in Chattanooga, on November 10,-1981, our pit.ns for fully describing the Browns Ferry onsite emergency organization were discussed and preliminary organization enarts were distributed for NRC information. Since this meeting, we have refined this organization and have outlined specific responsibilities for ea^h ksy position in the organization. We are presently drafting all necessary procedural changes to incorporate this organization and making changes in our training program to ensure that all members of the organization are aware of their responsibilities. However, TVA does not intend to assign specific emergency duties to specific individuals on shift, such as health physics technicians (other than thosc specific assignments such as site emergency director, already outlined in the implementing procedures). Instead, onshift personnel are trained as to specific responsibilities of their unit so that an individual can perform the various duties necessary to meet the unit responsibilities.
Stepa 'ihich Will Be Taken o
As was described to NRC in the above meeting, the defining of the emergency ort:nization will go through two major phases. The first realignmen, still provides for the site emergency director and a small staff to be i'cated in the Emergency Control Center (ECC) in units 1 and 2 control room, with NRC and additional licensee technical personnel to be located in the technical support center (TSC). The second phase will eliminate the ECC concept and move the onsite direction of any emergency to the TSC. Of course this will require a second realignment of the organization.
Schedule for Completion of Action Necessary procedures and training will be completed and the it'erim organization adopted by February 1, 1982. The final organization is presently scheduled to be in place by May 1, 1982. This final date is dependent on upgrading the communications in the TSC. However, we do not anticipate any problems in meeting this date at this time.
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' ;): Item 2 (50-259/81-19-07, 50-260/81-19-07, 50-296/81-19-07)
In the interim TSC, there was not sufficient work space available for the j
number of personnel assigned, there was inadequate communication to the control room and offsite centers, and there were no provisions to obtain i
control room data for analysis by the TSC staff. This deficiency is s
discussed in paragraph 4.1.1.2 of the enclosed report.
Steps Which Have Been Taken Data sheets were provided in our implementing procedures on October 27, 1981, for transferring control room data to the TSC staff.
Steps Which Will Be Taken i
As discussed in our response to deficiency 1, we are undertaking a phased program for development of our TSC. We are at present developing our organization, procedures, communications, and training programs to provide a suitable working environment in the TSC. We are also l
undertaking to move tre Division of Power System Operations (PS0) personnel presently located in the TSC to another location, thereby converting this space into an area exclusively used as a TSC. We are completing-our layout of the TSC; will draft necessary design change requests (DCR) to provide necessary layout and communications; and have ordered necessary furniture, blackboards, status boards, and other supplies.
Schedule for Completion of Action As discussed in the response to deficiency 1, we will have our interim i
j organization in the TSC in place by February 1, 1982, and our final communications and final organization by liay 1, 1982. However, this does not include the safety parameter display systems (SPDS) or TSC data I
system as required by NUREG-0696, which has been addressed in previous submittals to NRC.
Item 3.a (50-259/81 19-15, 50-260/81-19-15, 50-296/81-19-15)
With regard to the Browns Ferry methods and equipment for monitoring and assessing release of radioactive materials to the environment through the plant stack, there was no instrument available to monitor high activity releases through the plant stack in order to determine the magnitude of the release. This deficiency is discussed in paragraph 4.2.1.2 of the enclosed report.
Steps Which Have Beer Taken A new plant procedure is being drafted to use dose rates taken from effluent pipes at the stack for estimating stack release rates should existing stack radiation monitors fail or read off scale.
Steps Which Will Be Taken As stated above.
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i 1 Schedule for Completion of Action The procedure will be issued by January 1,.1982.
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l Item 3.b (50-259/81-19-24, 50-260/81-19-24, 50-296/81-19-24)
The Browns Ferry classification and emergency action level scheme did not i
provide procedures to relate radiation effluent monitor parameters to i
site boundary exposure rates in order to properly classify an accident L
. condition in accordance with Procedure IP-1.
This deficiency is discussed in paragraph 5.4.2 of the enclosed report.
l Steps Which-Have Been Taken
-Revisions to procedures IP-1, IP-3, IP-4, and IP-5 have been drafted which relate rr.diation effluent monitor parameters to site boundary exposure rates for accident classification. These procedures also j
provide for the estimation of site boundary doses by plant personnel before staffing of the MSECC. These classifications correspond to-the emergency classification exposure rates listed in NUREG-0654.
Gteps Which Will Be Taken As stated above.
Schedule for Comoletion of Action These procedure changes will be issued by January 1, 1982.
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. APPENDIX C Appraisal Improvement Items Item 1 (50-259/81-19-01, 50-260/81-10-01, 50-296/81-19-01)
Professional development training through formal courses or seminars In the area of emergency preparedness as not provided to the Emergency Planning Coordinator to maintain state-of-the art knowledge.
(1.0)
Steps Which Have Been Taken A professional development training course for the onsite emergency planning coordinator has taen budgeted for fiscal year 1982. The nuclear central office (NCO) has been requested to follow up on this item and make the plant aware of the availability of such a course. If an appropriate course is available, the onsite emergency planning coordinator will attend.
Steps Which Will Be Taken As stated a,bove.
Schedule for Completion of Action This item will be completed during fiscal year 1982, subject to course availability.
Item 2 (50-259/81-19-04, 50-260/81-19-04, 10-296/81-19-04)
An offsite environmental monitoring training program had not Deen implemented to, include lectures and walk-through field demonstrations on:
(1) collection and movement of essential radiological equipment and instruments to the dedicated environmental van, (2) plume monitoring, (3) dose limitations, (4) communications, (5) possible dose rates from (in) plumes at preestablished monitoring stations, and (6) use of the single channel analyzee for determining I-131 concentrations in the field.
Steps Which Have Been Taken A training program for field team personnel has been established and training conducted for plant offsite monitoring personnel.
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Steps Which Will Be Taken As stated above.
Schedule for Completion of Action
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This item is compleLe.
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,- l Item 3 (50-259/81-19-05, 50-260/81-19-05, 50-296/81-19-05)
An in-plant Browns Ferry health physics training course for both health h
physicists and technicians had not been provided to includ, lectures and wal.<-through demonstrations covering:
(1) pocsible ine' eases in dose-rates (on a location-by-location basis), (2) dose limitations and the
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appropriate supporting dosimeters and instruments appliosble to the full range of postulated accidents.
(3.1)
Steps Which Have Been Taken Procedures are being developed to direct plant personnel in performing onsite radiological surveys.
Steps Which Will Be Taken l
l Training will be provided to appropriate personnel.
Schedule for Completion of Actions The proceiure will be implemented and training complete by July 1, 1982.
nem 4 (50-259/81-19-09, 50-26p/81-19-09, 50-296/81-19-09)
There were no portable radiation survey instruments located in the emergency kits available tc OSC personnel, and there were no previsions
.to make health physius technicians and portable instruments readily available to teams which may be dispatched froul the O'3C. (4.1.1 3)
Steps Which Have Been Taken a'
After study it was decided that storing portable radiation survey
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instruments in emergency cabinets did not provide the best instrument j-reliability for emergency use. As stated in IP-4, paragraphs 4.2, 5 3, and 6.2, an ion chamber survey instrument will be taken to ECC, TSC, and OSC for use when these centers are activated.
Steps Which Will Be Taken IP-14 will be reiised to include a statement similiar 4 the following:
" Health physica personnel will periodically survey the LCC, TSC, and OSC. A health physics technician will accompany any personnel dispatched into areas of potential hazard."
Segedule for Completion of Action j
Revisions to IP-14 will be completed by February 1, 1982.
Item 5 (50-259/81-19-10, 50-260/81-19-10, 50-296/81-19-10) 1 I
I BFN-IPD-14 did not specify the procedures to be followed by Health Physics personnel in setting up checkpoints at the assembly areas.
j (4.1.2.1) if
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Steps Which Have Been Taken
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IP-8 was revised on October 6, 1981, and IP-14 ca October 27, 1981, to i
e specify that the health physics (HP) checkpoints would be cvincident with 4
the site access control points established by public safety service.
Steps Which Will Be Taken IP-14 will be revised to include a statement similar to the following:
" Health physics technicians will survey all vehicles and personnel with RM-14 friskers and smear techniques prior te release."
d Health physics personnel will be directed to the assembly areas by the radiation control supervisor.
Schedule for Completion of Action Revision of IP-14 will be completed by February 1, 1982.
Item 6 (50-259/81-19-11, 50-260/81-19-11, 50-296/81-19-11)
Alternate assembly areas were not designated for use in the event of high radiation levels or inclement weather at the primary assembly areas.
(4.1.2.1 and 5.4.3.2)
Steps Which Have Been Taken IP-8 was revised on October 6, 1981 to designate alternate assembly areas in the event of high-radiation levels at the primary assembly areas. We do not plan on making any changes regarding designation of an alternate-assembly area as a result of inclement weather as there is no other suitable facility nearby that TVA can control for this purpose.
Steps Which Will Be Taken As stated above.'
Schedule for Completion of Action The revirion to IP-8 was completed on October G, 1981.
Item 7 (50-259/81-19-12, 50-260/81-19-12, 50-296/81-19-12) 1 f
Provisions for decontamination had not been est ablished at a locction closer to the plant than the ';illson Hydro Plant to accornodate the reentry of necean w v,.c/ps nel Onsite.
(4.1.2 3)
Steps Which Have Been Taksi)
TVA has reviewed alternative locations for offsite decontamination.
There are no facilities suitable for decontamination closer than the designated area at Wilson Dam.
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. Steps Which Will Be Taken As stated'above.
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! Schedule for Completion of Action This item was completed on December 1, 1981.
Item 8 (50-259/81-19-13, 50-260/81-19-13, 50-296/S1-19-13)
Tae overcrowded TSC will not properly accommodate the. relocation of the HP laboratory and associated personnel.-(4.1 3)
Steps Vhich Have Been Taken We have identified an alternate area for relocation of the HP laboratory
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and associated personnel.
Steps Which '4111 Be Taken 4
IP-14 will be revised to specify the alternate HP area.
Schedule for Completion of Action IP-14 will be revised by February 1, 1982.
Item 9 (50-259/81-19-14, 50-260/81-19-14, 50-296/81-19-14)
The Emergency Kit inventory list and procedure.s did not include silver zeolite'for iodine collection.
Steps Which Have 3een Taken Silver zeolite cartridges have been placed in the REP van.
Steps Which Will Be Taken Ten silver zeolite cartridges will be added to the inventory listing for the REP van and health physics laboratory.
Schedule for Completion of Action Inventory listing changes in the implementing procedures will be completed by February 1, 1982.
Item 10 (50-259/81-19-16, 50-260/81-19-16, 50-296/81-19-16)
The note in E0I-12 Section E allows the radiation monitor to go off scale before operator actions are taken. (4.2.1.2)
Steps Which Have Been Taken E0I-12 was changed on August 11, 1981 to correct this problem.
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. Steps Which Will Be Taken As stated above.
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- Schedule for Completion of Action Tne revision to E0I-12 was completed on August 11, 1981.
Item 11 (50-259/J1-19-17,50-260/81-19-17,50-296/81-19-17)
There was no " note" in E0I-12 to call Chemistry for a confirmatory l
measurement should the stack monitor fail to work, or read off-7cale.
(4.2.1.2)
Steps Which Have Been Taken A step has been added to E0I-12 which requires the operator to notify radiochemistry for a confirmatory sample whenever abnormally high stack radiation levels are enc;untered.
l Steps Which Will Be Taken As stated above.
Schedule for Completion of Action Procedure changes were completed on August 11, 1981.
Iten 12 (50-259/81-19-18, 50-260/81-19-18, 50-296/81-19-18)
The mareorological data recorders in the control room area were not properly maintained (e.g., timing) and annotated to facilitate the use of data (e.g., wind direction from which the wind is blowing and atmospheric stability conditions). Engineering units were not found.
(4.2.1.4)
Steps Which Have Been Tch9n
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Plant operators have been instructed to ensure charts are installed correctly, working properly, and have proper time setting in accordance I
with section instruction letter No. 16. This information will also be included on the radiation release rate monitoring system (RRRMS) (see response to item 13).
Steps Which Will Be Taken I
As stated above.
Schedule for Completion of Actions Instructions wara issued August 3, 1981.
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I, tem 13 (50-259/81-19-19, 50-260/81-19-19, 50-296/81-19-19)
The temperature difference measurements are recorded on inappropriate I
recorders; le, range: -30 to + 3000 on a 6 inch wide chart. Recorders that allow a u;er to differentiate among atmospherig stability conditions; eg, -50C to +100C on a 12 inch wide chart, are more appropriate.
(4.2.1.4)
Steps Which Have 3een Taken TVA has previously recognized potential shcetcomings with these charts.
Desigt. Change Request (DCR) 728 and Engineering Change Notice (ECN) L2117 have been written to place this information on the RR3MS computer.
Steps Which Will Be Taken As described above.
Schedule for Comoletion of Action The modification is presently scheduled for performance in November 1983 Item 14 (50-259/81-19-20, 50-260/81-19-20, 50-296/81-19-20)
The emergency communication systems at the Browns Ferry TSC, the MSECC and the CECC are not yet complete.
(4.2 3)
Steps Which Have Been Taken i
l As discussed with NRC representatives in a meeting in TVA offices in Chattanooga on November 10, 1981, we are presently preparing necessary DCR's to upgrade our communication facilities in the Browns Ferry TSC.
Stops Which Will Be Taken The above modifications are being coordinated with our present outage schedule and South Central Bell and will be completed as soon as possible.
Schedule for Completion of Action Upgrade of the TSC communications are scheduled for completion by May 1, 1982.
1 Item 15 (50-259/81-19-21, 50-260/81-19-21, 50-296/81-19-21)
BFN-IPD-14 does not reference the i aable health physics standard instructions used during postulate,. ergencies nor the changed
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1 provisions to assure applicability during an emergency.
(5.1)
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Steps Which Have Been Taken p
I BFN-IP-14 is beir.g revised to refe.rence appropriate standard health
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physics instructions for emergency operations.
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Steps Which Will Be Taken As stated above.
Schedule for Completion of Action IP-14 will be revised by February 1, 1982.
Item 16 (50-259/81-19-22, 50-260/81-19-22, 50-296/81-19-22)
The BFN-IPD-1. seismic event criteria did not conform to existing seismic monitoring capabilities nor the operating procedure concerning the 0.2g Action Level criterion.
(5.2)
Steps Which Have Been Taken IP-1 was revised on detober 6, 1981 to correct this problem.
j Steps Which Will Be Taken L
4 As stated above.
Schedule for Completion of Action
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_The revision to IP-1 was completed on October 6, 1981.
Item 17 (50-259/81-19-23, 50-260/81-19-23, 50-296/81-19-23) l Guidance was not provided-in the notification procedures to maintain the 7
NiiC ENS line open between the control room and the NRC throughout the i
course of the accident unless specifically terminated by the NRC.
(5.4.1)
S_teps Which Have Been Taken h[
The present r9vicion of IP-f (October 6,1981) specifies to maintain an open line until released by NRC.
The present revisions of IP-3 (October 6,1981), IP-4 (October 6, 1981),
and IP-5 (July 21, 1981) also specify to maintain an open line until released by NRC, but also contain an a.lditional statement, " Communication with NRC by ringdown phone will only be used until CECC is manned. CECC I
will then handle further communications with NRC." This description was based on our misinterpretation of the use of the red phone during long-term emergency operations, i.e.,
that the NRC red phone was for notificaticn only. However, as discussed in the inspection report, onshift personnel are aware of the necessity of maintaining an open line f
until terminated by NRC.
- l q Steps Which Will Be Taken q
In the present revision of procedures to change our emergency organization, we are including changes to delete the statement, i
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" Communications with NRC...further communications with NRC." In thia, our notification procedures will specify to maintain the ENS line open unless specifically terminated by NRC.
Schedule for Completion of Action Procedure changes will be completed by February 1, 1982.
Item 18 (50-259/81-19-27, 50-260/81-19-27, 50-296/81-19-27)
The action levels and appropriate action guides did not specify which guides are to be used by assessment personnel to make protection action recommendations.
(5.4.2)
Steps Which Have Been Taken The protective action guides (PAGs) used by TVA's assessment personnel for the development of protective action re. commendations are based upon those contained in the Environmental Protectf.cn Agency report EPA-520/1-75-G01. These PAGs will be incorporated into MSECC IP-10.
, Steps Which Will Be Taken As stated above.
Schedule for Completion of Action Procedure changes will be completed by February 2, 1982.
Item 19 (50-259/81-19-26, 50-260/81-19-26, 50-296/81-19-26)
An overall procedure covering the accident assessment methodology, to include both operational and radiological aspects, was not employed to gather data and to make cal:ulations on which protective action recommerdations are based.
(5.4.2)
Steps Which Have Been Taken A procedure is being developed which will be used to determine appropriate protective actions based on radiological conditions during an emergency.
Steps Which Will Be Taken 1
As stated above.
Schedule for Completion of Action The procedure will be implemented by May 1, 1982.
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Item 20 (50-259/81-19-30, 50-260/81-19-30, 50-296/81-19-30)
Emergency procedures, training, and instructions for health physics personnel defining methods, equipment, communications, and radiation 6
-protection guidanco for emergency onsite radiological surveys were not available (5.4.2.2 and 5.4.2 3).
Steps Which Have Been Taken 1
Procedures are being developed to direct plant personnel in performing cnsite radiological surveys.
Steps Which Will Be Taken Training will be provided to appropriate personnel.-
Schedule for Completion of Action The procedure will be implemented and training complete by July 1, 1982.
Item 21 (50-259/21-19-28, 50-260/81-19-28, 50-296/81-19-28)
I An accord was not established with the State of Alabana concerning resolution of difference in offsite consequence projections.
(5.4.2)
Steps Which Have Been Taken TVA and the State of Alabama have an understanding that differences in offsite dose projections will be resolved prior to the releane of the resulte and the formulation of protection action recommendations.
Steps Which Will Be Taken As stated above.
Schedule for Completion of Action This item is complete.
Item P2 (50-259/81-19-31, 50-260/81-19-31, 50-296/81-19-31)
ALARA dose levels would not be achieved due to the absence of shielding in post accident sample collection and transpectation. (5.4.3.4)
Steps Which Have Been Taken Plant procedures have been revised to require laboratory personnel to measure dose rates associated with accident samples to ensure that samples with activity too high for counting with plant instruments are not needlessly transported to the laboratory.
4 Steps Which Will Be Taken l
We are evaluating the possibility of adding t mporary shielding around existing sample stations.
Schedule for Completien of Action Our evaluation is estimated to be completed by January 1, 1982, and apprepriate actions will then be taken.
Item 23 (50-259/81-19-33, 50-260/81-19-33, 50-296/81-19-33) l.
Procedures were not developed to govern the emergency functions of repair
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and corrective action teams including team formation, possible operations in high radiation fields, and radiological safety considerations.
(5.4.5)
Steps Which Ecve Been Taken 1
As stated in the report, section 5.4.5, TVA intends to utilize existing i
plant procedures for immediately required repair and corrective action.
Should a long-term situation arise requiring repair or corrective action not covered by existing procedures, the action would be completed in I
accordance with section 11.0 of the REP.
Steps Which Will Be Taken l
As stated above.
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Schedule for Completion of Action This item was completed on December 1, 1981.
I Item 24 (50-259/81-19-34, 50-260/81-19-34, 50-296/81-19-34 The initiating conditions in BFN-IPD-1 were considered to be ambiguous by the Shift Engineers.
(7.2)
Steps Which Have Been Taken On October 6,1981, a preface was added to IP-1 which briefly discusses the classification logic in general terms and is available for the shift engineer to use along with his professional judgement in classifying an i
event should it not fit into an exact category as defined by IP-1.
I IP-1 was developed to provide details of initiating conditions specifically applicable to Browns Ferry based on the examples given in NUREG-0654. The procedure itself has undergone several eevisions to clarify thost items that were felt to be ambiguous. It must be recognized that this procedure cannot be completely specific in covering all possible initiating conditions and TVA's philosophy in developing IP-I was one of conservatism.
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. Steps Which Will Be Taken
)l Je have no plans to make further changes' to IP-1 regarding possible ambiguities at this time. If specific problems are identified through experience, changes and clarifications will be made to IP-1..
Schedule for Completion of Action All contemplated actions have-been completed by the issuance of the revised IP-1-on October 6, 1981.
l Item 25 (50-259/81-19-35, 50-260/81-19-35, 50-296/81-19-35)
Implementing procedures and other procedures referred to by Shift Engineers in an emergency such as Special Instructions and Emergency Operating Instructions were not cross referenced.
(7.2)
Steps Uhich Have Been Taken Emergency operating instructions are presently being revised to incceporate BWR owners group guidelines. Revisions will include reference to the REP where appropriate.
Steps Which Will Be Taken As stated above.
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-Schedule for Completion of Action Revisions to emergency operating instructions will be completed by August 31, 1982.
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