ML20039E056

Responds to NRC 811112 Ltr Re Deficiencies Noted in 810908- 16 Appraisal of Emergency Preparedness Program.Results of Consideration & Schedule for Correction of Deficiencies & Description of Work in Progress Encl as App

ML20039E056
Person / Time
Site:	Duane Arnold
Issue date:	12/17/1981
From:	Root L IES UTILITIES INC., (FORMERLY IOWA ELECTRIC LIGHT
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20039E052	List: ML20039E056
References
LDR-81-343, NUDOCS 8201060475
Download: ML20039E056 (22)

Text

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4 Iowa Electric Light and Ibwer Company' ,

December 17, 1981 'PRI IPAL STAFF-LDR-81-343 MIR ) %Is

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Mr. James G. Keppler, Director Office of' Inspection and Enforcement ( / hP&OF File Region III U.S. Nuclear Regulatory Connission

'799 Roosevelt Road ,

Glen Ellyn, IL 60137 Project: Duane Arnold Energy Center

Subject:

Response to Emergency Preparedness Appraisal -

References:

Mr. Keppler's Letter of November 12, 1981 Phone conversation between M. Phillips (NRC), R. Portz (Iowa Electric), and 0.L. Reeves '(Iowa Electric)

NG-81-1753 File: A-221-

Dear Mr. Keppler:

This' letter is in response.'to_your latter of November 12, 1981, concerning'an appraisal of the Emergency Prr.paredness Progran at the Duane Arnold Energy Center conducted from September 8-16,1981. ~ Your letter requested that we submit a response describing our planned actions for improving each of the items in Appendix A and the-results of our i

consideratfor. of the items in Appendix ~B. In addition, you requested that we-submit a revised emergency plan _ which ~ corrects the deficiencies listed in Appendix C. -

Work on the items for immediate action is progressing within the constraints of the schedule established in Appendix A. As discussed with Mr. M. - Phillips, of your staf f, and Messrs. R. Portz 'and D.L. Reeves, of our-staff, we will advise you upon completion of these items by March 1,1981, with the exception of the update of the operating instructions, Item 4.B.

Confirmation of completion of this item will be provided with the submittal accompanying NUREG 0737, Task I.C.1, due at the end of the 1982 refueling outage.

As an attachment to this letter, please find the results of our consideration and schedule for correction of the deficiencies identified in-Appendix B, of your letter. The dates established 'for procedure changes reflect the intended date of availability of a final draf.t version for each of the procedures which incorporates the associated comments. We-expect that the- final approval cycle' may require an additional month beyond the

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date specified. -If it is necessary to revise this' schedule,'we will advise 8201060475 811250 PDR ADOCK 05000331 G  ! PDR ..

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Mr'. James Keppler December 17, 1981 LDR-81-343 i

As .a result of our conversation with Mr. Phillips, we intend tp submit only one revision to the DAEC Emergency Plan. This revision will cover all of the modifications made as a result of the correction of the deficiencies identified in Appendixes A, R,.and C of your letter. This revision will be submitted by March 1,1982. If this intended course of action is not acceptable, please inform us.

If there are any questions pertaining to our response, please contact Karl A. Meyer, Manager, Nuclear Licensing & Fuels (319-398-4687).

IOWA ELECTRIC LIGHT AND POWER COMPANY BY hef4/,[/lbut

-Larry D.

Subscribed nd sworn to Before Me on this / day of 10/e/s Je> 1981.

AL;Jh & /h. LAk)) M Notafy Pub' ic in and ~for the State of Iowa

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cc: R. Portz W. Axelson - NRC NRC Resident Office

APPRAISAL IMPROVEMENT ITEM RESPONSE IMPROVEMENT ITEM-1:

The Technical Support Center -(TSC) should be placed in an operational state of readiness. The exact location for each individual who reports to the TSC should be easily identified, and should be included in the Duane Arnold Energy Center (DAEC)

Emergency Plan and ' appropriate implementing procedure (EPIP 2.2). The use of the TSC for permanent office space-should be in accordance with the licensee's January 3,1980, submittal.

(Section 4.1.1.2.).

RESPONSE TO ITEM 1:

In our submittal of January 3,1980 to NUREG 0578, a statement was made which indicated that the TSC would not be used for normal. office space. Subsequent to that submittal and as planning continued, it'was determined that suitable use could be made of the facility which would, in fact, enhance its capability to serve as a Technical Support Center. Functions currently located within the overall TSC area include reactor and plant performance engineering, General Electric Company site engineering, document and records control, and telefax services.

Many of these functions are and all may well be required during an event that requires activation of -the Technical Support Center.

The existing layout cf cJr TSC provides dedicated space for emergency response personnel. The remainder of the space is utilized for functions needed during an emergency. Current facility utilization on a day to day basis is one which augments, rather than detracts from, the capability of the area to serve as a TSr. We therefore request the statement made in our January 3,1980 submittal be considered to be revised in accordance with the foregoing comments.

Subsequent to the Energency Preparedness Appraisal Inspection and prior to the Annual Exercise, the TSC was placed in an operational state of readiness. A revised layout drawing which identifies equipment, personnel locations and technical working spaces will be provided in the next revision to the DAEC Emergency Plan and incorporated into EPIP 2.2.

SCHEDULE FOR COMPLETION:

This ef fort will be completed by March 1,1982.

IMPROVEMENT ITEM 2:

All plans and procedures should be distributed both onsite and offsite-in accordance with Administrative Control Procedure (1)

I (ACP) 1402.4.. The controlled distribution list should be maintained by the Administration Supervisor, who should function with regard to all Emergency Plans and Procedures as described in ACP 1402.4. The out-of-date preparedness plans should be collected and discarded. Copies distributed to the NRC should not be sanitized to the point of rendering them useless.

(Section 5.5.3)

RESPONSE TO ITEM 2:

Distribution of revisions of the EPIPs is being conducted at the site, in accordance with ACP 1402.4 Distribution of Emergency Plans and Corporate Procedures is being made from the Corporate Office. Controlled distribution lists are maintained by the Support Services Supervisor at the DAEC and by the Emergency Planning Coordinator at the corporate level.

SCHEDULE FOR COMPLETION:

We consider action on this item to be. complete.

IMPROVEMENT ITEM 3:

An offhours shift augmentation drill should be conducted to ensure the duty officer system and procedure call out list meet the design objectives of Criterion II.B.5 of NUREG-0654, Revision 1. Reccrds should be maintained of these drills, which should be conducted quarterly. (Section 2.2.1)

RESPONSE TO ITEM 3:

It is our intent to conduct an off-hours shift augmentation drill by April 1,1982 and whenever major organizational changes or significant relocation of Emergency Response Organization nembers has occurred. In addition, notification drills will be conducted on a quarterly basis. Records will be maintained of these drills.

SCHEDULE FOR COMPLETION:

This action will be completed by April 1,1982.

IMPROVEMENT ITEM 4:

EPIP 1.1, Sections 2.0 and 4.5.2 should be reworded to say that other events not included in these EALs may be classified as an Unusual Event, Alert, or Site Area Emergency at the discretion of the Ernergency Coordinator or Shift Supervising Engineer, rather than the sentence referring to man-caused and natural emergencies. (Section 5.4.1)

RESPONSE TO ITEM 4:

This statement will be incorporated in conjunction with our re-evaluation of EALs.

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SCHEDULE FOR: COMPLETION: 3 x  %

Changes to the Plans and Procedures should be completed by ,

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e ,a IMPROVEMENT ITEM 5:

EPIPs 5.1 and 5.2 should be _ revised to specify that an':"under .

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control" situation exists when the plant is in a stablegtats i _

g' necessary plant equipment is functioning properly,.and;(there.iq .

no potential for uncontrolled radiological releases. Sectipn S.4.6)

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RESP 0?JSE TO ITEM 5: .e

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This has been incorporated into EPIPs 5.1 and 5.2. ' <;

SCHEDULE FOR COMPLETION: v.

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IMPROVEMENT ITEM 6:

-Section 3.1 of EPIP 4.1 should clearly specify that the Shift Supervising Engineer (SSE) is responsible to sound the- aT evacuation / assembly alarm for any event classified as an A1_ert' -

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or greater.- (Section 5.4.3.2) .

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RESPONSE TO. ITEM 6:

e , y' EPIP 1.2, " Notification of the Emergency Response Organization

' and the Off-Site. Agencies" and EPIP 2.2, " Activation and ~y .

Operation of the Technical Support. Center" .has been modified to -

ensure full-activation of the Emergency Response Organization .

upon declaration of an event classified as an Alert or greater. ' ' '

Additionally,- EPIP 4.1 will be modified to clearly specify that .

the SSE is responsible to sound the evacuation alarm for any event classified as an Alert or greater. W ,

SCHEDULE FOR COMPLETION: j,

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This action will be completed by March 1, ~1982. #

IMPROVEMENT ITEM 7:

O Walkthrough training for all SSEs and Health Physics Technic,lans should be conducted after correction of identified deficiencies

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in Appendix A of this report. Particular attention should be '

given to those areas where major changes have bien made. ..

(Section 7.2) .

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RESPONSE T;O . ITEM 3:

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the' DAEC'and the. CorporatD0ifice. Walkthrough training with' Health . Physics Technicians and SSEs .will be conducted for changes made' subsequent tot .he. An ual Exercise. Operating Procedure changes will be, handled _as pdrt of the Licensed Operator

. 'K't. - Requalificationborogram cx  : .. training.

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A s SCHEl10LE FOR COMPLETION:

> Walkthrough training-determined to be necessary with Health

'a' . . Dhysics Technicians and SSEs1will be conducted by April 1,1982.

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' ~" .IMPROVEMENTt' ITEM-8: -

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EPIP 5.1 should specifi wbo has the final authority for C '( downgrading / deactivating _ mrgency c1assification Llevels and Zi  : 9 x-

-declaring that' a recovery.'.physe-is .to be entered.

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., _ w s3 -  ?, N 3RPIP 5.1 has been. revised to;stath that the Emergency Response x ~*a,hd Recovery Di}ekty hasff.inal" authority for downgrading an

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'Ox . IMPROVEMENT ITEM 9:

3 3 When the d9ty officer paging systen becomes operational, EPIP

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1.2 and CPIP 1.2 should be. revised to incorporate the use of.

K' ; this system. (Section 5;4.1)

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/'<* ,TPIP 112 and CPIP 1.2 will be modified to include use of the

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y' IMPROVEMENT ITEM 10:

The' Emergency Coordinator and his alternates should be trained in the availability of the portable chlorine concentration sampler and the conditions under which it should be uset to determine EALs. (Section4.2.1.3).

RESPONSE TO ITEM 10:.

Emergency Coordinators will be advised of .the availability of the portable chlorine concentration sampler and the conditions-under which it should be used to determine E^1s.

SCHEDULE FOR COMPLETION:

This item will be covered during refresher training and included in the " formal" training program.

IMPROVEMENT ITEM 11:

The turbine building exhaust flow monitor should be properly labeled and the procedure should be changed to ensure proper flow units are recorded. (Section 4.1.1.7)

RESPONSE TO ITEM 11:

Subsequent to the Appraisal Inspection and prior to the Annual Exercise, walkthrough training was conducted with Radiation Protection Department personnel and proper labeling of the flow monitor was completed. EPIP 3.3." Initial Dose Projections" was modified to reflect the use of the % flow indicator.

SCHEDULE FOR COMPLETION:

We consider action.on this item to be complete.

IMPROVEMENT' ITEM 12:

Fire Brigade leadership should be under the direction of a Senior Reactor Operator (SRO). The Security Shift Supervisor should be relieved of this responsibility by July of 1982, when minimum

-shift staffing will include two SR0s. (Section 5.4.8)

RESPONSE TO ITEM 12:

,p Fihe protection' at the DAEC is in accordance with the DAEC Fire 1

. Plan. Consideration will be given to reassigning fire brigade leadership to an SRO, when mininum shift staffing is expanded to include'a second SRO.

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SCHEDULE FOR COMPLETION:

This item will be considered during the next review and revision cycle of the DAEC Fire Plan, after the second SR0 is qualified.

IMPROVEMENT ITEM 13:

CPIP 4.4 should specify who actually performs the audits of the emergency preparedness program. This descrircion should also specify that the auditors have no direct responsibilities for implementing the emergency preparedness progran. (Section 5.5.4)

RESPONSE TO ITEM 13:

CPIP 4.4 will be modified to state that the Manager, Corporate Quality Assurance is responsible for the conduct of an Emergency l Preparedness audit on a yearly basis.

SCHEDULE FOR COMPLETION:

This item will be completed by March 1,1982.

IMPROVEMENT ITEM 14:

Predetermined offsite sample / survey points should be selected for ease in identification of locations. (Section 5.4.2.1)

RESPONSE TO ITEM 14:

A grid system has been added to our maps. Predetermined nonitoring points exist at the intersection of each of these grid lines. The Site Radiation Prctection Coordinator or the Radiological Assessment Coordinator will determine which of these points should be used. During the Annual Exercise, directions to the offsite monitoring teams to sampling locations was simplified by the use of this grid system. Additional coordination with local and state authorities relative to this system as well as an increased emphasis on training is required.

SCHEDULE FOR COMPLETION:

These efforts are targeted for completion by June 1, 1982.

IMPROVEMENT ITEM 15:

Telephones in the TSC and Control Room should be located in areas where assigned functions are to be implemented. Section 5.6)

RESPONSE TO ITEM 15:

Telephones in the TSC and Control Room have been located in areas where assigned functions are to be implemented.

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I SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 16:

The program of training, drilling and exercising with the Palo '

Fire Department should be strengthened. (Section6.1}

RESPONSE TO ITEM 16:

Subsequent to the Appraisal Inspection and prior to the Annual Exercise, training was conducted with several offsite agencies including the Palo Fire Department. In addition, a mock fire drill was conducted with the Palo Fire Department as required-by the Fire Plan. Training, drills and exercises with the Palo Fire Department are conducted as prescribed in the DAEC Fire Plan.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 17: ,

Dedicated equipment and supplies in energency kits for emergency environnental monitoring should be provided. A limited scope program for taking and assaying water, soil, vegetation and milk samples for quick assessment should be developed. (Section 4.2.1.1)

RESPONSE T0 ITEM 17:

Dedica6ed equipment has been placed in the Emergency Lockers to conduct radiological monitoring and airborne sampling in the environment. Further, procedurcs have been developed to enable field determinations of radiciodine concentrations using silver zeolite cartridges and hard held instruments. We plan on expanding appropriate portions of our existing environmental sampling program in the impacted area following an accident where a significant release of radionuclides has occurred.

SCHEDULE FOR COMPLETI0ti:

We expect to complete action oa this item by June 1,1982.

IMPROVEMENT ITEM 18:

Formal training lesson plans should be developed to include specific performance objectives, hands-on practice, and walkthroughs. (Section3.2)

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RESPONSE TO ITEM 18:

Subsequent to the Appraisal Inspection and prior .to the Annual Exercise, training, hands-on practice ar.d walkthroughs were conducted for DAEC, corporate and of f-site agency personnel.

Formalized lesson plans were prepared for off-site monitoring and-off-site agency personnel training. Additional lesson plans will be developed covering other areas of energency response and will' include specific performance objectives, hands-on practice, and walkthroughs.

SCHEDULE FOR-COMPLETION:

This effort is expected to be completed by May 1, 1982,

' IMPROVEMENT ITEM 19:

Instrument check sources should be provided in emergency cabinets to facilitata functional testing of instruments before.use.

(Section 4.2.1.1)

RESPONSE TO ITEM 19:

A check source was placed in .the Energency Lockers during training conducted prior to the Annual Exercise.

SCHEDULE FOR COMPLETION:

We consider action on-this itam to be complete.

IMPROVEMENT ITEM 20:

Emergency supplies should be packaged .in a suitcase or other easily transportable container to prevent loss of portions of the supplies during movement and to aid in transport. (Section 4.2.1.1)

RESPONSE TO ITEM 20:

Energency supplies will be packaoed in a suitcase or other easily transportble container.

SCHEDULE FOR COMPLETION:

Thi . action will be completed by May 1,1982.

' IMPROVEMENT ITEM 21:

The . licensee should develop procedures for the onsite administration of and establish supplies of radio-protective drugs and include ' action levels for use, storage locations, and control. (Section4.1.2.2)

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a RESPONSE TO ITEM 21:

Action has been initiated to define criteria for administration of potassium iodide .in conjunction with our redical consultant.

A procedure for.the adnnistration of potassium iodide will be developed and included in the EPIPs.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 22:

The licensee should establish specific assignnents for functions required for radiation protection during emergencies not defined in the existing emergency plan; i.e., dosimetry, access control',

etc. (Section5.4.3.1)

RESPONSE TO ITEM 22:

EPIP 1.2, " Notification of the Emergency Response Organization and Off-site Agencies" was modified to include the dosimetry clerk. EPIP 2.1, " Activation and Operation of the Operational Support Center" has been revised to include provisions for a Health Physics Foreman to remain in the Access Control Area until relieved of that function by one of the Health Physics Technicians assigned by the Emergency Assignment Board.

SCHEDULE FOR COMPLETION:

• We consider action on this item to be complete.

4 IMPROVEMENT ITEM 23:

EPIPs should be reviewed to assure that procedures referenced in the EPIPs_ exist. (Section 5.4.3.1)

RESPONSE TO ITEM 23:

As EPIPs and Emergency Plans are being revised, they are being reviewed to ensure that procedures referenced therein are still applicable.

SCHEDULE.FOR COMoLETION:

This action will be completed by March 1,1982.

IMFROVEMENT ITEM 24:

Those Radiation Protection Procedures that only address emergency or accident actions should,be reissued as EPIPs. (Section 5.4.3.1)

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RESPONSE TO ITEM 24:

Those Radiation Protection Procedures that only apply to Emergency or Accident Conditions are being revised and will be reissued as EPIPs.

SCHEDULE FOR COMPLETION:

This action will be completed by May 1,1982.

IMPROVEMENT ITEM 25:

The licensee should develop a Letter of Agreement with the Paramount Theater for use as an alternate Emergency News Center.

(Section 4.1.4) ,

l RESPONSE TO ITEM 25: j See the response to Item 26.

l SCHEDULE FOR COMPLETION:

See the response to item 26.

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l IMPROVEMENT ITEM 26:

CPIP 1.4 should include provisions that explain how the news media center will be used by the State, local, federal, and licensee spokespersons to coordinate public information activities and conduct media relations. (Section 4.1.4)

RESPONSE TO ITEM 26:

The coordination of public information activities and the conduct of media relations during an emergency requires further discussions with local, state and_ federal public information personnel.

SCHEDULE FOR COMPLETION:

I These discussions will take place and a resolution reached by April 1, 1982.

IMPROVEMENT ITEM 27:

The licensee should update administrative procedures to cover the existing emergency plan and procedures. (Section 5.1)

RESPONSE TO ITEM 27:

- Administrative Control Procedure 1410.2 will be updated to reflect the new Emergency Plans and Implementing Procedures.

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SCHEDULE FOR C0i1PLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 28:

Instructions to radiological survey teams should be provided on disposition of survey data sheets, samples, and other pertinent information. (Section 5.4.2.3)

RESPONSE TO ITEM 28:

EPIP 5.1, " Deactivation of the Emergency Response Organization" has been revised to include, upon deactivation, collection of all data sheets, calculations, etc. EPIPs 3.1, "0nsite Radiological Monitoring" and 3.2, "Offsite Radiological Monitoring" will be modified to include instructions for Radiological Monitoring / Survey Teams regarding disposition of data sheets, samples, and other pertinent data.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 29:

A description should be included in EPIP 1.2 on the use of the backup communications available (IWAS and radio) for notifying offsite agencies. (Section 5.4.1)

RESPONSE TO ITEM 29:

EPIP 1.2 has been revised to include the use of backup communications available for notifying offsite agencies.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 30:

An alternate atmospheric stability categorization scheme should be outlined in the offsite dose assessment procedures to obtain stability categorizations based on data from the Cedar Rapids FAA facility. (Section4.2.1.4)

RESPONSE TO ITEM 30:

In the event that a stability classification can not be established by installed instrumentation, a worst case dose (11)

projection will be calculated for areas of interest. These instructions will be included in nodifications to EPIP 3.3,

" Initial Dose Projections", and CPIP 2.1, " Dose Assessment and

. Protective Action Recommendations."

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 31:

When the offsite relocation center is established, it should be designated in EPIP 4.1 with a map of the evacuation routes to be taken from the site to this area. (Sections 5.4.3.2)

RESPONSE T0' ITEM 31:

When the offsite facility is established, EPIP 4.1 will be nodified to identify its location and evacuation routes to be used.

SCHEDULE FOR COMPLETION:

This action will be completed by June 1,1982.

IMPROVEMENT ITEM 32:

The licensee's preventative maintenance program for meteorogical measurements should be formalized to represent controlled procedures for the following activities: . operational reviews, surveillance, and calibration. These proceduces should be unambiguous and self-contained, and should ba representative of state-of-the-art practices. (Section4.2.1.4)

RESPONSE TO ITEM 32:

A procedure will be developed which will describe the preventative maintenance program for existing meteorological equipnant.

SCHEDULE FOR COMPLET!0N:

This action will be completed by March 1,1982.

-IMPROVEMENT. ITEM 33:

Radwaste sampling equipment should be obtained 3nd procedures developed for handling elevated radwaste samples under accident conditions. (Section 4.1.1.8. and 5.4.2.10) i (12)

RESPONSE TO ITEM 33: ,

Radwaste sampling equipment will be obtained and a procedure develci.e( for handling high level radwaste samples.

SCHEDULE FOR COMPLETION:

This action will be completed by May 1,1982.

i IMPROVEMENT ITEM 34:

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EPIP 4.1 should specify that accountability will be accomplished within 30 ninutes, and should clarify the means by which all assembled personnel will be continuously-accounted for -

thereafter. (Section 5.4.3.3)

RESPONSE TO ITEM 34:

During the Annual Exercise, accountability of site personnel was completed in approximately 30 minutes. In a subsequent, plant evacuation conducted as a result of an airborne radiation problem, this function was completed within 30. minutes for all IELP site and contracted personnel. EPIP.4.1 will be modified to specify that accountability should be accomplished within 30 minutes.

Currently EPIP 4.1 specifies that security posts will be established at each assembly location and will be continuously manned by security personnel to maintain accountability.

Instructions as to how this function is being performed will be included in the modified procedure.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 35:

l The containment high range radiation monitor should be color l

coded in accordance with accident classifications. (Section 5.6)

RESPONSE TO ITEM 35:

This item will' be considered during the course of completing NUREG 0737 Task I.D.1, " Control-Room Design Reviews."

SCHEDULE FOR COMPLETION:

Completion of-this item will be in accordance with the completion schedule for Task I.D.1 of NUREG 0737.

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_ _ _ _ - _ _ _ _ = _ - _ _ _ _ _ _ _ _

IMPROVEMENT ITEM 36:

All EPIPs should be tabbed for quick access. (Section 5.6)

RESPONSE TO ITEM 36:

All EPIPs will be tabbed for quick access.

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SCHEDULE FOR COMPLETION:

This action will be completed by April 1,1982.

IMPROVEMENT ITEM 37:

Changes to EPIPs and CPIPs should he made upon determination that a change is needed rather than waiting for the annual review. (Section 5.5.2)

. RESPONSE TO ITEM 37:

Changes to EPIPs and CPIPs are being made on an as needed basis and are being submitted to the NRC in accordance with the requirements of 10CFR50, Appendix E. This effort is specified in EPIP 6.1, " Maintenance of the EPIPs" and will be reflected in a modification to CPIP 4.4, " Periodic Plan and Procedure Review."

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 38:

The licensee should establish a means for allowing public input in the content of the Public Information Brochure and its distribution. (Section 6.2.1)

RESPONSE TO ITEM 38:

! The Public Information Brochure was developed in coordination with both the Linn and Benton County Civil Defense Directors and l the State of Iowa Office of Disaster Services. The brochure contains phone numbers for Iowa Electric, Linn and Benton County Civil Defense Offices for any questions that the public may have.

Should it become apparent either by inquiries directed to Iowa i

Electric or-to the Civic Defense Directors or as a result of -

L . comments received duringLthe_ course of public neetings where-emergency planning is discussed,- additional information will be placed in future revisions of the brochure.-

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SCHEDULE FOR COMPLETION:

No further action :is planned ~ on this item.

IMPROVEMENT ITEM 39:

I Distribution of the annual emergency brochure should be expanded to fully cover the transient population, including signs, decals, and posted notices as indicated in Section G.2.1.4 of the DAEC Plan. (Section 6.2.1)

RESPONSE TO ITEM 39:

Section G.2.1.4 of the DAEC Emergency Plan will be revised to describe the nechanism by which we plan to disseminate information to the transient population. CPIP 4.1, "Public Information Program" will be modified to reflect these changes.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 40:

Implementing procedures should be reviewed to assure consistent use of titles in assigning responsibilities and actions .

(Section 5.1)

RESPONSE TO ITEM 40:

During the course of modifying plans and procedures and as a result of the expanded emergency organizations,. the consistent use of titles in assigning responsibilities and actions will be reviewed.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 41:

The licensee should provide for timely distribution of Emergency Plans and revisions to offsite agencies. (Section 6.1)

RESPONSE-TO ITEM 41:

Subsequent to the Appraisal Inspection and prior to the Annual Exercise, distribution of emergency plans and procedures was completed. Revisions to emergency plans and procedures will be distributed in a timely manner in the future.

(15)

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 42:

The Letter of Agreement with the Palo' Fire Department and Ambulance Service should be improved to describe the capabilities and responsibilities that will be expected in responding to incidents or emergencies. (Section 6.1)

-RESPONSE TO ITEM 42:

The Letter of Agreement with the Palo' Fire Departrent and Ambulance Service will be improved to describe the capabilities and responsibilities that can be expected in responding to

. incidents or emergencies.

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 43:

The remote switch for the high range noble gas scale should.be properly labeled. (Section 4.1.1.7)

RESPONSE TO ITEM 43:

The remote switch for the high range noble gas ~ scale ha's been relabeled to. be consistent with the procedure.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 44:

The selection.criteris established for emergency planning personnel should be stated as generic criteria, rather than describing the qualifications of the current incumbents.

(Section 1)

RESPONSE TO ITEM 44:

Section P of the DAEC Emergency Plan will be modified to respond specifically to the NUREG 0654 guidance associated with this subject.

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SCHEDULE FOR COMPLETION:

This_ action will be completed by March 1,1982.

IMPROVEMENT ITEM 45:

The Emergency Monitoring Log should include a description of the instrument node used for the radiation survey results; e.g.,

open window or closed window. (Section 5.4.2.1)

RESPONSE TO ITEM 45:

The Energency Monitoring Log will. be modified to include a discription of the instrument node used and will be incorporated into EPIPs 3.1 "0nsite Radiological Monitoring" and 3.2, "Offsite Radiological Monitoring".

SCHEDULE FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 46:

The eaergency planning function should also be assigned to a site individual so that the planning function would hcVe continual viability and site specific input. (Section1)

RESPONSE TO ITEM 46:

Energency planning responsibilities are assigned to the Assistant Chief Engineer, Radiation Protection and Security.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 47:

A system for identifying personnel surveyed at assenbly points should be established to assure that all personnel are surveyed.

(Section 5.4.3.4)

RESPONSE TO ITEM 47:

Personnel _ surveying will be done in accordance with Radiation -

Protection Procedures. These procedures require documentation only for those personnel found.to be contaminated. EPIP 2.1,

" Activation and Operation of the Operation Support Center" was modified prior to the Annual Exercise in a revision dated October 8,1981 to delete Attachment 4.

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SCHEDULE FOR COMPLETION:

We consider action on this itme to be complete.

IMPROVEMENT ~ ITEM 48:

The licensee should develop formal provisions for expanded support facilities (mobile. trailers, communications, other resources) necessary for contractor and nonlicensee augmentation personnel.

(Section 4.1.3)

RESPONSE TO ITEM 48:

Facilities exist at the site to accommodate contractors and other-personnel as assigned on a temporary basis. These facilities, resources and communications equipment have been adequate in the past for augmentation personnel required to support outages. We recognize that significant expansion of'these facilities may be required during the recovery phase of an energency condition.

Extensive recovery efforts of this nature clearly will require services of oae or more major contractors who routinely construct expanded support facilities for major construction / refurbishment projects. Therefore, we feel proper action will be taken in a timely manner, in the event that expansion of our support facilities was required.

SCHEDULE FOR COMPLETION:

We consider action this item to be complete.

IMPROVEMENT ITEM 49:

The licensee should develop and implement a fornal system for alerting and training emergency response personnel on significant changes in the plan and/or procedures between scheduled training sessions. Trai sing on these changes should be conducted using

. techniques. simiiar to initial training to arsure individual ability'to perform assigned tasks. (Sectior.3.2)

RESPONSE TO ITEM 49:

Walkthroughs and/or drills will be conducted whenever significant changes to the plans and procedures have occurred. This item will be incorporated into our " formal" training program.

SCHEDULE FOR COMPLETION:

This action will be completed by May 1,1982.

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IMPROVEMENT ITEh 50:

The licensee should improve the quality of documentation of training performed at,the corporate level and to offsite agency support personnel -(Section 3.2).

RESPONSE TO ITEM 50:

Subsequent to the Appraisal Inspection and prior to the Annual Exercise, of training including drills, critiques, and instructional. sessions were conducted with corporate and offsite

. support personnel. -These efforts will be formally documented.

~

The overall training program for corporate and offsite support personnel will be incorporated into our " formal" training program.

SCHEDULE FOR COMPLETION:

This action will be completed by May 1,1982.

IMPROVEMENT ITEM 51:

A procedure should be provided to assure the operability of energency kit equipment and periodic replacement of linited life items such as batteries. (Section 5.5.1.)

]

RESPONSE TO ITEM 51:

EPIP 6.3, " Maintenance of Emergency Facilities, Equipment and Supplies" will be upgraded to include operability checks of emeraency equipment and the replacement of limited life items, such: as batteries, on a periodic basis.

SCHEDULE-FOR COMPLETION:

This action will be completed by March 1,1982.

IMPROVEMENT ITEM 52:

Face masks gof emergency respirators should be bagged to maintain cleanliness and retard deterioration. (Section4.2.1.1.)

RESPONSE TO ITEM 52:

Face masks for emergency respirators have been bagged.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

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. IMPROVEMENT' ITEM 53i A system should be provided to inform and assure the- respirator user that the respirator has been inspected and surveyed.

(Section4.2.1.1.)

- RESPONSE TO ITEM 53:

During respirator training sessions, personnel are advised that bagged respirators have been inspected and surveyed and-consequently,'are suitable for use.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.

IMPROVEMENT ITEM 54:

The licensee should- review the use of the + 25% time tolerance allowed _on training and retraining frequen'cy to meet the intent of the requirements. (Section 3.2)

! RESPONSE T0 ITEM 54:

We have reviewed the +25% time tolerance. Every effort will be made to comply with the established training frequencies.

SCHEDULE FOR COMPLETION:

We consider action on this item to be complete.-

i (20)