ML20040G109
| ML20040G109 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 01/12/1982 |
| From: | Rausch T COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| NUDOCS 8202110270 | |
| Download: ML20040G109 (5) | |
Text
_ _ _ _ - _ _ _ _ _ _ _ _ _
/m PRINCIPAL S"t'AFF
[
~ N Commonwealth Edison 4 13 97%73
) one First Nation 21 Plaza, Chicago. Illinois
(
O 7 Addr:ss R: ply to: Post Offica Box 767 D/D PA0 x"/ Chicago, I!!inois 60690 A/D My W&PT' OE&TI q /v DEP&of File January 12, 1982 cn n
<0 4
Mr. James G. Keppler, Regional Administrator d
ED Directorate o f Inspection and T
EEB J 0 OOM Enforcement - Region III 9anc 7
U.S. Nuclear Regulatory Commission 799 Roosevelt Road f
Glen Ellyn, IL 60137 p
Subject:
Dresden Station Units 1, 2 and 3 Response to Emergency Preparedness Appraisal Associated With Inspection Report s 50-10/81-16, 50-237/81-27, and 50-249/81-20 NRC Docket Nos. 50-10/237/249-References (a):
J.
G. Keppler letter to C.
Reed dated December 14, 1981 (b):
J.
G.
Keppler letter to C. Reed dated November 13, 1981
Dear Mr. Keppler:
Reference (a) transmitted the results of a special appra' aal o f the Dresden Station emergency preparednes,s program conducted during the period of November 210, 1981.
In this appraisal Commonwealth Edison was requested to submit a written statement describing our planned actions for improving each of the items identified in Appendix A, and the results of our consideration t
of each of the items in Appendix B to Re ference (a).
The information requested is provided in Attachments A and B to this letter.
I To the best of my knowledge and belief the statements contained in the attachments are true and correct.
In some respects these statements are not based on my personal knowledge but upon information furnished by other Commonwealth Edison employees.
Such information has been reviewed in accordance witn Company practice and I believe it to be reliable.
h' I
18 h - )/
8202110270 820112
' ~ '
JAN gDRADOCK05000
. Please direct any questions you may have concerning tnis matter to this of fice.
Very t ruly yours,
<=ued Thomas J.
Rausch Nuclea r Licensing Administrator Boiling Water Reactors Attachments cc:
RIII Inspector - Dresden SUBSCRIBED and SWORN to oefore me this /3,f-L day
, 1982 g7 Notary Puolic 3218N
r-ATTACHMENT A Dresden Station Units 1, 2,
and 3 Response-to Appenuix A,
Confirmation of Action Letter 1.
The tahle containing the revised protective action recom-nuations ( Table 6.3-1) has been prepared for incorporation into the Generating Station Emergency Plan (GSEP) and the appropriate Dresden Station Emergency Plan Implementing Procedures (EPIPs).
The on-site review recommending approval and authorization of use of the change to the GSEP is in the final review process and is scheduled for completion prior to Feburary 1, 1982.
Also, a change has been prepared to EPIP 300-1 incorporating the revised protective action recommendations, and that procedure change will also be completed prior to February 1, 1982.
Operating personnel are currently being training on these changes, and all Station Directors and acting Station Directors will be trained on the use of this table for protective action recommendation decision making prior to February 1, 1982.
2.
The notification phone list in the Dresden EPIPs was revised on Novembe r 18, 1981, to provide additional assurance that augmentation capabilities at the station are appropriate.
3.
A change to the Corporate Command Center Director's call list has been prepared to ensure that a Recovery Manager should be at the near site Emergency Operating Facility (EOF) within 60 minutes of determining that the EOF must be activated.
This change is expected to be issued in its final form before February 1, 1982.
4.
A change has been prepared to EPIP 500-7 to ensure that communication checks with the NRC are conducted as required in 10 CFR 50, Appendix E.
The procedure change is currently undergoing its final review and is scheduled for issuance prior to February 1, 1982.
5.
The prompt notification system is currently scheduled for completion by February 1, 1982.
A description o f the prompt Notification System will be provided by February 1, 1982, as requested.
323 8N
f Attachment B Dresden Station Units 1,-2, and 3 Response to Appendix B Preparedness Improvement Items We have reviewed those items recommended during the Emergency Preparedness Appraisal Audit, and we have agreed in all cases to take action which should satisfy the suggestions for improvements expressed in the Inspection Report.
In most cases, the action has already been completed, or will be completed by June 30, 1982.
1.
We are reviewing the Emergency Radiation Protection Procedures which were developed af ter Emergency Prepa redness Appraisal Audits at LaSalle and Zion to encompass precautions taken, respiratory protection to be used, and radiation exposure controls to be followed during emergency conditions.
A procedure addressing those items specifically at Dresden will be preparea and issued for use before June 30, 1982.
2.
We have received a procedure from LaSalle Generating Station oefining the proper steps for making a radiation survey during an eme rgency.
This procedure is being reviewed at Dresden, and a procedure specific for use at Dresden will be prepared and approved prior to June 30, 1982.
3.
A step will be added to EPIP 100-Cl directing the Station Director to ensure RCTs begin conducting appropriate surveys and collect appropriate samples prior to the arrival of the Rad / Chem Director at the TSC.
This change to EPIP 100-Cl will be completed and approved prior to June 30, 1982.
4.
Guidelines for conducting an of fshif t augmentation drill will be prepared and incorporated into the appropriate EPIP.
This augmentation drill will consist of contacting the appropriate management personnel by telephone and obtaining from them an estimate of the time necessary for them to arrive at the site.
Because of the expense o f contacting bargaining unit personnel (Radiation Chemistry Technicians), these personnel will not be included in the orill.
The computerized surveillance file will be changed to include this of fshif t augmentation drill on a periodic basis.
These changes will be completed and approved for use prior to June 30, 1982.
5.
Procedure EG-3 (Revision 1) was just maae on November 9, 1981.
The next change to that procedure will identify the means by which a field team can determine whether or not they are inside or beneath a radiological plume.
This change is expected to be issued for use before June 30, 1982.
6.
On November 4, 1981, a copy of the Fire Hazards Analysis Report was placed in the Shif t Engineer's o f fice to assist the Shif t Engineer in determining whether equipment has been degraded to the point that a Lin.iting Condition for Operation requires a shutdown.
r
. 7.
The Quality Assurance Department has developed a matrix to ensure that commitments of the GSEP manual and EPIP's are examined in Quality Assurance Audits.
This matrix will bc attacned to the 1982 audit schedule for use at all operating sites during 1982 and will be incorporated into an internal QA memorandum containing the Audit Plans for Of f Site Quality Assurance Audits.
Inclusion in this memo will ensure periodic review and update of the matrix as the revisions to the GSEP occur.
8.
An inventory checklist has been prepared for the interim EOF to ensure that some of the required radiation detection equipment which is required at the EOF is always maintained there.
Steps will be added to the Rad / Chem Directo r's checklist (EPI P 100-C8) to ensure that any additional necessary equipment is sent to the interim EOF when the Environs Teams leave the station.
These changes to EPIP 100-C8 and the interim EOF inventory checklist will approved for use before June 30, 1982.
9.
The appropriate EG Procedures will be revised to ensure that Cutie-Pie survey instruments are bagged to prevent noble gases from entering the ionization chamber and getting false readings.
These changes are expected to be issued for use before June 30, 1982,
- 10. EOF-3 and ED-1 will be revised to specify the means for updating federal and state radiological assessment personnel at least every 15 minutes.
These changes are expected to be issued for use before June 30, 1982.
- 11. A formal letter of agreement has been sent to Drake's Farm t
Restaurant to ensure the acceptability of using that location as a back-up emergency news center.
The reply f rom Drake's Fa rm Restaurant is expected before March 1, 1982.
- 12. The meteorological chart recorders in the Control Room will be reviewed to ensure that the proper chart paper which matches the scale of the instruments is available and in use, and that a means is provided to ensure the rate of speed of the recorder is indicated.
Any necessary modifications of this equipment will be submitted by June 30, 1982, and completed as expeditiously as possible.
- 13. Liquio effluent sampling and analysis procedures have been prepared which contain proper precautionary statements warning the user of possible high sample activity in post-accident samples.
These procedures are currently being reviewed and approved for use in the High Range Sample Station.
The initial procedures are expected to be issued for use prior to June 30, 1982.
3218N