ML20053E947

Forwards IE Emergency Preparedness Appraisal Repts 50-317/81-19 & 50-318/81-18 on 811005-16.No Noncompliance Noted

ML20053E947
Person / Time
Site:	Calvert Cliffs
Issue date:	05/26/1982
From:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lundvall A BALTIMORE GAS & ELECTRIC CO.
Shared Package
ML20053E948	List: ML20053E947 ML20053E953
References
NUDOCS 8206100234
Download: ML20053E947 (30)

See also: IR 05000317/1981019

Text

{{#Wiki_filter:. _ _ _ _ _ _ _ _ - - _ _ _ _ _ _____ a NAY 2 61982 Docket Nos. 50-317 50-318 Baltimore Gas and Electric Company Attention: Mr. A. E. Lundvall, Jr. Vice President-Supply, P. O. Box 1475 Baltimore, Maryland 21203 Gentlemen: Subject: Emergency Preparedness Appraisal Combined Inspection Report Nos. 50-317/81-19 cnd 50-318/81-18 To verify that licensees have attained an adequate state of on-site emergency preparedness, the Nuclear Regulatory Commission is conducting a special appraisal at each power reactor site. These appraisals are being performed in lieu of certain routine inspections normally conducted in the area of emergency prepared- ness. The objectives of the appraisal at each facility are to evaluate the overall adequacy and effectiveness of emergency preparedness and to identify areas of weakness that need to be strengthened. We use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and ef fect improvements, but 'also for effecting improve- ments in NRC requirements and guidance. During the period of October 5-16, 1981, the NRC conducted an appraisal of the emergency preparedness program for the Calvert Cliffs Nuclear Power Plant. Areas examined during this appraisal are described in the enclosed combined report (50-317/81-19 and 50-318/81-18). Within these areas, the appraisal team reviewed selected procedures and representative records, inspected emergency facilities and equipment, observed work practices, and interviewed personnel. The findings of the emergency preparedness appraisal at the Calvert Cliffs ) Nuclear Power Plant indicate that certain corrective actions are required in your emergency preparedness program. These are discussed in Appendix A, "Significant Emergency Preparedness Findings". Significant findings for which you have made acceptable commitments to resolve, were discussed in the Confirmatory Action Letter dated November 6, 1981 and the subsequent clarification letter dated November 19, 1981. Copies of the letters, dated November 6, 1981 and November 19, 1981, are anclosed for your convenience as attachments to this letter. It is our understanding based upon your letter of November 16, 1981 that corrective actions on these items have been completed. ! Other areas needing improvement are discussed in Appendix B, " Emergency Pre- paredness Improvement Items". OFFICIAL RECORD COPY , 8206100234 820526 3 PDR ADOCK 05000317 h G PDR _ _ _ _ _ _ _ _ _ >

Baltimore Gas and Electric Company 2 gy 2 61992 In conjunction with the aforementioned appraisal, emergency plans for your facility were reviewed by the Emergency Preparedness Licensing Branch, Division of Emergency Preparedness, Office of Inspection and Enforcement. The results of this review indicate that certain deficiencies exist in your emergency plan. These are discussed in Appendix C, " Emergency Plan Evaluation Report". Appendices A, 8, and C of this letter contain an inclusive listing of all outstanding emergency preparedness items at your facility at this time. We recognize that an explicit regulatory requirement pertaining to each item identified in Appendices A, B and C may not currently exist. Notwithstanding this, you are requested to submit a written statement within thirty (30) days of the date of this letter, describing your planned actions for improving each of the items identified in Appendix A and the results of your consideration of each of the items in Appendix 8. This description shall include: (1) actions which have been taken; (2) actions which will be taken; and (3) a schedule for completion of actions for each item. This request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations. You are further requested to provide to this office, within 120 days of the date of this letter, page changes to your Emergency Plan correcting each deficiency iden- tified in Appendix C or provide written justification as to why you believe a revision should not be made. Copies of these change, are to be submitted in accordance with the procedures delineated in 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E(V). The items requiring correction in our Confirmatory Action Letters of November 6 and 19, 1981, have been subdivided into related findings in Appendix A. This is to inform you that if there are any remaining Appendix A items which are not corrected within 120 days from the date of this letter, the Nuclear Regulatory Commission will determine whether enforcement action is appropriate. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, witnin ten oays of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the require- ments of 2.790(b)(1). The telephone notification of your intent to request withholding, or any request for an extension of the 10 day period which you believe necessary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223. The reporting requirements contained in this letter affect fewer than ten (10) persons and are, therefore, not subject to Office of Management and Budget clearances as required by P L 96-511. OFFICIAL RECORD COPY

NY2a 51> Baltimore Gas and Electric Company 3 Should you have any questions concerning this inspection, we will be pleased to discuss them with you. Should you have any questions concerning the items of Appendix C, please contact Mr. F. Kantor, Emergency Preparedness Licensing Branch at (301) 492-4539. Sincerely, , Original Signed By: W,ht.Ckc M George H. Smith - Director, Division of Emegency Preparedness and Operational Support Attachments: 1. Appendix A, Significant Emergency Preparedness Findings 2. Appendix B, Emergency Preparedness Improvement Items 3. Appendix C, Emergency Plan Evaluation Report 4. Ltr to Baltimore Gas and Electric Company, dated November 6, 1981 5. Ltr to Baltimore Gas and Electric Company, dated November 19, 1981 6. NRC Region I Combined Inspection Report Nos . 50-317/81-19 and 50-318/81-18 cc: R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent T. Sydnor, General Supervisor, Operations QA R. C. L. Olson, Principal Engineer J. A. Tiernan, Manager, Nuclear Power j T. N. Pritchett, Project Manager, Nuclear Emergency Programs v, S. E. Jones, Supervisor of Training /- R. E. Denton, General Supervisor, Training and Technical Services f Public Decument Room (PDR) Local ~ Public Document Room (LPDR) 1 d Nuclear Safety Information Center (NSIC) 7 NRC Resident Inspector O ' D. M. Rohrer, Emergency Preparedness Analyst, NRC HQ ') State of Maryland (2) g J. W. Brucker, Director, FEMA Region III ,F bec: Region I Docket Room (with concurre s) 4 k RI:DEP< RI' RI: n R RI:DEP&O Crockr / S d - Stard ecki George mt'** dgg . l2.5 1] 5/4/82 - 7- 0FFIC AL RECORD COPY

APPENDIX A SIGNIFICANT EMERGENCY PREPARE 0 NESS FINDINGS Based on the results of the NRC's appraisal of the Calvert Cliffs Nuclear Power Plant (CCNPP) Emergency Preparedness Program conducted on October 5-16, 1981, the following improvements are required: (The areas are presented below along with the corrective action required by the Confirmatory Action Letter and the specific finding number (s) from the inspection report. References are to the sections in NRC Combined Inspection Report Nos. 50-317/81-19 and 50-318/ 81-16). 1. Emergency Action Levels / Procedure Flow A. Corrective Action Required by CAL: Review and revise the appropriate Abnormal Operating Procedures and Emergency Operating Procedures 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 Implementing Procedures. B. Related Specific Findings: 1. Correct the appropriate E0Ps and AOPs, where necessary to insure that the station operators can effectively and expedi- tiously move from normal operations, to abnormal operations, through emergency operations and into the appropiiate ERPIPs (317/81-19-45 and 318/81-18-45) (See Section 5.2). 2. Respiratory Protection A. Corrective Action Required by CAL: Determine which emergency response and other necessary operations i personnel must perform essential duties in locations where signifi- cant airborne radioactive contamination can be present during emergency conditions. Determine the availability and storage location of appropriate respiratory protection equipment (self-contained breathing devices). Insure that presently available respiratory protection equipment is located and available to personnel performing essential duties. If additional respiratory protection equipment is required, I inform the NRC Region I office, in writing, of the plans and schedules for procuring the additional equipment. l OFFICIAL RECORD COPY i i l A-1 , i __ _ - _ _ . - - - . . _ _ _ -.

Appendix A B. Related Specific Findings: 1. Provide appropriate respiratory protection equipment for all on-site emergency workers (317/81-19-39 and 318/81-18-39) (See Section 4.2.2.1). 2. Insure by training, fitting, and medical examination that all appropriate emergency workers can safely don respiratory pro- tective equipment during emergencies (317/81-19-40 and 318/ 81-18-40) (See Section 4.2.2.1). 3. Training and Retraining A. Corrective Action Required by CAL: 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 effect- ively. B. Related Specific Findings: 1. Develop and implement a program for training individuals, who are assigned emergency planning responsibilities, which will enable them to attain and maintain a state-of-the-art knowledge in the field of emergency preparedness (317/81-19-02 and 318/81- 18-02) (See Section 1.6); . 2. Develop and implement quality assurance procedures to evaluate the effectiveness of the emergency preparedness training (317/ 81-19-07 and 318/81-18-07) (See Section 1.6); 3. Develop and implement quality assurance procedures to evaluate the effectiveness of the emergency action training for the various functional areas (317/81-19-14 and 318/81-18-14) (See Section 2.3); 4. Develop and implement a program to test all key emergency response individuals to determine and verify that the indivi- duals are qualified to perform his/her assigned emergency task (s) and maintain the required minimum level of competence / proficiency (317/81-19-15 and 318/81-18-15) (See Section 3.1); 5. Provide specific training for the Plant Superintendent and all Shift Technical Advisors per Section 6 of the ERP (317/81-19-16 and 317/81-18-16) (See Section 3.1);

0FFICIAL RECORD COPY ! A-2

Appendix A 6. Develop and implement formal lessw. plans for training all key emergency response individuals (317/81-19-17 and 318/81-18-17) (See Section 3.1); 7. Establish a file or list of all instructors qualified in accor- dance with ERPIP 5.4 (317/81-19-18 and 318/81-18-18) (See Section 3.1); 8. Develop and implement a program to train all emergency response personnel in the proper use of all equipment which would actually be required to perform their assigned tasks under emergency conditions (317/81-19-19 and 318/81-18-19) (See Section 3.1); 9. Develop and implement a program for prompt training of all key emergency response personnel in significant changes to the ERP or ERPIPs (317/81-19-20 and 318/81-18-20) (See Section 3.1); 10. Develop and implement a program to train all key emergency response personnel on all emergency response plan implementing procedures as required by Exhibit 5.4-A of ERPIP 5.4 (317/81-19-21 and 318/81-18-21) (See Section 3.2); 11. Develop means to test the adequacy of the information transmittal process as part of communication drills required by ERPIP 5.5 (317/81-19-65 and 318/81-18-65) (See Section 5.5.2); and 12. Evaluate the status of training of offsite response personnel, develop a listing and course description of the types of train- ing to be provided for offsite response personnel, and offer initial training and annual retraining classes (in addition to the training received by participation in exercises and drills) to all offsite response organizations (317/81-19-69 and 318/ 81-18-69) (See Section 6.1). 4. Post-Accident Sampling and Analysis A. Corrective Action Required by CAL: Until your permanent post-accident sampling systems are operational in accordance with NUREG 0737 by January 1, 1982, improve your pre- sent 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. OFFICIAL RECORD COPY A-3

.. . . ._ . - _ k I Appendix A , 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 procedures to ensure that they are -- l applicable to emergency conditions as well as normal operating conditions. -- Assure that analytical capability exists for handling high activity post-accident samples. B. Related Specific Findings: 1. Provide equipment and appropriate procedures to safely obtain accurate and representative samples for the following systems under accident conditions until the permanent post-accident sampling system (s) is completed, installed and inspected: a. Reactor Coolant (317/81-19-28 and 318/81-18-28) (See Section 4.1.15.1) b. Containment Atmosphere (317/81-19-29 and 318/81-18-29) (See Section 4.1.1.5.2) c. Gaseous and particulate effluents (317/81-19-30 and 318/ 81-18-30) (See Section 4.1.1.5.3) ' 2. Review and evaluate all post-accident sampling and analysis procedures to ensure that proper consideration is given to ALARA practices (317/81-19-54 and 318/81-18-54) (See Section 5.4.2.2.1); 3. Develop and implement, as part of the ERPIPs, specific and complete procedures for post-accident sampling and analysis for the following systems, containing appropriate references to other necessary procedures and forms:

! a. Reactor Coolant (317/81-19-53 and 318/81-18-53) (See Section 5.4.2.2.1) I b. Containment atmosphere (317/81-19-55 and 317/81-18-55) (See Section 5.4.2.2.2) c. Gaseous and particulate effluents (317/81-19-56 and 318/ 81-18-56) (See Sections 5.4.2.2.3) 0FFICIAL RECORD COPY A-4 . . - - . . . -- - . . . . . - . . . . _ _ _ _

- Appendix A 4. Review the calculational bases used in all post-accident sampling and analysis procedures to insure their correctness (317/81-19-57 and 318/81-18-57) (See Section 5.4.2.2.3); 5. Assure that the following post-accident liquid effluent sampling and analysis elements are available. a. Procedures that are appropriate for expected releases. (317/81-19-58 and 318/81-18-58) (See Section 5.4.2.2.4) b. All necessary equipment (317/81-19-59 and 318/81-18-59) (See Section 5.4.2.2.4) 6. Provide guidance in the REMP procedure for personnel protection during field sampling activities (317/81-19-60 and 318/81-18-60) (See Section 5.4.2.3). 7. Include the use of the post-accident sampling systems in the quarterly health physics drills involving detection, analysis and response to simulated elevated airborne and liquid samples and direct radiation measurements in the environment (317/81-19-64 and 318/81-18-64) (See Section 5.5.2). 5. On-Site Emergency Organizational Augmentation A. Corrective Action Required by CAL: As you indicated in your August 10, 1981 letter to Mr. R. A. Clark, Chief, Operating Reactors Branch #3, USNRC, there is 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 Licens- ing, USNRC (Generic Letter No. 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 goals of Table B-1 of NUREG 065d 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. OFFICIAL RECORD CODy A-5

Appendix A B. Related Specific Finding: 1. Conduct an evaluation or drill that assesses your capability to achieve the 30 and 60 minute staff augmentation goals of Table B-1 of NUREG 0654 after the declaration of an emergency. (317/81-19-11 and 318/81-18-11) (See Section 2.3) . OFFICIAL RECORD COPY A-6

APPENDIX B EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS Based on the results of the NRC's appraisal of the Calvert Cliffs Nuclear Power Plant (CCNPP) Emergency Preparedness Program conducted October 5-16, 1981 the following items should be considered for improvement: (References are to Sections in the NRC Region I Combined Inspection Report Nos. 50-317/81-19 and 50-318/81-18): 1. Develop and implement explicit and specific functional responsibilities and authorities for the various Emergency Preparedness plar.ning and coordination functions (317/81-19-01 and 318/81-18-01) (See Section 1.6); 2. Evaluate the adequacy of existing staff at the site assigned responsibility for emergency preparedness planning and coordination, and develop a means to augment existing staff when necessary (317/81-19-03 and 318/81-18-03) (See Section 1.6); 3. Develop and implement a method to provide substantive input from plant staff, down to the working level, to the development of emergency prepared- ness plans and procedures (317/81-19-04 and 318/81-18-04) (See Section 1.6); 4. Develop and implement specific selection and qualification criteria for individuals performing emergency preparedness development activities (317/81-19-05 and 318/81-18-05) (See Section 1.6); 5. Develop and inplement methods to ensure that coordination of all company resources, both on-site and at the corporate offices, is enhanced and that the appropriate level of senior management awareness is achieved (317/81-19-06 and 318/81-18-06) (See Section 1.6); 6. Clarify the authorities, responsibilities and duties of individuals assigned to the licensee's emergency organization (317/81-19-08 and 318/81-18-08) (See Section 2.3); 7. Designate specific individuals by title within the BG&E site and corporate organization who will be sent as a licensee representative to the State and local emergency operations centers (EOCs) (317/81-19-09 and 318/81- 18-09) (See Section 2.3); 0FFICIAL RECORD COPY B-1

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.. -_ - ..- ) 1 Appendix B

8. Clarify the control and decision making relationship between the SEC and ! , the Recovery Manager with respect to who has the authority and responsi- bility for notification of off-site authorities and the transmittal of recommendations for off-site protective actions for the general public and specifical!y identify how and under what conditions those respon- sibilities would shift (317/81-19-10 and 318/81-18-10) (See Section 2.3); , , 9. Provide in the Emergency Response Plan copies of letters of agreement or 1 contracts which demonstrate that arrangements have been made with off-site j organizations (both commercial and private) to supply specifically defined q support or cooperation during an emergency (317/81-19-12 and 318/81-18-12)

(See Section 2.3); , 10. Develop and implement specific selection and qualification criteria for i individuals assigned to perform emergency actions and decision making ' (317/81-19-13 and 318/81-18-13) (See Section 2.3); i 11. Evaluate the adequacy of the system used to detect airborne contamination entering the Control Room Ventilation System and the subsequent isolation of the Control Room ventilation into the recirculation mode (317/81-19-22 and 318/81-18-22) (See Section 4.1.1.1);

12. Provide the specified radiological monitoring equipment with both visual 3 and audible alarms to perform the following functions at the designated i areas: a. To indicate direct radiation in the control room. (317/81-19-23 and 318/81-18-23) (See Section 4.1.1.1) . b. To indicate both radioactive airborne contamination and direct radiation in both the TSC and the proposed TSC Annex (317/81-19-24 i and 318/81-18-24) (See Section 4.1.1.2) j c. To indicate both radioactive airborne contamination and direct radiation in the OSCs. (317/81-19-25 and 318/81-18-25) (See Section ! 4.1.1.3) d. To indicate radioactive airborne contamination and direct radiation in EOF and its alternate (317/81-19-27 and 318/81-18-27) (See Section 4.1.1.4) , 13. Correct the Emergency Response Plan and ERPIPs to properly reflect the current location of the OSC (317/81-19-26 and 318/81-18-26) (See Section 4.1.1.3) 0FFICIAL RECORD COPY J n l B-2

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_ _ _ . . _ __ . _ . _ _ . . _ - . _ _ _ __ _ __ _ __ . d i Appendix B

14. Develop and implement specific procedures to govern the use of the decon- tamination facilities at the Farm Demonstration Building including the i collection and monitoring of liquid effluents from that facility (317/

81-19-31 and 318/81-18-31) (See Section 4.1.2.3); I 15. Provide tamper indicating d,evices on all emergency kits to assure that the dedicated emergency equipment and supplies are available and usable when needed for emergency response (317/81-19-32 and 318/81-18-32) (See Section 4.2.1.1); $ 16. Reduce the number and complexity of hand performed calculations in the field to decrease the possibility of errors (317/81-19-33 and 318/81-18-33) , l (See Section 4.2.1.1); j 17. Check, and correct as necessary, the Condenser Off gas Monitoring System to assure its operability (317/81-19-34 and 318/81-18-34) (See Section 4.2.1.2); 1 -. 18. Develop and implement procedures to govern the use of the Area and , l Process Radiation Monitors during emergencies (317/81-1.9-35 and 318/81-18-35) (See Section 4.2.1.2); l 19. Develop and implement procedures to govern the use of Non-radiation Process Mnnitors during emergencies (317/81-19-36 and 318/81-18-36) (See Section 4.2.1.3); I 20. Develop and implement techniques, to be incorporated into the dose calculational methcdology, to compensate for the potential uncertainty , associated with instrument exposure problems and sea treeze effects on plume trajectories. These techniques are intended to provide reasonable assurance that adequate protective measures (distance and directions) can i ' be recommended to off-site authorities in the event of a radiological emergency condition (317/81-19-37 and 318/81-18-37) (See Section 4.2.1.4); 21. Develop and implement a mechanism whereby Control Roo., Staff will be informed of impending severe weather conditions that may impact the site area (317/81-19-38 and 318/81-18-38) (See Section 4.2.1.4); 22. Evaluate, and upgrade as necessary, the P.A. system to insure that all j persons at the CCNPP can hear and understand emergency messages trans- J mitted over that system, even in high noise areas such as the Turbine Building (317/81-19-41 and 318/81-18-41) (See Section 4.2.3); i j 23. Provide " ringing indication lights" or other devices on all emergency telephones to enable emergency personnel to quickly identify when and which emergency telephone is ringing (317/81-19-42 and 318/81-18-42) (See Section 4.2.3); 0FFICIAL RECORD COPY 4 B-3 ' l _. _ _ _ . _ ._. _ _.__ ___._._ _ _ _ _ _ _ _, -_ ._. . _ _ - - _ _ - _ . - - - _ _ _ - _

Appendix B 24. Correct the ERP and the ERPIPs to properly describe the types, number, and equipment of vehicles dedicated for emergency response, including methods to assure their availability (317/81-19-43 and 318/81-18-43) (See Section 4.2.6); 25. Correct the ERPIPs to include all forms, referenced as being necessary to complete the procedure, within the specific procedures where they are needed (317/81-19-44 and 318/81-18-44) (See Section 5.1); 26. Provide direction in the off-site radiological survey procedure on the final disposition of the data at the completion of the survey (317/81-19-46 and 318/81-18-46) (See Section 5.4.2.1.1); 27. Include in the off-site radiological survey procedure provisions for a backup means of communication if the radio fails (317/18-19-47 and 318/81-18-47) (See Section 5.4.2.1.1); 28. Provide a copy of procedure ERPIP 4.3.2 in the mobile emergency kits with the referenced survey forms (317/81-19-48 and 318/81-18-48) (See Section 5.4.2.1.2); 29. Provide direction in the on-site (out-of plant-) radiological survey procedure on the final disposition of samples and data at the completion of the survey (317/81-19-49 and 318/81-18-49) (See Section 5.4.2.1.2); 30. Include in the on-site (out-of plant) radiological survey procedure provisions for a backup means of communication if the radio fails (317/81-19-50 and 318/81-18-50) (See Section 5.4.2.1.2); 31. Provide forms in the in plant radiological survey procedures to record results of surveys, including the area surveyed, data and time of survey and results of survey (317/81-19-51 and 318/81-18-51) (See Section 5.4.2.1.3); 32. Provide a method in the in plant radiological survey procedures for communication between the teams and the RPD (317/81-19-52 and 318/81-18-52) (See Section 5.4.2.1.3); 33. Develop and implement plans and procedures which will govern the operations of the CCNPP Recovery Organizations and criteria for its initiation (317/81-19-61 and 318/81-18-62) (See Section 5.4.6); 34. Develop procedures with specific criteria upon which the emergency class will be downgraded, including provisions for notification of Federal, State and local officials prior to entering a downgraded mode (317/81-19-62 and 318/81-18-62) (See Section 5.4.6); 0FFICIAL RECORD COPY B-4

-. - - - .- . _ , - .- ._ - . - - _ I ! Appendix B 35. Perform drills involving the Emergency Radiation Teams at least quarterly ] (317/81-19-63 and 318/81-18-63) (See Section 5.5.2); 36. Correct the inconsistency between the ERP and the ERPIPs regarding the individual responsible for the review, revision, and distribution of the Emergency Response Plan (317/81-19-66 and 318/81-18-66) (See Section 5.5.3); 37. Insure that the Emergency Preparedness Checklists, as called for in ERPIP 5.0 are completed in a timely manner to assure that an adequate

review of the ERPIPs is made on the required schedule (317/81-19-67 and

318/81-18-67) (See Section 5.5.3); ! 38. Review the existing methods used to track and correct deficiencies ! identified by audits, drills, exercises, and suggestions from the general ! plant staff, to assure that corrective actions will be completed in a timely i manner (317/81-19-68 and 318/81-18-68) (See Section 5.5.4); i 39. Review all letters of agreement with off-site support organizations to ensure that all are still acceptable and will be honored, and ensure that ' adequately detailed letters of agreement exist for all organizations the licensee will depend on for aid during an emergency (317/81-19-70 and 1 318/81-18-70) (See Section 6.1); , 40. Ensure that the EALs and their associated response actions are discussed and agreed on by the licensee, State and local governmental authorities and develop and implement a method to review the continued acceptability ] of the EALs and their associated response actions with the State and local governmental authorities on an ans 'al basis (317/81-19-71 and 318/81-18-71).

(See Section 6.1); and 41. Establish a formal program to familiarize the news media, initially, and on an annual basis, with the BG&E emergency plans for CCNPP, information on radiation, and points of contact for the release of public information during an emergency (317/81-19-72 and 318/81-18-72) (See Section 6.3). 1 i i i , OFFICIAL RECORD COPY 4 . A

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APPENDIX C EMERGENCY PLAN EVALUATION REPORT ON CALVERT CLIFFS NUCLEAR POWER PLANT BALTIMORE GAS AND ELECTRIC COMPANY EMERGENCY PLAN DATED AUGUST 1, 1981 EVALUATION SUMMARY The Calvert Cliffs Nuclear Power Plant Emergency Response Plan, Revision 1, dated August 1, 1981, was evaluated using the sixteen Planning Standards and the 96 suppurting criteria in NUREG-0654, Revision 1. The evaluation shows that, of the sixteen standards, three were satisfied, and twelve were satisfied except as noted and one was not satisfied. The rating of unsatisfactory was given to Planning Standard D, Emergency Classification System. The Planning Standard rated as unsatisfactory was so rated because the Emergency Plan failed to address the substantive points expressed in the Standard and in the evaluation criteria. The Planning Standards rated as satisfactory except as noted were so rated because the Emergency P:an failed to address, provided insufficient information about, or was unclear regarding some of the pertinent points enunciated in the Planning Standards' evaluation criteria. Comments were made on each of the deficiencies noted. In the pages that follow, findings on each Standard and its evaluation criteria are presented. A synopsis of criteria that are properly addressed is given, an evaluation of the degree of satisfaction provided by the plan is made and a set of comments noting deficiencies within criteria is provided. , C-1

,l Appendix C FINDINGS ON STANDARDS & CRITERIA CALVERT CLIFFS NUCLEAR POWER PLANT A. ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL) Planning Standard . I Primary responsibilities for emergency response by the nuclear facility licensee, and by State and local organizations within the Emergency Planning , Zones have been assigned, the emergency responsibilities of the various ,, supporting organizations have been specifically established, and each principal \\< response organization has staff to respond and to augment its initial response on a continuous basis. SKEEosis The Federal, State, local and private sector organizations that are intended to be part of the overall response organization of Emergency Planning Zones are identified. , The licensee's concept of operations and its relationship to the total effort is specified. The interrelationships among emergency organizations are illustrated in a . block diagram (Figure 3.5-1). The Site Emergency Coordinator (Shift Supervisor until relieved by . another SEC qualified individual) is identified as the individual who shall be in charge of the emergency response. 24-hour per day emergency respose, including 24-hour per day manning of . communications links is provided for. Written agreements referring to the concept of operations developed between Federal, State and local agencies and other stpport agencies having an emergency response role within EPZs are included, although certain portions of Appendix D were deleted from Revision 1 which were included in Revision 0 of the plan. These should be replaced and all letters of agreement should be as specific as possible and current. The Administrative Support Manager is the individual who will be . responsible for assuring continuity of resources. Evaluation: The plan satisfies Planning Standard A except as noted below. The authorities of all persons assigned to the licensee's emergency response organization are not defined in the plan. C-2 >

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o ' ' T: I Appendix C ' > B. ON-SITE EMERGENCY ORGANIZATION Planning Standard l ' ' On-shif t facility licensee responsibilities. for emergency response are unambig- ' ucusly defined, adequate staf fing to provide. initial facility accident response i in key functional areas is maintained at all' times, timely at:gmentation of response capabilities is available, and thesinterfaces among various onsite v response activities and offsite support and response activities are specified. Sy posis

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. The on-site emergency organization of plant personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement are specified. The Site Emergency Coordinator (SEC) is designated as the individual with the authority to direct aad coordigte emercency actions, including making protective action =rccommendations to off-site authorities. - A line'of succession of ?.m emergency coordinator (SEC) position is . ident'ified, as are the conditior.s .under which higher level utility officials will as'sume ttrh function. ?- ( ~The functional resphnsi Hl$ ties assigned to the emergency coordinator are . (SEC), soecif,ied, as are the responsibilities that may not be delegated.

. ~ The interfaces between and among the on-site fur.ctional areas of emergency . activity:. Mcensee headquarters support, local services support, and State and local government response organizations are specffied. The sorporate management, administrative and technical support personnel who will augment the plant:staf f are specified. The contractor and private ygm: anions that may be requested to provide . s technical assistance to and,aq m utation af the emerg'ncy organization ' are specified. - ' , ' ' , < / ' The services to be provided by ic:al' agencies for handling emergencies, including fire-fighting and medical services are identified. Copies of ' letters of agreement are appeaded to the olan. Evaluation: The plan satisf M Planning Standard B estept as noted below: Criterion 5: The minimum staffing levels shown in Jable' 3.1-1. of the plan do not meet the requir/mer.ts of Table B-1 of NUREG-0654: (a) A capability \\ for four additions in Off-site Surveys should be indicated; (b) A capa- , bility,for tds additions in On-site (out-of plant) surveys should be c indicited;-(c) In Repair and Corrective Actions, one on-shift Mechanical e . , ,s - I \\ C-3 , , --- - --

Appendix C Maintenance person, one on-shift Electrical Maintenance person and one Instrument and Control Technician additien should be provided; and (d) In Radiation Protection, two on-shift HP Technicians should be indicated. The plan provides no statement of the licensee's intention to meet the required staffing levels by July 1, 1982. " _ Criterion 6: No block diagram includes the TSC, OSC and EOF. Appendix J-2 indicates that an EOF will be constructed by some unspecified future date. C. EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard Arrangements for requesting and effectively using assistance resources have been made, arrangements to accommodate State and local staff at the licensee's near-site Emergency Operations Facility have been made, and other organizations capable of augmenting the planned response have been identified. Synposis Federal assistance can be requested by the Recovery Manager, the Site Emergency Coordinator and/or the State. The Federal resources expected are specified. . The licensee will dispatch representatives to the principal off-site EOCs. Radiological laboratories at BG&E's Baltimore headquarters are identified as well as those in a mobile van operated by the licensee. Organizations that can be relied upon in an emergency to provide . assistance are ident* fled; letters of agreement are appended to the plan. Evaluation: The plan satisfies Planning Standard C except as noted below. Criterion 1b: No times of arrival or specific sites are specified for the expected Federal resources. Criterion Ic: No licensee resources available to support the Federal response are specified. C-4 - -

Appendix C D. EMERGENCY CLASSIFICATION SYSTEM Planning Standard A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determination of minimum initial offsite response measures. Synopsis: An emergency classification and emergency action level scheme partially compatible to the scheme set forth in Appendix 1, NUREG-0554 has been established. The initiating conditions listed in the plan include some of the example . initiating conditions listed in Appendix 1, flVREG-0654 as well as all the postulated accidents in the FSAR. Evaluation: The Plan fails to satisfy Planning Standard D for the following reason. (A specific evaluation of the licensee's EALs appears as Annex B to the Emergency Preparedness combined Appraisal Report No. 317/81-19 and 318/81-18). Criterion 1 Notification of Unusual Event Initiating Conditions: 3 (fuel damage), 4 (abnormal temperatures and/or) pressures), 5 (leakrates), 7 (loss of ac power), 8 (loss of containment integrity), 9 (loss of engineered safety feature). One of the EALs for these initiating conditions has the requirement that the reactor be required to be placed in a lower mode of operation. The requirement for a lower mode of operation is irrevalent to declaration of an Unusual Event and should be dropped. Initiating Condition 1: (ECCS initiation) - The instrumentation for determining ECCS flow should be listed. Initiating Condition 3: (fuel failure) - An EAL for rate of fuel failures should be added. Initiating Condition 4: (abnormal coolant temperature and/or pressure) - EALs for low coolant pressure, high T and high core exit temperature ave should be added. C-5 . - - - _ _

Appendix C Initiating Condition 9: ~(loss of fire protection system function) - An EAL for loss of fire protection system function should be added. Initiating Condition 10: (fire) - The licensee's EAL is nonconservative in that it requires that the fire be ir on area containing safety . elated equipment. Any fire within the plant lasting more than 10 minutes is grounds for calling an Unusual Event. , Alert Initiating Condition 1: (severe loss of fuel cladding) - An EAL for rate of fuel failure should be added. Initiating Condition 3: (rapid failure of steam generator tubes) - The licensee should provide the instrument readings for this event not refer to actuation of an emergency procedure. The suggestions of NUREG-0818 should be considered. Initiating Condition 4: (steam line break with primary to secondary leakage) - The licensee refers to an emergency procedure instead of listing the instrument readings upon which actuation of the emergency procedure is based. The licensee has not addressed the requirement of primary to secondary leakage. The licensee should address this subject using the suggestions in NUREG-0513. Initiating Condition 5: (primary coolant leak rate greater than 50 gpm) - The licensee refers to implementation of an emergency procedure (LOCA) instead of providing the instrument readings which lead to use of that procedure. Moreover, unless the LOCA emergency procedure is indeed implemented at leak rates as low as 50 gpm, its use as a criteria for declaring an Alert may be nonconservative. Initiating Condition 7: (loss of AC power) - The instrument readings should be listed. Initiating Condition 12: (fuel handling incident) - the instrument levels and alarms should be listed. In developing an acceptable EAL set, the licensee should not " require visual observation of damage" as this may not be feasible under accident conditions. Initiating _ Condition 13: (fire) - The requirement for off-site support should be dropped. C-6

Appendix C Site Area Emergency Initiating _ Condition 6: (loss of AC power) - the instrument readings should be listed. Initiating Condition 10: (major damage to spend fuel) - The instrument levels and alarms should be given. Initiating Condition 11: (fire compromising the functions of safety systems) - The requirement that the fire "is not extinguished within 15 minutes after 3 off-site fire fighting personnel commence fire fighting efforts" should be dropped as it is nonconservative and irrelevant to declaring a Site Araa Emergency. Initiating Conditi_on'14: (imminent loss of physical control of the plant) - The licensee's EAL requires that a physical attack on the facility has resulted in damage to safety related equipment. This is nonconservative. All that is required for declaring a Site Area Emergency is imminent occupancy of any of the vital areas defined by the Modified Amended Security Plan. Initiatina Condition 15: (earthquake) - and 15b (high and low water) - The SSE earthquake levels should be specified. The low water levels should be specified. Initiating Condition 1_6c: (toxic and flammable gases) - The licensee's EAL is nonconservative because it requires the concentration to be above toxic or explosive levels before declaring a Site Area Emergency. Any concentration that poses problems in accessing vital areas is sufficient. General Emergency Initiating Condition 2: (loss of 2 out of 3 fission product barriers) - The licensee has taken the conservative approach of requiring 2 out of 3 fission oroduct barriers are breached without requiring imminent failure of the third barrier. This is acceptable. However, the suggestions of NUREG-0818 should be considered. These suggestions include the use of steam generator tube failure as a loss of primary coolant boundary, con- sideration of leaks via broken steam generator tubes and leaking MSIVs, use of radiation readings in containment as evidence of combined failure of the cladding and of the primary coolant boundary and use of high core temperature or inadequate subcooling margin as evidence of cladding failure. Initiating Condition 3: (security) - The EAL set is acceptable as long as " loss of control of the facility" means occupation of the control room, remote shutdown facilities or any other vital areas as defined by the Modified Amended Security Plan. C-7

Appendix C Note: The licensee's definition of an Alert, Site Area Emergency and General Emergency differs from that in NUREG-0654. For example the NUREG-0654 definition of an Alert states in part that " events are in process or have occurred which involves an actual or potential degradation of the level of safety of the plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels" (p. 2.1-6). The licensee's version differs significantly frem NUREG-0654. The licensee states that to declare an Alert there must be a " radiological effluent release with a potential of causing in plant projected doses of greater than or equal to 0.1 rem whole body or greater than or equal to 0.5 rem to the thyroid." Though some of the initiating conditions under an Alert might have projected doses of this magnitude associated with them, many do not (such as those relating to security, high winds, loss of off-site AC power, etc.). Therefore, the use of such a blanket statement is incorrect and could contribute to a nonconservative philosophy regarding declaration of an Alert. Similar statements are made for the Site Area Emergency class (p. 2.1-10) and for the General Emergency Class (p. 2.1-13). The text should be rewritten so that a radiation release is not the only reason for declaring an emergency. Criterion 2: The licensee did not orepare EAL sets for the following initiating conditions. Unusual Event - 6, 11, 13, 14b, 14e, 16 and 17. Alert - 2, 6, 8, 9, 10, 14, ISb, 18c and 18e. Site Area Emergency - 2, 3, 5, 7, 8, 9, 12 and 16n. General Emergency - 5. E. NOTIFICATION METHODS AND PROCEDURES Planning Standard Procedures have been established for notification, by the licensee of State and local response organizations and for notification of emergency personnel by all response organizations; the centent of initial and followup messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established. Sy.npo s i s Procedures are established which describe mutually agreeable bases for . notification of response organizations consistent with the emergency classification and action level scheme. Procedures for alerting, notifying and mobilizing emergency respo1se personnel are established. The contents of the initial emergency messages to be sent frca the plant are established. C-S

Appendix C Follow-up messages from the facility to off-site authorities, containing . appropriate information, are established. Copies of written messages intended for the public, consistent with the . licensee's classification scheme and giving instructions to the public with regard to specific protective actions, are provided (Appendix K). Evaluation: The plan satisfies Planning Standard E except as noted below. Criterion 6: The specific means and time required for notification within the plume exposure EPZ are not given, urther, the licensee's plan provides for 1 hour to notify off site r authorities at the notification of Unusual Event and the Alert stages. This does not meet the requirements of 10 CFR Part 50, Appendix E(IV)(D)(3). F. EMERGENCY COMMUNICATIONS Plannin_g Standard Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public. __Snyposis 24-hour notification to and activation of the State / local emergency . response network are provided. Communications with contiguous State / local governments within the EPZs are provided. Communications as needed with Federal emergency response organizations . are provided. The alerting or activating of emergency personnel is provided for. . Communications by the licensee with NRC Headquarters and NRC Regional . Office EOCs are provided. Periodic testings of communications systems are provided. . Evaluation: The plan satisfies Planning Standard F except as noted below: Criterion 1: Organizational titles and alternates for both ends of communication links are omitted. Criterion 2: No provision is made for a coordinated communication link for fixed and mobile support facilities. C-9 t

Appendix C

G. PUBLIC EDUCATION AND INFORMATION Planning Standard Information is made available to the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency (e.g., listening to a local broadcast station and remaining indoors), the principal points of contact with the news media for dissemination of infor- mation during an emergency (including the physical location or locations) are established in advance, and procedures for coordinated dissemination of information to the public are established. Snyposis A coordinated yearly dissemination of information to the public regarding . how they will be notified and what their actions should be in an emergency is provided. Written material that is likely to be available in a residence during an . emergency is provided for and updated annually. The points of contact and physical locations for use by news media during . an emergency (Media Communications Center) are designated. The President and Chief Operating Officer is designated as spokesperson. . Arrangements for timely exchange of information among designated . spokespersons at the Media Communications Center are established. Annual programs to acquaint news media with the emergency plans, . i information concerning radiation and points of contact for release of public information in an emergency are provided. Evaluation: The plan satisfies Planning Standard G except as noted below. Criterion Id: The special needs of the handicapped are not addressed. Criterion 2: No provisions are made for transient population. Criterion 3: The Emergency Operations Facility is not yet constructed. Criterion 4: No explicit arrangements are made for dealing with rumors. H. EMERGENCY FACILITIES AND EQUIPMENT Planning Standard Adequate emergency facilities and equipment to support the emergency response are provided and maintained. C-10 . _ - .,_ m__ _ -

Appendix C Synposis: A Technical Support Center (TSC) and Operations Support Center (OSC) have . been established. The TSC is adjacent to the Control Room and is within the Seismic I boundary of the Auxiliary Building and is ventilated by the same system provided for the Control Room. The OSC is 1ccated in training classroom 3 of the South Services Building. The TSC will be upgraded as required to meet NUREG-0696 criteria. Two Emergency Control Centers (ECC) have been established. The primary . ECC is located at the South Services Building. The alternate ECC is located near the Farm Demonstration Building at the site boundary west of the plart. Altnough not definitely stated, the plan implies that these facilities will function as the primary an alternate EOF until an EOF facility to be located about 12 miles northwest of the plant is constructed. The new EOF will comply with NUREG-0696 requirements. Provisions have been made for timely activation and staffing of emergency . response facilities. . Geophysical phenomena monitors (i.e., meteorological and seismic), radiological monitors, process monitors, and fire and combustion detectors have been installed and are identified. Provisions have been mde to obtain meteorological and seismic data from . off site sources. Provisions have been made to acquire data from and have access to . off-site radiological monitoring and sampling devices. Provisions have been made to have access to or get information from the . BG&E Electric Test Department Laboratory at company headquarters. Radiological monitoring equipment is in place at locations near the plant for use in off-site monitoring. Appendix J.3 of the plan states that a new meteorological tower ordered . in 1981 will meet the acceptance test criteria of Regulatory Guide 1.23 - and NUREG-0737. Provisions have been made to inventory equipment / instrumentation each . quarter (respiratory protection equipment will be inventored monthly) and checked to verify that calibration and location are in accordance with inventory lists. Emergency kits and their contents are identified by location. C-Il _ _

Appendix C Evaluation: The plan satisfies Planning Standard H except as noted below. Criterion 1: The plan does not contain enough information to determine if the OSC meets (or will be upgraded to meet) NUREG-0696 criteria. Criterion 2: The plan implies, but does not specifically state, that the primary and alternate ECC's will serve as the EOF until the proposed facility is constructed. It is impossible to determine from the plan (Section 5.12 and Figure 5.1.1) if the primary ECC located in the South Service Building is inside or outside the protected area fence. If it is inside (as was verified during inspections) and is used as the EOF it would appear to violate the intent of NUREG-0654 to have an EOF located so that reasonably prompt access is provided to appropriate Federal, State and local personnel. The plan does not indicate if the ECC's meet NUREG-0696 requiremer.ts. The licensee does not state in the plan when new EOF will be completed and ready for operattori Criterion Sa: The plan fails to state if hydrological equipment has been installed at a plant site location (s). Criterion 6a: The plan fails to indicate if arrangements have been made to obtain hydrologic data or information from off-site sourcas. Criterion 6b: The plan does not indicate if dosimetry from radiological monitors will meet as a minimum the NRC Radiological Assessment Branch Technical Position for the Environmental Radiological Monitoring Program. Criterion 8: Although the plan in Appendix J-3 indicates a new meteorological tower ordered in 1981 will meet the acceptance criteria for Regulatory Guide 1.23 and NUREG-0737 there is no statement concerning satisfying the criteria in Appendix 2, NUREG-0654. The plan also fails to indicate if current meteorological data meets the intent of Appendix 2, NUREG-0654. No prognosis is given concerning the completion date for the new tower. C-iterion 9: The emergency equipmer.t listed in Table 5.1-2 of the plan is identified as being assigned to the ECC. It is unclear if this same equipment is intended for use by the OSC. If so it appears that the quantity of equipment may be insufficient for use by both facilities. Criterion 10: The plan does not state if sufficient reserves of equipment / instruments exist to promptly replace those removed from service. The plan also does not indicate if calibrations will be done in accordance with manufacturers specifications. Criterion 12: Establishment of a central point for receipt and analysis of all field monitoring data and coordination of sample media is not clearly stated in the plan. C-12

Appendix C I. ACCIDENT ASSESSMENT Planning Standard Adequate methods, systems and equipment for assessing and monitoring actual or potential off-site consequences of a radiological emergency condition are in use. Synposis: Plant systems and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents are identified (see comments under Standard D). parameter values and the correspondence emergency class are included in the facility ERPIP's. The kinds of instruments used and their capabilities are listed in Table 2.2-2. The capability and resources to provide initial values and continuing . assessment during an accident are available including post-accident sampling, radiation and ef fluent monitors, in plant iodine instrumentation and containment monitoring. Methods and techniques have been established for determining the source . term of releases of radioactive material within plant systems and the magnitude of the release based on plant system parameters and effluent monitors. The relationship between effluent monitor readings and on-site and off-site exposures and contamination for various meteorological conditions have been established. The methodology for determining release rate / projected doses if . instrumentation is off-scale or inoperable has been established. The capability and resources required for field monitoring within the . plume exposure EPZ are described. . The methods, equipment and expertise to make rapid assessments of the magnitade of radiological releases is described. Deployment times for field teams is estimated at 15 to 30 minutes from notification. The means for relating various measured parameters to dose rates for key isotopes has been established. Provisions have been made for estimating integrated doses from projected or actual dose and comparing them with protective action guides. Evaluation: The plan satisfies Planning Standard I except as noted below. C-13

' \\ Appendix C , 1 Criterion 5: There is not enough information in the plan to determine if the current meteorological information meets Appendix 2, NUREG-0654 criteria. Discussion of new meteorological installation, Appendix J.3 of the plan, fails to indicate if Appendix 2, NUREG-0654 criteria will be met. The plan also fails to indicate if meteorological data and information originating at the facility will be available to the ECC/ EOF, TSC an offsite NRC Center, and appropriate State agencies. Criteria 9: The plan states in Section 4.2.1.7 that radioiodine can be detected in the field as low as 10 'Ci/m' Criterion 9 requires capability to detect radiciodine in the field as low as 10 'pCi/cc. J. PROTECTIVE RESPONSE Planning Standard A range of protective actions have been developed for the plume exposure pathway EPZ for emergency workers and the public. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed. Synposis: The means and time required to warn or advise on-site individuals and individuals who may be in the controlled area have been established. Provisions have been made for evacuation routes to suitable off-site . locations. Provisions have been made for radiological monitoring of evacuated . on-site personnel at the assembly location (s). Decontamination will be provided at the Farm Demonstration Building. . Provision has been made to account for all on-site personnel within 30 minutes after declaration of an emergency and continuously thereafter. Provisions have been made to supply personnel remaining or coming on-site with protective clothing, respiratory protection, and radioprotective drugs as required. Mechanisms for promptly notifying responsible off-site authorities a id . recommending protective actions have been established. Time estimates for evacuation within the plume exposure EPZ are contained . in Tables 1 and 2 of Appendix F. C-14 -_- .. . -

Appendix C Maps showing evacuation routes, areas, preselected radiological mcnitoring . and sampling points and relocation centers are shown in Figures 4.4.1-2, 4.2-1 and Figure 1, Appendix K - respectively. Figures 1, 2, 3, 4 and Table 1, 2 in Appendix F show population distribution . around the plant in evacuation and sector format. The bases for the choice of recommended protective actions from the plume exposure pathway is discussed. Evaluation: The plan satisfies Planning Standard J except as noted below. Criterion Ic: The plan does not specifically address the matter of warning or advising contractor / construction personnel. Section 3.2.1.4 states that ! personnel within the protected area fence and adjacent areas will be notified. It could be concluded that contractor / construction personnel are included. A specilic statement on this point would be helpful. Criterion 2: The plan fails to address provisions made for alternate evacuation routes or for transportation available to evacuated on-site personnel. Criterion 7: Although it appears that the recommended protective actions to State and local authorities meet the requirements of the EPA Manual of Protective Action Guides and Protective Actions for Nuclear Incidents there is no indication in the plan that this is the case. Criterion 10a: Identification of radiolooical sampling and monitoring points (Figure 4.2-1) does not include designators, or equivalent system, in accordance with Table J-1, NUREG-0654. Criterion 10c: The plan does not clearly discuss the means used to notify all segments of the transient and resident population. Table 3.6-2 implies that initial notification can be by means of radio and TV via a Public Information Coordinator or by means of mobile and fixed public address or alert systems or via the County Sheriffs Department, and other county agencies. Appendix K-1, Figure-1 states that notification will be by emergency vehicle, personal contact or other means. A clear specific statement in the plan concerning the means used to notify the affected population would be useful. Criterion 10m: The plan does not address the expected local protection afforded

by residential or shelter locations. ] C-15 t

Appendix C K. RADIOLOGICAL EXPOSURE CONTROL Planning Standard Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Livesaving Activity Protective Action Guides. Synposis: Exposure guidelines consistent with EPA Emergency Worker and Lifesaving . Activity Protective Action Guides have been established. The on-site radiation protection program for implementation during emergencies has been established. Procedures for permitting on-site volunteers to receive radiation in excess of 10 CFR 20 limits are in place. The Site Emergency Coordinator and the Radiological Protection Director are authorized to approve radiation dose in excess of 10 CFR 20 limits. Provisions have been made for the distribution of dosimeters, reading them at appropriate frequencies and maintaining dose records. Action levels for determining the need for decontamination and criteria . for returning areas and items to normal use have been established. The means for radiological decontamination of personnel, supplies, instruments and equipment, and for waste disposal have been established. On-site contamination measures to control access to contaminated areas are in place. Evaluation: The plan satisfies Planning Standard K except as noted below: Criterion Ic through g: The pian does not specifically address these items. It is not clear if personnel engaged in these activities can be authorized to receive radiation dose in excess of 10 CFR 20 limits. EPIP 4.1.5.3(8) states only that exposure must be maintained in accordance with RCP 3-300 series. This procedure is not available for review. The licensee should consider placing a statement in the plan that clearly covers these items. Criterion 3a: The plan addresses the responsibility of the Radiation Protectior. Director for distribution and processing of dosimeters and maintenance of dose records. The plan fails to indicate if procedures are in place to provide 24 hour per day capability to determine doses received by emergency workers. C-16 . . - - -

Appendix C , Criterion 6b: The plan fails to discuss provisions for contamination control of on-site drinking water and food supplies (i.e. food in canteen dispensers, lunches, etc.) Criterion 7: The plan discusses on-site decontamination but fails to discuss the licensee's capability to decontaminate relocated on-site personnel, supply personnel with clothing if required and provide them with decon- taminating agents including those for removal of radioiodine from the skin. L. MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard Arrangements are made for medical services for contaminated injured individuals. Synopsis Local and backup hospital and medical services having the appropriate . capabilities are arranged for. On-site first aid capability is provided. . Transporting victims of radiological accidents to medical support facilities . is arranged for. Evaluation: The plan satisfies Planning Standard L. M. RECOVERY AND REENTRY PLANNIN3 AND POST-ACCIDENT OPERATIONS Planning Standard General plans for recovery and reentry are developed. Synopsis General plans and procedures for reentry and recovery are developed, and . the means are described by which decisions to relax protective measures are reached. , > The structure, functions, and memberships of the facility recovery organ- . ization are described. Means are specified for informing members of the response organizations . that a recovery operation is to be initiated. , A method for periedically estimating total population exposure is established. . C-17 . .-- _ , _ _ . - , . _ .

Appendix C Evaluation: The plan satisfies Planning Standard M. Note: The NRC Emergency Prepardness Appraisal team did determine, during its on-site evaluation, that procedures to govern the operations of the Recovery Organization had not bee prepared. N. EXERCISES AND DRILLS Planning Standard Periodic exercises are (will be) conducted to evaluate major portions of emergency response capabilities, periodic drills are (will be) conducted to develop and maintain key skilis, and deficiencies identified as a result of exercises or drills are (will be) corrected. Synopsis An emergency preparedness exercise that simulates an emergency that . results in off-site radiological releases is provided. Exercises are conducted as set forth in NRC and FEMA rules. A joint exercise to involve mobilization of State and local personnel anJ . resources is provided. A critique of the annual exercise by Federal and State observers is provided. The scenario for the exercise will be varied each year to provide for . testing all elements of the Emergency Plan within a five year period. Required communication drills are provided. Fire drills are conducted in accordance with plant technical . specifications. Required medical drills are provided. Required radiological monitoring and health physics drills are included. Exercise scenarios include the appropriate information. . A critique by governmental observers, resulting in a formal evaluation is provided. Organizational means are established for resolving plan deficiencies . . identified as a result of a drill or exercise. Evaluation: The plan satisfies Planning Standard N. C-18

. Appendix C 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING Planni.'q Standard Radiological emergency response training is provided to those who may be called on to assist in an emergency. Synopsis: Provisions have been made for training of those personnel who will be . part of the emergency organizations. Off-site response organizations such as fire, ambulance, medical and . rescue, will be afforded annual training on notification procedures, radiation protection and site access and reporting procedures. Practical drills will supplement formal classroom training. Erroneous . performance will be corrected on-the-spot by the drill instructor. Individuals assigned to first aid teams will receive Red Cross Multi-Media training. Provisions have been made for instructing and qualifying most individuals . who will implement radiological emergency response plans including initial and annual re-training programs for personnel with emergency response responsibilities. Evaluation: The plan satisfies Planning Standard 0 except as noted below. Criterion Ib: The plan does not include off-site police forces in the emergency response training. C_riterion 4 : Civil Defense / Emergency Service personnel are not specifically 9 identified. Criterion 41: The plan does not address training for or identify headquarters support personnel. The plan instead discusses training of Recovery Organization personnel (Section 6.1.2). It is not clear if members of this organization are considered as headquarters support personnel. A specific statement should be made regarding training of headquarters support personnel. P. RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENTT~sERI~0DTC REVIEDFD DT5~TlU!i0fiC;N OF ER$fiGENCY PLANS ~ - - - Planninc_ Standard Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained. C-19

Appendix C Synopsis The Project Manager-Nuclear Emergency Program is designated as the indiv- . idual with overall authority and responsibility for radiological emergency response planning. The General Supervisor-Radiation Safety is designated as the Emergency . Response Coordinator. Periodic revision of the plan, as needed, including changes identified by . drills and exercises, is provided. The distribution of plans and approved changes to all organizations and . appropriate individuals is provided. A detailed listing of supporting plans and their sources is given. A list.ng of the procedures required to implement the plan is given. .

A table of contents is included. . An annual review of the Emergency Response Plan Program by the Plant . Operations and Safety Review Committee is provided. Quarterly review of the plan and its implementation procedures, including . updating of telephone numbers, is provided for. Evaluation: The plan satisfies Planning Standard P except as noted. Criterion 1: Training for individuals responsible for the planning effort is not discussed. Criterion 7: The listing does not include the section(s) of the plan to be implemented by each procedure. Criterion 8: The cross references to the NUREG-0654 criteria are highly inaccurate and therefore more frustrating than helpful. 3 C-20 - - - ._ - , --_ _ . _ - _ . .

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f 431 PAft K AVENUE % ** ' 4 g KING OF PROS $1 A. PENNSYLV ANI A 19486 ..... NOV 6 1981 n In Reply Refer To: Docket Nos. 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mrp* A. E. Lundvall , Jr. ~ V' ice' President, St , ply P. O. Box .1475- Bal timode',j Naryland 21203 ." "

I Gentlemen: This letter refers to a meeting between you and members of your staff and Mr. 0.M. Rohrer, NRC Appraisal Team Leacer, and other members of the NRC Er.ergency Preparedness Implementation Appraisal Team, which was held at the Calvert Cliffs Nuclear Power Plant on October 16, 1981 and to a subsequent telephone discussion between Mr. Thomas N. Pritchett, of your staff, and Mr. G.L. Snyder of my staff, on October 30, 1981. With regard to the matters relating to emergency preparedness discussed at this meeting, we understand that you will undertake and complete the following actions: 1. Review and revise the appropriate Abnormal Operating Procedures and Emergency Operating Procedures 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 appropr ate Emergency Response Plan. Implementing Procedures. This will be accomplished by November 1, 1981. 2. Determine which emergency response and other necessary operations personnel must perform essential duties in locations where significant airborne radioactive contamination can be present during emergency conditions. Determine the availability and storage location of appropriate respiratory protection equipment (self-contained breathing devices). Insure that the personnel are provided with the appropriate respiratory protection. This will be accomplished by November 16, 1981. ~ 3. 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. . - .. - . . .- - .- . .. -

v . Baltimore Gas and Electric Company 2 NOV 6 1981 - e . This will be accomplfshed by November 16, 1981. 4. 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 atmnsphere, ani gas and particulate effluent sampling by performing the following: Determi,ne the plant conditions and resultant, radiological conditions - undhr which the post-accident sampling can be safely performed. y ,u . Revis%I[e interim sampling procedures and$dify'the sampling Y - equipment so that representative samples are obtained with as low personnel exposure as practicable. - Revise the interim sampling procedures to ensure that they are applicable to emergency conditions as well as normal operating conditions. - Assure that analytical capabili'.y exists for handling high activity post-accident samples. This will be accomplished by November 16, 1981. 5. As you indicated in your August 10, 1981 letter to Mr. R. A. Clark, Chief, Operating Reactors Branch #3, USNRC, there is 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, USNRC (Generic Letter No. 81-10). Tha NRC Staff is actively reviewing your proposed interim action in th s 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. In addition to the above, please inform this office in writing when the aforementioned actions have been completed. - - -

f " a Ba'ltimoreGasandF.lec3.ricCompany 3 Y

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. ' , i If our understanding of your planned actions, describid above, is not in l ) accordance with the actual plans and actions being implemented, please ! , cc ntact this office by telephong and in writing within 24 hours. . Your cooperation in this matter is appreciated. [I Sincerely, I CM b ~ ,- w- , Ronald C. Hayne_ _ m, c _,3 ~ Director j[ j =- lN "" cc: R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent, (Receives 2.790 Info) .t T. Sydnor, General Supervisor, Operations QA R. C. L. Olson, Principal Engineer J. A. Tiernan, Manager, Nuclear Power T. N. Pritchett, Project Manager, Nuclear Emergency Programs R. E. Denton, Ceneral Supervisor, Training and Technical Services , j{ Public Document Room (PDR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) 1 ! NRC Resident Inspector State of Maryland (2) > > . ~ - - - . . -. _ . - _ ~ . . . _ ._ _ _, , , , _ _ , , ,_ __ , I . c , .

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[jp Wug% UNITED STATES NUCLEAR REGULATORY COMMISSION l - , l g j j nEciou s e' g 638 FARK AVENUE , .f K8NG OF PRUS$1 A, PENNSYLVANI A 19406 ' , , +..... NOV 1 91981 Docket Nos. 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mr. A. E. Lundvall, Jr. . Vice President, Supply P. O. Box 1Q5 5 e;m Baltimore,QFyland 21203 Gentlemen: This letter refers to our letter to you dated November 6, 1981 and to subsequent telephone discussions between Messrs. T.N. Pritchett and S.E. Jones of your staff, and Mr. G.L. Snyder of my staff on November 10, 1981. Your staff members expr>ssed concern that items 2 and 3 in our letter dated November 6 were broader in scope than had been agreed upon. Based on discussion of these two items, we understand that the following equivalent actions were completed by November 16, 1981: 2. Determine which emergency response and other necessary operations personnel must perform essential duties in locations where significant airborne radioactive contamination can be present during emergency conditions. Determine the availability and storage location of appropriate respiratory protection equipment (self-contained breathing devices). Insure that presently available respiratory protection equipment is located and available to personnel performing essential duties. If additional respiratory protection equipment is required, inform the NRC Region I Office, in writing, of the plans and schedule for procuring the additional equipment. 3a Using your present training program, complete tha training of emergency response organization personnel for whom training deficiencies have been identified. 3b Qualify your instructors and prepare formal lesson plans for use

during subsequent training.

If our understanding of your planned actions, described above, is not in accordance with the actual plans and actions being implemented, please , contact this office by telephone and in writing within 24 hours. l ! ! , E s // A Q i

. - - - - - .. . haltimore Gas and Electric Company 2 NOV 191981 ' - Your cooperation in this matter is appreciated. Sincerely, wY - [ ' { i i'T- Ronald C. Haynes . Regional Administrator cc: ,7 ~ . _ %eee. l:ipb w ' ' ' R. M. Douglass, Manager, Quality Assurance L. B. Russell, Plant Superintendent, (Receives 2.790 Info) T. Sydnor, General Supervisor, Operations QA " R. C. L. Olson, Principal Engineer 4. A. Tiernan, Manager, Nuclear Power T. N. Pritchett, Project Manager, Nuclear Emergency Programs S. E. Jones, Supervisor of Training R. E. Denton, General. Supervisor, Training and Technical Services Public Document Room (PDR) " Local Public Document Room (LPLR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of Maryland (2) 1 4 , . . , ,. - - . _ _ . - - - , _ }}