ML20058H299
| ML20058H299 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 06/24/1982 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20058H245 | List: |
| References | |
| 326, NUDOCS 8208030534 | |
| Download: ML20058H299 (13) | |
Text
-
5 f Ob e
G Ogn,v l
'/71/2 ij t m.C PFC'_'
8Q og
' vim'0 INIA ELECTRIC AND Powna COMPANY RIcauoMD, VIRGINIA 20 261 a1 32 Jul 26 Pl2 3d
[
=
7 B.M.I.masseno s;
J Vacs Pameament
~
Neca. mas 075B&TIONS
.7 3
u:
June 24, 1982 cs Mr. James P. O'Reilly, Regional Administrator Serial No.
326 U.S. Nuclear Regulatory Commission N0/ REB:ddp Office of Inspection and Enforcement Docket Nos. 50-280 Region II 50-281 101 Marietta Street, N.W., Suite 3100 License Nos. DPR-32 Atlanta, Georgia 30303 DPR-37
Dear Mr. O'Reilly:
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS SURRY POWER STATION The Preparedness Improvement Items listed in Appendix B to your letter of May 25, 1982, have been evaluated and considered for inclusion in our emergency preparedness program.
The enclosed list comprises the results of our consideration of each of the improvement items in Appendix B.
A complete revision of the Surry Power Station Emergency Plan and Implementing Procedures is in progress and will be completed by August 2, 1982.
As a result of this effort, many of the items listed in Appendix B will be incorporated in the Surry Plans and Procedures.
Should you have any questions concerning our response to the " Prepared-ness Improvement Items" or other items concerning the March 15-26, 1982 Appraisal of Surry Power Station, please notify us.
l l
Respectfully yours, f
I J
Jashorg l
R. H l
Enclosure
\\/
/
(,fi 8208030534 820727 PDR ADOCK 05000280 G
RESPONSE TO APPENDIX B PREPAREDNESS IMPROVEMENT ITEMS The Preparedness Improvement Items listed in Appendix B of your letter of May 25, 1982, have been reviewed and considered for inclusion in the Surry Power Station Emergency Plan and Implementing Procedures as appropriate.
The following list comprises our response to each of the 79 items.
Item 1.
Upgrading the descriptive material for the emergency organization so that the assignment of emergency functions and the interface between emergency functions is clarified. (2.1)
Response: A task force was formed in March 1982, to perform a complete revision of the Surry Power Station Emergency Plan and Emergency Plan Implementing Procedures.
The task force expe~ s to have the procedures and training completed by August 2,
1982.
This item will be specifically addressed in the new plan and implementing procedures.
Item 2.
Developing the training manual to provide guidance and to increase the uniformity of the training program. (3.1)
Response: See response for Item No. 1.
Item 3.
Developing lesson plans and tests to be based on the functional activities of the emergency response organization. (3.1)
Response: See response for Item No. 1.
Item 4.
Upgrading the training matrix to include all training received by members of the emergency response organization. (3.1)
Response: The training matrix has been deleted.
Emergency response personnel will receive training as described in the revised Chapter 8
" Maintaining Emergency Preparedness" of the Station Emergency Plan.
Item 5.
Clearly establishing the basic set of courses for the First Aid Team that are to be required. (3.1)
Response: See response for Item No. 1.
Item 6.
Documenting all training to include the name of attendees, a descriptive course title, the training date, and the instructor's name. (3.2)
,e App;ndix B Praptradnaza Improvsment Itens Response: See response for Item No. 1.
Item 7.
Designating the Tralning Department to be the central repository for all training records. (3.2)
Response: See response for Item No. 1.
Item 8.
Revising the activation procedure EPIP-1, APX 7, Section 2, for the interim TSC to include the installation of additional tables, desks, and other supplies to better accommodate all TSC personnel.
(4.1.1.2)
Response: Under present space limitations, there is not room in the TSC for additional tables, desks and supplies.
This item has merit and will be considered for implementation when suitable space becomes available.
Item 9.
Revising the OSC activation procedure, to include provisions for personnel and emergency equipment, to require all emergency response personnel not immediately performing emergency duties to report to the OSC to facilitate the formation of the various emergency teams, and relocation of the OSC based on potential or actual hazardous radiological conditions. (4.1.1.3)
Response: OSC activation procedure revision is being included in the current upgrade of EPIPs.
The revised EPIP will specify actions fer emergency response personnel not immediately performing emergency duties.
Item 10.
Developing and implementing procedure for the activation and staffing of the EOF. (4.1.1.4)
Response: See response for Item No. 1.
Item 11.
Assuring that adequate monitoring and decontamination equipment are provided to support the operation cf the EOF. (4.1.1.4) l
[
Response: Special monitoring equipment or replacement clothing will be l
provided from Station Supplies as needed.
Item 12.
Providing for taking and analyzing more than one post-accident coolant sample. (4.1.1.5)
Response: When the post accident sampling system is installed, the Station l
will have the capability of analyzing more than one coolant sample. The System is installed and presently undergoing testing.
l It is expected that all testing problems will be resolved no later than September 1, 1981.
1 l
l L
AppIndix B Prsparsdn223 Irprovr=2nt Itats Item 13.
Providing a shielded container for transporting post accident air samples. (4.1.1.6)
Response: Evaluation shows that the air sample is less than 1 R/hr (maximum), therefore, no shielding is required.
Item 14.
Providing special tools for handling and removing post accident gas sampling cartridges and filters. (4.1.1.7)
Response: The new Kaman system being tested has special tools provided for handling post accident gas sampling cartridges and filters. The system will in installed by September 30, 1982.
Item 15.
Providing alternate sampling points for essential post-accident liquid effeuent samples for those systems where the primary sample point is likely to be inaccessible. (4.1.1.8)
Response: See response for Item No. 1.
Item 16.
Upgrading the marking of assembly (shelter) areas and the instruction of personnel as to the location of their assembly areas. (4.1.2.1)
Response: This item is being included in the revised plan and will be implemented by October 13, 1982.
Item 17.
Establishing an alte rnate offsite assembly area in case the primary site becomes unuseable. (4.1.2.1)
Response: See response for Item No. 1.
Item 18.
Establishing a decontamination capability, for timely decontamina-tion of personnel, at or very near the remote assembly area.
(4.1.2.1)
Response: The establishment of a decontamination facility at or very near the remote assembly area is not practical at this time.
If decontamination is required, individuals must return to the Station or go to Surry High School.
Item.19. Clearly designating the person responsible for distribution of Potassium Iodide tablets. (4.1.2.2)
Response: See response for Item No. 1.
Item 20.
Establishing a system for the disposal of radioactive waste collected at the remote assembly area. (4.1.2.3) s
App ndix B Prspsrgdnsss Irprovr.unt Iter.s Response: See response for Item No. 1.
Item 21.
Establishing a system for replacing contaminated clothing at the remote assembly area. (4.1.2.3)
Response: See response for Item No. 1.
Item 22.
Assessing the electrical wiring and making provisions for additional wiring, in case needed. (4.1.4)
Response: The Public News Center will be checked for electrical wiring requiremente and evaluai.ed for additional
- wiring, if
- needed, by October 13, 1982.
Item 23.
Storing the Press Center telephones and other dedicated equipment at the facility. (4.1.4)
Response: See response for Item No. 1.
Item 24.
Making provisions for adult-sized tables to replace the elementary school-sized tables. (4.1.4)
Response: The tables are replaced on an as needed basis.
Item 25.
Performing calculations or testing to assure that field sample analysis has the capability to measure air particulate activity as low as 1E-09 microcuries per cubic centimeter. (4.2.1.1)
Response: See response for Item No. 1.
l l
Item 26.
Including in the Emergency Plan a complete listing and description of all area and process radiation monitors. (4.2.1.2) i Response: Since the equipment used to assess and classify an emergency is already specifically cited in Table 4.1 of the Emergecy Plan, it is not considered a requirement to relist all plan instrumentation.
l t
Item 27.
Providing a specific listing of the non-radiation process monitors that are relied upon for classification and assessment in the emergency plan or procedures. (4.2.1.3)
I Response:: Response to this item same as Item 26.
l Item 28.
Providing for periodic testing of the electrical switches and controls at the Auxiliary Shutdown Panels. (4.2.1.3) l l
i
App 2ndix B Prsparsdneas Improvement Items Response: A procedure to test switches and controls on the Auxiliary Shutdown Panels will be developed by the next refueling outage scheduled for March 1983.
Item 29.
Establishing an inspection, maintenance and calibration program for the Control Room meteorological data recorders similar to the program provided for instrumentation at the meteorological towers.
(4.2.1.4)
Response: An inspection, maintenance and calibration program for the Control Room meteorological data recorders was completed on June 3, 1982.
Item 30.
Modifying the control room meteorological instruments to provide single recordings of sigma theta and of temperature difference values. (4.2.1.4)
Response: A design change will be initiated to modify the Meterological Data read out package.
In the interim, procedural controls will be established to clearly define which of the dual recordings should be used as first priority.
Item 31.
Identifying a procedure that requires that shift operations personnel be informed of all severe meterological phenomena likely to affect the site. (4.2.1.4)
Response: The Systems Operations Office at Corporate Headquarters has an administrative directive which specifies that Power Station Shift Operations personnel are notified of severe meterological conditions.
Item 32.
Improving the recording of variables currently recorded on the multi-point recorder at the primary tower location so that the variable values will be readable. (4.2.1.4)
Response: The recently installed met data system is believed to provide satisfactory data for emergency plan use.
The actions described in Item 30 will further improve the system performance.
Item 33.
Providing for the needs of transportation in the Plan and in the applicable emergency procedures. (4. 2. 6)
Response: See response fe; Item No. 1.
Item 34.
Establishing a single EPIP for notifications with clearly established event activated notification lists. (5.4.1)
Response: See response for Item No. 1.
Item 35.
Providing guidelines for recommendations to offsite authorities in the implementing procedures. (5.4.2)
e Appindix B Prcparsdnaca Irprovement Items i
Response: See response for Item No. 1.
Item 36.
Basing all thyroid dose protective action recommendations on a child's thyroid rather than the adult. (5.4.2)
Response: See response for Item No. 1.
Item 37.
Incorporating into the licensee's guidelines provisions for estimating the duration of a release as recommended in EPA 520/1-75-001.
(5.4.2)
Response: See response for Item No. 1.
Item 38.
Revising procedures to provide for prouptly notifying the offsite authorities of any change to the emergency status and the closing out of emergency situations in accordance with Appendix 1,
(5.4.2.)
Response: See response for Item No. 1.
Item 39.
Dividing the assessment and notification procedures into two phases; the initial quick response and the long term phases.
(5.4.2)
Response: See rcaponse for Item No. 1.
Item 40.
Upgrading established procedures to assure primary and backup transportation for offsite monitoring teams, and the means by which team members, vehicles, and equipment are to pass expedi-tiously through security when departing the plant. (5.4.2.1)
Response: See response for Item No. 1.
Item 41.
Upgrading established procedures to specify radiation protection levels and protective actions for offsite team members tracking a plume, a central collection point for the return of environmental samples and completed survey data forms, and the unique labeling of all environment samples. (5.4.2.1)
Response: See response for Item No. 1.
Item 42.
Expanding form EPIP-16.1 to include spaces for instrument identi-fication, mode of instrument operation, air sampler flow rate, background radiation levels, and sample count time. (5.4.2.1)
Response: See response for Item No. 1.
App ndix B Prsp3rsdnzsa Improvsment Its:s Item 43.
Revising the routine survey procedures that are to be used for accident conditions to include special sample handling techniques designed to avoid unncessary radiation exposures from abnormally
" hot" samples.
(5.4.2.1)
Response: See response for Item No. 1.
Item 44.
Establishing emergency radiological survey and air particulate sampling procedures, to include special provisions for handling abnormally " hot" samples, which are consolidated with other emergency procedures.
(5.4.2.2)
Response: See response for Item No. 1.
Item 45.
Making provisions for recordning vital information for emergency onsite and inplant surveys, (5.4.2.2)
Response: See response for Item No. 1.
Item 46.
Establishing a central collection point for all samples and vital sample information and including this in applicable procedures.
(5.4.2.2)
Response: See response for Item No. 1.
l Item 47.
Modifying post-accident coolant sampling procedures to describe the required means for transporting samples to the Hot Lab.
(5.4.2.4)
Response: See response for Item No. 1.
Item 48.
Specifying the sample point locations. (5.4.2.4) i Response: See response for Item No. 1.
Item 49. Modifying the sampling procedures to make provisions for labelling the sample. (5.4.2.4)
Response: See response for Item No. 1.
Item 50.
Developing procedures for the analysis of high level, post accident samples. (5.4.2.5)
Response: See response for Item No. 1.
AppIndix B Prsp3rsdntas Improvtment Itenc Item 51.
Revising analytical procedures to specify methods of protecting the counting facilities from contamination. (5.4.2.5)
Response: See response for Item No. 1.
Item 52.
Revising analytical procedures to specify means of counting if the counting area has a high background. (5.4.2.5)
Response: See response for Item No. 1.
Item 53. Revising analytical procedures to specify means of recording data and to assign responsibility for providing data to the organiza-tional element responsible for the assessment function. (5.4.2.5)
Response: See response for Item No. 1.
Item 54.
Revising analytical procedures to provide for the disposition of samples af ter analysis.
(5.4.2.5)
Response: See response for Item No. 1.
Item 55. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to containment air sampling. (5.4.2.6)
Response: See response for Item No. 1.
Item 56. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to stack effluent sampling. (5.4.2.8)
Response: See response for Item No. 1.
Item 57. Applying the general needs identified as improvement items in paragraph 5.4.2.4 to liquid effluent sampling. (5.4.2.10)
Response: See response for Item No. 1.
Item 58.
Upgrading established procedures to assign specific authority for organizing and coordinating environmental monitoring teams.
(5.4.2.12)
Response: See response for Item No. 1.
Item 59. Establishing a means to assure timely access to the north bank of the James River for monitoring. (5.4.2.12)
App 2ndix B Prsparsdness Irprovement Itsas Response: Timely access to the north bank of the James River would be via the James River Bridge.
The Jamestown-Scotland Ferry is not always the fastest route acress the James River. Availability of the State Department of Highways and Transportation Jamestown-Scotland Ferry would not appreciably improve transportation time to the Peninsula (North Bank of the James River) monitoring positions.
Use of the James River Bridge provides more control and reliability.
Therefore, no agreement to keep the ferry operating is considered necessary to ensure access to the north bank of the James River.
Item 60. Developing an overall procedure for radiation protection during emergencies which assigns responsibilities and priorties for health physics activities. (5.4.3.1)
Response: See response for Item No. 1.
Item 61.
Developing specific guidance within the emergency procedures for issuance of dosimeters to non-plant personnel, dose assessment, control of access to radiation zones, keeping exposure records, and limiting exposure during an emergency. (5.4.3.1)
Response: See response for Item No. 1.
Item 62.
Upgrading established procedures to provide specific administra-tive responsibility for the authorization of emergency exposures.
(5.4.3.1)
Response: See response for Item No. 1.
Item 63.
Upgrading established procedures to clearly activate the emergency plan with regard to evacuation routes, means of transportation and l
alternatives in case of unfavorable radiological conditions.
l (5.4.3.2) l Response: See response for Item No. 1.
Item 64.
Clearly marking evacuation routes both inside and outside the plant. (5.4.3.2)
Response: Station personnel are trained on evacuation routes during general employee training and periodically thereafter. The next training cyle will l
be completed by October 13, 1982.
Marking of evacuation routes has been j
evaluated and is not considered to have an appreciable effect on evacuation L
time.
l l
Item 65.
Upgrading established procedures to assume completion of account-ability within 30 minutes and providing for continuing account-ability of onsite personnel. (5.4.3.3)
App:ndix B Prcp r:dn: s Imprev:; ment Itc=s Response: See response for Item No. 1.
Item 66.
Revising procedures to clearly indicate where personnel; are expected to assemble for accountability under all circumstances.
(5.4.3.3)
Response: See response for Item No. 1.
Item 67.
Revising procedures to indicate exactly what actions individuals on the north end of the Peninsula will be requested to take.
(5.4.3.3)
Response: See response for Item No. 1.
Item 68.
Establishing or upgrading existing procedures to assure that Health Physics personnel are dispatched to monitor personnel in tha remote assembly area.
The procedures should describe the monitoring and decontamination methods, establish contamination action levels for decontamination, and provide a form for recording all pertinent survey information for each person.
(5.4.3.4)
Response: See ret.ponse for item No.N1.
Item 69.
Expanding the implementing procedures to designate the personnel responsible for calling the onsite ambulance into service, driving the ambulance, and exchanging dosimetry prior to ambulance departure. (5.4.3.5)
Response: See response for Item No. 1.
Item 70.
Revising the implementing procedures to specify when the shift supervisor is to notify the hospital, and-to also assure health physics coverage for medical / rescue personnel arriving from offsite locations. (5.4.3.5) l I
Response: Sei response for Item No. 1.
o.
s Item 71. The rumor control program will reu in open pending review of the s
proiedure after issuance. (5.4.1) 3 l
Response: The rumor control program procedure will be completed on August 2 L
1982.
,1 Item 72. Including the periodic inventory of radiological equipment and supplies stored in the plant ambulance in a periodic test. (5.5.1) j Response: Ambulanc.e' emergency supplies will be periodically inventoried.
1
App;ndix B Prcp:r:dnacs Irprcycosnt Itsu Item 73. Having the Emergency Planning Coordinator maintain a log of all Emergency Planning correspondence and reports. (5.5.2)
Response: The existing correspondence and records handling procedures in effect at the station are providing satisfactory control of correspondence and reports.
Additional procedures for Emergency Planning correspondence and reports are not considered necessary.
Item 74.
Adding the current revision number and date of issuance to each item in the Table of Contents for the Emergency Plan and the EPIPs. (5.5.3)
Response: Current established procedures call for all changes to be indicated by vertical lines in the margins where the changes occur, for the dates of the pages where changes occur to reflect the dates of the changes and the first pages of all station publications to indicate the dates of the latest changes.
In addition, Request to Change Procedure forms must be prepared to affect the changes, document approvals of the changes and to provide documentation of the transactions. These records are maintained in Station Records and are auditable.
It is felt that this procedure is adequate and meets all regulatory requirements in addition to providing an uncomplicated method of identifying changes to the users and documenting those changes as a matter of record. Therefore, plans do not provide for any changes in current methods of affecting changes to the Emergency Plan and its implementing procedures.
Item 75.
Providing for an annual audit of the Emergency Plan and Emergency Plan Implementing Procedures in the appropr' ate manual or procedures. (5.5.4)
Response: See response for Item No. 1.
s Item 76. Providing audit assessments and comments relative to the items s
specified in Section 8.4 of the Plan. (5.5.4)
Response: See response for Item No. 1.
Item 77.
Expanding the audit checklist item for drills and exercises to specifically address the commitments in Section 8.1.2 of the Emergency Plan for the drills and exercises listed in Table 8.1.
(5.5.4)
Response: See response for Item No. 1.
Item 78.
Upgrading the Health Physics training to include monitoring techniques under adverse, high radiation conditions. (7.2.10)
Response: See responig ior Item No. 1.
i
App:ndix B Prcparadn2sa Imprev; ment Itema Item 79. Training technicians to be aware of protective measures available for keeping exposures to a minimum when monitoring in high radiation conditions. (7.2.10)
Response: See response for Irem No. 1.
i i
J 9
1 l
2
.--