ML20062G202

Responds to NRC Re Violations Noted in IE Emergency Preparedness Appraisal Repts 50-317/81-19 & 50-318/81-18.Corrective Actions:Emergency Planning Unit Established & Staffed on 820401

ML20062G202
Person / Time
Site:	Calvert Cliffs
Issue date:	06/25/1982
From:	Poindexter C BALTIMORE GAS & ELECTRIC CO.
To:	Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20062G168	List: IR 05000317/1981019 ML20062G202
References
NUDOCS 8208120272
Download: ML20062G202 (7)

Text

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BALTIMORE GAS AND ELECTRIC CHARLES CENTER P.O. BOX 1475 BALTIMORE, MARYLAND 21203 ARTHUR E. LUNOVALL. JR.

Vice PRtssoENT I Su pe=t v U.S. Nuclear Regulatory Commission Office of Inspection & Enforcement Region 1 631 Park Avenue King of Prussia, PA 19406 l ATTENTION: Mr. G. H. Smith, Director

REFERENCE:

(a) Letter dated May 26,1982, to Mr. A. E. Lundvall, Jr., from Mr. G. H. Smith; NRC Emergency Preparedness Implementation Appraisal; Combined Inspection Report No. 50-317/81-19 and 50-318/81-18 (b) Letter dated November 16, 1981, to Mr. Ronald C. Haynes, from Mr. A. E. Lundvall, Jr., NRC Emergency Preparedness Implementation Appraisal Gentlemen:

This letter is provided in response to the thirty day requirements specified in reference (a). Our response to the corrective actions required by the Confirmatory Action Letter, j which are restated in Appendix A of reference (a), was provided in reference (b) and is J reaffirmed. The information required by Appendix B of reference (a) is provided as an Enclosure to this letter.

Should you have any questions regarding this response, we would be pleased to discuss them with you.

Very truly yours, 9

) .

~

4 4 6YyveA Vice President - Supply AEL/DWL/JMM/gla l

J cc: 3. A. Biddison, Esquire G. F. Trowbridge, Esquire ,

D. H. Jaffe, NRC R. E. Architzel, NRC j

8208120272 820804 PDR ADOCK 05000317 G PDR i

Mr. G. H. Smith June 25,1982 Page 2 STATE OF MARYLAND  :

TO WIT:

CITY OF BALTIMORE  :

C. H. Poindexter, being duly sworn states that he is Vice President of the Baltimore Gas and Electric Company, a corporation of the State of Maryland; that he provides the foregoing response for the purposes therein set forth; that the statements made are true and correct to the best of his knowledge, information, and belief; and that h was authorized to provide the response on behalf of said Corporation.

WITNESS my Hand and Notarial Seal: J iht _

• h 70tary Publi6 My Commission Expires: -

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ENCLOSURE (1)

REPLY TO APPENDIX B OF NRC INSPECTION REPORT 50-317/81-19; 50-318/81-18

1. The Emergency Planning Unit was established and staffed April 1,1982, as part of the Training & Technical Services Section of the Nuclear Power Department.

Explicit and specific functional responsibilities and authorities for emergency preparedness planning and coordination functions have been developed for and are being implemented by this Unit.

2. Staff augmentation is not necessary due to the formation of the Emergency Planning Unit.

3. Emergency Response Plan Implementation Procedures, Section 5.0, Revision 8, Preparation and Control of Emergency Response Plan implementing Procedures, requires the ERPIP reviewer (a member of the Emergency Planning Unit) to establish a liasion with ERPIP users to obtain inputs regarding procedure content and usability. Additionally, training personnel have been instructed to solicit user comments on an evaluation form during training sessions and to transfer this information on to the Emergency Planning Unit for consideration in ERPIP revisions.

4. Job descriptions and specifications developed for positions established in the Emergency Planning Unit implement specific selection and qualification criteria for individuals performing emergency preparedness development activities.

5. The Emergency Planning Unit was developed as a method 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.

6. The implicit authority of individuals assigned emergency responsibilities is adequate to satisfy the requirements of 10 CFR 50.54. Section 3.2.2.1.1 of the ERP authorizes the Site Emergency Coordinator to act for the Company until relieved by the Recovery Manager. This is the only situation where one performs responsibilities outside the scope of the normal corporate organization and hence its delineation in the Plan. Authority statements for personnel assignments would not enhance the emergency response and would be contrary to the regulatory guideline to keep the Plan as concise as possible, while making clear what is to be done in an emergency, how it is to be done, and by whom.

7. Specific licensee representatives have been designated in Recovery Organization Procedure #3, Revision 0, as Technical Representatives to the State and local EOC's.

l

ENCLOSURE (1)

REPLY TO APPENDIX B OF NRC INSPECTION REPORT 50-317/81-19; 50-318/81-18

8. The Emergency Response Plan, Revision 1, Section 3.3.2, states in part: "The Recovery Manager can, at any time, relieve the Site Emergency Coordinator of overall command and coordination of the emergency organization. If a Site or General Emergency has been declared, the Recovery Manager, upon arrival at the Site, will assume this responsibility. liowever, the SEC under the direction of the Recovery Manager will remain the Key Individual for accident assessment, emergency classification, notification of, communication with, and recommendation of protective actions to off-site agencies."

The Emergency Response Plan, Revision 1, Section 1.4 defines: " Command Individual: that person designated as responsible for and assigned the authority to be in overall charge of BG&E's emergency response efforts." " Key Individual: that individual designated as having responsibility to ensure that a particular emergency task function is accomplished."

This detail specifies the control and decision making relationship between the SEC and the Recovery Manager. This delineates the authority and responsibility for notification of off-site authorities and the transmittal of recommendations for off-site protective actions for the general public. These responsibilities shif t by voice command which is announced over the public address system and recorded on status boards.

9. Updated agreements have been obtained for letters currently in Revision 1 of the ERP. These will be incorporated in Revision 2 of the ERP scheduled for issue in August 1982. Revision 2 of the ERP will be reviewed to identify svhich off-site organizations (both commercial and private) require letters of agreement. These will be obtained and incorporated into Revision 3 of the ERP. Revision 3 is scheduled for distribution in the second quarter of 1983.

10. The current practice of defining emergency organization position responsibilities and matching personnel qualifications and authority with the position is adequate.

This mechanism is used for BG&E's corporate organization and is in keeping with standard human resources administration policy.

11. The Control Room Ventilation Monitoring System has been evaluated and found adequate for detecting airborne contamination. The detector proximity to the main vent affords a conservative actuation into the recirculation mode.

12. To improve personnel exposure monitoring capabilities in the facilities listed by the recommendation, individuals will be designated for this sole purpose. These people will be qualified to perform this activity in their respective area. Personnel assignment and qualifications will be complete by September 30,1982.

ENCLOSURE (1)

REPLY TO APPENDIX B OF NRC INSPECTION REPORT 50-317/81-19; 50-318/81-18

13. The location of the OSC has been corrected in Revision 2 of the ERP and Revision 8 of the ERPIP. These documents will be issued in August and July 1982, respectively.

14. Implementing procedures to govern the use of the decontamination facilities at the Farm Demonstration Building will be developed by December 31,1982.

15. Tamper indicating devices will be provided for all emergency kits. This will be complete by September 30,1982.

16. As an interim solution, mobile field kits haw been supplemented with calculators.

The number of calculations to be performed will be evaluated and reduced, if required, during the second quarter of 1983.

17. The Condenser Off-Gas Monitoring Systems have been modified. The systems have been functioning continuously for six months. New detector response curves are in development and should be available by June 30,1983.

18. Procedures to govern the use of the Area and Process Radiation Monitors during emergencies will be developed by September 30,1982.

19. The Technical Support Center Data Acquisition Display System provides remote i indication of non-radiation process monitors. The licensee feels this equipment installation is adequate to resolve the encountered problems.

20. A real-time meteorological information system was in existence on April 1,1982.

Sea breeze effects have been considered and it is the licensee's position that the sea breeze effects are insignificant and not applicable to the Calvert Cliffs site.

21. Baltimore Gas and Electric's System Operator-Bulk Power maintains a liasion with the National Weather Service and has in-house capability to monitor the Patuxent River Naval Station Radar Weather Report. Severe weather conditons that may impact the Calvert Cliffs site would be observed by the System Operator and reported to the Control Room. This system is currently in operation.

22. An evaluation of the plant PA sytem is in progress to determine the improvements needed to insure that all persons at Calvert Cliffs can hear and understand emergency messages transmitted. This engineering evaluation will be completed by June 30,1983.

23. Ringing indication lights are being installed on all emergency telephones. This will be complete by September 30,1982.

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r ENCLOSURE (1)

REPLY TO APPENDIX B OF NRC INSPECTION REPORT 50-317/81-19; 50-318/81-18

24. Section 5.4.2.2 of the ERP will be revised to reflect current vehicle status with respect to type, number, and equipment. The revision will be complete by September 30,1982.

Section 4.3.1 of the ERPIP will be revised to include instructions for the acquisiton of emergency vehicles as described by the RAD. The revision will be completed by September 30,1982.

25. The ERPIP's will be corrected to eliminate the need to retrieve required forms from other documents and minimize the need to retrieve neebd forms from other ERPIP's. This will be complete by December 31, 1982.

26. Direction will be provided in the off-site radiological survey procedure (ERPIP 4.1.6, 4.3.1) regarding the final disposition of the data at the completion of the survey. This will be complete by December 31,1982.

27. The back-up communications for radio failure is the C&P telephone system.

Procedures and equipment are in place to facilitate this system.

28. ERPIP 4.3.2 with the referenced survey forms has been included in the mobile emergency kits. -

29. ERPIP 4.3.2 will be revised to include instructions in the handling and final dispositon of samples taken by on-site monitoring teams. The revision will be complete by December 31,1982.

30. Runners will be utilized as a back-up means of communications for radio failures for the on-site (out-of-plant) monitoring teams. ERPIP 4.3.2 will be revised to reflect this provision by September 30,1982.

31. Forms will be provided in the in-plant radiological survey procedures (ERPIP 4.5.2; 4.8) to record the results of surveys, including the area surveyed, data, and time of survey and results of survey. This will be complete by December 31,1982.

32. Methods of communication between the RPD and in-plant survey teams will be included in ERPIP 4.5.2. This will be completed by September 30,1982.

33. Plans and procedures have been developed which govern the operations of the Calvert Cliffs Recovery Organization and criteria for its activation. Recovery Organization Procedures #1-6 are approved and distributed.

I

ENCLOSURE (1)

REPLY TO APPENDIX B OF NRC INSPECTION REPORT 50-317/81-19; 50-318/81-18

34. Emergency Response Plan Implementation Procedure (e.g., ERPIP 3.7 & 3.10) has provisions for reclassification (upgrading or downgrading) the emergency classification based on established Emergency Action Levels, and reporting any reclassification to Federal, State, and local officials. Emergency Response training programs address this provision to ensure decision snaking personnel are aware of the requirements.

35. Emergency Radiation Teams will be drilled in accordance with NUREG-0654, Revision 1, Section N.2.d, recommendations. The ERPIP will be revised to reflect NUREG-0654, Revision 1, Section N.2.d, recommendations. This will be completed by Septe.mber 30,1982.

36. The inconsistency between the ERP and ERPIP regarding the individual responsible for the review, revision, and distribution of the ERP will be corrected in Revision 2 and 8 of these documents, respectively. Revision 2 of the ERP will be complete and distributed by August 1982. Revision 8 of the ERPIP is complete.

37. Mechanisms for accomplishing the checklist items are being developed as part of the normal activities of the Emergency Planning Unit. Appropriate documentation shall be maintained to demonstrate that the required tasks have been completed.

The mechanisms will be developed and implemented by December 31,1982.

38. It is the Emergency Planning Unit's responsibility to assure that corrective actions are tracked and completed in a timely manner.

39. The licensee has obtained updated letters of agreement currently in Revision 1 of the ERP. These will be incorporated in Revision 2 of the ERP which is scheduled to be issued in August 1982. Revision 2 of the ERP will be reviewed to determine the adequacy of the letters of agreement to detail the aid offered the licensee during an emergency. This review will be ccmplete December 1982. Any changes will be incorporated into Revision 3 of the ERP which will be issued the first quarter of 1983.

40. The licensee reviews the ERP on an annual basis. As part of the review, State and local government authorities will be contacted to review the EALs and the associated response actions. The mechanism for this review is currently being implemented.

41. Baltimore Gas & Electric's Corporate Communications Department has an established program to familiarize the news media on the Calvert Cliffs Emergency Plan. The program provides for annual review of information on radiation and points of contact for the release of public information.

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