ML20063J607
| ML20063J607 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/04/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20063J596 | List: |
| References | |
| NUDOCS 8209020480 | |
| Download: ML20063J607 (27) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 23o1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.191o1 SHIELDS L. DALTHOFF atac'Tmic PnN rioN June 14, 1982 Docket Nos. 50-277 50-278 Mr. R. C. Haynes Administrator U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Haynes:
This letter is in response to your letter to Philadelphia Electric Company, dated April 29, 1982, and addresses those items listed in appendices A and B.
Due date for this response was within 30 days from receipt of your letter, or by May 29. Through a phone conversation on May 27 between W. J. Knapp of PECo., and G.
Snyder of your office, we requested an extension to more adequately respond to the numerous items in appendix B. An extension to June 4 was readily granted. We appreciate your understanding.
The items listed in appendix A are the same as those in j
your letter of December 24, 1981. Except for item 5, we have responded to these items by letters dated February 2, 1982, March 15, 1982 and May 6, 1982. All responses are repeated here for your convenience.
If you have any questions, please do not hesitate to contact us.
Very truly yours,
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Attachment cc: C. J. Cowgill - Site Inspector 8209020400 820825 PDR ADOCK 05000277 e PDR
Peach Bottom Atomic Power Station Docket Nos. 50-277 50-278 ATTACHMENT 1 APPENDIX A
> ITEM 1 Develop and implement a method to insure that updated emergency procedures are available for use when and where needed by all persons who have emergency response roles.
This will be accomplished no later than February 1, 1982.
j Pesponse i
. Administrative Procedure A-2 identifies locations for
' distribution of emergency plan procedures and other pertinent plant procedures. This procedure has been revised to incorporate into the distribution list additional locations selected for E.P.
procedures. The Operations Support Center, the Alternate Chemistry Lab - Unit 1, Cold Chemistry Lab Units 2&3, Dosimetry Office and Maintenance Supervision Offices have been added. .,
Currently a separate list is maintained for distribution of EP-C procedures. These distribution lists are available for
, inspection. This coverage should adequately accommodate the i needs of personnel having emergency response roles.
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, ITEM 2.a.
I I Expand on your letter to the NRC, dated April 3, 1981, to
! describe how the shift personnel discussed in the letter will fulfill the intent of the functions listed in Table B.1 of
! NUREG 0654 for 30 minute augmentation.
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! Response i
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l The April 3, 1981 letter proposed a minimum Peach Bottom staff l that did not involve 30 minute augmentation of the on-site staff.
I As an alternative, we proposed to provide on-shift personnel, in l lieu of 30 minute call-ins for those who would be expected to l
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p rform necessary tasks within 60 minutes af ter an emergency had been declared, and established a 60 minute arrival period for the other personnel . This proposal was based on our assessment that 30 minute augmentation was not feasible due to the commuting time requirements of most plant employees. The area demographic and environmental characteristics that favors the siting of a nuclear facility has the effect of discouraging employees from situating in the immediate vicinity of the facility. The 30 minute response time would require personnel to live within 5 miles of the facility considering the time required to conduct the off-site personnel notification, plus the time for individuals to prepare themselves and travel to the plant. The imposition of such requirements would force limitations on the housing and behavioral patterns of individuals. This would have an adverse effect on morale, result in a loss of experienced personnel, and further aggravate the industry's problems in attracting additional qualified personnel .
Justification of the minimum staf fing requirements proposed in our April 3, 1981 letter follows.
- 1. Table B-1 Requirement : 30 minute call-in for notification / communication function.
Response : It was proposed to meet this requirement by assigning an additional communicator to each shift since we consider the function to be essential during the early phase of an emergency. Therefore, our proposal is more conservative than Table B-1.
- 2. Table B-1 Requi reme nt : Provide the following electrical maintenance / instrument and control support for performing maintenance.
On Shif t : 1**
30 min. capability: 2 60 min. Capability: 1
- *may be provided by shif t personnel assigned other functions.
Response : The Table B-1 criteria requires human resources in this functional area of two man-hours during the first hour of the emergency. Additionally, the table does not require the on-shift support to be A-2
exclusively dedicated to this function. The PECO proposal specified two on shift personnel and two 60 minute call-ins. This provides an equivalent resource of two man-hours during the first hour. Further, all personnel are dedicated exclusively to this function.
We consider our proposal to be at least as conservative as the Table B-1 criteria.
- 3. Table B-1 Requirement Technical support in the area of core / thermal hydraulics is required within 30 minutes.
Response : The proposal in the April 3, 1981 letter meets the intent of the Table B-1 criteria. We proposed additional personnel with this technical knowledge
- within one hour. Additionally, Peach Bottom has at least six individuals on shift with formal training in the subjects of heat transfer, hydraulics and thermodynamics (shift superintendent (1), shift supervisor (1), control room operators (3), STA ( 1) ) .
The STA is a graduate engineer and will provide the 3
technical engineering support needed during the first hour of the accident. Therefore, the Peach Bottom on-shift staff currently possesses the necessary expertise to handle all response activities during the first hour.
Additional engineering support will be available within an hour.
- 4. Table B-1 Requi rement : Provide the following staff to perform on-site and inplant surveys.
On-shift: 1 30 min. capability: 2 60 min. capability: 2 Response : The Table B-1 criteria requires human resources of two man-hours during the first hour to perform these tasks. The PECO proposal specified two on-shif t F . P. technicians and three 60 minute call-ins.
This provides an equivalent resource of two man-hours during the first hour and therefore meets the intent of the NRC criteria.
- 5. Table B-1 Requirement : Provide the following staff to perform off-site dose assessment, of f-site surveys, out-of-plant surveys, access control, maintenance coverage, search and rescue, personnel monitoring, and dosimetry.
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On-shift: 0 30 min. capability: 5 60 min. capability: 4 Response : The April 3, 1981 letter propoced a 60 minute call-in of nine health physics personnel to perform these tasks. We concluded that this response capability is sufficient for handling accident situations during non-outage, weekend and back-shift periods. The basis for this conclusion is provided below: ,
a)
The off-site dose assessment is performed by shift supervision during the initial phase of the ,
accident using procedure EP-316 and data from installed instrumentation. The results of this assessment are forwarded to the various emergency response agencies for use in initiating the appropriate protective measures. The effectiveness of the assessment technique has been demonstrated during previous emergency drills. Computerized dose calculation capabilities will be operational j in the near future that will enhance the speed and accuracy of this assessment. Consequently, senior health physics expertise and H.P. technicians are not required during the first hour for the initial dose assessment and off-site surveys.
b) The extent to which H.P. technician support is needed for access control, maintenance coverage, -
search and rescue, first aid, personnel monitoring
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and dosimetry is a function of the number of ,
personnel working on site and the type of ,
activities in progress. The NRC criteria appears to provide for periods of significant maintenance activity. During a regular Company work day, and during periods of significant maintenance activities, there are more than sufficient H.P.
t personnel available to perform these functions if an emergency should occur. The need to perform these functions would be limited if an emergency should occur at a time when there are fewer personnel working in the plant, such as weekends i and backshifts with little or no maintenance in progress. In this situation, the two H.P.
technicians identified in item 4 above would have sufficient time to perform these functions to the
- extent that they are needed during the first hour.
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The NRC staffing criteria for H.P. technicians appears to provide for tasks that are better performed by the licensed operators using installed instrumentation, and for periods of significant maintenance activity. To implement the NRC criteria would involve having a senior health physicist and seven H.P technicians on shif t at all times. Our proposal to increase the on-shift Health Physics coverage, and to call in an additional eleven technicians within an hour would provide the necessary support required during an emergency. The effectiveness of the emergency organization can best be demonstrated during the upcoming drill.
ITEM 2b.
Describe your plan for assuring that a plant staff manager will be onsite in about 60 minutes to assume the role of EOF Director.
This will be accomplished no later than February 1, 1982, except that the drills will be completed by March 1, 1982.
Response
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The EOF Director is identified in our plan and procedures as the Site Emergency Coordinator. It is recognized that the designated Site Em'ergency Coordinator and his alternate could not relocate to the EOF within the required 60 minute response time. Their r6sponse would be on the order of 1-1/2 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. To overcome '
this problem, a list of eight alternates who could relocate to the EOF in 60 minutes hac been established. Two from this list are on-call'at all times. The individuals rotate to on-call status every four weeks. They have been assigned beepers. Their namos have,been added to the 60 minute call list. The first on-
- call individual contacted would~ report to the EOF and serve as the Interim Site Caergency Coordinator until relieved by the
- ' designated Site- Emergency Coordinator.
3-ITEM-3a -
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-Com'p]cte the_do.velopment of and' formalize the emergency preparedness training 'peogram for Peach Bottom personnel having eiergency response' roles and supporting personnel .
Formalization of the training program and the prompt training of selected individuals will be acconiplished no later than February 1, 1982.
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Response
Emergency response training following a revised and updated format started in early January, 1982. A formal description of the Training Program has been prepared and reviewed by appropriate personnel, and approved. This document is available for inspection. Modifications and revisions to the Training Program will continue based on criticisms received during implementation.
ITEM 3b Promptly conduct training to assure that several individuals are fully trained in each functional area described in the Peach Bottom emergency response organization.
Formalization of the training program and the prompt training of selected individuals will be accomplished no later than February 1, 1982.
Response
The training which has been implemented since early January, 1982 consists of classroom presentations and group drills. The drills included demonstration in the field and tabletop problem solving.
The schedule developed and presented throughout the month of January resulted in a majority of key emergency response leaders and emergency team members receiving training in their functions.
Primary personnel or alternates have received this training. In some cases both primary and alternate attended. We believe that this effort more than satisfied your concern that a group of several individuals be promptly trained. A schedule for February has been developed to accommodate those few who could not attend the January sessions. Repeat drills and practice exercises over the next few months are planned to enhance the proficiency of emargency response personnel.
ITEM 4 Prepare a job description for the Site Emergency Planning Coordinator position which describes the responsibilities and authorities for coordinating all emergency response planning and preparedness functions at the Peach Bottom Atomic Power Station.
This shall be accomplished no later than February 1, 1982.
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Response
A job description for the Site Emergency Planning Coordinator position has been prepared and is available for inspection.
ITEM 5 Review all emergency procedures to eliminate deficiencies and identify missing procedures. Issue revised and new procedures, as necessary. ( See Section 5.1)
Response
EP & EP-C Implementing Procedures were reviewed and revised as needed. New procedures were written to correct omissions. The new and revised procedures were approved and became effective by April 15, 1982.
O Copies of these procedures have been forwarded to the Nuclear Regulatory Commission per requirements of 10 CFR 50.
i Efforts will continue to improve all procedures as deemed
! necessary particularly based on lessons learned from practice exercises, i
ITEM 6 Clarify the emergency response organizational concepts (especially Table 5.4 of the Emergency Plan) to show the EOF as the primary emergency coordination location (the TSC retains the primary responsibility for plant operations).
All other organizations which provide support, including corporate organizations, will provide this support through the EOF Director.
This will be accomplished no later than February 1, 1982, e Response The emergency organization chart has been changed to better reflect the intended relationship between the Emergency Director, the Site Emergency Coordinator and Support Groups. The intent of the Plan has always been to use the EOF as the major emergency response center and the Site Emergency Coordinator as the key decision maker. The Emergency Director, operating from the TSC will concentrate on plant activities. The remainder of the emergency organization provides support for these two main functions. The original chart identified an Emergency Control
- Officer operating from corporate headquarters. This title has
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been changed to Emergency Support Of ficer to better reflect the intended function. Likewise, the Headquarters Emergency Control Center has been changed to the Headquarters Emergency Support Center.
A copy of the revised chart is available for inspection. Other revisions to the plan are in process. The revised chart will be distributed when the next revision of the plan is published.
This is expected in the next few months.
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Psach Bottom Atomic Power Station Docket Nos. 50-277 50-278 ATTACHMENT 2 APPENDIX B Emergency Preparedness Improvement Items Based on the results of the NRC's Appraisal of the Peach Bottom Atomic Power Station Emergency Preparedness Program conducted December 7 - 17, 1981, the following items should be considered for improvement: (references are to sections in Office of Inspection and Enforcement Report Nos. 50-277/81-28 and 50-278/81-33).
- 1. Develop emergency preparedness instructor selection and qualification criteria. ( See Section 3.2 of this report)
Response :
Instructor selection is based on the qualification requirements established by the applicable position description which includes instructional training and experience. Technical competence of the training staff instructor assigned to emergency preparedness training is being achieved by undergoing the full scope of training provided by the consultant and will be so certified upon completion of his training. In addition to a training staff instructor to oversee the entire emergency preparedness training effort, " guest" lecturers are used to cover areas of specific expertise.
- 2. Develop a procedure for emergency training of augmentation personnel during an emergency. ( See Section 3.2 of this report)
Response :
An Emergency Plan Implementing Procedure EP 307 has been developed and issued to cover the reception and orientation training of augmentation personnel . In addition to security information, badging and dosimetry, it includes a basic description of the plant status, work shift hours assigned, arrangements for hotels and meals, person to report to, General Employee Training and, if necessary, General Respiratory Training.
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- 3. Increase the use of handouts and other instructional aids in emergency training classes. ( See Section 3.2 of this report)
Response :
The use of handouts has been increased. During exercises being conducted, pictures are taken for preparation of slides. . A video tape will be prepared to augment emergency preparedness annual training.
- 4. Provide a backup method to verify the habitability of the T SC . ( See Section 4.1.1.2 of this report) f i Response :
The backup to the PING's to verify habitability of the TSC is
- use of low volume portable air samplers and RM-16 gross Beta-Gamma monitors. Air samplers will be available in the TSC, EOF, of Unit 1 first floor storage room no later than June 16, 1982. However, the BM-16 monitors will not arrive from the manufacturer until July, 1982; RM-14 's will be used as substitute until RM-16 's arrive.
~; 5. Develop a procedure which reflects the current TSC which encompasses the EOF; activation of this singular facility; and a diagram of the working spaces in the TSC and EOF functi6ns including equipment allocation. (See Section 4.1.1.2 of this report)
Response :
, The TSC and EOF are now separate and permanent facilities, i The TSC is located on the third floor of Unit 1 and the EOF
! is located on the first and second floor. Each facility has distinct resources for the performance of the respective functions.
Separate procedures now exist for activation of these facilities; EP-201 and EP-203.
l Engineer drawing A-210 describes the TSC and EOF equipment l layout. This drawing is revised as necessary to reflect l major changes to the facilities. This drawing is available l for inspection but is not intended as part of an emergency l plan implementing procedure.
. 6. Provide dedicated maintenance and radiation protection survey equipment within the primary OSC location. (See Section 4.1.1.3 of this report).
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Response s Equipment resources for use by maintenance and health physics I personnel as related to the OSC area are not specifically
- dedicated. There are adequate resources of radiation area l survey equipment and maintenance tools and equipment within
! the plant and in the plant maintenance shop.
An inventory of specific items including tools, spare parts and consumables is maintained in the plant storeroom. Tool cages are also located within the plant.
Additional reserves are available in the Philadelphia area at
- the Oregon Maintenance Shop and the Berwyn storeroom.
I The primary OSC has been relocated to a facility in the turbine building at elevation 135'. This facility serves operating personnel primarily. The Health Physics field office in the turbine building elevation 116' has been designated as an auxiliary OSC.
- 7. Provide a procedure and equipment for transporting post- l accident reactor coolant samples to the laboratory to
, minimize the radiation dose to personnel. ( See Section 4.1.1.5 of this report)
Response :
Existing procedures and equipment will be re-evaluated and I
revised as needed by July, 1982.
- 8. Provide a procedure to ensure safe transport of the exhaust stack air samples and cartridges. ( See Section 4.1.1. 7 of this report) 1 f Response :
Existing procedures and equipment will be re-evaluated and revised as needed by July, 1982.
- 9. Determine if the sample station in the base of the stack would be habitable during accident conditions. ( See Section 4.1.1.7 of this report) l l
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Response
Existing procedures and equipment will be re-evaluated and revised as needed by July, 1982.
- 10. Develop a procedure for identifying locations and taking liquid effluent samples following an accident. ( See Section 4.1.1.8 of this report)
Re sponse :
The applicable HPO/CO procedures which identify locations and sampling of liquid ef fluents following an accident will be issued as part of the EP-205 series before July, 1982.
- 11. Provide appropriate supplies to enable decontaminatlon and record tracking for the number of persons that might be expected during an emergency. ( See Section 4.1. 2. 3 of this report)
Response :
Off-site decontamination supplies are maintained at three locations, the North substation (vehicle only), the President's Utility Building, and the Delta Service Building.
Radiation Management Corporation decontamination and sample taking kits are maintained at the President's Utility Building and the Delta Service Building and additional kits are available on-site. The kits contain " betadine surgical scrub" which may be used to remove radiciodine from the skin.
Replacement clothing will be available at personnel decontamination centers by June 15, 1982. The decontamination kits also contain body sketches which may be used at the discretion of decontamination personnel. Record tracking will be accomplished by logging decontamination
, efforts on the forms provided in HPO/CO-7, " Personnel Decontamination".
- 12. Document within the Emergency Plan those facilities planned l
for use for expanded support. (See Section 4.1.3 of this report) l i Response :
The Emergency Plan is being revised. This item will be resolved by incorporating within the Plan more details on facilities planned for use for expanded suppo rt. This should be accomplished as part of the response to Appendix C of the NRC letter.
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- 13. Complete the installation of the telephone service in the Muddy Run News Center. (See Section 4.1.4 of this report) ,
Response :
The installation of the telephone service at Muddy Run News Center is complete. Twenty FX lines are in service and twenty OPX linen . in service.
- 14. Include high range survey instruments in the emergency kits.
(See Section 4. 2.1. 2 of this report)
Response :
Two high range ion chambers have been ordered; delivery is expected by mid-July. One of these instruments will be dedicated for emergency on-site surveys.
- 15. Demonstrate and document the ability to detect radioiodine in I
the presence of noble gases and particulate radioactivity in the air as required by NUREG-0654. ( See Section 4. 2.1.1 of this report)
Response :
Current field sampling and analysis for radiciodine involve the use of a battery operated air sampler, charcoal or silver zeolite cartridge, particulate filters and an Eberline SAM II detector system. This equipment provides the capability to detect 10 -7 uCi/cc iodine -131, per NU REG-0654. Silver zeolite cartridges are used to avoid significant absorption of noble gases when sampling for iodine. Further, the dual channel capability of the SAM II is used to subtract counts contributed by energies above I-131. Filter papers are used on the cartridge to exclude particulate.
- 16. Include a list of the non-radiation process monitors within the Emergency Plan. ( See Section 4. 2.1. 3 of this report)
Response :
We propose to not add a list of non-radiation process monitors to the Emergency Plan because non-radiation process instrumentation important to safety is part of the FSAR and has been reviewed by the NRC prior to issuance of the operating license. This list of non-radiation process instruments is quite extensive and use of such a list is considered of minimal benefit particularly when it is B-5
recognized that such data is available at the emergency facilities.
- 17. Document the procedures used for the inspection of the instrumentation in the control room and the meteorological towers and verify that these procedures are being followed.
( See Section 4.2.1.4 of this report)
Response :
It is not current policy to provide formal procedures for routine inspection. There are inspection guidelines posted at each meteorological tower and in the control room. The technician performing the inspection is thoroughly familiar with the equipment and is therefore qualified to determine if there is a problem, diagnose it, and make any repairs. The technician making the routine inspection acknowledges his inspection by noting same in a logbook at the appropriate location. Periodic review of the logbooks by supervision ensures that adequate inspections are being performed.
- 18. Provide quarterly calibration of the meteorological instrumentation as opposed to semi-annually. ( See Section 4.2.1.4 of this report)
Response :
Calibration guidelines specify six month calibration frequency. The consistency of past calibration data does not support the need for quarterly calibrations.
Equipment reliability is enhanced by weekly inspections of equipment as a preventative maintenance measure. Refer to the response to item #17.
- 19. Relocate the major storage site for emergency SCBA devices out of the main reactor buildings to areas of lower radiological hazard. (See Section 4. 2. 2.1 of this report)
Response :
Emergency reserves of SCBA equipment will be maintained in the EOF /TSC facility when the equipment currently on order is delivered.
- 20. Pelocate the refilling area for emergency SCBAs out of the main reactor buildings to areas of lower radiological hazard.
( See Section 4.2.2.1 of this report)
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Response
The SCBA refilling station within the plant consists of a number of size 1A certified breathing air cylinders. SCBA air tanks are filled from this system using a cascade technique. This serves routine needs, but may also be used for emergency purposes.* This system will not be re-located.
An air compressor has been installed within the Unit 1 facilities which also contain the TSC and EOF. This air compressor is intended for use during emergencies as a backup refilling station.
- 21. Evaluate dedicated equipment needs for damage control, i corrective action and maintenance, and the positioning of this equipment at specified locations for use during an 4
emergency, and make changes where necessary. ( See Section 4.2.4 of this report)
Response :
A large supply of maintenance tools and equipment is maintained in the plant tool cages and in the plant maintenance shop. The nearby Company facilities at Muddy Run Power Plant and Conowingo Power Company provide the means for prompt response to tools and equipment should the need arise.
Additionally, the resources at the central maintenance facility at Oregon Shops in Philadelphia can be used.
- 22. Check the type of equipment that will be borrowed during emergencies from sister plants and supplied by PMC for compatibility with existing equipment. ( See Section 4.2. 5 of this report)
Response :
j The type of equipment which might need to be borrowed from t other utilities cannot be accurately predicted. The Company participates in a cooperative program. Extensive use of INPO's Emergency Resources Manual has been made during the emergency drills. Philadelphia Electric Company expects that such borrowed equipment will be of common integral type ready for use.
- 23. Provide transportation from the main parking lot to the assembly area for potential stragglers during a site evacuation. (See Section 4.2.6 of this report)
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Response
The numerous private vehicles which would be used during any site evacuation provide ample means for " stragglers" to avail themselves of transportation to an assembly area. It is inconceivable that " stragglers" would be denied a ride.
At least two four wheel drive Company vehicles are available for emergency purposes on a priority basis. These vehicles could serve as lackup for transportation of " stragglers".
24 Obtain or designate sufficient vehicles to permit vital emergency functions to continue under any conditions. (See Section 4.2.6 of this report)
Response :
The four wheel drive Company vehicles identified in response to item #23 will be used by the field monitoring teams.
These vehicles ensure transportation capabilities under most conditions. A station truck (with snow plow and salter) and another four wheel drive vehicle although not dedicated for emergency use can serve as backup.
- 25. Clarify the reporting requirements for a General Emergency and revise the procedures accordingly. This action is part of the overall procedure review identified as necessary for Section 5.1. ( See Section 5.4.1 of this report)
Response :
The procedure defining reporting requirements and response to a General Emergency has been revised. This revision clarifies the parties to be notified and the overall site response when a General Emergency is declared. It also requires implementation of procedures for Dose Assessment and Protective Actions to States and Counties as warranted.
- 26. Provide an implementing procedure to aid the person assigned the responsibility for coordination of assessment actions for trend analysis, for escalation or de-escalation, and for
! protective action recommendations. The procedure should guide this person to the correct actions when indicated by i
sample analysis and process instrumentation. ( See Section 5.4.2 of this report) i B-8
Response :
Key personnel fulfilling roles in the emergency organization are selected with care based on their high degree of experience and training. They are well qualified to perform their emergency functions, to recognize and evaluate trends and to interpret data. In most cases, their emergency functions are extensions of their normal corporate functions.
Specific emergency plan implementing procedures to assist in their assessments is believed to be counterproductive and therefore, unnecessary.
- 27. Provide radiation protection guidance to of f-site teams surveying in the plume. ( See Section 5.4. 2.1 of this report)
Response :
Guidance will be provided in procedures and presented to PORC for approval.
- 28. Revise data sheets to include provision for recording the time of each survey, duration of meter reading and mode of operation, in procedure EP-205B. (See Section 5. 4. 2.1 of this report)
Response :
Guidance will be provided in procedures and presented to PO RC for approval.
- 29. Identify in procedure EP-205B emergency equipment location for the onsite survey team. ( See Section 5.4.2. 2 of this report)
J Response :
Procedures now identify the location of emergency equipment for the plant survey teams as either the emergency kits or lockers at the Emergency Operations Facility or the normal storage locations of HP portable instruments in the plant.
- 30. Identify in procedure HPO/CO-66 sampling points for the site perimeter. ( See Section 5.4. 2. 2 of this report)
Response :
Specific sampling points have not been chosen. In order to l most effectively determine the consequences of a release, the l
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Radiation Protection Team will choose appropriate sites based on release conditions and weather information..
- 31. Provide for primary and backup communication methods within procedure EP-205B. ( See Section 5.4. 2. 2 of this report)
Response :
Procedures now provide for primary and back-up communications between survey teams and their leaders. The field survey teams and the plant survey teams use radio as the primary communication method. The off-site teams use telephones as necessary should radios fail. The on-site teams shculd use P.A. system or plant telephone if radios fail.
- 32. Revise procedure EP-205B to include radiation protection guidance for in-plant survey teams, methods or reference to procedure for use of all in plant survey equipment, and listing of instrument (s) and type (s) of surveys to be completed by in-plant teams. (See Section 5.4.2.3 of this report) i Response :
Guidance will be provided in the procedures and presented to PORC for approval .
- 33. Provide an emergency plan implementing procedure for reactor coolant sampling for the current and/or the new system being installed to meet the NUREG-0578 requirements. (See Section 5.4.2.4 of this report)
Response :
EP 205A.1, Operation of Post- Accident Sampling Station Following Accident conditions was POFC approved May 19, 1982.
. 34. Provide an implementing procedure in the EP series that
! provides for: methods of analysis; the limitation of radiation levels to be applied to personnel and facilities; tracking of samples; reporting of data (keyed to emergency action levels) to the personnel responsible for assessment and protective actions; and escalation and de-escalation of the emergency classification. (See Section 5.4.2.6 of this report)
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Response
EP 205A, Chemistry Sampling and Analysis Group and EP 205A.11 Sample Preparation and Chemical Analysis of Highly Radioactive Liquid Samples were PORC approved on May 19, 1982.
- 35. Provide an emergency plan implementing procedure which includes the information contained in the HPO/CO procedures 121, 124 and 125. In addition, consideration should be given to providing a checklist, data sheets and provision for prelabeling samples. ( See Section 5.4.2.6 of this report)
Response :
EP 205A.2, EP 205A.3 and EP 205A.4 replace HPO/C0 121, 124 and 125, respectively, and procedures were PORC approved on May 19, 1982.
- 36. Provide a procedure in the EP series which addresses post-accident sampling analysis. The procedure should include checklists, data sheets, labeling of samples, and reporting of results. ( See Section 5.4.2.7 of this report)
Response :
EP 205A, Chemistry Sampling and Analysis Group was PORC approved on May 19, 1982.
- 37. Provide an Emergency Plan Implementing Procedure for Sampling of the Exhaust Air Release Points which integrates the sampling steps in HPO/CO-126 into the Emergency Procedure.
Consider the inclusion of a data sheet to record vital information relevant to the sample and method for providing packaging and pre-labeling. ( See Section 5.4. 2.8 of this report)
Response :
EP 205A.10, Obtaining Off-Gas Samples from the Off-Gas Hydrogen Analyzer Following Accident Conditions, EP 205A.4, Obtaining Drywell Gas Samples from the Drywell Radiation Monitor Sampling Station, EP 205A.3, Retrieving and Changing Sample Filters and Cartridges from the Drywell Radiation Monitor During Emergencies, and EP 205A.2, Obtaining Drywell Gas Samples from Containment Atmosphere Dilution Cabinets; were PORC approved on May 19, 1982.
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- 38. Include a procedure for post-accident sampling of displaced liquid and liquid ef fluent in the emergency plan implementing procedures. ( See Section 5.4. 2.10 of this report)
Response :
EP 205.A.5, Obtaining Reactor Water Samples from Sample Sinks Following Accident Conditions, EP 205A.9, Obtaining Samples from Condensate Sample Sink Following Accident Conditions, EP 205H.6, Obtaining Canal Discharge Water Samples Following Radioactive Liquid Release Af ter Accident Conditions and EP 205A.8, Obtaining Liquid Radwaste Sampics from Radwaste Sample Link Following Accident Conditions, were PORC approved on May 19, 1982.
- 39. Amend the follow-up instructions in EP-205C for the Personnel Dosimetry, Bioassay and Respiratory Protection Group Leader to include reference to procedures to process respiratory equipment for reuse. ( See Section 5.4. 3.1 of this report)
Response :
Procedures have been revised to give the Personnel Dosimetry, Bioassay, and Respiratory Protection Group Leader guidance as to which procedure to use to process respiratory equipment for reuse.
- 40. Decrease the time required to identify onsite and missing individuals'.from 60 minutes to 30 minutes. ( See Section 5.4.3.3 of this report)
Response :
Computerized operation are utilized to conduct personnel accountability. Following a site evacuation, a computer listing is obtained to identify personnel apparently remaining in the plant. This list is checked off at the assembly area and then in the control room for missing
, personnel. In many cases, this accountability can be accomplished in 20 to 30 minutes. Because of extenuating
- circumstances, (such as generation of the list by badge rack checks upon computer failure, adverse weather conditians),
the 60 minute claim is more reasonable.
- 41. Fevise the appropriate procedures to include: methods of monitoring and decontaminating large groups of personnel during accident situations; special considerations for skin l contaminated with radiciodine; data sheets and body sketches to track decontamination events; and ensuring that collected B-12
1 data are provided to the emergency organizational element responsible for radiation protection during emergencies.
( See Section 5.4.3.4 of this report) .
Response :
Procedures have been written and distributed which detail methods of monitoring and decontaminating large groups of personnel during accident situations. These procedures describe the process by which .the Personnel Safety Team monitors and decontaminates personnel due to the various types of contamination encountered both on and off site and how personnel should be decontaminated depending upon contamination type and extent. This procedure will be revised to include special considerations for skin contaminated with radiciodine (using " Betadine surgical scrub") and includes data sheets to trace decontamination (refer to response to item #11). The personnel decontamination kits are located at specific emergency facilities and contain both data sheets and body sketches to trace decontamination. The applicable procedures ensure that.
collected decontamination data is obtained and provided to the Personnel Safety Team, which is the emergency organizational element responsible for personnel radiation protection during emergencies. The Personnel Safety Team Leader is stationed in the Technical Support Center and reports directly to the Emergency Director.
- 42. Implement emergency procedure 207A. ( See Section 5. 4. 3. 5 of this report)
Response :
The Search and Rescue procedure was implemented and distributed before April 15, 1982. It provides guidance to the Personnel Safety Team in conducting Search and Rescue operations.
! 43. Submit procedure PP-10 to POFC review and train the security
! force on its contents. ( See Section 5.4.4 of this report)
Response :
Procedure PP-10 has been reviewed by PORC and was approved February 3, 1982. Security forces have been made aware of the revised procedure.
- 44. Incorporate into EP-206B specific locations and description of equipment (e.g., radiation detection instruments, _ tools, B-13
etc.); the criteria and logistics of selection of repair team members; communication means and precautions to be employed. I
( See Section 5.4.5 of this report) i Response :
The Emergency Repair Group procedure has been revised to include the criteria for selection of repair team members by the Fire and Damage Team Leader and the communications means and precautions to be employed when functioning as a member of the Emergency Repair Group. Specific locations and descriptions of equipment were not included so as not to restrict the repair group to certain locations where they could obtain equipment. Training of the Fire and Damage Teams has stressed that the Emergency Repair Group uses primarily the hot tool shop for tools and contacts the HP&C OSC leader for radiation monitoring.
- 45. Complete the recovery organization chart and amend the Emergency Plan to include the revised chart. ( See Section 5.4.6 of this report)
Response :
The emergency organization chart has been revised and completed. It now appears as two separate charts: one addresses the initial phase and the other is dedicated to the recovery phase. Both charts will be included as figures in the Emergency Plan.
- 46. Revise the emergency equipment inventory and calibration procedure to define the specific checks required to ensure instrument operability, and steps to take when discrepancies are encountered. ( See Section 5.5.1 of this report)
Response :
The Emergency Equipment Operability Check, Calibration and Inventory Procedure will be revised before June 16, 1982 to include new emergency equipment, calibration methods, and the specific checks required to ensure instrument operability.
Additionally, steps will be added to detail what to do when discrepancies are encountered.
- 47. Provide a Radiological Monitoring ST/EP to include an annual drill in addition to the annual exercise. The ST/EP shall be compatible with NUREG-0654, Section N. 2.d . ( See Section 5.5.2 of this report)
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Fbcpon=er A new procedure will be written and distributed by July 27, 1982 to allow a radiological monitoring drill to be conducted as specified in NUREG-0654 in the last half of 1982 and as required semi-annually thereafter.
- 48. Provide a Health Physics ST/EP to include semi-annual and annual drills in addition to the annual exercise. The ST/EP shall be compatible with NUREG-0654, Section N. 2.c.1. ( See Section 5.5.2 of this report)
FMsponse :
3 A new procedure will be written and distributed by July 27, 1982 to allow a health physics drill to be conducted as
, specified in NUREG-0654 in the last half of 1982 and as
- required semi-annually thereafter. One of these drills may be performed in conjunction with the annual exercise. NUREG-0654, Section N.2.3.1 describes a Health Physics drill to be conducted semi-annually.
- 49. Ebview existing ST/EPs and bring all references to EPs up-to-date. ( See Section 5.5.2 of this report)
Response :
Existing procedures will be reviewed and references will be corrected by June 16, 1982.
- 50. Standardize ST/EP format so that all procedures clearly
~
indicate critique responsibilities and the responsibility for corrective actions. ( See Section 5.5.2 of this report)
Fesponse:
A standardized procedure format is being considered so that surveillance procedures will indicate critique action responsibilities, a time limit, and responsibility for i
corrective actions. This new format for applicable l procedures will be completed by July 27, 1982.
- 51. Amend ST/EP-8 to include provision for backshif t and unannounced exercises as required by NUREG-0654, Section N.1.b. ( See Section 5.5.2 of this report)
! Response :
I B-15 l
l l
L /
The procedure for the Annual General Emergency Exercise has been revised to include provision for backshif t and unannounced exercises per NUREG-0654 requirement.
- 52. Distribute recent changes of the emergency plan to those on the distribution list. ( See Section 6.1 of this report)
Response :
Distribution of revisions to the Emergency Plan to parties on the distribution list will be completed by October 1, 1982.
- 53. Include all letters of agreement and memos of understanding within the emergency plan. ( See Section 6.1 of this report)
Response :
Letters of agreement and memos of understanding will be incorporated in the Emergency Plan by July 29, 1982.
- 54. Complete and distribute to the general public, the brochure covering emergency information. ( See Section 6.2 of this report)
Response :
The emergency information brochure has been completed and will be distributed to the general public within the 10 mile EPA by mid-June.
- 55. Conduct a meeting with the news media to acquaint them with the emergency plan. ( See Section 6.3 of this report)
Response :
A meeting with the news media to acquaint them with the emergency plan will be conducted at the Muddy Run News Center on June 7, 1982.
- 56. Perform a medical drill in accordance with required frequency. ( See Section 7.1 of this report) l B-16
Response
The present Emergency Plan and NUREG-0654 require an annual medical emergency drill. The medical drill which was postponed in early December, 1981 was rescheduled as part of the Annual Emergency Exercise to be held in June, 1982.
Medical Emergency classroom training and mini-drills were conducted with the members of the personnel safety team January, 1982 through mid-April, 1982 to stress medical emergency procedures. The May 12, 1982 Emergency Exercise dress rehearsal included a full medical emergency drill involving the off-site ambulance and hospital. Results of this drill were satisfactory from the utility standpoint.
Annual re-training of ambulance crews and hospital staffs is scheduled for early June, 1982. The graded Annual Exercise in June, 1982 will also include a medical emergency drill.
- 57. Provide a time restraint for corrective acticns identified by drills. ( See Section 7.1 of this report)
Response :
As noted in response to item #50 above, a reformatting of the sorveillance procedures in a standard manner will include determination of a time restraint for corrective actions to deficiencies identified by drills. This new format will be completed and new procedures distributed by July 27, 1982.
- 58. Training on the new EAL table in EP-202 should include the purpose of EALs, and emphasize that no waiting is necessary for dose calculations (after a general emergency is declared) before notifying offsite authorities. This should also be emphasized to the offsite authorities-during their training.
( See Section 7.2.1 of this report)
Response :
We concur with the comment. Emphasis will be placed on the need for prompt notification of off site authorities without waiting for dose calculations during the emergency preparedness annual training.
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