ML20080A907

Responds to NRC Re Violations Noted in IE Emergency Preparedness Appraisal Rept 50-341/83-24. Corrective actions:30 & 60 Minute Augmentation of Emergency Personnel Will Be Satisfactorily Demonstrated

ML20080A907
Person / Time
Site:	Fermi
Issue date:	01/04/1984
From:	Jens W DETROIT EDISON CO.
To:	Paperiello C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20080A898	List: ML20080A907
References
EF2-66-773, NUDOCS 8402060395
Download: ML20080A907 (46)

Text

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,,,.4 v,ce President Nuclear Opera ons 2

Ed*ison =000Second Avenue =r-January 4, 1984 EF2 - 66,773 Mr. C. J. Paperiello, Chief Emergency Preparedness and Radiological Safety Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137

Subject:

'vetroit Edison's Response to Inspection Report No. 50-341/83-24

Dear Mr. Paperiello:

With this letter, we are providing the information you requested in your letter of November 28, 1983, transmitting Inspection Report No. 50-341/83-24. This inspection report describes the findings of a special NRC appraisal of the Onsite Emergency Preparedness Program at Enrico Fermi Unit 2, conducted during the period of October 11 -

21, 1983.

The enclosed response describes our planned actions for completing each of the items identified in Appendix A (Appraisal Open Items) and the results of our consideration of each of the items in Appendix B (Appraisal Improvement Items). The responses are arranged to correspond to the sequence of items listed in Appendices A and B of your report.

We trust this response will satisfactorily address your request. If you have any questions, please contact Mr. Lewis Bregni, (313) 586-5083.

Sincerely, .f'

{

cc: Mr. P. M. Byron Mr. R. DeYoung

(( g1 h (Af Mr. F. Kantor _;

B402060395 840201 0 1984 PDR ADOCK 05000341 PDR G

THE DETROIT EDISON COMPANY ENRICO FERMI A'IGIIC POWER PIANT, UNIT 2 NUCLEAR OPERATIONS DEPAR31EtTT Response to NRC Report No. 50-341/83-24 Docket No. 50-341 License No. CPPR-87 Inspection at: Enrico Fermi 2, Newport, Michigan Inspection Conducted: October 11 through 21, 1983 i

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APPENDIX A - OPEN ITEMS

1. Satisfactorily demonstrate that shift augmentation can be consistently achieved within the goals specified in Table B-1 of NUREG-0654, Rev. 1; e.g., 30 to 60 minute response time with 11 persons in 30 minutes and 15 persons in 60 minutes. This must be completed prior to initial criticality. (Section 2.2) (341/83-24-01)

RESPONSE

30 and 60 minute augmentation of emergency personnel will be satisfactorily demonstrated prior to initial criticality. The emergency call-out list that was in place has been reorganized to call the person living closest to Fermi 2 first. Drills to test augmentation times have already been conducted, with an actual call-out planned for the first quarter of 1984. Staff augmentation levels will be revised in our Table B-1 to reflect the staffing levels outlined in NUREG-0654, Table B-1. The RERP plan will reflect this change in its next revision scheduled -

for the first quarter of 1984.

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• APPENDIX A - OPEN ITEMS

2. Complete installation, development of procedures, and training on the use of Post-accident Primary Coolant Sampling System. This must be completed prior to exceeding 5% power. (Sections 4.1.1.5, 5.4.2.4, and 5.4.2.5) (341/83-24-02)

RESPONSE

The above item will be completed prior to exceeding 5% power.

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e APPENDIX A - OPEN ITEMS 3 Complete installation, development of procedures, and training on the use of Post-accident Containment Atmosphere Sampling System.

This must be completed prior to exceeding 5% power. (Sections 4.1.1.6, 5.4.2.6, and 5.4.2.7) (341/83-24-03)

RESPONSE

The above item will be completed prior to exceeding 5% power.

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APPENDIX A - OPEN ITEMS

4. ' Complete installation, development of procedures, and training on the use of Post-accident Special Particulate, Iodine and Noble Gas (SPING) System. This must be completed prior to fuel load.

(Sections 4.1.1.7, 5.4.2.8, and 5.4.2.9) (341/83-24-04)

RESPONSE

The above item will be completed prior to fuel load.

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APPENDIX A - OPEN ITEMS

5. Calibrate the analytical instrumentation in the Emergency Operations Facility (EOF) laboratory. This must be completed prior to exceeding 5% power. (Section 4.1.1.9) (341/83-24-05)

RESPONSE

The above item will be completed prior to exceeding 5% power.

APPENDIX A - OPEN ITEMS

6. Complete the Emergency Decontamination Facility. This must be completed prior to fuel load. (Section 4.1.2.3) (341/83-24-06)

RESPONSE-The above item will be completed prior to fuel load.

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APPENDIX A - OPEN ITEMS

7. Complete calibration of containment high range monitors (ARMS) and all other process radiation monitors. This must be completed prior to fuel load. (Section 4.2.1.2) (341/83-24-07)

RESPONSE

The above item will be completed prior to fuel load.

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APPENDIX A - OPEN ITEMS

8. Licensee must develop a program for the surveillance, maintenance, and calibration of the meteorological measurement system. This must be completed prior to exceeding 5% power. (Section 4.2.1.4)

(341/83-24-08)

RESPONSE

The above item will be completed prior to fuel load since meteor-ological parameters require daily channel checks according to Technical Specifications and meteorological data must be available in the Control Room at the time of fuel load.

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APPENDIX A - OPEN ITEMS

9. The Emergency Plan and Procedures must be revised to reflect 10 CFR 50 Appendix E, IV.E.9.d requirements such that communication checks to the NRC Headquarters niad Regional Office from the Control Room, TSC, and EOF will be conducted monthly. This must be completed prior to fuel load. (Section 4.2.3) (341/83-24-09)

_R_ESPONSE Detroit Edison is currently conducting monthly communication checks with NRC Headquarters and NRC Region III. The RERP plan and procedures will be revised to reflect this requirement, consistentwith10CFR50AppendixE,SectionIV.E.$.d. .

The next revision of the Plan is scheduled to be issued the first quarter of 1984.

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APPENDIX A - OPEN ITEMS

10. Develop procedures and complete training for tne collection of liquid effluent samples. This must be completed prior to fuel load. (Sections 5.4.2.10 and 5.4.2.11) (341/83-24-10)

RESPONSE

The above item will be completed prior to fuel load.

APPENDIX A - OPEN ITEMS

11. Maintain provisions with an offsite vendor to expand the environmental monitoring program in the event of an emergency to collect and analyze water, milk, soil, vegetation and air samples. This must be completed prior to exceeding 5% power. (Sections 5.4.2.12)

(341/83-24-11)

RESPONSE

Provisions will be incorporated in the contract issued to the vendor who conducts the offsite Radiological Environmental Monitoring Program (REMP) to collect and analyze samples on request during an emergency at Fermi 2.

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APPENDIX A - OPEN ITEMS

12. Implement security system for accountability. This must be completed prior to fuel load. (Sections 5.4.3 3) (341/83-24-12)

RESPONSE

TPe security system is scheduled for completion in early 1984. An accountability drill will be ccnducted before fuel load.

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k APPENDIX A - OPEN ITEMS h

13. Complete training or appropriate offsite governmental support 3.

~ agencies, including a review of Emergency Action Levels (EALs)

- and expected response and site access procedures for local Michigan S, tate Police personnel. This must be completed prior to exceeding 5% power. (Sections 6.1.1, 6.1.2, and 6.1.3)

- (341/83-24-13) i' .

RESPONSE

The training program for off-site governmental support agencies ,

is a joint' program with the state, county and licensee. The training program will be conducted prior to the next full-scale exercise. Further in accordance with the requirements specified in 10 CFR 50, Appendix E, Section B, an.information

review and training seminar will be conducted with the state, i."' county and Canadian authorities to discuss EALs, PACS and Dose Assessment methodology. This program will be conducted prior to fuel load.

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APPENDIX A - OPEN ITEMS

14. Complete installation of non-radiological process monitors (hydrogen, oxygen, chlorine). This must be completed prior to fuel load. (Section 4.2.1 3) (341/83-24-14)

RESPONSE

The above item will be completed prior to fuel load.

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c APPENDIX A - OPEN ITEMS

- 15. Complete installation and testing of the Prompt Public Notification System to ensure that physical means exist to alert the public of 4 an' emergency condition. :his must be completed prior to exceeding 5% power. (Section 6.2.2) (341/83-24-15)

RESPONSE

ThE installation of the sirens is complete. Installation of the activation equipment will be completed upon authorization of the

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counties to install such equipment in their facilities. Testing of the sirens will be done in accordance with the guidance given in Standard Guide for the Evaluation of Alert and Notification for Nuclear Power Plants (FEMA-43). Testing is expected to be complete by June, 1984.

. l APPENDIX A - OPEN ITEMS

16. EALs which are general in nat'ure should be made more specific by including instrument readings or equipment status indicators which are used to classify an emergency. For example, EALs involving high radiological effluent condition and the contain-ment high range radiation monitor must include specific radiation levels. This must be completed prior to initial criticality.

(Section 5.3) (341/83-24-16)

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RESPONSE

Effluent Monitors - Gaseous and Liquid Those monitors associated with radiological effluents have set points and trip points that will vary throughout the year in accord-ance with the Radiological Effluent Technical Specifications and 10CFR50, Appendix I and 10CFR20 requirements for doses to unre-stricted areas. For this reason, specific radiation levels will not be delineated in the EALs.

The operator must verify the alarm and trip signals with the print-out on the CT2, with the Rad / Chem Group, or perform a dose calcu-lation to confirm an entry into an emergency classification level.

Containment High Range Radiation Monitor (CHRRM)

When the CHRRM is calibrated and the response to various nuclides is determined, calculations will be made to determine a radiation level applicable to the appropriate EAL.

Degraded Safety Systems and Reactor Control System Failures Items such as " inability to pressurize the reactor", " main conden-sor cooling becomes inoperable", and " inability of RHR systems to maintain the reactor in cold shut down" were, by design, left general in nature at the request of the Operations Group. There are many possible combinations of parameters available to the oper-ator to indicate these entry conditions. To list all of the com-binations as viable indicators would be nonproductive in terms of emergency classification. Edison provides sufficient knowledge through training on the system to allow the operator to determine what is required to maintain the system in an operating mode.

General The Fermi 2 EALs have been carefully delineated by a group of engineers, specialists, and licensed operators as specific to the reactor, reactor systems, and plant site. They have been reviewed and walk-throughs conducted by the Nuclear Shift Supervisors and a number of operators who will be directly involved in their

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General (Continued-)

application. Since the walk-throughs with Control Room personnel conducted by the NRC indicated they were " competent in making accident classifications" (Section 7.2) there should be no further requirement for NRC " approval" of EALs.

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APPENDIX B - IMPROVEMENT ITEMS

1. Develop instruction sheet on how to energize the H7"iC (heat, ventilation, air conditioning) System in the Technical Support Center (TSC) and attach it to the front of HVAC System control panel. (Section 4.1.1.2)

RESPONSE

An instruction sheet on energizing the TSC HVAC system will be developed and posted on or near the TSC HVAC control panel.

A similar instruction sheet will be attached to the HVAC system control panel in the EOF. These instrue.tions will be in place prior to the next exercise.

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APPENDIX B - IMPROVEMENT ITEMS

2. Revise Emergency Procedure 301-2, Section 5.5.1, relating to elevated airborne radioactivity levels, to reflect current practice. (Section 4.1.1.2)

RESPONSE

EP-301-2 is being revised to exclude the use of respiratory equipment by TSC personnel.

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APPENDIX B - IMPROVEMENT ITEMS 3 The alternate Operational Support Center (OSC) should be equipped with fixed permanent emergency lighting. (Section 4.1.1.3)

RESPONSE

Emergency Preparedness agrees that the alternate OSC should be equipped with permanent emargency lighting. A request to effect this change in design will be submitted to the Fermi 2 Project Manager's change control board.

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APPENDIX B - IMPROVEMENT ITEMS

4. Acquire for the Emergency Operations Facility (E0F) decontamination supplies and protective clothing. (Section 4.1.1.4)

RESPONSE

Decontamination supplies and protective clothing will be available in the EOF for the 1984 full-scale exercise.

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. o APPENDIX B - IMPROVEMENT ITEMS 5 Develop an inventory of supplies for the Alternate EOF, include it in procedures, and maintain a copy with the Alternate EOF supplies.

(Section 4.1.1.4)

RESPONSE

An inventory of supplies for the Alternate EOF is being developed.

A copy of the inventcry will be maintained with the Alternate EOF supplies. However, the inventory will not be included in the pro-cedures since it is a changing document and would require procedure revision each time the inventory changes.

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APPENDIX B - IMPROVEMENT ITEMS

6. Position the staged Personnel Monitoring Team kits at the three offsite assembly locations. (Section 4.1.2.1)

RESPONSE

The Personnel Monitoring Team kits have been located at the three off-site assembly areas.

APPENDIX B - IMPROVEMENT ITEMS 7 Include a copy of the latest completed inventory list in each of the emergency kits. (Section 4.2.1.1)

RESPONSE

An inventory list has been placed in each of the emergency kits.

These lists are checked and updated periodically.

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APPENDIX B - IMPROVEMENT ITEMS

8. All equipment contained in the emergency supply kits should have expiration dates where appropriate and should be kept calibrated.

(Section 4.2.1.1)

RESPONSE

All equipment contained in the emergency supply kits will be cali-brated and will be marked with an appropriate expiration date.

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APPENDIX B - IMPROVEMENT ITEMS

9. The applicant is encouraged to work with other BWR owners to develop emergency action levels which are symptomatic based similar to Emergency Operating Procedures as opposed to event oriented emergency action levels which are contained in the current emergency plan implementing procedures. (Section 5.2)

RESPONSE

The BWR Owners Group Subcommittee on Emergency Operating Procedures (EOPs), of which Edison is a member, has addressed the topic of symptom oriented EALs and has discussed this with the NRC. It was concluded that this would defeat the purpose of the present EOPs and would not comply with the intent of the NRC guidelines presented in NUREG-0654/PEMA-REP-1, Appendix 1, Revision 1, November 1980.

Therefore, the concept would not be addressed.

At present, the PWR EOPs are more event-oriented than symptom-oriented and are, therefore, more directly adaptable to EALs. At Fermi 2, the operator will respond to an occurence by referring to the Abnormal Operating Procedures (A0P) which are event-oriented. The AOPs in turn refer to EP-101 and the E0Ps as appropriate. EP-101 has been organized and tabbed to provide the user easy accessibility to categories of events. These categories were reviewed by the Operations Group.

For the above reasons, Edison dces not intend to pursue symptom-oriented EALs.

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APPENDIX B - IMPROVEMENT ITEMS

10. Revise the Radiological Emergency Response Preparedness (FERP)

Procedures 102-105 to reflect the requirement of 10 CFR 50.72, that State and local agencies will be notified prior to notifying the NRC. (Section 5.4.1)

RESPONSE

Section 5.0 Immediate Actions and the procedure checklist of RERP procedures 102 through 105 presently specify that state and local agencies are notified prior to the NRC.

• O APPENDIX B - IMPROVEMENT ITEMS

11. An apprcpriate type and number of hand-held calculators should be provided to the individusls who implement manual dose assessment procedures EP-540 and -541. (Section 5.4.2)

RESPONSE

Appropriate hand-held calculators are being purchased for the Environmental Assessment Team.

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• 12. Make a provision for incorporating field monitoring data into dose projection calculations. (Section 5.4.2)

' . RESPONSE-Attached is an exerpt.from a draft report on dose projection considerations prepared by Battelle-Pacific Northwest Laboratory for the NRC. Based on a review of this material,

- the NRC guidelines for recommending protective actions, and the basis on which the dose model projects doses, "incorp; rating field monitoring data into dose projection calculations" ,

would not enhance the capability of the decision makers to

. protect the health and safety of the public.

• NRC guidelines for recommending protective actions within 15 minutes of declaring a general emergency are based on potential for a release, core /contain-1' ment status, or actual releases. Field survey data are not applicable in the first two cases and are not available on a timely basis to be of value in the third case.

• Actual releases are measured by instrumentation specified in NUREG-C737. Calibration and survillance of the instrumentation is required by plant Technical Specifications. Calculating projected doses based

' on a single observation defeats the purpose of in-stalling the instrumentation.

• Under the guidelines cf NUREG-0654, methods must be established for determining the release rate / projected l doses if the instrumentation is off scale or inoperable.

Procedures are underdeveloped for determining release

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i rate based on measurements within the plant. This is more accurate than attempting to back calculate frcm field readings especially where complex site specific lake breeze diffusion models are used.

Basically,. Edison believes that field readings should be

' used to confirm the location of the plume, to verify the presence (or absence) of radio iodines and particulates, and provide a base for determining actual population doses.

In addition, they should be considered together with cal-l culated dose projection data in making protective action L recommendations once they are available.

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a Excerpt from Draf t Report Prepared by Battell-Pacific Northwest Laboratory for the U. S. Nuclear Regulatory Commission Dose Project Considerations for Emergency Conditions at Nuclear Power Plants August 1982 G. A. Staetzel D. C. Powell J. V. Ramsdell A. E. Desrosiers R. W. Poeton 2.5 Conclusions 2.5.3 Field Measurements Initial release estimates should be based on available plant parameter information. Field measurements provide important feedback relative to these estimates, but must be used with caution. Field measurements are subject to errors in sampling techniques, and even measurements properly made can be effected by local and temporal variations in concentrations.

Integrated, rather than instantaneous, radiation measurements should be used wherever possible. Field measurement data should be examined for I

internal consistency and compared with known atmospheric conditions before being used to modify release statements. Procedures for field measurements should provide methods for distinguishing between ground contamination and plume exposures and for locating the center of the plume.

100/RERP17/1.0

. 3.1.5 Basic Problems in' Evaluating Airborne Releases 3.1.4' Comparing Model' Predictions and Monitoring Results.

! After an' airborne release, there will come a time when model estimates of dose rates and ~ observed dose rates from monitors are both available.

1 Reconciliation of model' predictions and monitoring results-was discussed by Working Group C at the'NRC sponsored workshop at SRI (Dabberdt et al.

1982). Model validation discussions -(e.g., Fox 1981) are also applicable to this problem.

t-Basically, cteospheric models predict averages; monitoring at a point gives a single observation. The observation may be a time average, but it is still a single observation made at a specific point in space and specific period under a single set _of meteorological conditions. Given what appear p.

J to be identical meteorological conditions at a different time it is unlikely that monitoring at the same point would result in an identical *

. concentration or dose rate. However,' a meteorological model will give an identical prediction. 'A range of variability around model estimates must i

be accepted as a natural consequence of our inability to completely define

- the ' state of the atmoshpere at any time and to solve the full set of gov-erning equations. The first question to be asked in reconciling a differ-ence between model predictions and monitoring results is. therefore: "Is the difference within the range of normal variability for differences between predictions and observations?"

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In 1977 the American Meteorological Society Committee on Atmospheric

- Turbulence and Diffusion (American Meteorological Society 1978) estimated the upper limit of accuracy of diffusion models to be about a factor of two under conditions where the meteorological parameters controlling diffusion are measured near the point of release and topographic relief is minimal.

Under exceptional circumstances, which include rough terrain, wake flows, over water trajectories, extremes of atmospheric stability or instability and ranges of more than 10 km, uncertainties may be as great as an order-s of-magnitude if standard models are used.

Use of site specific models may decrease the uncertainty. Working Group C at the-SRI Workshop (Dabberdt 1982) estimated the uncertainty of site specific models to be about a factor of three under optimum day time condi-tions with relatively strong winds. Greater uncertainty, approaching a f actor of 10, was estimated for conditions when the wind speed decreases toward calm. A similar range of uncertainty (factor of 3 to 10) was given for nightime, ground-level releases. The uncertainty range was extended to a factor of 100 for complex terrain. No level uncertainty was estimated for unstationary meteorological conditions such as sea breezes.

These uncertainty estimates are generally for maximuu ground-level concen-trations, considering only diffusion. They do not consider other atmos--

pheric process that affect concentrations, such as radioactive decay, dry

. deposition and washout by precipitation. It is also important to note that these are estimates of the unsertainty at the plune centerline; they are 100/ RERPl7/1.2

, not estimates of uncertainty at specific points in space. This difference

.is'significant. Estimates of uncertainty at a point in space must include uncertainty in plume position, a aource of uncertainty not included in the estimates given.

The uncertainty associated with 'model estimates is also a function of aver-aging time. In general uncertainty decreases with increasing averaging time. Estimates given above are associated with hourly averages. If the averaging interval is reduced to 5 to 10 minutes an additional factor of 2 can be added to the urcertainty (Ramsdell and Ilinds 1971). Uncertainties associated with instantaneous, spot estimates and observations are even larger.

If an inconsistency between the model and monitoring is suspected, many potential sources of the discrepancy must be considered. Some of these are

< listed below:

o source term (magnitude and radionuclide composition),

o release time and duration, o normal plume meander-(horizontal and vertical),

o error in plume position (horizontal and vertical),

, o improper specifications of diffusion parameters, e

o inadequate or misapplied model, o inaccurate or inadequate meteorological data, o monitoring errors.

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Any one or combination of two or more of these sources of discrepancy could be responsible for a significant difference. The recommendation of Working Group C is:

"Model parameters should not be indiscriminately adjusted to make model estimates agree with isolated measurements. Similarly, a meas-urement should not be disregarded because it appears to be incompa-tible with model predictions. In terms of model/ measurement inter-action, a successful comparison between model output and field data provides significantly more information than does an unsuccessful comparison. Disagreement between model estimates and field measure-ments should be treated as an indication that further analysis or

-refinement is needed."

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. o APPENDIX B - IMPROVEMENT ITEMS

13. Document that the vendor's environmental monitoring program and the applicant's emergency environmental monitoring program will provide comparable results for all possible environmental media.

(Section 5.4.2.12)

RESPONSE

The Fermi 2 Chemistry Group will review the vendor's procedures for the Radiological Environmental Monitoring Program (REMP) and determine the most appropriate and effective method for ensuring comparable results between the two laboratories.

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• APPENDIX B - IMPROVEMENT ITEMS

14. Clearly mark assembly / evacuation routes with conspicuously posted arrows, signs, floor markings (colored lines), and/or readily visible means. (Section 5.4.3.2)

RESPONSE

Detroit Edison will clearly designate the assembly areas and more precisely identify evacuation routes to these assembly areas.

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15. Any " dead spots" of HI-COM or radio reception within the plant should be identified and the system upgraded accordingly.

(Section 5.4.3.2)

RESPONSE

HI-COM and radio dead spots have already been identified within the plant. Detroit Edison is awaiting delivery of a strobe lighting system that will be used for alarming in higit noise areas. Instellation of additional UHF and/or VHF antennae to eliminate radio dead spots is also planned. These design change.

requests have been submitted by Emergency Preparedness to the Fermi 2 Project Manager's change contr ol board.

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APPENDIX B - IMPROVEMENT ITEMS

16. A controlled copy of the applicant's emergency plan should be provided to all offsite support agencies, e.g., police, fire, ambulance, county EOC's and Brownstown Township. (Sections 6.1.1, 6.1.2, and 6.1 3)

RESPONSE

The County Offices of Civil Preparedness (OCP) have controlled copies of the Plan and Procedures. At this time Detroit Edison does not see the value in placing any other local agencies on controlled distribution. Their primary interface is with and through the county OCP.'

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17. Keys for the emergency lockers should be available, but on a centro 11ed basis. (Section 7.2)

RESPONSE

Keys for equipment lockers to be used by emergency teams within the plant are available. All operators have a key to access emergency equipment for Fire Brigade and Damage Control & Rescue.

Both the Health Physics Technician on+ shift and Nuclear Shift Supervisor have keys to access all HP equipment lockers, As such, the disposition of the keys is controlled.

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18. Detector units for portable radiation survey probes should be replaced as part of the radiation monitoring equipment at Seaway Hospital, Trenton, Michigan. (Section 6.1.6)

RESPONSE

The detector units for portable radiation survey probes will be re-placed at Seaway IIospital at the time of the next inventory or cali-bration.

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APPENDIX B - IMPROVEMENT ITEMS 19 Revise I.etter of Agreement with Frenchtown Fire Department (FFD) to specify who will be in charge while onsite, the FFD (Chief) or the Fire Brigade Leader. (Section6.1.7)

RESPONSE

The Letter of Agreement will be reviewed with Frenchtown Fire Department to assure that it is consistent with, and everyone's under-standing is consistent with, the current state law on this topic.

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~20. Resolve the status'or the request to change paragraph 4(c) of the Fixsd Facility Emergency Response . Voluntary Assistance Agreement-as requested by INP0 in a Detroit Edison letter of March 11, 1981. (section 6.1 7)

RESPONSE-F This item will be pursued with INPO. .It should be recognized that

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the Agreement involves a large number of utilities. As a result, Detroit-Edison's suggested change may not be readily incorporated by INPO. 1 i

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APPENDIX B - IMPROVEMENT ITEMS

21. Provide training for all accident types listed in the RADOSE menu.

(Section 7.2)

RESPONSE

Training will be provided for all accident types listed in t"e RADOSE menu as a part of the annual requalification.

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APPENDIX B - IMPROVEMENT ITEMS i . .

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22. Specify the individual or organizational element responsible for performing 'the tasks covered in each emergency plan implementing procedure.- (Section 5.1)

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In general, the emergency plan implementing procedures do specify ,

the individual or organizational element responsible for performing the tasks covered. An exception to this is EP-202-3 off-Site

!~ Personnel Monitoring Team (PMT): Activation. This procedure says the -

i team shall be composed of " select personnel". Team composition was ,

left vague awaiting a determination of what personnel would be available to be trained to fulfill this function. Once this decision is made, this procedure will be revised to specify the '

responsible organizational element or individual. At'present, individuals from Rad Chem are trained to function as. members of the Off-Site PMT.

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