ML20091B489
| ML20091B489 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/25/1984 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20091B480 | List: |
| References | |
| NUDOCS 8405300306 | |
| Download: ML20091B489 (20) | |
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DOCKETEP U:3NRC UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION *g4 g.f g Before the Atomic Safety and Licensing Board L F r - 0. w.,a l
In the Matter of E'lig.yE '
Philadelphia Electric Company ) Docket Nos. 50-352 C2C
) 50-353 g(,
(Limerick Generating Station, )
Units 1 and 2) )
SUPPLEMENT TO APPLICANT'S MOTION TO SUBSTITUTE CERTAIN ONSITE EMERGENCY PLAN IMPLEMENTING PROCEDURES IN EXHIBIT 33 On May 4, 1984, Applicant filed a motion requesting i
the Board to substitute seven revised implementing procedures for those offered in evidence as part of Applicant's Exhibit
- 33. On May 7, 1984, the Licensing Board requested Applicant to provide "some better identification of what the changes are in the updated procedures, so we can decide if there is any material change beyond the hearing time frame; and that would have to be annotated in some fashion." (Tr. 10296)
Attached as Appendix A are a series of tables which enumerate each of the changes made in the procedures as requested.
l Respectfully submitted, CONNER & WETTERHAHN, P.C.
) (f. f Troy . Conner, Jr. 6 Ccunsel for Applicant May 25, 1984 l
l 8405300306 840525 PDR ADOCK 05000352 L
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C0CKETEP USNRC UNITED STATES OF AMERICA 84 W 29 A11:51 NUCLEAR REGULATORY COMMISSION L T F : . - C F 5 !. ..
COCFli% & SEFv, In the Matter of ) BRANCH
)
Philadelphia Electric Company ) Docket Nos. 50-352
) 50-353 (Limerick Generating Station, )
Units 1 and 2) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Supplement to Applicant's Motion to Substitute Certain Onsite Emergency Plan Implementing Procedures in Exhibit 33," in the captioned matter have been served upon the following by deposit in the United States mail this 25st day of May, 1984:
- Lawrence Brenner, Esq. (2) Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section
- Dr. Richard F. Cole Office of the Secretary Atomic Safety and U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 *
- Ann P . Hodgdon, Esq.
Counsel for NRC Steff Office
- Dr. Peter A. Morris of the Executive Atomic Safety and Legal Director Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Washington, D.C. 20555
- Hand Delivery on May 29, 1984
- Hand Delivery
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.i Atomic Safety and Licensing Angus Love, Esq.
Board Panel 107 East Main Street U.S. Nuclear Regulatory Norristown, PA 19401 Commission Washington, D.C. 20555 Robert J. Sugarman, Esq.
Sugarman, Denworth &
Philadelphia Electric Company Hellegers ATTN: Edward G. Bauer, Jr. 16th Floor, Center Plaza Vice President & 101 North Broad Street General Counsel Philadelphia, PA 19107 2301 Market Street Philadelphia, PA 19101 Director, Pennsylvania Emergency Management Agency Mr. Frank R. Romano Basement, Transportation 61 Forest Avenue and Safety Building Ambler, Pennsylvania 19002 Harrisburg, PA 17120 Mr. Robert L. Anthony Martha W. Bush, Esq.
Friends of the Earth of Kathryn S. Lewis, Esq.
the Delaware Valley City of Philadelphia 106 Vernon Lane, Box 186 Municipal Services Bldg.
Moylan, Pennsylvania 19065 15th and JFK blvd.
Philadelphia, PA 19107 Limerick Ecology Action P.O. Box 761 762 Queen Street Spence W. Perry, Esq.
Pottstown, PA 19464 Associate General Counsel Federal Emergency
- *
- Charles W. Elliott, Esq. Management Agency Brose and Postwistilo 500 C Street, S.W., Rm. 840 1101 Building Washington, DC 20472 lith & Northampton Streets Easton, PA 18042 Thomas Gerusky, Director Bureau of Radiation
- ** Zori G. Ferkin, Esq. Protection Assistant Counsel Department of Environmental Commonwealth of Pennsylvania Resources Governor's Energy Council 5th Floor, Fulton Bank Bldg.
1625 N. Front Street Third and Locust Streets Harrisburg, PA 17102 Harrisburg, PA 17120 Jay M. Gutierrez, Esq.
t U.S. Nuclear Regulatory l Commission 631 Park Avenue King of Prussia, PA 19406
- Federal Express
I r 4 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 Timothy R.S. Campbell Director Department of Emergency Services 14 East Biddle Street West Chester, PA 19380 Robert M. RHder i
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.- *n' 'Page 1 of 2 s
Title Rev.
Procedure Unusual Event Response 2
' EP-102 e
S_teig Change
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2.1 Added "unless Emergency Director is present" to clarify assumption of role. Capitalized " Unusual Event".
4.1 Added "CP-101, Classification of Emergencies has been completed" to strengthen sequencing between EP-101 and EP-LO2.
9.1 Actions capitalized and underlined.
9.1.1.1 Adged "unless determination has jus t been made" to reduce r.on-productive reclassification of the event.
9.t.1.2 Added "Shif t Supervision to initiate" to match the active party in EP-303.
9.t.1.3 Added " if necessary" to avoid duplication of calls.
9.1.1.4 -
Changed " commence" to " complete" to make indication that task completion is required on a more definite note. Adds "at higher level classifications" to give addi ti anal information.
9.1.1.7 Corrected title f rom " Fire and Damage Team Leader" to
" Fire and Damage Control Team Leader" .
9.1.1.9 Added s tep to provide an interf ace with EP-208.
9.2 Capi talized and underlined f ollow-up.
9.2.1.2 Added "at higher level classifications" to give addi tional information.
9.2.1.3.a Corrected Shif t Chemist to Shif t Chemistry Technician.
9.2.1.3.d Added step to ensure actifications are completed and results returned to (Interim) Emergency Director.
9.2.1.4 Corrected "any' to "an".
9.2.2 & 9.2.2.1 Added steps as a companion step to 9.2.1.3.d and to clarif y Communictor's duties.
10.7 Corrected procedure title.
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'Page 2 of 2 4
Change Stee 102-1 Contracted Limerick Generating Station to LGS.
Added a blank f or a title or name of appropriate person.
Added "24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time" and "date" to indicate what should be in blanks.
102-2 Deleted extra blank lines.
LO2-3 Added "unless already notified by the Interim Emergency director" to reflect step 9.1.1.3.
Added new access code to Centrex telephone.
Reversed order of Pennsylvania Emergency Management Agency ,md Montgomery county calls to reflect order in Annex E, Disaster Operations Plan.
Added new access code.
Added new access code.
Added " communi ca tor : Inform (Interim) Emergency Director when notifications are completed." to reflect addi tion of 9. 2. 2.1.
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Page i of 2 Rev.
t!rqceduEe Title Algrt Response 2 EP-103 Stog i:hanqo,
'4 .1 Added "MP-101, Classification of Emergencies, completed" to strenghthen sequencing between EP-101 &
9.1.1.1 Added "unless determination has just been made" to reduce non-productive reclassification of the event.
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9.t.1.2 Combined content of 9.1.1.2 and 9.1.1.3 of Revision 1 to make a single decision step of the
. assembly / evacuation options. Added the " assembly without accountability" and the " assembly with acdountability" to reflect the change i n EP-110.
9.1.t.3 Step number changed due to previous change.
9.1.1.4 Deleted "I f necessary and" . Added "S ite Evacuation or" and " depending on plant condi tions" to provide more options and c decisional basis, 9 . t . t . 5 -0 - Step number changed.
9.t.l.9- ,
Deleted reference to Instrument and Control Technician as this is covered in EP-201, 9.1.1.11 Expanded note to clarify action.
3.1.1.12 Added title of security contact and number so Emergency Director knows who he's contacting.
9.1.1.12 Corrected job title f rom "Shif t Chemist" to Shif t Chemistry Technician" .
9.1.1.14-18 Changed step number.
9.2.1.4.a- Added " f rom Security Team Leader" to parallel structure of rest of step.
9.2.1.4.g Added step to ensure notifications are completed and r es ul ts returned to Emergency Director.
9.2.t.7. Reworded step to provide more direction to (Interim)
Emergency Director.
9 . 2. 2, 9.2.2.1 Added steps as companion steps to 9.2.1.4.g and to clarify communicator's dutiec.
10.21 Corrected ti tle of EP-260.
Page 2 of 2 S_ t e.2 C,hange 10.23 No. change.
103-1 dded "24 hr clock time", "date" to indicate use of blanks.
103-4 A. Added "unless already notified by (Interim)
Emergency Director to prevent unnecessary duplicate calls, B. Added new access code to Centrex telephone.
C. Reversed order of (1) & (2).
Added " Communicator : Inform Emergency Director when notifications are complete" , to reflect 9.2.2.1.
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e Page 1 of 2 Procedure Title Rev.
EP-104 Site Emergency Response 2 x
3.E22 ghange 4.1 Added "l?P-101, Classification of Emergencies, completed to strengthen sequencing between EP-101 and EP-102.
9.1.1.1 Added "unless determination has just been made" to reduce non productive reclassification of event.
9.1.1.2 Reworded to provide more direction as to actions to be taken and to reflect changes in EP-110.
9.1.1. 3, 4 Cha$ged the page placement.
9.1.1.5 . Added step to cover evacuation of construction personnel without evacuation of operating personnel.
9.1. L . 6, 7 Cnanged step number.
9.l.1.8 -
- Reworded to simplify action to be taken by person on
" cod phone".
9.L.l.9 Changed s tep number .
4.1.1.10 Deleted ref erence to Instrument and Controls Technician as this is covered in EP-2Ol.
9.1.1.11 Spacing changed to put EP-203 on 1 line.
9.l.1.12 Added s tep to shorten amount of time needed to activate the EOF by having people called while Dose Assessment team leader is enroute.
9.1.1.13 Step number changed and note clarified.
9.1.1.14 Added title and number to let the Emergency Director know who he's calling.
9.1.1.15 Step number changed and job title corrected.
9.1.1.16-18 Step number changed.
9.1.1.19 Step number changed and team title corrected, a 9.l.1.20 Step number changed.
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Step ghange 9/2.1.4 a. Added " f rom S ecurity Team Leader" to parallel structure of remainder of step.
- b. Job title correction
- f. Team titi ? correction.
- g. Added to ensure notifications are completed.
9.2.1.8 Reworded to clarify action.
9.2.1.9 Added step to give procedural responsibility, given in Emergency Plan.
- 9. 2. 2( O ld) Moved to EP-120.
9.2.2.2 Added s tep to parallel 9.2.1.4.g and clarif y communicator's duties.
10.19 Title correction.
EP-104-1 . Added "24 hr clock time" and "dnte" to indicate use of blanks.
EP-104-4 a. Added "unless already notified by (Interim)
Emergency Director" to reduce unnecessary duplicate calls,
- b. Added new access code.
- c. Reversed (1) & (2).
Added " Communicator: Inf orm Emergency Director when notifications are completed" to reflect step 9.2.2.1
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Page 1 of 2 4
T igle Rev.
EEqqqdyge General Emergency Response 2 EP-105 a
Chango EE"O 4.1 Added "EP-101, Classification of Emergencies, completed." to strengthen sequencing between EP-101 and EP-LOS.
9.1.1.1 Added "unless determination has just been made" to coduco 'on-productive reclassification of the event.
9.L 1.2 Added a comma between 305 and Site. Added cauti onary note to provide additional option.
9.1.1.3 Simplified wording.
9.1.1.6 Changed " commence" to " complete" to emphasize that completion is necessary. Reworded to simplif y action to be taken by person on " red phone" .
9.1.1.7 Changed to place bases on procedure not emergency
,' lovel.
'3.1.1.8 Deleted ~ reference to Instrument & Control Technician since this is in EP-201.
9.1.1.9 Added a source for necessary phone number.
9.1.1.10 Added step to reduce activation time for EOF as calls can be made while Dose Assessment Team leader is enroute.
9.1.1.11 Changed step number and note clarified.
9.1.1.12 Added title and phone number so identity of person being contacted is known.
9.1.1.3 Job title corrected.
9.1.1.14-16 Step number changed.
9.1.1.17 Team title corrected.
9.1.1.18 Step number changed.
9.2.1.4.a Changed to parallel structure of rest of step, g Added step to ensure completion of notifications.
9.2.1.8 Reworded and expanded to provide more options.
9.2.1.9 Added step to provide procedural responsibilities given in the emergency plan.
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- Page 2 of 2 Eteg Change 9.2.2(016) Moved to EP-120, 9.2.2, 9.2.2.1 hdded step as companion steps to 9.2.1.4 g and to clarify communicator's responsibilities.
10.19 Corrected procedure title.
10.21 Added missing ref erence 105-1 Added "24 hr clock time" and "date" to indicate use of spaces.
105-2 Added (INTERIM) that was missed in Revision 1.
105-4 a. Added "unless already notified by Emergency
' Director" to reduce duplicate notifications
- b. Added new access code, to Centrex telephones,
- c. Revorsed (1) & (2).
- e. Added "make this phone call last and remain on telephone until NRC disconnects" to reflect step
. 9.1.1.6 change.
Added " Communicator : Inform (Interim) Emergency Director when notifications are complete" to reflect step 9.2.2.1 f
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Page 1 of 3 Procedure Title Rev.
CP-110 Pegsonnel Assembly and Accountability 1 S $EG _hango 1.0 Deleted the f ollowing wording af ter " accountability",
"of Peco personnel and contractors is required when an Alert of partial plant evacuation i s declared" .
Reason:
Procedure.
This is stated in 7.0 Action level of 2.1 Change "PECo personnel and contractors to " Personnel" deleted "for purposes of accountability" and added "or as otherwise directed". Reason: To clarif y that there are alternate emergency assembly areas that can be ,used.
2.2 Added "when required", af ter " Emergency Assembly Area Coordinator". Changed "of personnel at the
' designated area" to "of personnel at their areas".
Deleted "and report missing persons to Security" after the wording of " designated area".
2.3 -
Changed "2.3" to "2.4" and added a new step "2.3" to explain Bechtel and sub-contractor responsibili ties during accountability.
2.4 (Originally 2.3 in Rev. O) . Changed "a list of missing persons" to "a list of unaccounted for persons". Added "when accountability checks are required" after " persons" - Explain only when assembly with accountability is done that checks are required. Added the "(Int erim) Personnel Saf ety Team Leader".
2.5 (Originally 2.4 in Rev. 0) . Added " Interim" to
" Emergency Director". Added " Interim" to " Personnel Saf ety Team Leader" . Corrected "the S earch and Rescue Group" to "First Aid / Search and Rescue Group".
Changed " missing personnel" to " unaccounted f or personnel".
7.0 Added af ter "an Alert" the f ollowing " Site Emergency, General Emergency, Partial Plant Evacuation". Reason to clarify when this procedure should be enacted.
Changed and capitalize "Af ter a site evacuation is declared, this procedure no longer applies" to
" Accountability section of this procedure do not apply during a si te evacuation",
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Reason - to clarify when sections of this procedure u are not applicable and personnel assembly locations E are still being used, f; a
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'Paga 2 of 3 Steg Change ,
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9.1 Added explanatory note to clarify when personnel Assembly will be enacted af ter announcements, t
9.1.1 Added steps to establish two types of assembly:
- a. Assembly without accountability (emergency teams report to assembly area - others standby (step 9 .1.1, Rev. 1).
- b. Assembly with accountability (emergency teams report to assembly areas - others leave the protected area (step 9.1.2 Rev. 1).
9.L.3 (Originally 9.1.2 of Rev. 0) .
9.1.3.1 Cha'nged steps to establish action steps for assembly without accountability and assembly with accountability.
9.1. 3.1 - Assembly without accountability.
9.1. 3. 7 - Assembly wi th accountability.
9.1. 3. 2 -
Expanded on how to do an accountability check at assembly area for Emergency Assembly Area Coordinators.
9.1.4 (Originally 9.1.3 of Rev. 0)
Added steps to establish security actions for assembly without and with accountability.
9.1. 4.1 Assembly wi thout accountability.
9.1. 4. 2 Assembly wi th accountability.
9.2.1 Added "(Interim)" in f ront of " Emergency Director"
.and deleted Interim Emergency Director.
9.2.1.1 Changed " missing personnel" to " unaccounted f or p e rsonn el" .
9.2.1.2 Added "(Interim)" to " Personnel Saf ety Team Leader" .
Appendix EP-110-1, Emergency Assembly Areas s
- 1) Changed the following groups to leave the protected area for accountability purposes.
Dechtel/ Subcontractors in Restricted Area
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e Page 3 of 3 S !'E C_1ange 3
PECo Field Engineers Administration S taff and Unescorted Visi tors Escorted Plant Visi tors (Note 1)
- 2) Added assembly areas for Maintenance and I&C Technicians
- 3) Added Note relating to OSC habitability (Note 2) .
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- Paga 1 of 2 Title Rev.
Procedure .
' EP-208 Security Team Activation 1 Change Ste2 2.1 Added " designated" to indicate who may assume role.
3.2 Added Appendix EP-208-2 containing material f rom EP-254.
5.1 Added material from EP-254.
7.0 Added "Whenever a personnel assembly is announced" to cover their use in EP-110. Capitalized Site Evacuation.
3'.9.1 Changed "Immediate Actions" to " Actions" per change in A-21, 9.1.1.2 Expanded and reworded to allow delegation.of making actual call.
9.1.1.3 ,
Changed wording to make it assignment of group leaders not the entire group. Added note to provide for transition f rom Interim team leader to tecm loader.
9.1.1.4 Added s tep to ensure personnel are properly equipped.
9.1.1.5-6 Added duties of Interim team leader that were listed previously only under team leader.
9.2.1.4 Resequenced from 9.2.1.7.
9.2.1.5 Added step with inf ormation f rom EP-254 to reduce number of procedures the Security team must work with. (Same f or rest of EP-254 inclusions).
9.2.1.6 Added s tep as interf ace to EP-102 through EP-105 follow-up.
9.2.1.7 Added step to provide a point of interface for PP's.
Pago 2 of 2 St?2 Change 9/2.2.1 Added step to indicate by whom they are activated.
9.2.2.2 Added s ucp to describe communications and added location of traf fic vest f rom EP-254.
9.2.2.3 Changed wording clarify action. Added note to give information removed from step's text.
9.2.2.4 Added step f or duty not previously covered.
9.2'.2.5.a Moved list to EP 208-2 table.
b Added to be consistent with EP-305 ( f rom EP-254) c Reworded to clarify duty when computer is operating.
9.2.3.1 Added step because of changes in EP-110.
9.2.3.2.a Reworded to reflect changes to 9.2.2 b Reworded to interf ace with Bechtel Procedure, c .
Reworded to clarify action required.
e Added to provide inf ormation f or Emergency Director and Personnel Saf ety Team Leader.
9.2.4.2 Added " ( s ee EP-110) " .
CP-208-2 Added table to include inf ormation f rom EP-254.
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Pags 1 of 2 Procedure Title Rev.
EP'-2 3 0 Chemistry Sampling and Analysis 1 Team Activation i
S, t,e2 Ch*"9' 1.0 Added " required to activate" Chemistry Sampling and ,
Analysis Team.
2.3 Changed " direct members by performing "to direct members y perform." .,
3.3 Deleted appendix to EP-230-3 "Of f site Post Accident Sampling Analysis" and moved of f site sampling procedure to EP-244, Rev. O.
l l /.1 Added "(Interim)" Emergency Director activates
- Chemistry Sampling and Analysis Team. l 8.2 Changed "the" Health Physics Tech to "a" Health
! Physics Tech. t i
9.1 - Changed "Immediate Actions" to " Actions"
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l 9.1.1.1 Added "(Interim)" to Chemistry Sampling and Analysis Team Leader. ,
-l 9.1.2 Changed " Chemistry Sampling & Analysis Team Leader "
to " Senior Shif t Chemistry Technician" (who is the
! Interim Chemistry Sampling and Analysis Team Leader) .
9.1.2.1 Moved note about minimizing exposure if chem lab habitability is degraded.
Added where to report if laboratory is uninhabitable- l 2nd floor Admin. l i
9.1.2.2 Added Interim Chem Sampling & Analysis Team Leader assuming role af ter discussion with Emergency Director and note that Team Leader will relieve him once f ully cognizant of situation. ,
f 9.1.2.5 Added step f or Team Leader to request Emergency Exposure authorization from the Emergency Director as required, j 9.1.3.1 Added that the Group Leader assembles group "at the Cold chem Lab" .
Changed " Ensure that s Health Physics Technician or !
Health Physics Qualified Chemistry Technician is *;
available" to " request a Health Physics Technician i I
from the Plant Survey Group Leader in the OSC."
Pegs 2 of 2
! i i Steg Change ,
9.l.3.2 Added step f or Group Leader to evaluate sample pondition and or locations and instruct group members to take the necessary samples using indicated I
pro cedur es .
. 1.7 Added step for Group Leader to have member's doses ovaluated to ensure that members don't exceed guidelines without prior approval of (Interim)
Emergency Director.
9.1.3.8 Added steps f or Chem Sampling and Analysis Group ,
Londer to request Team Leader to obtain emergency exposure authorizations f rom the (Interim) Emergency Directoe.
9.1.4.2 Added for members to " collect and analyze samples as directed by Group Leader".
9.2.1.1 Changed step so that Chemistry Sampling and Analysis Team Leader reports results to Emergency Director and Dose Assessment Team Leader and took out Rad
. Protection Team Leader.
9.2.1.2 -
Changed step to provide group leaders (not members) with periodic status changes etc.
9.2.1.3 Put of f-site analysis in separate procedure EP-244, Of f Site Analysis of High Activity Samples instead of Appendix EP-230-3.
9.2.2.2 Added Group Loaders will inf orm group members of status changes .
9.2.2.3 Added step Group Leader will request augmentation personnel f rom Team Leader as requi red.
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- Pog3 1 of 1 i
Title Rev.
Procedure .
Local Evacuation 2 EP'-3 03 Step change f 1.0 Changed word " provide" to " define" steps necessary to be taken by site personnel in the evenc that a local i
evacuation is required.. . deleted (due to a localized uncontrolled hazard .
4.1 Added Prerequisite " Implementation of EP-101, Classification of Emergencies is not required." .
9.1.1 Added "if radioactive contamination is suspected remain at a safe area until frisked by HP."
o I 9.2 Changed " Follow-up Actions" to " Follow-up."
9.2.1.1 Added " Ensure that all personnel who have left the area are not contaminated."
l 9.2.1.3 ,
Changed the word " problem" to " occurrence" .
l 9.2.1.4 ', If problem cannot be contained. . . added " consult EP 101" bef ore "and direct evacuation of other areas".
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