ML20092P401
| ML20092P401 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 06/11/1984 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20092P396 | List: |
| References | |
| 8711N, NUDOCS 8407060252 | |
| Download: ML20092P401 (21) | |
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/~ N Commonwealth Edison
[
- j One First Nitional Plaza, Chicago, lihnois
~T gj] Address Reply to: Post Office Box 767 Chicago, Illinois 60690 June 11,.1984 Mr. James G. Keppler Regional Administrator U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137
Subject:
Byron Generating Station Units 1 and 2 Emergency Preparedness Appraisal I&E Inspection Report Nos. 50-454/83-56 and 50-455/83-39 Reference (a):
February 3, 1984 letter from C. J.
Paperiello to Cordell Reed.
Dear Mr. Keppler:
This is to provide Commonwealth Edison's response to the open items and improvement items which were identified during the Byron emergency appraisal.
Attachments A and B to this letter contain the responses to the open items and improvement items, respectively, listed in reference (a).
As you will see, only a few actions remain to be taken to address the NRC's concerns.
Please addres's further questions regarding this matter to this office.
Very ' uly yours o~
?
D. L. Farrar Director of Nuclear Licensing 1m 8407060252 840702 PDR ADOCK 05000454 8711N G
PDR JUN 131984 L_
i ATTACHMENT A RESPONSES TO OPEN ITEMS f
OPEN ITEM #1 Develop and implement an augmentation or staffing procedure to ensure that.the Corporate Command Center (CCC) and/or the Emergency Operations
-Facility.(EOF) will be fully staffed in a timely manner, e.g.,
one hour for the EOF being operational.
This procedure could be a call tree type similar to that used by the station for off-shift augmentation.
This must be completed prior to initial criticality (454/83-56-01; 455/83-39-01).
RESPONSE
J The corporate Generating Station Emergency Plan (GSEP) manual has been revised to describe the method by which both the CCC and/or EOF 1
shall be so activated as well as the mechanism by which specific responsible individuals are contacted to activate the ERF's.
The GSEP phone directory does identify sufficient individuals to staff the ERF's (CCC and EOF).
.The GSEP phone directory was revised in January of 1984 to include i.
prioritized EOF director positions versus people by station.
These lists were based upon the home geographic location and the ability to report to a specific EOF in a timely manner.
-The April, 1984 revision of the GSEP phone directory has a call out tree for use during non business hours.
This call out tree shall apply to EOF and CCC directors.-
With these changes it is reasonable to expect partial manning of the EOF or CCC within 60 minutes for site and general emergencies.
OPEN ITEM #2 Update procedure BZP 600-Al to incorporate current emergency response assignments such that those closest to the station are notified first;
.and provide a copy of the completed and revised procedure to all personnel responsible' for implementing sit such that a copy of this procedure will-be available near the callers' home-telephone.
This must be completed prior to-fuel load.
(454/83-56-02; 455/83-39-02).
RESPONSE
Byron procedure BZP 600-Al has been revised :and appro/ed to incorporate current job assignments and distances from the plant.
The procedure directs that' people living closest to the plant should be called first.
An_"information only" copy of the. procedure will be given to the call supervisors.
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- OPEN ITEM #3 Complete the Technical Support Cente; (TSC) by making the ventilation system and its associated radiation monitoring system operable and include a copy of the Final Safety Analysis Report (FSAR) and Technical Specifications in the TSC working area.
This must be completed prior to initial criticality.
(454/83-56-03; 455/83-39-03)
RESPONSE
Testing of this ventilation system for the TSC has been completed.
Installation of the HEPA and charcoal filters is complete.
The TSC ventilation system is operational.
The radiation monitoring systems are operational with the exception of the continuous air monitor (CAM).
The CAM will be tested and operational prior to initial criticality.
A copy of the Final Safety Analysis Report and the Technical Specifications have been placed in the Technical Support Center.
OPEN ITEM #4 Complete installation, development of procedures, and training on the use of the Post Accident Containment Atmosphere Sampling System and the methods for analyzing this sample.
This must be completed prior to exceeding 5% power.
(454/83-56-04; 455/83-39-04)
RESPONSE
Completion of the containment air sampling panel, bendix gas chromatograph and the gas partitioner as well the associated training and demonstration of sampling capability within'1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> will be completed prior to fuel load.
OPEN ITEM #5 Complete installation, development of procedures, and training on the use of the General Atomics Wide Range Gas Monitors and methods for analyzing the corresponding particulate, gas, and radiciodine cartridge samples.
Specific attention must be paid as to how the lead shielding cask will be transported from the' sample ' location to the counting facility.
This must be. completed prior to fuel load.
(454/83-56-05; 455/83-39-05)
RESPONSE
A functional evaluation of the_ revised procedures for use with the eide range gas monitors has been performed and all radiation chemistry.
technicians have been trained.
Approval of the revision to Procedure BZP-380-3 is complete.
Specific attention has been given to transporting
.the lead shielding cask in this procedure revision.
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. OPEN ITEM #6 Complete installation, development of procedures, and training on the
~ use of the. General Atomics station blowdown monitor and sampler.
This must be completed _ prior to. fuel load.
(454/83-56-06; 455/83-39-06)
RE SPONSE Procedure BZP-380-4 has been revised and approved.
Training and pre-operational testing has been completed.
Additionally, sample collection points have been modified to direct the sample downward.
OPEN ITEM #7 Complete construction, installa'clon, and stocking of equipment, supplies and instrumentation l' the medical treatment and decontamination facility.
This must be completed prior to fuel load.
(454/83-56-07; 455/83-39-07)
RESPONSE
Construction and stocking of the required equipment is complete.
OPEN ITEM #8 Complete calibration and insta11a'.lon of the containment high range monitor, General Atomics RM-11 System, and all other process or area radiation monitors used for emergency classifications or accident assessment.
This must be completed prior to fuel load (454/83-56-08;
- 455/83-39-08)
RESPONSE
4 All area-radiation monitors used for emergency classifications or eccident assessment will have approval of pre-operational test results by fuel load.
The approval of pre-operational test results~for all process radiation monitors used for emergency classifications or accident assess-ment will be completed prior to fuel load.
The area and process detectors ere currently calibrated and will be recalibrated at refueling outages.
OPEN ITEM #9-Complete installation of.non-radiological process monitors used-for cmergency classifications or accident assessment.
This must be completed prior to fuel load.- (454/83-56-09; 455/83-39-09)
. RESPONSE The test results for the containment hydrogen monitors, ionization detectors and seismic monitors are ready for NRC review.
Testing of the annunciator windows and analog control room indicators for the Containment hydrogen monitors is not complete and is listed as an open item in the test.
OPEN ITEM #10 Complete ~ installation of respiratory protection equipment, such as the Self Contained Breathing Apparatus (SCBAs) in the Control Room, TSC, OSC, -outside of Unit 1 and 2 containments, at the remote shutdown panels, and the rad / chem area of the Auxiliary Building.
This must be completed prior to fuel load.
(454/83-56-10; 455/83-39-10)
RESPONSE
1 All SCBA's are now in place.
OPEN ITEM #11 Develop a procedure for the Acting Station Director (Shift Engineer).
This procedure must include all responsibilities that the Shift Engineer would perform, such as event classification, appropriate notifications, on-hours and off-hours augmentation, a streamlined flow chart for protec-tive action decision making, how to fill out the Nuclear Accident Reporting System (NARS) form, guidance on which tasks Rad / Chem Technicians
( RC Ts) should perform and in what order, and the sounding of the assembly /
evacuation alarm for any Site Area or General Emergency.
This procedure should not contain any extraqeous in7ornation that is not needed by the Shift Engineer to jmplement his responsibilities.
Training of all potential Acting System Directors must be performed after the procedure is issued.
This must be completed prior to fuel load.
(454/83-56-11; 455/83-39/11)
RESPONSE -
-A procedure (BZP-310-5) for Acting Station Director has been written and reviewed by the appropriate operating department personnel who should perform the function of Acting Station Director.
The procedure has been approved.
Training of Acting Station Director candidates will occur before fuel load.
. OPEN ITEM #12 Complete installation, testing, and calibration of the associated equipment and completion of procedures for the use and operability of the computerized " Class A" model.
This must be completed prior to exceeding 5% power.
(454/83-56-12; 455/83-39-12)
RESPONSE
In lieu of the interface for the Westinghouse and General Atomics computers, procedure BZP 320-2 was written.
This procedure will allow manual entry of "A Model" monitoring data into the plant process computer as it is recorded from the RM-ll computer console.
This procedure will be used as an interim measure until a data link between the RM-ll console and the plant process computer can be established.
Procedure BZP 320-2 will also be used in the event of a data link failure.
Also, in order to clarify statements made in Inspection Report 83-56 as to the operation of the "A Model" and it associated equipment the following statements are made.
The control room SPDS will consist of two iconic displays to fulfill the requirements of NUREG 0696, but will not be used for point status or point trending, as stated under 5.4.2 of the assessment actions.
The SPDS in the TSC and EOF will be operational to pull both point status and point trending as stated.
GSEP classifications and protective action recommendations will not be produced at the RM-ll consoles in the cuntrol rooms.
GSEP classifications will be output on the process computer alarm typer in the control room.
Also, no alarm will sound if an emergency classification has been exceeded, as stated.
The SPOS will be operational 'oy commercial service.
Completion of the data link between the RM-11 consoles and the plant process computers remains to be completed.
This activity is scheduled to be completed by October 15. 1984 Procedure BZP 320-2 has been approved.
OPEN ITEM #13 Develop a procedure to determine radiciodine concentrations in the field as low as lE-07 uC1/cc for the equipment currently available to field teams.
This must be completed prior to exceeding 5% power.
(454/83-56-13; 455/83-39-13)
RESPONSE
All SAM-2 electronics are now operational.
Procedures BRP 1740-2 and BRP 1740-3 have been revised and approved for the SAM-2.
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9 OPEN ITEM #14
. Develop and implement communication check procedures.
This must be completed prior to fuel load.
(454/83-56-14; 455/83-39-14)
RESPONSE
Recently approved procedures BZP-500-1 and BZP 500-Tl now perform a monthly communications check.
OPEN ITEM #15 Complete installation of the Sentry High Radiation Sampling System (HRSS) primary coolant sampling capability for Unit 2.
(455/83-39-15)
RESPONSE
The Unit-2 HRSS is to be operational prior to-fuel load on Unit 2.
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ATTACHMENT B RESPONSES TO IMPROVEMENT ITEMS J
IMPROVEMENT' ITEM #1 The Stores Diretor's-binder in the Technical Support Center (TSC) i should contain as complete and.as current information regarding health physics and vendor contacts for these supplies as are on file in the Stores Supervisor's Office.
RESPONSE
4 Procedure BZP 600-A2 has been revised and approved to now include the Stores Director's updated list of vendor contacts.
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. IMPROVEMENT ITEM #2 A copy of the technical specifications should be on file in the i
Emergency Operations Facility (EOF).
RESPONSE
A Proof and Review copy of the Technical Specifications is now at the EOF.
IMPROVEMENT ITEM #3 The health physics storage. area should contain an appropriate check source.
RESPONSE
I A non-licensed check source has been provided to perform response testing by initial criticality.
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-IMPROVEMENT ITEM'#4 W
The GSEP kit used by the security force should be more readily,
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accessible to the team dispatched to the EOF and should contain a route map to the EOF, instructions regarding when and how the team should
. contact plant security, and a. current _ roster of persons-allowed EOF access.
RESPONSE
ThelGSEP. kit used by the security force has been relocated to'be more
- readily accessible to the security force-and will tHe equipped with associated maps and rosters as'statedLin the BZP's. --These actions'will-
<be completed prior.to: fuel load when-full. security is-: implemented.
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IMPROVEMENT ITEM-#5
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Procedure CC-1 -should be revised to list the locations of the Byron Station's TSC, Operational Support Center (OSC), and EOF in Attachment D, and the appropriate two digit Nuclear Accident Reporting System (NARS) codes for Byron in Attachment E.
' RE SP ONSE
~J The new r6 vision of Procedure CC-1,-Revision 9, Attachment E, contains the locations of the OSC, TSC and EOF.
Attachment D contains the appropriate NARS dial code for, Byron Station.
IMPROVEMENT ITEM #6
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The three' foot' reach rod should be store'd in the High Radiation
, Sampling System cabinet.
RESPONSE
The reach' rod is stored in a cabinet next to the High Radiation Sampling Syste'm cabinet.
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" IMP ROVEMENT _ _ ITEM - # 7 Instruments for analysis of chloride and dissolved hydrogen should be made operational and perfornance tested.
RESPONSE
~ All iristruments -have been installed and calibrated.
Procedures, preoperational tests-and RCT training will be ccmpleted by initial criticality.
IMPROVMENT ITEM #8 Evacuation route designations /(arrows) delineating directions to the assembly areas should be installed.
RESPONSE
-Evacuation route delineation arrow installation will be completed by initial criticality.
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IMPROVEMENT ITEM #9 f
The emergency lighting in the Maintenance Sh'op and the Unit 1 turbine i
_ building trackway assembly areas should be improved.
RESPONSE
Emergency lighting in the maintenance shop and the Unit 1 turbine i
building trackway assembly area will be improved prior to initial criticality.
IMPROVEMENT ITEM #10 l
Procedure EOF-4 should be revised to provide the correct locations 3
i for Byron Station's Emergency News center (ENC) and any alternate locations.
RESPONSE
i i
The location of Byron Station's Emergency News Center and any I'
alternate locations will be included in the next revision to EOF-4 by j
September, 1984.
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IMPROVEMENT ITEM #11 Additional briefing aids, such as less complex and/or-larger-scale 1
drawings of major plant systems and key components, should be available I
at the ENC.
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- RE SPONSE i
All aspects of design and equiping of the various CECO JPIC l
facilities are being reviewed to assure that an effective public information effort can be supported.
This project ~is to be completed by i
April 1, 1985.
In the interim, additional poster diagrams depicting 2
plant arrangement and key plant' systems will be'provided by September.1, 4
1984.
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1-i IMPROVEMENT ITEM #12 The cart containing the support hospital supplies should be locked and sealed until needed and inventoried whenever the seal is found broken.
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RE SPONSE.
The cart containing.the support hospital supplies will be locked, sealed and inventoried quarterly, or upon receipt of notification that the seal integrity'is. violated as per procedure BZP 500-T9.
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. IMPROVEMENT ITEM #13 The Eberline Survey-Assay Meter-(SAM-2) instruments should be 3
returned to-the field? monitoring emergency kits, or an alternative method L
of measuring airborne 'radiciodine in the field must be developed.
' RESPONSE The SAM-2-instruments have~been returned to the field monitoring emergency kits.
The kits are located in the guardhouse.
IMPROVEMENT ~ ITEM #14 e
The "A~Model's" meteorlogical date quality control tests should be refined to better assure that obviously invalid parameter values, which do not exceed sensor performance limits, are readily identifiable to i
persons involved in dose assessment activities within the TSC, EOF, or Corporate Command Center (CCC)_.
RESPONSE
The "A Model" program print out has been designed to supply rapid
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basic release rate information dose projections and affected-sectors as P
well as a printoutoof.tha-last 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> of meteorological data.
The program print out-was: designed for' individuals who are not trained meteorologists.
The meteorological portion of the "A Model" has=been verified _ to the design intent of the CECO "A Model" criteria.
Additional manipulation of meteorological-data to find proposed invalid parameters within sensor performance-limits is~not appropriate for inclusion.within.
the "A Model" logic.
Checks. of the operability of meteorological equipment are made
. independently-cf the "A~Model"~at regular ~ intervals.
Weekly checks of; I
meteorological equipment are performed by' Byron Rad-Chem Technicians to verify that control room and tower _ readings-coincide., _ Additionally,.the sev
.s ' are' checked ' for proper operation ~ tyr -Murrayl and Trettle,
..sulting meteorologists,fon_a weekly basis independent'oflthe Rad Chem system ' check.
Repairs are:made asfrequired at this time by Murray-and LTrettle.
Calibrations are performed by.Murray and Trettle on a bi-monthly ~ basis.-
Meteorological:readingsLare-taken at CECO's. downtown office'for all'
- Nuclear = Generating. stations'on atcontinuous basis.
If a value-falls:
outsideLof sensor range ~or does~not change:for1 our hours an
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'investigationiis-1nitiated. }Murray and Trettle71nterrogatesLthe Byron Microtel '3 ' times; a n day and checks l the data nfor validity.
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. IMPROVEMENT ITEM #15 The applicant should acquire an appropriate dedicated vehicle and/or implement a system to ensure that an appropriate number and type of station vehicles will be immediately available for use by field monitoring teams.
RESPONSE
Byron Station has several vehicles.
A list of available vehicles is kept by the Shift Engineer.
Further,_ Byron Station will share a dedicated vehicle with Quad Cities Station.
Implementation will occur by initial criticality.
4 IMPROVEMENT ITEM #16 The implementing procedure format should be modified to accommodate a section for " precautions."
All procedural precautions should be identified in the early stages of each procedure.
RESPONSE
Precautions are included in the implementing procedures at points in the procedure where the precautions are applicable.
This format is copied from the format used at Dresden Station.
The NRC praised this format during a GSEP evaluation there.
No revisions to existing procedures to incorporate this concern are planned.
IMPROVEMENT ITEM #17 Station Group Director's check 11sts should be revised to include references to the appropriate BZP procedures used to implement specific functions.
RESPONSE
The Group Director's checklists will be updated to-include references to the appropriate BZP's.
The checklist will be reviewed the appropriate directors and approved by initial criticality.
sa IMPROVEMENT ITEM #18'
' All11mplementing' procedures should be reviewed Eto erisure that all s
action steps are provided with guidance on "how" to do the step and "who" is responsible for its accomplishment.
Procedures should be detailed aids which-accomplish more than reminding the responsible party of what
- his' job entails.
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RESPONSE
Station direction procedures and' checklists will be reviewed and revised as necessary to include' applicable references-by initial
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criticality, i
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-IMPROVEMENT ITEM #19-As emergency procedures, contingency action procedures, functional restoration procedures, and abnormal procedures, are reviseJ the precautionary note should be changed to make reference to F AP 200-Al (Emergency Action Levels) as opposed to Table BYA 5-1 of the' annex in all procedures.- This will add consistency and eliminate potertial confusion.f4 t-
RESPONSE
- Byron BEP's, BFR's,. BOA's and BCA"s have been revisej to reference
'BAP-200-Al instead of Table BYA 5-1.
IMPROVEMENT ITEM #20
- Clarify.the policy on the Shift' Engineer's ability to delegate NARS' form completion.
RESPONSE
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-The procedurefdelineating the-Shift Engineers ability to delegateLthe t.
NARS form will be revised to clarify the7 policy about. delegating:thelNARS L
form completion.
This procedure.will bel of fered as part.of Annual'
- Re-training for all' Acting Station' Directors after approval of-the Acting Station ~Directnrs Procedure.
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' IMPROVEMENT ITEM #21 h
The GSEP responses in BZP. 310-1 for the Alert and Site Emergency should read the same as described in the GSEP response for the General l
Emergency, namely, the Station Director should be aware that if the CCC or EOF is-activated, then the information contained in the completed NARS Form must be conveyed to the CCC Director or Recovery Manager.
RESPONSE
Procedure BZP 310-1 will be updated to reflect this recommendation by initial criticality.
IMPROVEMENT ITEM #22 Section III.B.3 of BZP 100-Tl should list the phone numbers of the Federal and local services support agencies.
RESPONSE
Procedure BZP 100-Tl will be updated to include a reference to the BZP which contains all federal and local ser'vice phone numbers.
This action will be completed by initial criticality.
IMPROVEMENT ITEM #23 A manual and computerized Environmental Director (ED) series procedure should be developed for determining the offsite consequences of a steam generato; tube rupture event.
RE SPONSE The need for a manual procedure and computerized Environmental Director (ED) series procedure regarding the offsite consequences of a steam generator tube rupture event is being evaluated; however, its future has not yet been determined.
IMPROVEMENT ITEM #24 A summary' table of relevant conversion factors (such as gallons per minute to cubic feet per~ minute and miles per~ hour to meters per second) should be provided in the ED' procedures ~ binders.
RESPONSE' During 'the 1984 review of.the ED procedures the addition of a l-conversion factor table will'be considered.
Needless ~ conversion tables l
that would lead to confusion of~the reader will not be included.
L Equations within,the ED procedures are designed to include the needed
! conversions.
This eliminates the need of -the. reader to convert '(for example - gallons _per: minute to cubic feet per second)-before-the value can be entered-into'the equation.
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8-IMPROVEMENT ITEM #25 Section C.l.b of BZP 380-10 should be expanded to include information on specific-portable air samplers, continuous air monitors, sampling media, etc.
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RESPONSE
Generic procedure BRP 1740-1 was developed for. addressing sampling
. equipment'-and sampling media for use in accident conditions.
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_ procedure-is believed to be' adequate for addressing NRC concerns and therefore does not need to be included in procedure BZP 380-10.
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IMPROVEMENT ~ ITEM #26 Procedures BZP 380-11, 380-12 and 380-16 should be revised to include the following:1 valve and control identification in the procedure should be identical to valve and control labels on the sampling panel; add a step in the procedure to label the sample bottle before it is first inserted into-the cask; and add a precaution to alert the operators to i
watch for small leaks.of' coolant from the fill station-onto the cask and/or' floor after the cask is removed.
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RESPONSE
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The procedures have been revised to address these comments.
IMPROVEMENT ITEM #27-
' Unlabeled valves and controls.on the High Radiation SamplingLSystem
-(HRSS) Liquid Sample Panel.should be clearly. labeled in accordance with the sampling procedures.
RESPONSE
i AdditionalLlabeling has been addeo to the1 panel as recommended.-
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I MPROVE MENT ITEM-#28 i
Procedures BZP. 380-17 and BZP 380-A7'should be expanded to include-p transfer of-post accident samples fromLthe containment air _ sample' panel, the stack ~ effluent grab sampler, and the station blowdown ll monitor / sampler.
RESPONSE
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- The procedures have been expanded and approved.
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. ' IMPROVEMENT-ITEM'#29
. Sectisn C.2.c and C.2.d of. procedure BZP 380-16 should be expanded to clearly identify the hardware, sample bottle sizes, and the-sequence and nature of the manipulations.
RESPONSE
There are only two bottle sizes used.
These bottles are located
-adjacent to the-panel in a cabinet.
Procedures' governing use of this hardware are a part of the training program.
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. IMPROVEMENT ITEM #30 Procedures ~ BCP 800-2 and BCP 800-3 should be functionally tested and verified when the pertinent equipment _becomes operational.
RESPONSE
l Procedure BCP 800-2 was. functionally tested without problems.
Procedure BCP 800-3 was functionally tested and required minor revisions.
Revision to-BCP 800-3 will be completed by initial criticality.
IMPROVEMENT-ITEM #31
}
~The references of procedure BZP 380-6 should be expanded to apply to j
all post accident samples that would be received by the Hot Chemistry. Lab for-sample preparation and analysis and Section C.4 of this procedure should specify the use of a' continuo,us air monitor to evaluate habitability.
RESPONSE
Procedure BZP 380-6 was. expanded on December 7, 1983.to' include these concerns.
l-I IMPROVEMENT ITEM #32-
' Procedure'BCP 800-8.should be expanded to include all' post accident samples that may need dilution prior to analysis; Section F.1.a.should.
provide detailed. instructions-for measuring the dose: rates around the
- shielded and/or unshielded sample; and depending on the dose rate measurements, various methods and special1 handling tools for removing the sample container: cap or otherwise extracting the diluting the sample' should be specified.
-RESPONSE
. Procedure BCP 800-8 will4be1 expanded by in..ial criticality.
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. LIMPROVEMENT ITEM #33
' Procedure BCP-800-1 should be revised as follows:- valve and control
! identifications.in.the procedure should be identical to those on the sample panel; sections F.6 and F.8 should completely and correctly specify the valve alignments; sections F.7, F.8, F.9, and F.10 should
.. correctly. reference other steps in the procedure; movements between various panels should be clearly specified; and.the data tables
-referenced in sections F.7.e.
(7) and F.8.a (6) should be provided.
RESPONSE
Procedure BCP 800-1 is being revised.
Revision will be comriete by 4
initial criticality.
i IMPROVEMENT ITEM #34 BZP 100-T8 should be expanded to provide guidance.for determining the priorities of actions RCTs-should: implement should a limited number of
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personnel be available.
RESPONSE-
-Procedure BZP 100-T8 will be revised to provide priority guidance by
-initial criticality.
IMPROVEMENT ITEM #35 r
-An overall emergency' radiation protection procedure should be developed'which covers or: references'all actions necessary to implement j
.the radiation protection program during accident conditions; e.g.,-
i respiratory protection, radiation exposure' controls, exposure records, personnel dosimetry, priorities for assessment actions, decontamination limits,. criteria for use.of respirators and types to be worn, and criteria for use of protective; clothing.
' RESPONSE l-The concerns of this item are covered under' procedure BRP 1740-1.
further action is plunned.
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IMPROVEMENT ITEM #36 li preparedymessage should be available in the procedures for use when-
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announcing ~ assembly or evacuation on the plant paging' system.
RESPONSE
A' prepared message will'be included in the procedures for-use-when announcing assembly;or evacuation.
Implementation will occur-byLinitial p
criticality.-
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IMPROVEMENT ITEM #37 The evacuation siren should be periodically tested in order to familiarize plant workers with its sound.
RESPONSE
Testing of the evacuation siren, on a monthly basis, began on March 6, 1984.
Prior to sounding the assembly / evacuation siren an announcement is made stating the siren is in test and that no assembly is required.
IMPROVEMENT ITEM #38 A separate Search and Rescue procedure should be prepared, which summarizes all aspects of conducting an onsite search and rescue operation, including team composition, team briefing the debriefing, and responsibility for team direction af ter dispatch.
RESPONSE
A separate search and rescue procedure is not necessary.
The security force will have the last known location of the missing person.
The radiation chemistry technicians are trained in first aid.
When further search and rescue actions are undertaken through GSEP, they will be directed by the Station Director, with inputs from the Rad-Chem Director and the Security Director.
IMPROVEMENT ITEM #39 The site evacuation decontamination procedure, EG-10, should be referenced in BZP 310-4 and BRP 1470-1.
RESPONSE
Procedure EG-10 will be included in BZP 310-4 and BRP 1470-1 by initial criticality.
IMPROVEMENT ITEM #40 A copy of EG-10 should be placed in the Rock River Division Headquarters in Rockford, IL.
RE SPONSE A copy of EG-10 is in each field team's field kit.
During an cvacuation, a field team will be sent to the applicable relocation. center to perform monitoring as required by EG-10.
. IMPROVEMENT ITEM #41 BZP 380-2 should be revised to instruct the user to forward the completed BZP 380-Tl to the Rad / Chem Director.
RESPONSE
Procedure BZP 380-2 will be revised by initial criticality to instruct users to forward BZP 380-Tl to the Radiation Chemistry Department Director.
IMPROVEMENT ITEM #42 The contamination levels that require decontamination stated in BRP 1110-1 and BRP 1480-1 should be referenced in BRP 1470-1.
RESPONSE
Procedure BRP 1470-1 is being revised to reflect a standardized corporate procedure.
This standardized procedure does not incorporate contamination limits but rather, the method to be used for decontamination.
Additionally, all Radiaton Chemistry personnel are being issued wallet cards which summarize Byro Station radiological limits.
IMPROVEMENT ITEM #43 The contamination levels that require decontamination should be consistent between BRP 1110-1 and EG-10.
RESPONSE
Technical Services Nuclear Department has been informed of this discrepancy and will ammend personnel decontamination in EG-10 to match those in BRP 1110-1.
IMPROVEMENT ITEM #44 l
l A procedure that provides guidance in the treatment of casualties during an emergency should be developed.
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_. RESPONSE Procedures BZP 380-6 and BZP 380-2 address emergency treatment of personnel.
These procedures include priorities for first aid, treatment of shock, hemorrhage or life threatening conditions.
These procedures also address actions-to be taken if offsite medical attention is required.
All Radiation Chemistry Technicians are required to complete the National Red Cross mulimedia course in first aid as a part of their initiql training and are retrained on continuous basis.
Actual trectment of
- casualties is determined by the type of injury and the experience and training of the person administering aid.
IMPROVEMENT ITEM #45 Develop a procedure.for-repair / corrective action-activities to ensure that teams are briefed prior to dispatch into the plant on potential hazards, radiological considerations, and operations to be performed such that ALARA considerations are taken into account.
RESPONSE
An Operation Support Center Director Procedure is being developed to ensure team briefings.
This procedure'will be implemented prior to initial criticality.
IMPROVEMENT ITEM #46 Proposed procedure changes should be reviewed by-personnel involved z
in their implementation to ensure that'they are workable..Where a procedure affects the Shift Engineer,' input from these personnel on-the-proposed. change should be sought.
RESP 0MSE Procedures affecting different' departments are being given to all-relevant. departments for review.
IMPROVEMENT-ITEM #47-(.
The applicant should develop an audit procedure which~will provide guidance on all~ emergency. planning requirements'and.their location'in the
.GSEP, Site Annex, and 10 CFR sections,.and.will include the. current GSEP
. audit matrix.
This' procedure.should be flexible enough to allow the
. auditor to use professional 1 judgement in' developing the auditLquestions..
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RESPONSE
)
The e.uditing of GSEP functions does not dif fer substantively from that given in Quality Procedures 18-51 and 18-52.
We do not feel that a separate procedure is warranted.
However, in line with discussions with the Inspector, we agree that the present GSEP matrix, contained in Quality Assurance Department Memorandum #11, can be expanded in scope and depth to be more definitive.
Therefore, Quality Assurance will prepare a revised table for incorporation in that Memorandum identifying a broad coverage of the specific provisions to be covered In GSEP audits, including corporate program audits and audits or surveillances of drills and exercises.
The guidance embodied in the current audit matrix will be included.
The matrix will be utilized in such a way that each matrixed item will be audited at least once within a three-calendar-year period; for unique items applicable to individual sites, this schedule will apply independently for each site.
Corporate and generic items will meet a similar schedule.
The new table will be available within 60 days following the release of Revision 4 of the corporate GSEP, and it is any event expected to be completed by 9/4/84.
IMPROVEMENT ITEM #48 Procedure BZP 400-2, step 4.d should be revised to assign the Health Physics Foreman in the OSC specific responsibility to maintain an up-to-date record of emergency personnel absorbed radiation dose.
RE SPONSE Procedure BZP 400-2 will be revised to ensure that an up to date Lose record is maintained in the Operational Support Center.
This program will be implemented by initial criticality.
IMPROVEMENT ITEM #49 All operators should participate in operator seminar training to trace all required Control Room operator actions from initial detection through emergency classification, notifications, to finally make protective action recommendations.
This series of training seminars should be coupled with the required Acting Station Director procedural development.
RESPONSE
A procedure for the Acting Director has been written.
This procedure is being studied by the licensed operators during the retraining week.
This retraining week occurs on a 6-week cycle.
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