ML20094A449

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Responds to NRC Re Violations Noted in IE Insp Repts 50-272/84-10 & 50-311/84-10.Corrective Actions:Revised Emergency Plan Brochure Distributed in Feb 1984 & Emergency Response Training Program Undergoing Review & Evaluation
ML20094A449
Person / Time
Site: Salem  PSEG icon.png
Issue date: 06/08/1984
From: Liden E
Public Service Enterprise Group
To: Martin T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20094A428 List:
References
NUDOCS 8408030247
Download: ML20094A449 (8)


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..3 OPSEG l Pub! c Service Electric and Gas Company - P.O. Box 236 Hancocks Bridge, New Jersey 08038.

Nuclear' Department June 8, 1984 U.S. Nuclear Regulatory Commission Region'1 631. Park-Avenue King,of Prussia, PA 19406-Attentions.

Mr. Thomas T.' Martin, Director Division of Engineering and Technical Programs.

Gentlemen:

NRC COMBINED INSPECTION 50-272/84-10 AND 50-311/84-10 SALEM GENERATING STATION UNITS NO. 1 AND 2 DOCKET NOS. 50-272 and 50-311 During the subject inspection,. conducted from February 27 to March 2, 1984, one violation and five items of concern were identified on our emergency preparedness program.

PSE&G's response to these findings is as follows:

Item of Violation 10 CFR.50.54(q) requires that nuclear power reactors have and follow plans that meet the standards in 10 CFR 50.47(b) and the requirements of Appendix E to 10 CFR 50.

10 CFR 50.47(b)(7) requires that information is made available to'the public on a periodic basis on how they will be notified and what their initial actions should be in an emergency.

Section 8.1 of the Emergency Plan states in part:

The program for protective response information will be more specific in nature and will contain material on the followings 1)

Protective response options 8030247 840718 ADOCK 05000272

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L Mr.' Thomas T.

Martin 6/8/84 2)

Evacuation methods 3)

Methods of alerting and notification This information will be either updated and redistributed or verified to be in place at appropriate locations annually.

Contrary to the above:

Protective response information was neither updated and redistributed nor verified to be in place at appropriate locations annually during calendar years 1982, 1983.

Reply:

During calendar year.1982, the PSE&G Corporate Management structure was changed and the Nuclear Department was relocated from Newark, New Jersey to Lower Alloways Creek Township, New Jersey (Artificial Island), the site of the Salem and Hope Creek Generating Stations.

During the summer of 1982, a 42-day strike further compounded the situation.

The_ mailing of this brochure was inadvertently omitted during this period.

A revised Emergency Information Brochure was developed during 1983; this incorporated a new format with increased potential for retention and usage by recipients.

Mailing was planned for mid-1983.

However, unanticipated printing and address verification problems delayed actual distribution of the 1983 edition.

a.

Corrective steps which have been taken and the results achieved:

The 1983 revised Emergency Information Brochure was distributed in February 1984.

The 1984 edition will be issued in the fall of 1984 in conjunction with the annus1 emergency response exercise.

Actions to ensure that appropriate corrections and updated information as well as recommendation from State and Federal agencies would be incorporated into the 1984 version are proceeding toward a September or October 1984 mailing.

b.

Corrective steps which will be taken to avoid further violations:

To preclude the possibility of recurrence, the requirement to update the brochure annually has been added to the station's inspection order system.

g Mr.' Thomas T. Martin 6/8/84 c.

Cate when full compliance will be achieved:

We are now in full compliance.

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. Items of Concern Item 1 Provide specialized training to emergency response personnel by appropriate department heads in addition to training given by the Training l Department.

Reply:

As was discussed during the course of the inspection, the emergency response < training program is undergoing review and evaluation.

Following this review, which is intended to identify areas of weakness, the training program will be

_' modified in both form and content.

A more functionally oriented and need-to-know, hands-on program will be instituted.

This new program will contain 3

both emergency response position functional training and generic training for the entire emergency response organization.

Item 2

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a)

As presented in a letter to the NRC (7/30/81) incorporate the following items in Salem's Emergency Plan and

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Procedures.

1)

An outline of the moteorological monitoring program with thesuppropriato reference to the complete description in FSAR section 2.3.3; 2)

A description and procedure for remote interrogation Li

'- of the meteorological monitoring systems and i

3)

Uso of 15-minute computer generated average meteorological monsuromonts in dose calculations.

b) 1)

Develop a more realistic method to classify elevated

-rdleases based on source characteristics, actual s

R meteorological conditions, release height and building wake effects.

One method that is recommanded can be found in NUREG/CR-2521, Methods for Estimating Wake

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Mr. Thomas T.-Martin 6/8/84 2)

Develop site specific correction factors for interpolating-meteorological measurements to a more representative-level for use in dose cilculations during elevated ~ atmospheric releases.

Reply:

2.a.1 The Emergency Plan -and Procedures will be revised to include an ' outline of the meteorological monitoring program with appropriate references to UFSAR Section 2.3.3.

This update is scheduled for completion by August 31, 1984.

2.a.2 A. final draft of the description and procedure for remote interrogation of.the-meteorological monitoring system has been prepared and is currently in review.

Final procedures and user training will be accomplished by August 31, 1984.

2.a.3 Use of 15-minuto computer-generated average meteorological measurements in dose calculations are included in 2.a.2 above and Emergency Plan Imple-menting Procedures.

Final procedures and user 4

training will be accomplished by August 31, 1984, 2.b.1 Building wake effects are provided in the interim dose assessment code on the upgraded meteorological monitoring system communications computer (DEC 11/23).

The calculation of near field atmosphere dispersion around structures is a very complex problem

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depending on many variables.

Treatment of this phenomenon is inappropriate for hand calculations.

The present dose assessment procedures provide for the wake ef fects caused by the containment structure from ground level releases (i.e.,

releases in the influence

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of the containment).

The modeling of this wake effect is consistent with the guidance in USNRC Regulatory Guide 1.45 and Meteorology and Atomic Energy, 1966 The regulatory position of USNRC Regulatory Guide 1.111 defines elevato/ releases as

... effluents exhausted from release points that are higher than twice the height of adjacent solid structures...", and ground level as "... points less than or equal to the height of adjacent solid structures...".

For manual J

dose calculations or incorporation of manually entered meteorological data into the existing computerized f

gaussian model, a simplified default method will be

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used to minimize user confusion.

All releases except plant vent releases with prevailing stable meteorology will be considered ground releases for the sake of P

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Computerized' methods for' treatment of

, wake 'effect will be provided by Public Service in the, development.of an extended model'as described in our-

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response) to Item 4.a' of this document.

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3'A Site specific correction factors will be developed by PSE&G for inclusion in the. refined dispersion model jdescribsd in=our re.ponse to Item 4.a of this

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Item 3

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'a)- Amedd the Salem Uniti 2 Technical Specifications in

.T7 Appendix B, 3.1 Nonradiological Surveillance to a Standard Appendix A, Technical Specification as

_FL writt'en for Unit 1, Section 3.3.3.4.

1) : Adapt more stringent internal I&C (Instrument and Calibration) procedures for acceptable channel checks.on the: meteorological parameters and Edisplays.

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3.a.1 The Salen' Unit 2 Technical Specifications will be amended to. include the channel checks on the meteorological parameters and displays, as outlined in 6

Unit 1 Technical Specifications.

Submittal to the NRC f

will be by October 1,.1.984.

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Implement a more refined dispersion model for use in the/ EOF.

Consider recommendations made in Appendix 2 i

j of t40 REG-0654 for model capabilities.

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Identify lhe height-of the mixing layer as a fanction of~ season and mesoscale circulation and include this ej information in the more refined dispersion model.

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Provide a copy of the data comparison done between the i.

Splemisite meteorological data and the PSE&G Ouinton

((;4 Training Facility, installed on February 13, 1981.

Discuss how this information will be included in j.

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' r" emergency.r;esponse planning and implementing 7, > procedures,for dose assessment.

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Mr. ' Thomas T. - Martin. 6/8/84
Reply:
4.a

- Public' Service lElectricE& Gas Company. is currently in the f procurement process' for obtaining a refined-dispersion model for emergency' dose assessment.

._Onsite1 bidder _ demonstrations have been conducted and all bids have.been received.

Bids are currently under

. evaluation by the. appropriate user groups.

The

- contract--for this dose model acquisition _is expected to be. awarded by-July-1, 1984.

A functional i

, description of ~ he' model will-be submitted to.the NRC by December 1, 1984.. We are targeting.t'o have the

- model up and-running by the date.of the scheduled annual 1 exercise: ( Oci.. 23, 1984).such that the NRC team can observe its use.

The model which will be. procured will be a ; variable trajectory or puff type model which will incorporate features such.as building wake ef fect and the height of the mixing layer.

4.b Th'e treatment of these and other complexities with' respect to dose and _. dispersion assessment will be treated in th^ upgraded dose assessment model described-in 4.a.

4.c The meteorological monitoring system at Quinton was installed - to support the old emergency operations 4

facility in Ouinton and was not originally intended to be used for comparison of data with the primary meteorological monitoring system on site.

Data capture for the Quinton system was far below the 90%

- data recovery rate suggested in NRC RegulatoryL Guide 1.23.

Because data from Quinton cannot be used for comparison, incorporation of the results of such comparison into emergency response planning and implementing procedures for dose assessment would not be meaning ful.

PSE&G has previously performed meteorological data comparisons in response to condition 24.d.iii of the Salem Unit 2 OL.

PSE&G shall provide sabstantiation that the backup source of meteorological information from the NWS office, Greater Wilmington Airport, adequately characterizes the site conditions with respect to wind direction and wind speed by July 1, 1981".

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Mr. Thomas T.

Martin 6/8/84 This response was provided in a technical report transmitted by letter dated June 30, 1981 (R.

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Mittl to F.

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Miraglia).

This report compared data from the onsite meteorological system with data from the NWS office, Greater Wilmington Airport and a limited amount of data from the Delmarva P&L Summit site, located approximately 10 miles-NW.

The comparisons did not1 indicate a complex meteorological situation.-

Item 5:

Consider additions _and changes to the emergency plan as shown in paragraph 3.h of the inspection report.

Reply:

Revisions to the Salem Generating Station Emergency Plan will include provisions for all of the items contained in item 3.h of the Inspection Report with the exception of items 3.h.21 and 3.h.22. - These revisions to the Emergency Plan have a scheduled completion date of August 31, 1984.

Item 3.h.21 concerned a description of the training for the individual responsible for the emergency planning ef fort.

PSE&G's position on this item is adequately provided in our letter (P. W.

Schneider to Mr.

B. H.

Grier) dated June 18, 1981 (attached).

This response is considered to fulfill the requirements of Planning Standard P1 of NUREG-0654.

Item 3.h.22 is a request that the Emergency Plan include an appendix that lists by title procedures required to implement the plan.

Table 1-2 of the Emergency Plan contains this information Sincerely, L

E. A.

Liden Manager - Nuclear Licensing and Regulation Attachments

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IMr. Th'oma s T. 'Ma r t i n 6/8/84 C.

' Mr. Donald C.

Fis'cher w/ attach.

' Licensing Project-Manager f

Mr.. James Linville w/ attach.

Senior.. Resident Inspector

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u 201/430-7373 Public Service Electric and Gas Company 80 Park Plaza. Newark, N.J.07101 Fredeeisk W.Sohneider v m Preement Julie 18,1981 Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region.I 631 Park Avenue King of Prussia, PA 19406

Dear Mr. Grier:

RESPONSE TO EMERGENCY PREPAREDNESS APPRAISAL (APPENDIX A AND B)

MARCH 23 - APRIL 2,1981 SALEM GENERATING STATION DOCKET NOS. 50-272 AND 50-311 We have reviewed the results.of your Appraisal which was conducted on March 23 - April 2, 1981, and transmitted with 19, 1981.

Our response to the Appendix A your letter of Mayand B items is attached as Enclosures 1 and 2 respectively.

The response and implementation of the Appendix A items were reviewed and found to be responsive by Mr. Dale Donaldson of A revised Salem Emergency Plan and Procedures your staff.

I which z.eflects our overall response to the Appraisal was submitted to the U.S. Nuclear Regulatory Commission on May 26, 1981.

We feel that our Emergency Treparedness Program including the commitments and programs described in Enclosure 1 provides for an adequate state of on-site emergency preparedness as required by 10 CFR 50.47 (a) (2).

If you have any further questions concerning this matter, please feel free to contact me.

sincerely, I

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' 6/1B/81 Mr. Boyce H. Grier, Director U.S. Nuclear Regulatory Commission

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BCC k.P. - Production Const. Mgr. Pr'ojects

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V.P. - Engg. & Constr.

Mgr. - Hope Creek

'J Asst. V.P. - Elec. Prod.

Mgr. - Salem Station Chief Controls Engr.

Genl. Mgr. - Const.

Chief Electrical Engr.

Igd Genl. Mgr. - Corp. Qual. Assur.

Chief Mechanical Engr.

Genl. Mgr. - Engg.

Chief Structural Engr.

Genl. Mgr. - Fossil Prod.

Genl. Mgr. - Lic. & Environm.

Asst. General Solicitor k

G.enl. Mgr. - Nuc. Production Engg. Department Coordinator Resident NRC Inspector-Salem Genl. Mgr. - Prod. Support Genl. Mgr. - Research & Testg.

Station QA Engineer-Salem Lab.

On Site Safety Review Group-Salt Mgr.,- Emergency Preparedness Sr. Nuc. Training. Supv.-Salem Mgr. - Nuc. Opers. Support NRB (2)

Mgr. - Salem Projects Salem Simulator Project -

Controls Division Attn: I. Weissman (2)

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. ENCLOSURE.1 RESPONSE TO EMERGENCY PREPAREDNESS APPRAISAL

) APPENDIX A The Manager - Emergency Preparedness has been given the Item 1 direct working level responsibility and authority over all aspects of the development and maintenance of the A description of this Emergency Preparedness Program.

authority and responsibility is given in Section 18 of the Emergency Plan (Revision 0).

Section 3 of the Emergency Plan has been revised to Item 2 reflect functional areas of the emergency activity, reporting chains and interrelationships for functional areas down to the working level.

New functional descriptions, job descriptions and organization charts A cross reference to Table B-1 of have been added.

NUREG-0654 has also been provided.

The Assistant to Manager - Salem Generating Station has Item 3 been charged with the responsibility of maintaining a list of qualified individuals who perform emergency Addendum 1 currently lists those planning activities..

individuals who are assigned specific on-site emergency Update training was completed on response functions.

May 15, 1981 and as a result a revision to Addendum 1 will be made.

Figures 3-1, 3-2 and 3-3 of Section 3 of the Emergency Item 4 Plan show how the Radiation Management Corporation and the Salem Memorial Hospital report into the Emergency Response Organization.

Other support

  • organizations will be directed to report to the Site Support Manager (shown in Figure 3-3) for reassignment to other in-dividuals within the Emergency Response Organization.

These assignments will be made on a case by case basis and in accordance with the services to be provided.

Section 4 of the plan identifies off-site support organizations.

The various administrative off-site support groups are listed in EP II-6.

Section 3 of the Emergency Plan contains a functional Itam 5 descripti'on of each position noted on the Organization The candidates to fulfill those positions are Charts.

noted as a part of the functional descriptions.

EP II-4 contains a list of those corporate individuals who are qualified to perform emergency response functions.

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-) Item 6 A new Emergency Preparedness Training Program is presently under development and will be completed byThis trai September 1, 1981.

lesson plans, training objectives, and means for verifying attendee performance and the means to train the emergency organization in changes of assignment or responsibilities.

Short term training has been provided to individuals assigned Fmergency Preparedness duties and records of Item 7 this training are available at Salem Generating Station This training fell-into three for NRC inspection.

categories, initial emergency preparedness training of approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> duration, emergency prepare and Operations Support Center training of-approximately Training in accordance with the l-1/2 hours duration.

training program being developed under Item 6 noted i

above will be completed by January 1, 1982.

1 The conceptual use and staffing of the TSC has been Item 8 reviewed in light of the organization described in Section 3 describes Section 3 of the Emergency Plan.

the transfer of the various emergency planning functions from the normal on-shift. organization (Control Room) to Center and then to the Emergency

.J the Technical Support Section 9 of the Emergency Plan Operations Facility.

gives a description of the facilities available at the

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l TSC.

The Operations Support Center has been reevaluated in Item 9 light of the organizational changes and the location in the aisleway between the two Control Rooms has been I

If increased staffing is required, found to be adequate.

the function of the Operations Support Center will be transferred to the Machine Shop in the Clean Facilities l

. Building (B Building).

An OSC coordinator, described in Section 3 of the Plan, will direct the operations of EP I-19 details the activation of this the OSC.

facility.

The Emergency Operations Facility and its conceptual Itam 10 use and staffing has been reviewed in light of the Section 3 of the Emergency organizational changes.

Plan describes this functional use and staffing and Section 9 describes the facility itself.

This new organization reflects the overall coordination of response consistent with NUREG-0654.

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-} Item 11 vent samples.

collected with the Interim High Level Sample Syst 22, 1981 via Porter Consultants analysis dated April (entitled " Sample Line Plateout Factors for Particulate

& Halogens In the Interim High Level Sample System").

Implementation of this plateout information will be via a revision to EP V-2.

Assembly / Reassembly areas for individuals w Item 12 augment the on-site response organization have beenT reevaluated.

parking lots or Quinton Township School.

Provision for supplies and equipment for decontainating persons and vehicles evacuated from Salem and H Item 13 As a result of the reevaluation of the Operations Support Center, it has been determined that no additional Item 14 equipment is needed in the OSC to support repair andThese corrective action teams.

necessary equipment'for performing their functions from If radiation protection their normal duty stations.

and/or habitability equipment is needed for thesete J

quantity.

The Salem Generating Station Emergency Instructions have been appropriately revised to direct the operators Item 15 t'a. reference the new Accident Classif,1catien Guide in This Accident Classification Guide then directs the operator to take emergency actions under EP I-0.

The Emergency Procedures EP I-l through EP I-4. Accid Appropriate on the spot changes of the Emergency Plan.

to specific Emergency Instructions have been made.

The emergency action levels have been reviewed and a new Accident Classification Guide in EP I-0 has been Item 16 developed which provides clear, readily observa Direction to proceed to the Accident or exceeded.

Classification Guide is given in the Salem Generating Station Emergency Instructions.

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4-Emergency procedures have been developed for the

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Item 17 Emergency Response Manager EP II-1, Site Support Manager EP II-2 and the Radiological Emergency Manager EP II-3 which are the three primary functions. associated with making recommendations for protective actions to i

off-site authorities from the Emergency Operations These procedures describe how functions are Facility.

transferred from the Technical Support Center to the Procedure EP II-4 has Emergency Operations Facility.

been implemented for calling in all corporate licensee personnel having emergency duties associated with the Call in procedures for Emergency Operations Facility.

station personnel are contained in EP I-l through 4.

The call in list is contained in Addendum 1.

Protective Action Guides have been developed that Item 18 correlate certain plant conditions directly with EALs.

This procedure, EP I-4, Attachment 5, gives actual distance and sector protective action recommendations based upon plant conditions and wind direction.

Procedures for containment air sampling under accident condition using interim equipment have been developed Item 19 and are EP IV-121 for Unit 1 and EP IV-122 for Unit 2.

A new Evacuation Procedure for personnel at the Item 20 This Salem and Hope Creek sites has been implemented.

(Table V) takes into account the new procedure EP I-12 single access road and provides the option for evacuating personnel to other areas on Artificial Island based upon meteorology and projected dose.

Personnel and vehicles evacuated from the Salem / Hope Item 21 Creek sites requiring monitoring and decontamination will be accommodated at a decontamination facility run Procedures for by the State of New Jersey in Quinton.

the operation of this facility arc provided as a part of the New Jersey Radiological Emergency Response Plan.

Salem Emergency Procedures are available for backup to Evacuation will be in the State procedures if needed.

accordance with EP I-12 and any decontamination conducted

-119 by Salem personnel will be in accordance with EP and EP IV-120.

A new section of the Emergency Plan Procedures with 5 l

Item 22 procedures has been provided to account for the actions of the Security Force under emergency conditions.

These procedures cover activation of the TSC and EOF, station accountability, site evacuation and communication equipment and are referenced in EP I-21.

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' Procedure EP I-17 has been developed and incorporated 3

Item 23 into Emergency Plan Procedures and governs emergency actions of the repair and corrective action teams.

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This group is described functionally in Section 3 of the Plan.

Procedure EP VI-l has been developed and incorporated into the Emergency Plan Procedures for reviewing, Item 24 approving, and distributing the revisions to the documents comprising the Emergency Preparedness Program This procedure insures proper and its implementation.

review of all revisions in accordance with the Facility Maintenance and scheduled Technical Specifications.

review of the Emergency Preparedness Program documents is accomplished in accordance with Section 18 of the Plan.

The Salem Emergency Plan and Emergency Plan Procedures have been reviewed by the Station Operations Review Item 25 Committee and Manager - Emergency Preparedness.

Subsequent to this review it was determined that the Manager -Salem Generating Station had not reviewed and signed approval of the SORC meeting recommendation due This deficiency was to an administrative oversight.

4 immediately corrected.

In the future, the Manager -

7 Salem Generating Station will sign each Procedure and EP VI-l will be Plan Section prior to implementation.

revised to insure proper approval signatures prior to 3

implementation, (Director of Site Operations)

The interface between the NRC j

Item 26 and the PSE&G Emergency Organization is shown on the l

Emergency Organization Charts in Section 3 of the The Emergency Response Manager who is i

Emergency Plan.

located in the EOF has responsibility for overall direction and control.

All NRC interactio.1 will be coordinated at this level.

Information regarding actions to be taken by individuals Item 27 within the Emergency Planning Zone during a radiological I

emergency has been distributed to individuals within Similar the Plume EPZ in the State of New Jersey.

information tailored to the State of Delaware will be given to the State for distribution.

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) ENCLOSURE 2 i

' RESPONSE TO EMERGENCY PREPAREDNESS APPRAISAL APPENDIX B It is not intended at this time to develop or implement Item 1 a selection and qualification criteria specifically for individuals performing emergency preparedness activities.

Personnel assigned to perform these' activities meet the corporate selection criteria for employment with the Company.

It is not intended at this time to develop a specific Item 2 structured program for training individuals who are As training assigned emergency planning responsibilities.

programs, seminars or other meetings which pertain to emergency preparedness become available, Company personnel who are assigned emergency preparedness developmental and/or implementation functions may be given the opportunity to attend.

Attendance at such programs or meetings will be based upon the individual's specific function and relevance to the material being presented, the availability of the individual's time and the cost associated with the program.

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Item 3 Training will be documented by use of a training matrix.

This matrix will indicate what training each Functional Title will be given.

In addition, the Assistant to the Manager will develop and maintain records that will list each Function and the names of those individuals qualified to perform the Function as well as the training they have received.

This item will be initiated by September 1, 1981.

i Item 4 We will continue to use individuals who are familiar with the Emergency Plan and Procedures as instructors.

We do not anticipate d9veloping specific criteria for qualification of emergency preparedness instructors.

Item 5 The habitability and accoustics of the interim TSC located on the third floor of the Clean Facilities Building are considered acceptable until the interim TSC is moved to a new location on the second floor of the Clean Facilities Building.

This change in location is necessary to permit construction of the ultimate TSC in the location where the interim TSC (third floor of Clean Facilities Building) now exists.

The location of the new interim TSC on the second floor of the Clehn Facilities Building should afford somewhat better accoustics because it contains an accoustical tile ceiling.

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Item 6 This modification the TSC.

telephones will be located in this area.

l will be accomplished as part of our TSC_ upgrade program.

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The present computer displays are part of the inter Item 7 by an emergency response facility data system. Consideration i

TSC.

l will be given to providing units for plant parameters in l

our proposed data system.

l The present computer displays are part of the inte Item 8 Consid-TSC.

by an emergency response facility data system.eration display capability in our proposed data system.

Existing procedures will be revised to provide for staffing the Technical Document Room with appropriately Item 9 These revisions will be included qualified personnel.

The in Revision 1 to the Emergency Plan Procedures.

procedural improvements of Revision 0 of the Emer data transmission outlined in Items 7 and 8 above should provide improved data transmission.

A system to provide' multiple high radiation liquid Item 10 and gas samples during normal and post accident conditions has been selected and shall be installed by January 1, 1982.

The necessary post accident reactor coolant sample 4

analytical supplies are now stored in a designated area in Item 11 The supplies shall be periodically the chemistry lab.

The inventory will be requested by an inventoried.

inspection order card as described in Station Administrative Procedure AP-10.

The equipment for obtaining the remote plant vent and Item 12 It is stored containment sample has been assembled.

in the emergency locker at the control point.

The representativeness of post accident containment air samples has been determined empirically from actual air Item 13 An insufficient Iodine source term was present samples.

in the containment at the time of the sample and a correction factor for Iodines will be determined when Until a specific value is the source term is adequate.

obtained the particulate correction factor will be used for Iodines.

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The locaticn of tha oparationa Support Conter ir. tha hallway

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between the two Control Rooms has been'found acceptable Item 14 in light of the new organization described in Section 3.0If additio 3

of the Emergency Plan.

assemble support personnel, provisions have been made to

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use the Machine Shop in the Clean Facilities Building.

PSEEG has received separate correspondence from the U.S.

Nuclear Regulatory Commission dated May 5,1981 which Item 15 Our requests that we address the " bay breeze" question.

response to this May 5, 1981 letter will be provided by July 1, 1981.

Information on severe weather varnings or watches isThis Item 16 announced via the National Warning System (NAWAS).

system is monitored in the Senior Shift Supervisor's office.

Procedures EP I-1, EP I-2, EP I-3 and EP I-4 are being reviewed to determine where it may be necessary to include Item 17 references to appropriate procedures, be more specific on who is responsible for implementing the procedurgs and identify which responsibilities can or cannot be delegated by the person performing the duties of the Emergency These changes will be made in Revision 1 Coordinator.

to the Emergency Plan Procedures.

Procedures have been reviewed and, where necessary, Item 18 These telephone numbers will be. referenced or included.

changes will be made in Revision 1 to the Emergency Plan

'j Procedures.

EP I-1, EP I-3 and EP I-4 will be revised to provide Item 19 These for notification of the NRC Resident Inspector.

changes will be unde in Revision 1 to the Emergency Plan Procedures.

It is not necessary to provide for an ' automatic activation Item 20 of the TSC in response to a Radiation Alert Alarm.

i The Emergency Plan Procedures EP I-2 thru 4 require an announcement over the public address system of " Radiation protection personnel report to your emergency duty stations."

and a proceeding step in the procedure requires the Senior Shift Supervisor /EDO to verify activation of the TSC by the Shift Technician - Nuclear.

i Item 21 The Health Physicist and Radiation Protection Engineer will review existing procedures and incorporate additional discussions, where necessary, to provide for integration and prioritization of assessment data.

This review will be completed prior to Revision 1 to the Emergency Plan Procedures.

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. Itcm 22 the timeliness for manuel does oneGment Amprovad in Revision 0 to the Emergency Plan Procedures.

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Item 23 Procedure PD 15.12.315 has been incorporated into the station emergency procedures and is now referred to as f

EP IV-110.

The dose data tables were corrected and included in Revision 0 to EP IV-110.

Item 24 Procedure EP IV-110 (previously PD 15.12.315) has been reviewed with the following results:

i Radiation Protection guidance provided in Revision 0 a.

is considered adequate.

The flow of information between the TSC and-the b.

survey teams by radio is now discussed in the procedure. Documentation of survey results is achieved through the use of an emergency survey log which is included as an attachment to the procedure.

The procedure will be revised in Revision 1 to include returning the samples to the counting room, for logging and storage.

The new onsite survey points were included in c.

Revision 0 to the procedure.

Item 25 The procedures governing routine surveys (dose rate, con-l j

tamination and air sampling) were reviewed and will be i

i revised in Revision 1 to the Emergency Plan Procedures.

l l

The seemingly long time required to aquire the primary Item 26 j

coolant sample which was observed was because the available radiation protection personnel were assigned to higher priority activities while the plant was brought to j

a safe condition. It is felt that the sample was conducted i

in accordance with the priority assigned to it at the time.

l Item 27 We have not previously noted problems communicating with Control Room personnel during sampling drills.

However, we will review communications requirements during primary sampling and install equipment or revise procedures if necessary by January 1, 1981.

Item 28 Procedure EP V-1 " Interim Post Accident Primary Coolant Sampling" (Rev. 0) requires verification that the following are obtained or achieved prior to initiating the sampling Process:

1) availability of the proper survey meters,
2) use of protective clothing, 3) appropriate respiratory device, 3) dosimetry and 4) worker briefings.

The details on specific protective measures and briefings are identified in EP IV-106 "Alara Task Review" (Rev. 0).

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An alternate counting fccility is located in tha

-Item 29 radiation protection office' area beyond the Control This item is addressed in the procedure for primary Point.

coolant sampling (PD-3.8.032) and will be included in the 3

next revision to the procedure for sample analysis

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(PD-3.5.071).

The dissemination of the containment air sample Item 30 analytical results is provided in Emergency Plan Procedure EP IV-ll8 "High Activity Sample Analysis" (Rev. 0) which requires that the person performing the analysis notify both the individual requesting the analysis and the Alara/ Dose Assessment Supervisor of the results.

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Item 31. The necessity to verify containment vent flow rate will be reviewed further to determine the necessity for flow rate verification.

The transportation of post accident plant vent samples will be reviewed and equipment provided where required Item 32 by January 1, 1982.

Procedure EP V-2 " Emergency sampling procedure for the Item 33 (Rev. 0), currently. includes a precaution plant vent" statement identifying the hazards of high contamination and high dose rates. Additionally, procedure EP IV-106 "Alara Task Review" is listed as a prerequisite.

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Item 34 Radiation Protection precautions for high activity post accident plant vent sample analysis is provided in Emergency Plan Procedure EP IV-ll8 "High Activity Sample Analysis" (Rev. 0).

An organization for receipt and distribution of analytical results and the administration of original data sheets has been agreed upon and will be included in Revision 1 to the Emergency Plan Procedures.

Item 35 Upon review of the data by a Chemistry' Supervisor, the data will be presented to the Radiation Protection Engineer /

Designee.

Original data sheets will be retained (during the emergency) by the chemistry group.

Copies of the plant vent analytical results will be transmitted to the Radiological Emergency Manager for his use during an emergency.

Chemistry procedures will be revised to show this routing in Revision 1 to the Emergency Plan ProceduresSection IV.

Item 36 An EAL will be provided which will interface post accident plant vent sample analytical results.

This EAL will be provided in Revision 1 to the Emergency Plan Procedures.

An interface between the post accident analytical results and protective action recommendations is currently provided in Emergency Plan Procedure EP I-12 (Rev. 0).

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d in Revioion 3 to the Precautions and prcrcquoitoo for cnliquid efflue 5.071).

Itcm 37 sample analysis procedure (PD-3. i i g is provided for all This training

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Emergency Plan implementation tra n ntal training programs tation.

pcrsonnel badged.for access.to the s This' program Item 38 program and the individual departmen site.

h provide direction on evacuation of t ef the station is diation protection 9,~.

coupled with direct guidance from ra

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1 nel from these f

s personnel in the Controlled Areas o considered adequate to. direct person event of an evacuation.

areas in the accident class Procedures will be revised to addressThe criteria is appropriate de' escalation and event termination.used I

Item 39 h

will be the plant observables of t e will be fication Guide.

ovided for the The " kitchen card" which has been prbeen placed in States of Delaware and New Jersey hasThese " kitchen car Item 40 taken by the press kits.information on protective actions to be the Public.

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