ML20098G252

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Forwards Draft Page Changes to Emergency Plan as Discussed in Emergency Preparedness Appraisals 50-352/84-18-10 & 50-352/84-18-32.Changes Will Be Incorporated in Rev Scheduled for Oct 1984
ML20098G252
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 09/26/1984
From: Daltroff D
PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To: Murley T, Schwencer A
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), Office of Nuclear Reactor Regulation
References
CON-#484-237 OL, NUDOCS 8410040240
Download: ML20098G252 (9)


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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 FHILADELFt'.l A, PA.19101 SHIELDS L. DALTROFF sulcEU'.*clEEo September 26, 1984 Re Docket Nos. 50-352 50-353 Dr. Thomas E. Murley I

Region I Office of Inspection & Enforcement U. S. Nuclear Regulatory Commission t

631 Park Avenue L1 King of Prussia, PA 19406 7

Mr.-A. Schwencer, Chief Y,.

Licensing Branch No. 2 b

Division of Licensing F

U. S. Nuclear Regulatory Commission

' Washington, D. C.

20555 I

Subject:

Limerick Generating Station

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Units 1 & 2 Emergency Plan Revision e

Reference:

Appraisal No. 50-352/84-18 Letter dated August 14, 1984 h

T. T. Martin to J. S. Kemper I'

Gentlemen

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Enclosed are draft page changes to incorporate plan changes as discussed in Emergency Preparedness Appraisal 50-

'352/84-10-10 and 50-352/84-18-32.

These changes will be

' incorporated as indicated in the revision scheduled for October

-1984.

In response to 50-353/84-18-04, Philadelphia Electric has designated the Technical Eng'ineer as the secondary alternate for the Emergency Director.

This plan change will be reflected In the plan changes addressed in 50-352/84-18-03.

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i Dr. Thomas E. Murley Page 2 l

If you have any questions regarding this, please contact us.

Very truly yours, gWnal signed by 3, g;, DAl.TROFF l

l Attachment

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Site Inspector-Limerick Generating Station'!

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See Attached Service List Document' Control Desk U.~S.

Nuclear Regulatory Commission Washington, D. C.

20555 L

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cc: Judge Lawrence Brenner Judge Peter A. Morris

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- Judge Richard F. Cole Judge Christine N. Kohl Judge Gary J. Edles Judge Reginald L. Gotchy Troy B. Conner, Jr., Esq.

Ann P. _ P, Esq.

Mr. Frank R. Romano Mr. Robert L. Anthony Ms. Maureen Mulligan Charles W. Elliott, Esq.

Zori G. Ferkin, Esq.

Mr. Thomas Gerusky Director, Penna. Emergency Management Agency Angus Love, Esq.

David Wersan, Esq.

Robert J. Sugarman, Esq.

Martha W. Bush, Esq.

Spence W. Perry, Esq.

Jay M.' Gutierrez, Esq.

Atomic Safety & Licensing Appeal Board Atomic Safety & Licensing Board Panel

. Docket & Service Section James Wiggins Timothy R. S. Campbell t

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Attachment LGS EP

(r R.O MAINTAINING iMERGENCY PREPAREDNESS Personnel and ecui. nment shall-he saintained in a state of preparedness to ensure that the provisions of this Eneroency Plan and implementinn procedures can he accomplished in energency conditions.

This seccion describes the means to achieve and maintain this praparedness and the means to maintain this Emergency Plan and imolementing procedures.

Personnel are assigned, in this Emergency P.lan, to emergency organization positions in a manner to benefit from their i

previous experience and training and from the expertise needed in their normal responsibilities.

Therefore, cualification to assume an emergency organization position is met by virtue of holding the designated position in the Corporate or plant staf f organizatior and by completion of the training required ly Table 8-1.

R.1 ORGANIZATIONAL PREPA."tEDNESS R.l.1 TRAINING i

The objectives of training are:

gl a)

To familiarize personnel with the contents and M

manner of implementation of the Emeroency Plan and the implementing procedures; E

b)

To train personnel with respect to the performance of the specific duties assigned to them ir the Emergency

' Plan and in applicable implementing procedures; A

c)

To keen personnel informed of any changes in the Emergency Plan and the implementing procedures; and d)

To maintain a

high degree of preparedness at all levels of the Emergency Plan response organization.

To accomplish these objectives, the initial training and periodic retraining described in Table R-1 shall be performed.

Many emergency response positions filled by corporate support personnel use the same individuals for both Limerick and Peach Bottom Atomic Power Station.

In such cases, training credit for tasks and functions which are common to both plants may be coordinated.

Functions which'are unique to Limerick will be covered in coordinated pro pams or specific sessions for Limerick will be used.

Training and qualification forTechnician,[4pos $ ions, such as job Licensed

Operator, Chemistry Health Physics

-l Technicianr ;nd Cancral-Employee-T-rai-ningC/are recognized as a

base upon which the speci fic Emergency Plan training described in Table R-1 may be built.

Practical training

! R-1 Pc J.

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Attachmant 4

LGS EP and hands-on demonstration of required skills are parts of the training and qualifications for job positions.

Where such skills are used in both routine and emernencv functions, skill demonstrations are not covered in Table O-1.

CCm.Jfg Training of local support service personnel (ambulance, physici ans, and fire company) who may enter the site to 1-perform emergency tasks is nrovided hv Philadelphia Electric Company.

This training is also described in Table R-1.

8.1.2 DRILLS AND EXERCISES Emergency drills and exercises have the following objectives:

a)

To test the adecuacy of the ef fectiveness, timing, and content of implementing procedures and methods; b)

To test

' emergency eauipment and communication networks including the public notification system; c)

To ensure that the emergency organization personnel are familiar with their duties and responsibilities.

Drills and exercises will be conducted as realistically as is reasonably possible.

Preplanned descriptions or scenarios for-drills and exercises will be prepared to define the objectives and methods and to form a

basis for evaluating adequacy of performance.

Scenarios will identify the simulated events, describe the expected response by the emergency ' organization including a

secuence of events or timing if applicable, and provide for observer (s).

Advance

material, information, or training to be provided to of ficial observers and evaluators will be noted.

Scenarios may be develooed in such a manner as to accomplish more than one p.eriodic requirement.

For examp? e, an annual emergency exercise scenario may include a simulated radiation / medical casualty

and, therefore, fulfill two exercise / drill l provisions.

Scenarios for annual exercises are submitted to l NRC for review of adequacy of scenario and expected l response, i

Records of exercises and drills, including dates, times, places,, and participants as appropriate, shall be developed i

and maintained.

Critiques of exercises and drills will be held and written evaluations will be prepared.

Federal and State obs ervers or evaluators will be invited to critiques of exercises in which they participated as observers or evaluators.

As indicated by evaluation,

weak areas in training, procedures, or equipment will be identified in the

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written evaluation.

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8-2

Attachment Insert No. I General Employee Training (CET) provides annual training for those persons needing unescorted plant access and covers:

fire prevention / protection; fire and medical emergencies; evacuations.

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'dttachment LGS EP k

h TABLE 8-1 (Page 1 of 9)

INITIAL TRAINING AND PERIODIC RETRAINING INITIAL TRAINING AND PERIODIC PERSONNEL CATEGORY / POSITIONS RETRAINING 1.

Directors of plant

. Initial Trainino:

Instruction emeroency organization:

in scope, organization, respon-

. Interim Emergency sibilities, and functions of Director and Emergency this Emergency Plan and Director associated implementing Station Superintendent procedures'.

Command authority, Assistant Station emergency classification, and Superintendent communication / notification Shift Superintendents methods are emphazised.

Shift Supervisors (Federal, State and County Annual Retrainino: Review of emergency management areas covered by initial coordinators are invited training with emphasis on to attend changes in the Emergency Plan

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and associated implementing procedures since the previous training period.

2.

Personnel responstble Initial Trainino:

In addition for assessment

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to the topics listed under activities and plant Initial Training for Item 1 technical supports above, initial training will

. Station Superintendent emphasize the instruments and Assistant Station implementing procedures used Superintendent for projecting radiological Engineer-Operations consequences. Activation of Engineer-Technical the various emergency centers Senior' Chemist and control of radiation l

Senior Health survey teams are included.

Physicist Applied Health Physicist Support Health Physicist

-Shift Superintendents Annual Retrainino: Review of Shift Supervisors areas covered by initial Shift Technical Advisors training with emphasis on changes in the Emergency Plan, associated implementing procedures, and equipment associated with assessment since last training period.

10 bSV Il Rev.' +9, 99/9f-

LGS EP TABLE 8-1 (Cont'd)

(P go 9 of 9)

INITIAL TRAINING AND PERIODIC

, PERSONNEL CATEGORY / POSITIONS RETRAINING

13. Chemistry Samplino and Initial Trainino: Activation Analysis Team:

and notification.

Sampling Senior Chemist and analysis equipment i

Assigned Chemistry Tech's and procedures.

Anticipated Assigned Plant Staff results under emergency members conditions.

Annual Retrainino: Same as Initial Training with emphasis on equipment and associated procedure changes since the last training period.

14. Operations Support Center Initial and Annual Training:

Coordinator:

Activation and purpose of the OSC.

Assigned Plant Staff Communications and record-members keeping.

Associated imple-Shift personnel menting procedures.

15. Dose Assessment Team initial Training and Annual Training Senior Health Physicist Training with emphasis Support Health Physicist on equipment and procedures Physicist, Dosimetry used for projecting and Bioassay radiological consequences.

Physicist, Radioactive Materials and Radwaste Shipping Physicict, Respiratory I

Protection and Radwaste Clothing Administration Physicist, Special Projects Dosimetry, Techincal Assistant

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j LGS EP in the Technical Support Center or in-a temporary f acility such as a trailer.

b)

Training.

In-coming support personnel would be niven indoctrination in topics such as plant layout, security,,

access limitations, dosimetry recuirements, and other areas related to their support functions, c)

Dosimetry.

Dosimetry appropriate for the individual's support function would be issued and l

applicable records initiated to control exposures.

Statements of exposure history would be reauested.

d)

Security.

Authorized support personnel would be issted passes or other identification to identify escort requirements or access limitations, such as access only to the Technical Support Center or to the plant.

e)

Facilities for medical aid, sample preparation and analysis, instrumentation calibration and

repair, food preparation, and sanitary facilities are designated as shown in Figure 7-1.

7.1.6 PEco Headouarters Emergency Support Center

-l The PECo Headauarters Emergency Support Center (HESC) l located at the Philadelphia Electric Company offices at 2301 l Market Street in Philadelphia.

Corporate support personnel l (see Section 5.0) report here when activated.

The main i support activities are controlled from a single floor in the l building with additional personnel reporting to locations l throughout the building.

This center has a map of the Limerick area to enable tracking and evaluation of off-site radiological consequences.

Comrunications with Limerick and

-l the EOF, and access to as-built drawings, P&ID's, and plant procedures enable technical evaluation of problems by l engineering personnel.

The HESC is under the direction of l the Emergency Support Officer and is activated at a Site or

.l General Emergency.

7.1.7 Emergency News Center l The Emergency News Center (ENC) is located in the l Philadelphia Electric Company offices in Philadelphia.

The Emeroency News Center will have the equipment, facilities, and documents to accommodate the media and for I conducting press conferences.

The Emeroency News Center has and HESC.

The FNC is l communication [s links with the EOF I activated at Sitefor General Emergency.

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