ML20209C425
| ML20209C425 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/14/1987 |
| From: | Lemons J BALTIMORE GAS & ELECTRIC CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8704280678 | |
| Download: ML20209C425 (8) | |
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t BALTIMORE GAS AND ELECTRIC CHARLES CENTER. P. O. BOX 1475 + BALTIMOR E, MARYLAND 21203 1
l JAMES R. LEMONS April 14,1987 MANAGER
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NUCL. EAR OPERATIONS DEPARTMENT t
U. S. Nuclear Regulatory Commission Docket Nos.
50-317 Region 1 50-318 631 Park Avenue License Nos. DPR-53 King of Prussia, PA 19406 DPR-69 i
ATTENTION: Mr. Thomas T. Martin, Director ll Division of Radiation Safety and Safeguards
REFERENCE:
(a)
Combined Inspection Report Nos. 50-317/86-14, 50-318/86-14; Emergency Preparedness Inspection on September 8-10, and October 14-17, 1986 Gentlemen:
This letter is in response to the referenced routine safety inspection of Calvert Cliffs Nuclear Power Plant's annual emergency preparedness exercise and remedial drill. While no reply to the Inspection Report is required, we do want to inform you of actions taken i
or in progress to enhance our demonstrated response capabilities.
These actions, stemming from both the inspection as well as the most recent drill held on February 25,1987, are outlined in Attachment (1).
Significant improvements have been made through the addition of personnel and clarification of responsibilities in dose assessment, additions of specific performance objectives to drill scenarios, and the development of an update report to enhance the interface between dose assessment and protective action decision makers.
These l
Improvements (also included in Attachment 1) were demonstrated during the February 25,1987, drill.
1 Should you any have questions regarding these actions, we will be pleased to discuss them
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with you.
Very truly yours,
,[
w ent' a wg,-
3RL/TEF/LSL/ dim i
Attachment
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B704280678 870414 DR ADOCK 050 7
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M
Mr. Thomas T. Martin April 14,1987 Page 2 cc:
D. A. Brune, Esquire
- 3. E. Silberg, Esquire R. C. Capra, NRC S. A. McNeil, NRC
- 3. M. Allen, NRC T. Foley/D. A. Trimble, NRC l
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ATTACHMENT (1)
REPLY TO INSPECTION REPORT 50-317/E14; 50-318/E14 l
l The following are actions taken or in progress to enhance our demonstrated response l
capabilities. Headings and item numbers refer to the respective headings and item l
numbers of the subject inspection Report. Should you have any questions regarding these actions, please contact:
Thomas E. Forgette Supervisor - Emergency Planning (301) 260-4996 Data Transfer /Information Flow - (50-317/ElbO3; 50-318/ElbO3) o A specific performance objective has been added to drill scenarios effective January 1,1987:
Ob;ective II.F: "(Demonstrate) Ability to update center personnel by facility briefings (i.e., initial briefing and updates; routine updates can be expected at three hour intervals or less; significant change update can be expe:ted within an hour of the occurrence)."
This emphasis on center updating has enhanced staff awareness of the need to keep emergency personnel aware of plant conditions.
During a February 25, 1987, emergency response drill, Objective II.F was adequately demonstrated.
To document that data has been transmitted between centers, the Emergency o
Message form (ERPIP 4.1.22.2, Attachment 2) has been revised.
Revision 0, Change i provides for positive evidence (a signature and the time that the message is sent) that a message is transmitted.
Communication - (50-317/Elb05; 50-318/86-lb05) o The improved Chemistry Director / Radiological Assessment Director interface demonstrated in the remedial drill resulted from relocating the Chemistry Director from the Operational Support Center to the Technical Support Center. This move affords the Chemistry Director better access to the data needed for a source term determination. A specific performance objective has been added to drill scenarios effective January 1,1987:
Objective !!.G:
"(Demonstrate) Ability of Chemistry Director to I
I communicate information on actual source term determination or total
(
curies being released to the Radiological Assessment Director...." I
l l
l ATTACHMENT (1) l REPLY TO INSPECTION REPORT 50-317/E14; 50-318/E14 I
l Training subsequent to the Chemistry Director move and the added emphasis of a specific objective have enhanced staff awareness of the need for this communication. Adequate performance of Objective ll.G was demonstrated in a February 25,1987, drill.
A position paper (dated December 19, 1986) that reviews Dose Assessment and o
Technical Support Center functions has been distributed to key personnel to enhance understanding in this area. Special training afforded by this paper and subsequent conversations with individual recipients will minimize opportunity for information discrepancies between Dose Assessment and the Technical Support Center and thereby ensure timely handling of data.
o Regarding communications between the field monitoring team in the helicopter and the field team coordinator, we are investigating the feasibility and benefit of permanently installed radio equipment in the helicopter. This investigation will be completed by June 1,1987.
o Problems associated with the Operational Support Center's Security liaison relaying data from the Radiation Protection Director have been reviewed with personnel involved. Increased awareness on the part of these people will ensure that this discrepancy does not repeat. This unplanned communication path was not used during a February 25,1987, drill.
c o
Additional telephones will be made available for drill use in the Control Room. This will improve information flow from this location to the Emergency Operations Facility between the Interim Radiological Assessment Director and the Radiological Assessment Director.
Initial Dose Assessment (CR)-(50-317/E14-06; 50-318/E14-06) initial dose assessment is performed in the Control Room by a Radiation Safety o
Technician trained to use MIDAS. The MIDAS automatic data collection program produces an Emergency Planning Zone map and Emergency Action Level based on release rate as mea.ured by the main vent gaseous monitor.
o The Radiation Safety Technician serves as an Interim Radiological Assessement Director until relieved by the designated Radiological Assessment Director stationed at the Emergency Operations Facility.
The Interim Radiological Assessment Director provides the Emergency Planning Zone map and Emergency Action Levels 1
generated by MIDAS to the Shif t Supervisor who is acting as Interim Site Emergency Coordinator.
o General emergency initial protective action recommendations are made in the Control Room (or Technical Support Center) by the Interim Site Emergency Coordinator based on plant conditions and in consideration of the MIDAS Emergency Action Level and Emergency Planning Zone map. The assessment process in the Control Rovn continues until the Emergency Operations Facility is staf fed. During work hours, this occurs approximately 30 minutes af ter declaration of an Alert.
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ATTACHMENT (1)
REPi,Y TO INSPECTION REPORT 50-317/E14; 50-318/E14 o
improvements made to dose assessment at the Emergency Operations Facility include enlargement of the assessment staff and various procedural changes as discussed below.
o The Radiological Assessment Director tasks have been divided between two people.
The lead person is designated as Directing Radiological Assessment Director, the i
support perron is Assessing Radiological Assessment Director.
The Directing Radiological Assessment Director is responsible for direct communications with the Site Emergency Coordinator via a new form, the Protective Action Status Report.
This form facilitates Protective Action Recommendation decision making. The Assessing Radiological Assessment Director manages plume tracking and dose prediction (as necessary) on separate terminals in the Emergency Operations Facility.
The support staff of Radiological Assessment Specialists has been increased from two to four per shif t.
Because of increased staff, each of the two dose assessment terminals can have a separate operator at any given time. A bound, paginated log book is now available to document dose assessment actions.
in order to assure the primary assessment tool is the dose assessment computer o
system, the manual calculations have been made subordinate to the computer calculations with Revision 9 of ERPIP 4.4.1, Dose Calculations, and 4.4.4, Meteorological Data. Manual calculations will be used as a backup.
o The February 25, 1987, drill demonstrated the following improvements in dose assessment:
1.
Quick initial Control Room dose assessment.
2.
Division of labor in Emergency Operating Facillcy dose assessment.
3.
Use of computer calculations as the primary assessment tool.
4.
Use of two terminals, one to track the plume and the other to predict dose.
5.
Use of a standardized Protective Action Recommendations form.
Post Accident Sampling Analysis -(50 317/86-14-02; 50-318/86-14-02) l To ensure the proper post-accident sampic system keys are available for the o
l Chemistry Technician's use, a set of keys have been added to the Operational I
Support Center inventory. This addition was effective with Revision 12, Change 5, to ERPIP B.1, Equipment Checklists (November 19, 1986).
Effcctive October 1,1986, provisions have been made to facilitate breathing zone o
air sampling. An air sampler kit has been assembled that allows :,ampling in the immediate vicinity of the chemical fume hood. Samples acquired in this manner will represent radioactive concentrations in the breathing zone.
o A modification has been made to the shleiding setup at the gamma analysis station to incorporate a mirror so that the user will not be required to bend over the shield to view work.
ATTACHMENT (1)
REPLY TO INSPECTION REPORT 50-317/86-14; 50-318/86-14 o
Delays experienced in the analysis of post-accident samples were caused by the unavailability of Ge-Li detectors due to their use in support of routine plant operations. To ensure use conflicts do not recur, routine detector operations will be scheduled around drill activities to the fullest extent possible.
o Successful post-accident sampling and analysis was performed February 27, 1987, during an NRC Inspection of the Post-Accident Sampling System (Inspection Report 50-317/86-03; 50-318/86-03).
Medical Emergency (Contaminated / Injured Individual) - (50-317/E14-07: 50-318/86-14-07) o Arrangements are being made to conduct a medical emergency drill (contaminated, injured person) with participation by BG&E, a local rescue squad, and Calvert Memorial Hospital. Tentative date for this activity is August 14,1987.
The following items are in response to Section 3.0.c. (page 7) of the Inspection Report.
This section identilles areas needing further evaluation by the licensee:
Transfer of Radiological Assessment Director from Control Room to Emergency o
Operations Facility. Response to item 86-14-06 describes how the dose assessment function is carried out over time.
From the onset of off-normal conditions, responsibility for accomplishing this task is c!carly defined. Every effort is made to minimize the time that interim personnel perform dose assessment and to ensure functions transfer from the Control Room to the Emergency Operations Facility expeditiously. This philosophy has been reviewed with the responsible Individuals.
During a February 25,1987, drill, no undue delay was observed.
o Data documentation. As noted in response to item 86-14-03, provisions have been made to verify that emergency messages are actually transmitted. The revised form was successfully used in the February 25,1987, drill. However, post-drill record review indicates that additional training is needed to ensure all communicators sign the form as required. This matter will be reviewed with responsible personnel and monitored during the scheduled June 18,1987, drill.
o Dose assessment training. Effective January 28, 1987, dose assessment training became the shared responsibility of the Technical Training Unit with the Emergency Planning Unit. In.luding Technical Training in this effort enhances expertise and resources availabic to perform dose assessment training. Both Units will evaluate the current training program and develop recommendations for program enhancement. The evaluation completion date is June 30,1987.
o Radiological Assessment Director involvement.
The response to item 86-14-06 describes how Radiological Assessment Director tasl<s have been divided between two people.
This action allows one Director to be involved in detalled dose assessment and the other to concentrate on overall assessment. ERPIP changes required to implement this will be completed by lune 1,1987; the Emergency
Response
Plan will be changed with the annual review and update (December 1,1987).
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r ATTACHMENT (1)
REPLY TO INSPECTION REPORT %317/E14; E318/E14 Dose computations. As noted previously, a position paper (dated December 19, 1986) o has been prepared to enhance awareness of dose assessment and Technical Support Center functions (assumptions and limitations). The training afforded by this paper will minimize opportunities for dose computation differences.
Additionally, increased communications between dose assessment personnel and the Chemistry Director ensures awareness for each others actions and therefore eliminates confusion. This was successfully accomplished in a February 25,1987, drill.
The following items are not addressed in the referenced Inspection Report, but have been undertaken to improve overall response:
o We have reviewed staf fing of key positions in the emergency organization. Based on this review, personnel changes for some assignments have been made to ensure that the most effective organization exists.
o Protective action decision makers (Recovery Managers and Site Emergency Coordinators) will participate in enhanced training to provide them with a better appreciation for the possible and probable off-site consequences of specific accident situations. This will include the review of a recent analysis of a postulated Steam Generator Tube Rupture accident, o
Data to be used for drills and exercises is receiving additional technical review to t
add confidence in the data, in the process of reviewing the data, those people performing the review will receive additional practice in accident assessment calculations.
o The drill / exercise evaluatlo has been enhanced through the use of center directors and other key personnel as evaluators.
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