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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insps 50-317/86-14 & 50-318/86-14
	ML20214J970
Person / Time
Site:	Calvert Cliffs
Issue date:	05/14/1987
From:	Martin T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Tiernan J; BALTIMORE GAS & ELECTRIC CO.
References
	NUDOCS 8705280268
	Download: ML20214J970 (2)
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MAY 14 1987

Docket No. 50-317

50-318

Baltimore Gas and Electric Company

ATTN: Mr. J. A. Tiernan

Vice President

Nuclear Energy

P. O. Box 1475

Baltimore, Maryland 21203

Gentlemen:

Subject: Combined Inspection Nos. 50-317/86-14 and 50-318/86-14

This refers to your letter dated April 14, 1987, in response to our letter

dated October 1, 1986.

Thank you for informing us of the corrective and preventive actions documented

in your letter. These actions will be examined during a future inspection of

your licensed program.

Your cooperation with us is appreciated.

Sincerely,

original signea BY*

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Division of Radiation Safety

0 and Safeguards

cc:

M. Bowman, General Supervisor, Technical Services Engineering -

Thomas Magette, Administrator, Nuclear Evaluations

Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector

State of Maryland (2)

8705280268 870514

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Baltimore Gas and Electric Company 2

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Region I Docket Room (with concurrences)

Management. Assistant, DRMA (w/o encl)

DRP Section Chief

M. McBride, RI, Pilgrim

T. Kenny, SRI, Salem

S. McNeil, LPM, NRR

Robert J. Bores, DRSS

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BALTIM ORE

GAS AND

ELECTRIC

CHARLES CENTER * P.O. BOX 1475 BALTIMORE, MARYLAND 21203

JAMES R. LEMONS April 14,1987

MANAGER

NUCLEAn OPERATIONS OEPAntMENT

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

ATTENTION: Mr. Thomas T. Martin, Director

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

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

improvements (also included in Attachment 1) were demonstrated during the

February 25,1987, drill.

Should you any have questions regarding these actions, we will be pleased to discuss them

with you.

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Very truly yours,

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Attachment

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Mr. Thomas T. Martin

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April 14,1987

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, cc: D. A. Brune, Esquire

3. E. Silberg, Esquire -

R. C. Capra, NRC

5. A. McNeil, NRC

. 3. M. Allen, NRC

l T. Foley/D. A. Trimble, NRC

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ATTACHMENT (1)

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REPLY TO INSPECTION REPORT 50-317/86-14; 50-318/86-14

The following are actions taken or in progress to enhance our demonstrated response

capabilities. Headings and item numbers refer to the respective headings and item

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 - (50-317/86-14-03; 50-318/86-14-03)

o A specific performance objective has been added to drill scenarios effective

January 1,1987:

Objective li.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

expected 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.

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o To document that data has been transmitted between centers, the Emergency

Message form (ERPIP 4.1.22.2, Attachment 2) has been revised. Revision 0,

Change 1 provides for positive evidence (a signature and the time that the message

is sent) that a message is transmitted.

Communication - (50-317/86-14-05; 50-318/86-14-05)

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 ll.G: "(Demonstrate) Ability of Chemistry Director to

communicate information on actual source term determination or total

curies being released to the Radiological Assessment Director . . . ."

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ATTACHMENT (1)

REPLY TO INSPECTION REPORT 50-317/86-14; 50-318/86-14

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 II.G was demonstrated in a

February 25,1987, drill.

o A position paper (dated December 19, 1986) that reviews Dose Assessment and

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.

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)-(50-317/86-14-06; 50-318/86-14-06)

o initial dose assessment is performed in the Control Room by a Radiation Safety

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 measured 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

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 Room continues until the Emergency Operations Facility is staffed. During

work hours, this occurs approximately 30 minutes af ter declaration of an Alert.

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ATTACHMENT (1)

REPLY TO INSPECTION REPORT 50-317/86-14; 50-318/86-14

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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

support person 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.

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o In order to assure the primary assessment tool is the dose assessment computer

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.

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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)

o To ensure the proper post-accident sample system keys are available for the

Chemistry Techracian's use, a set of keys have been added to the Operational

Support Center inventory. This addition was effective with Revision 12, Change 5,

to ERPIP B.1, Equipment Checklists (November 19, 1986).

o Effective October 1,1986, provisions have been made to facilitate breathing zone

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air sampling. An air sampler kit has been assembled that allows sampling in the

immediate vicinity of the chemical fume hood. Samples acquired in this manner will

represent radioactive concentrations in the breathind zone.

o A modification has been made to the shielding 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.

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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) - (50-317/86-14-07; 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 identifies areas needing further evaluation by the licensee:

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o Transfer of Radiological Assessment Director from Control Room to Emergency

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 clearly 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. Including Technical Training in this effort enhances expertise and

resources available 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 tasks have been divided between

two people. This action allows one Director to be involved in detailed dose

assessment and the other to concentrate on overall assessment. ERPIP changes

required to implement this will be completed by June 1,1987; the Emergency

Response Plan will be changed with the annual review and update

(December 1,1987).

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ATTACHMENT (1)

REPLY TO INSPECTION REPORT 50-317/86-14; 50-318/86-14

o Dose computations. As noted previously, a position paper (dated December 19, 1986)

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 staffing 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.

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o Protective action decision makers (Recovery Managers and Site Emergency

Coordinators) will participate in enhanced training to provide them with a better

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appreciation for the possible and probable off-site consequences of specific accident

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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

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.

I o The drill / exercise evaluation has been enhanced through the use of center directors

and other key personnel as evaluators.

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ML20214J970

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