ML040820875

Slides from Predecisional Enforcement Conference with Point Beach

ML040820875
Person / Time
Site:	Point Beach
Issue date:	01/13/2004
From:	Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
IR-98-020
Download: ML040820875 (11)

Text

Point Beach Nuclear Plant Predecisional Enforcement Conference January 13,2004 1

t Agenda Opening Remarks Doug Cooper Overview Fred Cayia Background Renee Milner Root Cause Contributing Causes Corrective Actions Summary Fred Cayia Closing Remarks Doug Cooper 2

Overview P Nuclear Management Company Understands and Acknowledges the Apparent Violation

> Point Beach Nuclear Plant is Protecting the Health and Safety of the Public

> We have learned from the Apparent Violation and have taken Actions to Prevent Recurrence 3

Background

9 In Response to an NRC Identified Inspector Follow-Up Item (IF1 50-266/98020-03; 50-30 1/98020-03(DRS)), Point Beach Nuclear Plant initiated changes to the EAL Scheme to add a Fission Product Barrier Matrix and Incorporate Technical Bases from NUMARCDTESP-007 as described in EPPOS- 1 4

Background

PEP Staff improperly interpreted a Statement in EPPOS-1 that was thought to Permit the Use of the Technical Bases under the Example EALs in NUMARCNESP-007

>The Intention was to to Enhance and Clarify Site Specific EALs developed from NUREG-0654

&The Result was a Cross Between the NUMARC and NUREG EALs 5

Background

PThe Revised EAL Scheme was presented to Region 111Inspectors at a Public Meeting on July 29, 1999

>The EP Staff thought that the Changes were Pre-Approved Due to the Wording in the EPPOS and did not recognize that the Change Required NRC Approval Prior to Implementation 6

Root Cause P The Station did not understand that the Change of a Commitment or Change to the EALs would Constitute a Decrease in Effectiveness of the Plan Pursuant to 10 CFR 50.54(q) Regardless of the Continued Ability to Meet 10 CFR 50.47(b) and 10 CFR 50 Appendix E 7

I .

Contributing Causes P Overconfidence The EP Staff was Experienced but did not Incorporate Industry and NRC Guidance such as NE1 99-02, EPPOS 4, or RG 1.101 Rev 3 into the Emergency Plan P Inadequate Review of EP Program Changes

. EP Plan Changes were only Reviewed by EP Staff unless the EP Staff determined that a Change Resulted in the Decrease of the Effectiveness of the Plan 8

Corrective Actions Nuclear Management Company has hired an Experienced Corporate Senior Emergency Preparedness Specialist The EP Staff has been Changed. New Staff has been Trained on EP Regulations The EP Plan Change Process was Revised to Require Approval by Regulatory Affairs and the Plant Operations Review Committee The EAL Scheme is being Revised to NE1 99-01, Rev. 4 Scheme 9

Summary k Nuclear Management Company Understands and Acknowledges that the Changes Made to the EAL Scheme between October 1998 and December 1999 were not in Accordance with 10 CFR 50.54(q)

> Point Beach Nuclear Plant will use the Excellence Plan and Corrective Action Plan to Verify the Effectiveness of our Corrective Actions 10

From: Donna Pirok To: Brent Clayton; Bruce Boger; Dale Thatcher; DNS-DIV; Doug Weaver; DRPIII; DRSIII; Frank Congel; Geoffrey Grant; James Luehman; Jan Strasma; Janet Kweiser; Jennifer Dixon-Herrity; John Jolicoeur; Laura Gerke; Mark Satorius; Michael Johnson; OEMAIL; Patricia Buckley; Paul Krohn; Rani Franovich; Richard Borchardt; RidsNrrDipmlipb; Roland Lickus; Stuart Richards; William Dean; William Reckley; William Ruland Date: 1/28/04 1:27PM

Subject:

Point Beach Units 1 and 2 letter to licensee re Predecisional Enforcement Conf Emer Action Levels Place: DN S-D IV The subject document has been completed and has been submitted to DPC to be declared in ADAMS. A Wordperfect copy of the document has been attached and the document has been assigned Accession

1. ML040280371.