ML111651321
| ML111651321 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 01/02/1981 |
| From: | Mathews E Wisconsin Public Service Corp |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML111651320 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8104100193 | |
| Download: ML111651321 (3) | |
Text
WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 January 2, 1981 Dr. Harold R. Denton, Director Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Dr. Denton:
Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Radiological Emergency Response Plan Lq Pursuant to 10CFR50.54(u), Wisconsin Public Service Corporation hereby submits ten copies of the Kewaunee Nuclear Power Plant Radiological Emergency Response Plan, Revision 0, January, 1981. By copy of this letter, three copies of the Plan are hereby submitted to Mr. James G. Keppler, Director, USNRC, Region III, Glen Ellyn, Illinois.
Several criteria of NUREG-0654 are not addressed in the submitted plan. These items are categorically discussed below.
NUREG-0654, Appendix 2:
Meteorological Monitoring Criteria It is the intent of Wisconsin Public Service Corporation to upgrade the on-site meteorological tower and the corresponding monitoring system. This upgrade is considered a part of the effort in progress to upgrade the on-site process computer to address the requirements of NUREG-0696. WPSC submitted comments relevant to Appendix 2 of NUREG-0654 in response to the initial issue of NUREG-0696, specifically regarding the lack of an integrated data base from which all NRC needs may be met. As NRC is aware, NUREG-0696 has not been reissued and WPSC's comments have not yet been addressed. The WPSC position is consistent -
the need for a Nuclear Data Link has not yet been demonstrated and, if required, only one data.baee'slll be transmitted to an agency from which it may redirect specific data subsets.
WPSC is presently working with Wisconsin Electric Power Company in the design of plant computer system upgrades. This effort will be extended to include meteorological data systems when the requirements are clear. The computer upgrade schedule is such that immediate action to procure an improved meteorological system would be wasteful from two respects:
- 1)
The support systems are not defined; and 2) revised system requirements later could add to the cost of implementation..
o1A1.z MD U.j 0 0 1j4 p
00 1 04 T 0 1'5 bik -"' 1
_7"'
.:wmce Irlic,.-
1
('
Dr. Harold R. Denton January 2, 1981 Page 2 Existing and new implementing procedures will use the existing system. WPSC will include the design of the meteorological tower in the system design des cription required by NUREG-0696 when that report is reissued. The continued cooperative effort with WEPCO will assure that compatible installations will provide redundancy from the two plant sites.
Public Notification Systems Due to the overlapping nature of the 10 mile zones about the Point Beach Nuclear Plant and the Kewaunee Nuclear Power Plant, and the inclusion of two counties within that zone, special considerations exist for the public notification system. WPSC intends to work with Wisconsin Electric Power Company in the development of a mutually agreeable system.
Pending review of system studies, a description of the system or its implementation schedule cannot be provided.
WPSC will provide to the NRC a revised status of the public notification system development in 60 days.
Staffing Portions of NUREG-0654 that require an increased on-shift staff are not addressed in the plan. WPSC has committed to increasing the on-shift staff, in accordance with the requirements established by D. G. Eisenhut's letter of July 31, 1980, as reported in our response to NUREG-0737 (letter from E. R. Mathews to D. G. Eisenhut, to be submitted January 5, 1981).
As the additional personnel become available.for assignment to the shifts, associated implementing procedures and sections of the emergency plan will be revised to incorporate the functions of Table B-1 of NURE-0654.
The plan, as submitted, represents the in-place staffing levels.
Letters of Agreement The Plan, in Appendix A, includes letters of agreement between WPSC and various off-site response organizations. These agreements have been established amicably between WPSC and those parties, and each organization is familiar and agreeable with the range of assistance it might be called upon to deliver if necessary.
In some cases (e.g., fire or law enforcement),
detailed enumeration of the customer services provided is superfluous.
In other cases, the specific services delivered would depend on the nature of the emergency. Therefore, detailed lists of services do not warrant inclusion in the letters of agreement.
A letter of agreement between Wisconsin Electric Power Company and WPSC providing for mutual assistance beyond the Sample Analysis Agreement is not included in Appendix A. This agreement is in final internal review form and will be signed shortly, and included in future revisions of the plan.
Implementing Procedures WPSC will submit a set of emergency plan implementing procedures to the NRC, as required by 10CFR50, Appendix E, by March 1, 1981.
Those procedures are cur rently under development. As this development progresses, revisions to the plan will be made to ensure consistency. Revisions to the plan will also be submitted by March 1, 1981, along with a correlation between implementing procedures and plan sections.
PERSONAL PRIVACY INFORMATION, DELETED IN ACCORDANCE WITH THE FREEDOM OF INFORMATION ACT
Dr. Harold R. Denton January 2, 1981 Page 3 Exceptions WPSCtakes exception to the following criteria of NUREG-0654:
- 1. J.6.c -
Use of radioprotective drugs It is our position that the use of such a drug must be under thestrict control of a physician, not the operator.
- 2. I.3.a -
Correlations between containment radiation monitor(s) reading(s) and the radioactive material available for release from containment.
The NRC is following several probabilistic risk assessment (PRA) studies currently in progress by other utilities. These studies identify various failure modes which result in totally different correlations. To arbitrarily select one failure scenario from which a correlation may be developed could result in non-conservative conclusions and the initiation of improper protective actions.
It is our position that the requested correlation cannot be technically justified.
Very truly yours, E. R. Mhthews Vice President Power Supply & Engineering jac cc -
Mr. James G. Keppler, Director, Region III, US NRC, 799 Roosevelt Road, Glen Ellyn, IL 60137 Mr. Robert Nelson, NRC Resident Inspector, RR #1, Box 999, Kewaunee WI 54216 DSQVAL PRIVACY INFORMATION DELETED IN ACCORDANCE wITH THE
'PED1AOF NOUTNAI