ML111670757

Comments on IE Insp Rept 50-305/79-09 Re Reactor Cavity Radiation Exposure Incident.Operational Personnel Followed Procedures Found Acceptable by NRC & Too Much Emphasis Placed on Dose Received

ML111670757
Person / Time
Site:	Kewaunee
Issue date:	07/20/1978
From:	James E Wisconsin Public Service Corp
To:	James Keppler NRC/OI/RGN-III/FO
Shared Package
ML111670754	List: ML111670752 ML111670757 ML111670887
References
FOIA-92-510 NUDOCS 7905300050
Download: ML111670757 (2)

Text

-WISCONSIN PUBLIC SER~VICE CORPORATION I 6 P.O. Box 1200, Green Boy, Wi~onzin $4305 July 420, 1978 Ntr. James G. K-eppler, Director Inspection & Enforc-et Division Region III US. - uclear Regulatory Coinls ion 799 Roosevelt Road Glem Ellyn, IL 60137

Dear Mr. Kappler:

Docket 50-305 Operating License DPR-43 1S lms;.ectic-n Revort 1Fo. 50-305/79-09 The reference. inspection report addresses a meeting inu our office on MAy 17, 197S, &:id subsequent evaluations of dose, in reSard to the reactor cavity "IC" radiation exposure incident. The report presents the positions noted by mbes o6; he RC Regional Office; however, we lbelieve that tepositions

-~ -~ presented by members of Licensee organization were not completely reflected in the repcrt. In an effort to achieve *coleeness and remo e the possi.bili~ty of niLsinter pretation, we believe that our positions ad opinions axpresaaed shoufl4 be included in the formal record of that meeting.

1L,-. Ciesler stated, both at the subject meeting and a subsequent conference call, that had the correct radiation level data been available or by some other =ea had the ahift supervisor Lmw that the radiation levels were in the 20C-0 Rdhz?

zamge, the incident would not have occurred.

As a result of our reviewing of the incident and the associated acceas eontrol procedures, we cannot .idrantify where the operatio-aal personnel failed to fl~.

the procedures. It is our understanding that through the R~egion III review the appropriate procedures were found to be acceptable. 1: should be recognized that respomsible oneararlng personnel =st be provided with the latitude to make decision-s &zimg. ecergency situatioas from information and input from supportia&

r-rots sa,,mlable to them at the time. it vas not rnd sti.ll-has not been ac~nwleged by your review of the incident that the shift supervisor ":as a::

• cler. a potenzial emergency situation atd that ras~omsibl'ty for zpacifyin;

-4 or entry into radiation araas rett %:4h the Hslth P'nVzics gr'~

in regard to the opiin e-nressed in your letter th t tb.i s Lmcident was :,he no-sm fiatevent that had occu-..2d at the  ?!aneePlt, we can on>i- acnc:

St*-a: ononif you =ea:-i to confine that st'at~et to the area o E- l phvsics =d pe-rsonnel radiation protection.

7i905 3.00050)

hrJ. G. Keppler July "0, 1978

.age 2 We would further like to comment that in the investigation of this incident, there has been far too much emphasis placed on the dose received by the person involved rather than considering plant operations in relation to his actions.

This incident should have been evaluated along with the fact that infcrmation had reached the shift supervisor that water was observed leaking around the hot and cold legs into the Reactor Coolant Pup vaults probably due to leakage from the reactor refueling seal ring. To evaluate whether there was a danger to personnel or plant equipment and to find what corrective action was required, a judgment de:ision to enter the reactor cavity area was made based on the information available o" hand. We would be in real trouble if responsible operating personnel vcre overly restricted or hApered by the consequences of hindsight evaluations when such decisions Would be a necessity in a real amrgency. To best be prepared

c- emergencies and future events of this nature we can only hope to train to the best of our ability the operating personnel and support group personnel to provide the most accurate information available.

Should you desire to review this matter further, we are at your disposal.

Very truly yours,

&L).

5, W. Jzaes Senior V. P esidant Power Supp y & Engineering