ML20005B917

Notifies That Special Order Implementing Requirements of Generic Ltr 81-04 Re Emergency Procedures & Training for Station Blackout or Loss of All Ac Power Events Will Be in Effect by 810930

ML20005B917
Person / Time
Site:	Point Beach
Issue date:	09/11/1981
From:	Burstein S WISCONSIN ELECTRIC POWER CO.
To:	Clark R, Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-TM GL-81-04, GL-81-4, TAC-43944, TAC-43945, NUDOCS 8109160117
Download: ML20005B917 (2)

Text

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I Nsconsin Electnc ecata couesur 231 W. MICHIGAN, P.O. BOX 2046, MILWAUKEE, WI 53201 September 11, 1981

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Mr. Harold R.

Denton, Director 49 i, b py 4

Office of Nuclear Reactor Regulation O bb d U U.

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NUCLEAR REGULATORY COMMISSION

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Washington, D.

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20555 Attention: Mr.

R. A. Clark, Chief Operating Reactors Branch 3 v'

Gentlertan:

f DOCKET NOS. 50-266 AND 50-301 INTERIM LOSS OF ALL AC POWER PROCEDURE POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Iour letter dated August 21, 1981 discussed aspects of our June 9, 1981 response to Generic Letter 81-04 regarding emer-gency procedures and training for station blackout or loss of all AC power events.

Specifically, you stated that our schedule for unplementation of these procedures and training did not satisfy the urgency you have assigned to this matter.

You, therefore, requested that we expedite implementation of emergency procedures and operator training for loss of all AC power events such that they will be in effect by about September 1981.

In a letter 20 Mr. Eisenhut dated August 7, 1981, the Westinghouse Owners Group provided an explanation of its NUREG-0737, Item I.C.1, schedule modification to give a high priority to the loss of all AC power guidelines.

The Owners Group reiterated that presentation of procedure and training guidelires at the September seminar should permit each utility to augment the guidelines with plant-specific considerations and implement plant-specific procedures and training no later than the first refueling in 1982.

We believe this schedule reflects the earliest reasonably practical date for implementation of procedures and training for loss of all AC power events while still allowing accommodation of the many other NRC imposed activities, chapges, and modifications currently in progress at the Point Beach Nuclear Plant.

As discussed in the July 1, 1981 NRC document, " Survey of Licensee Viewpoints on Regulatory Activities", NRC SECY-81-437, the imposition of NRC requirements in the form of generic letters, fD 8109160117 810911 O

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' e Mr. Harold R. Denton September 11, 1981 i

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bulletins, circulars, notices, Regulatory Guides, NUREG's, rule changes, and orders has become nearly overwhelming.

SECY-81-437 also discussed tsie negative safety impacts that repeated procedural changes may have on plant ope *ations.

Development or a procedure is obviously only the first " cap in implementatior..

More important is the operator trainino necessary to insure the procedure is under-etood by the present operators and integrated into the qualification, requalification, and NRC operator testing program.

En this example, you are requesting licensees to include in the plant operator training and cualification program an izterim procedure subject to almost certain change within a relatively short time.

We believe your present requirement for an immediate loss of all AC power procedure, at a time when owners group organizations have been diligently working on the development of emergency procedures in response to the TMI Action Plan, is an inappropriate and unnecessary imposition of new requirements by the NRC staff.

As mentioned in our initial response to your reauest, the availability of four transmission lines to the Point Beach' site,

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emergency diesel generators, and an on-site 20 MW gas turbine-powered generator make the possibility of a complete loss of all AC i

power extremely remote.

Nonetheless, in order to satisfy the urgent requirement you have placed on implementation or these procedures and training, we are developing a special order for response to loss of all AC power events at the Point Beach Nuclear Plant.

This special order will be in effect and sufficient operator training conducted to insure familiarization with the special order to meet your requirement for expedited implementation by September 30, 1981.

Refinement of this special order, based on our review and appraisal of the Westinghouse owners Group guidelines and implementation of the permanent loss of all AC power procedures and training, will be conducted in accordance with the schedule discussed in the August 7, 1981 Owners Group letter.

Very truly yours, A

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Exe utive Vice President Sol Burstein 4

Copy to NRC Resident Inspector

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