ML20011A879
| ML20011A879 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 10/29/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Mathews E WISCONSIN PUBLIC SERVICE CORP. |
| Shared Package | |
| ML20011A880 | List: |
| References | |
| NUDOCS 8111030319 | |
| Download: ML20011A879 (9) | |
See also: IR 05000305/1981013
Text
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OCT 2 9198h
Docket No. 50-305
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Wisconsin Public Service
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Corporation
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ATTN:
Mr. E. R. Mathews
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Vice President
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Power Supply and
Engineering
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Post Office Box 1200
Green Bay, WI 54305
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Gentlemen:
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Subject: EMERGENCY PREPAREDNESS APPRAISAL
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Office of Inspection and Enforcement is conducting special
appraisals of the emergency preparedness programs at all operating nuclear
power reactors. The objectives of these appraisals are to evaluate the
overall adequacy and effectiveness of emergency preparedness and to identify
areas of weakness that need to be strengthened. We will use the findings
from these appraisals as a basis not only for. requesting individual 'iceasee
action to correct' deficiencies and effect improvements, but also for effect-
ing improvements in NRC requirements and guidance.
During the period of June 8-19, 1981, the NRC conducted a special appraisal
of the emergency preparedness program at the Kewaunee Nuclear Generating
Station. This appraisal was performed in lieu of certain routine inspec-
tions normally conducted in the area of emergency preparedness. Areas
examined during tnis appraisal are described in the enclosed report
(50-305/81-13). Within these areas, the appraisal team reviewed selected
procedures and representative records, inspected emergency facilities and
equipment, observed work practices, and interviewed personnel.
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Wisconsin Public Service
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Corporation
The findings of this emergency preparedness appraisal indicate that aaveral
significant deficiencies exist in your emergency preparedness program. These
are discussed in Appendix A, "Significant Appraisal Deficiencies," and in
summary include:
1.
Deficiencies in preparedness program staffing and augmentation of the
Emergency Orgaaization.
2.
Lack of training and retraining of the Emergency Organization.
3.
Deficiencies in emergency facilities and equipment.
4.
Weaknesses in procedures for implementing the emergency plan.
5.
Deficiencies in coordination with offsite support agencies.
6.
Weaknesses in the understanding and performance of emergency plan
implementing procedures.
Significant deficiencies for which you have made acceptable commitments to
resolve were discussed in the confirmatory (immediate action) letter dated
June 22, 1981.
During this appraisal, certain of your activities appeared to be in noncom-
pliance with NRC requirements, as described in the enclosed Appendix B.
The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program. These are discussed in
Appendix C, " Appraisal Improvement Items."
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed. The results of this review indicate that certain
deficiencies exist in your Emergency Plan. These are discussed in Appendix D,
" Comments On Emergency Plan."
Several areas in your emergency preparedness program were not complete at
the time of this appraisal and therefore were not examined. These areas
are identified as Open Items and are listed in the enclosed Appendix E.
These will be examined by our staff upon complete implementation of the area
involved. Please notify our office relevant to your completion schedule of
these items for re-examination by our staff.
Wisconsin Public Service
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Corporation
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A, C, and D may not currently exist. Notwithstanding
this, you are requested to submit a written statement within thirty days of
the date of this letter, describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration
ot each of the items in Appendix C.
This description is to include:
(1)
steps which have been taken; (2) steps which will be taken; and (3) a schedule
for completion of actions for each item. This request is made pursuant to
Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations. With
regard to Appendix C, within 90 days of the date of this letter you are re-
quested to provide changes to the emergency plan correcting each deficiency.
Copies of these changes are to be subnitted in accordance with the procedures
delineated in 10 CFR 50.54(q).
This is to inform you that should the deficiencies addressed in the Immediate
Action letter of June 22, 1981, not be corrected by the commitment dates pro-
vided, or if the other deficiencies in Appendix A are not corrected within
four months of the date of this letter, the Commission will determine whether
the reactor shall be shut down until such deficiencies are remedied or whether
ot her enforcement action is appropriate.
In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this
letter, the enclosures, and your response to this letter will be placed in the
NRC's Public Document Room.
If the enclosures contain any information that you
or your contractors believe to be exempt from disclosure under 10 CFR 9.5(a)(4),
it is necessary that you (a) notify this office by telephone within seven (7)
days from the date of this letter of your intention to file a request for with-
holding; and (b) submit within twenty-five (25) days from the date of this
letter a written application to this office to withhold such information.
Section 2.790(b)(1) requires that any such application must be accompanied
by an affidavit executed by the owner of the information which identifies the
document or part sought to be withheld, and which contains a full' statement of
the reasons on the basis which it is claimed that the information shoald be
withheld from public disclosure. This section further requires the statement
to address with specificity the considerations listed in 10 CFR 2.790(b)(4).
The information sought to be withheld shall be incorporated as far as possible
into a separate part of the affidavit.
If we do not hear from you in this
regard within the specified periods noted above, a copy of this letter, the
enclosures, and your response to this letter will be placed in the Public
Document Room.
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Wisconsin Public Service
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Corporation
The reporting requirements contained in this letter affect fewer than ten
persons and therefore are not subject to Office of Management and Budget
Clearance as required.by P.L.96-511.
Should you have any questions concerning this inspection, we will be pleased
to discuss them with you. Should you have any questions concerning the items
of Appendix D, please contact Mr. J. A. Pagliaro, Emergency Preparedness
Licensing' Branch at (312) 932-2538.
Sincerely,
Original signed by
he Bart Davis
James G. Keppler
Director
Enclosures:
1.
Appendix A, Significant
,
Appraisal Findings
2.
Appendix B, Notice of
Violation
3.
Appendix C, Appraisal
Improvement Items
4.
Appendix D, Emergency
Preparedness Evaluation Report
5.
Appendix E, Open Items
6.
IE Inspection Report
No. 50-305/81-13
cc w/encls:
D. C. Hintz, Plant Supt.
DMB/ Document Control Desk (RIDS)
Resident Inspector, RIII
John-J. Duffy, Chief Boiler Inspector
Stanley York, Chairman
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Public Service Commission
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Appendix A
SIGNIFICANT APPRAISAL DEFICIENCIES
The following is a list of Significant Findings regarding the Kewaunee
Emergency Preparedness Appraisal. These findings are arranged according
to the planning standards of 10 C7R 50.47(b). These findings must be
resolved in order for the onsite state of emergency preparedness to pro-
vide reasonable assurance that appropriate protective measures can and
will be taken in the event of a radiological emergency.
1.
Planning Standard (b)(2) (Onsite Emergency Organization)
The following deficiencies were identified:
Measures have not been taken to provide minimum shift staffing
.
and augmentation as specified in NUREG-0654, Revision 1,
Evaluation Criteria II B.5 and the licensee has not provided
an acceptable alternative.
(Section 2.2.2) (305/81-13-01)
An augmentation and staffing procedure for the first 30 nd
.
60 minutes of an emergency has not been provided.
(Sectisa 2.2.2)
(305/81-13-M.)
The procedure defining the Emergency Director's responsibilities,
.
ACD 12.1, does not define those responsibilities which can not be
delegated. (Section 5.3) (305/81-13-03)
2.
Planning Standard (b)(4) (Emergency Classification System)
The following deficiencies were identified:
Several Emergency Operating Procedures do not provide a require-
.
ment that the user notify the SRO (acting plant manager) of a
possible Emergency Action Level requiring implementation of the
(Section 5.2) (305/81-13-04)
The initiating conditions for emergency levels listed in the
.
emergency plan and procedures are not based on observable and
reliable indicators for plant operating parameters, nor are
they described in sufficient detail to categorize an incident
at the appropriate emergency action level.
(Section 5.3)
(305/81-13-05)
Appendix A
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3.
Planning Standard (b)(6) (Emergency Communications)
The following deficiency was identified:
An acceptable system La notify the general public as specified in
.
Appendix 3 of NUREG-0654 has not been developed and implemented.
(Section 7.2.3) (305/81-13-06)
4.
Planning Standard (b)(7) (Public Education and Information)
The following deficiency was identified:
A method, such as brochures, bill board signs, has not been
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developed to inform the resident and transient adult population
what to do in the event of an emergency. This information shall
be updated and disseminated annually.
(Section 6.2 and 5.4.7)
(305/81-13-07)
5.
Planning Standard (b)(8) (Emergency Facilities and Equipment)
The following deficiencies were identified:
Procedures to assure that emergency support supplies / equipment
.
are operationally checked and inventoried have not Leen developed.
(Section 5.5.1) (305/81-13-08)
Radiological emergency survey / sampling kits that contain instru-
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mentation, procedures, and support equipment (e.g., flashlights,
keys, batteries, filters) have not been provided.
(Section 4.2.1.1)
(305/81-13-09)
Lake breeze effect is not incorporated into dose calculations
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and peak dose rates are not identified from the dose calculation
mannual.
(Section 4.2.1.4) (.^05/81-13-10)
Adequate telephone communications for use by NRC and State and
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local governments consistent with NUREG-0696 have not been estab-
lished in the EOF.
(Section 4.1.1.4) (305/81-13-11)
6.
Planning Standard (b)(8) (Accident Assessment)
The following deficiencies were identified:
The capability ta collect post-accident samples of radioiodine
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using silver zeolite from containment does not exist.
(Section 4.1.1.6 and 5.4.2.6) (305/81-13-12)
Post-accident sampling and analysis procedures for the Containment
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Sump, have not been developed or implemented.
(Sections 4.1.1.8,
5.4.2.10, and 5.4.2.11) (305/81-13-13)
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Appendix A
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A procedure does not exist which will provide guidance in
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implementing the radiological accident assessment scheme for
gathering information.
(Section 5.4.2) (305/81-13-14)
Specific provisions / procedures have not been developed to do
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specific radiological assessment trend analyses.
(Section 5.4.2)
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(305/81-13-15)
Compensating actions outlined in NUREG-0737, III.A.2 for an
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adequate interim meteorological monitoring / dose assessment
program have not been established.
(Section 4.2.1.4)
(305/81-13-16)
Provisions and procedures have not been developed for using and/or
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incorporating offsite environmental survey sampling data into the
and protective action recommendation scheme.
(Section 5.4.2)
(305/81-13-17)
The capability to make dose predictions and estimates at any
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location within the ten mile EPZ for guidance in the areas of
assessment and protective action recommendations has not been
developed.
(Section 5.4.2) (305/81-13-18)
Emergency survey, sampling and sample analysis equipment and
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procedures are inadequate in the following areas; (1) plume
monitoring, (2) emergency air sampling 17(3) equipment to make
field radioiodine measurements to IX10
uCi/ce, (4) metero-
logical measurements and QC program for these measurement, and
(5) use of protective equipment under emergency conditions.
(Sections 4.2.1 and 5.4.2) (305/81-13-19)
7.
Plauning Standard (b)(10) (Protective Response)
The following deficiency wi.s identified:
A procedure has not been developed for relocation of personnel
.
to assembly areas and the existing Procedure ACD 12.9, " Personnel
Accountability" needs revision.
(Section 5.4.3.2) (305/81-13-20)
8.
Planning Standard (b)(11) (Radiological Exposure Control)
The following deficiencies were identified:
Specific provisions and procedures for establishing and imple-
.
menting an emergency radiological and environmental monitoring
program and analysis of the collected samples have not been
provided.
(Section 5.4.2.12) (305/81-13-21)
Radiation protection procedures do not reflect the accident
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conditions.
(Section 5.4.3.1) (305/81-13-22)
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Appendix A
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Provisions have not been made for expanding the respiratory
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protection requirements that would be imposed under accident
conditions (i.e., decontamination, testing, and acquisition of
additional respiratory units and supplies).
(Section 5.4.3.1)
(305/81-13-23)
9.
Planning Standard (b)(12) (Medical and Public Health Support)
The following deficiency was identified:
'
Procedure HP-RET-14 does not provide sufficient detail for rescue,
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transporting, handling and giving first-aid to contaminated injured
personnel and for the interface with Two Rivers Community Hospital.
(Section 5.4.3.5) Criteria for moving the person to the hospital
have not been developed in sufficient detail and the contacts and
telephone numbers at the hospital have not been listed in the
procedure.
(Section 5.4.3.5) (305/81-13-24)
10.
Planning Standard (b)(13) (Recovery and Re-entry)
The following deficiency was identified:
Procedures have not been developed specifying all of the positions
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and duties of the recovery organization, and how recovery will be
implemented.
(Section 5.4.6) (305/81-13-25)
11.
Planning Standard (b)(15) (Training)
The following deficiencies were identified.
A formal training program consistent with NUREG-0654 for offsite
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governmental organizations and agencies in the area of Emergency
Plans and Procedutes has not been established.
(Section 3.1 and
3.2) (305/81-13-26)
A formal training program which provides for the maintenance
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of training records and is consistent with NUREG-0654 for all
onsite and corporate emergency response personnel in the area
of emergency plans and procedures has not been established.
(Section 3.1 and 3.2) (305/81-13-27)
The security force has not been formally trained by KNPP personnel
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regarding the effects of radiation ta the body, Emergency Class-
ification categories, and what actions are expected of them during
an emergency.
(Section 5.4.4) (305/81-13-28)
Appendix A
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All health physics technicians have not been trained in the per-
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formance of activities contained in Procedure RC-HP-180.
(Section 5.4.2.6)-(305/81-13-29)
12.
Planning Standard (b)(16) (Responsibility for Planning Effort)
The following deficiencies were identified:
Procedures for emergency plans and procedure review to assure
.
completeness and accuracy of plans and procedures have not been
developed.
(Section 5.5.3) (305/81-13-30)
The audit procedure does not provide for an annual audit of the
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emergency plan and does not provide for auditing equipment, inter-
viewing personnel, and drills.
(Section 5.5.4) (305/81-13-31)