ML20039C012

Discusses Preparation for Emergency Preparedness Exercise Scheduled for Wk of 820222.Requests Concurrence W/ Interpretations of 10CFR50,App E Re Involvement of Offsite Response Agencies

ML20039C012
Person / Time
Site:	Kewaunee
Issue date:	12/08/1981
From:	Mathews E WISCONSIN PUBLIC SERVICE CORP.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
CON-NRC-81-198 TAC-46313, NUDOCS 8112280313
Download: ML20039C012 (3)

Text

'( NRC-81-198 WISCONSIN P U B LIC S ERVICE CO RPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 __

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" DFAPI No December 8, 1981

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Mr. J. G. Keppler, Regional Administrator // DEPMX File Office of Inspection & Enforcement Region III U. S. Nuclear Regulatory Commission d

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Kewaunee Nuclear Power Plant ,A MM if' Preparation for an Emergency Preparedness Exercise g/ C. ; 3 \ ;),g In support of the upgraded emergency preparedness at the Ke ' nae Nuclear Power Plant, and to comply with the requirements of 10 CFR 50, Appendix E, WPS is in advanced stages of preparation for an emergency exercise. We are concerned about the level of involvement of offsite response agencies for the exercise we plan to conduct in February and seek your concurrence with the following interpretations of sections of 10 CFR 50, Appendix E.

Section IV.Fl:

A full-scale exercise which tests as much of the licensee, State, and local emergency plans as is reasonably achievable without mandatory public participation shall be conducted;

a. For each site at which one or more power reactors are located and licensed for operation, at least once every five years and at a frequency which will enable each State and local govemment within the plume exposure pathway EPZ to participate in at least one full scale exercise per year and which will enable each State within the ingestion pathway to participate in at least one full-scale exercise every three years.

WPS interprets this as a requirement for an annual exercise of the Kewaunee and Manitowoc County Emergency Covernment organizations, and that on at least five year intervals the State will participate in the exercise conducted with these counties. The State has a similar annual requirement, however, on a rotating basis, it may participate in the exercise conducted at a number of licensed facilities to meet both the annual and five year requirements. (The three year requirement for the State of Wisconsin is met by compliance with the five year requirement of several licensees.)

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O Mr. J. G. Keppler December 8, 1981 Page 2 More specifically, and a matter of concern to the two county organizations, is to recognize that a full scale exercise of each county organization is required only annually, recognizing that there are two licensed facilities with plume exposure EPZ's contained within each county. The rule expects an annual exercise of each organization to assure an adequate level of preparedness; to exercise the county organizations on a semi-annual basis imposes an unreason-able hardship, both financial and for personnel, on these organizations whose performance depends greatly on volunteers engaged in other activities. We further interpret this section to be met, by both licensees, by alternating the site of the initiation of the annual exercise between the Point Beach and Kewaunee facilities. On alternate years at which time a full scale exercise is not conducted, we interpret the exercise requirements as follows:

Section IV.F3:

A small scale exercise which tests the adequacy of communication links, establishes that response agencies understand the emergency action levels, and tests at least one other component (e.g., medical or offsite monitoring) of the offsite emergency response plan for licensee, State, and local emergency plans for jurisdictions within the plume exposure pathway EPZ shall be conducted at each site at which one or more power reactors are located and licensed for operation each year a full-scale exercise is not conducted which involves the State (s) within the plume exposure pathway EPZ.

The small scale exercise will include the establishment of communication links with the offsite agencies and communication of information relevant to the exercise which will meet the intent of the above. Further, in addition to a full activation of the on site emergency organization, at least one site specific component of the offsite planning will be exercised. Specifically, however, in consideration of the full scale exercise conducted at one of the two sites (Kewaunee or Point Beach), full county response will not be required p/

at the site of the small scale exercise.

It is our understanding, from joint conversations with members of your staff, FEMA Region V, State of Wisconsin, Manitowoc County, Wisconsin Electric Power Company and WPS personnel (and, separately, Kewaunee County officials) that the presented position is acceptable.

In a related matter we wish to address the request made in reference (1), the full scale exercise to be performed between April 1,1981, and April 1,1982.

In January,1981, a full scale exercise was conducted centered on an incident at the Kewaunee Plant; there was full activation of the State and County response organizations under observation of FEMA. WPS did not exercise its emergency plan because of its early stage of revision, but did support communi-cation to the agencies. The offsite exercise received a generally favorable FEMA review and identified weaknesses are being addressed. W"S submits th at , in consideration of that exercise conducted in January,1981, only a

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. 1 a Mr. J. G. Keppler December 8, 1981 Page 3 smal" .cale exercise need be conducted prior to April 1,1982, as discussed abo' We understand that prior to April 1,1982, a full scale exercise will be c aducted at the Point Beach facility.

As before, all agencies involved have indicated, informally, that this position is acceptable. We, therefore, advise you of our intent to conduct a small scale exercise the week of February 22, 1982. In the event you find this position unacceptable, WPS must submit an exercise scenario to FEMA and NRC Regions for review by January 8, 1982 (45 days prior to the exercise as outlined in B. K. Grimes' letter of February 2,1981, to NRC Regional Directors), and considerable schedule alterations of State and FEMA personnel must be made. Consequently, we urge you to advise us of your position in this matter at your earliest opportunity.

Very truly yours,

$. O E. R. kithews Senior Vice President Power Supply & Engineering suf cc - Mr. S. A. Varga, US NRC Mr. J. Pagliaro, US NRC Mr. B. K. Grimes , US NRC Mr. J. L. LaFleur, Emergency Government Mr. E. Lipke, WEP Co.

Mr. Gordon Wenger, Federal Emergency Mgt Agency, Reg V Mr. C. F. Riederer, PSCW Mr. Robert Nelson, US FRC