ML20042A398

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Forwards IE Emergency Preparedness Appraisal Repts 50-266/82-02 & 50-301/82-02 on 820104-15 & 20 & Confirmation Action Ltr
ML20042A398
Person / Time
Site: Browns Ferry, Point Beach  Tennessee Valley Authority icon.png
Issue date: 02/11/1982
From: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Burstein S
WISCONSIN ELECTRIC POWER CO.
Shared Package
ML20042A399 List:
References
RTR-NUREG-0654, RTR-NUREG-654, TASK-3.A.2.1, TASK-TM TAC-46259, TAC-46260, NUDOCS 8203230389
Download: ML20042A398 (4)


See also: IR 05000266/1982002

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February 11, 1982

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Docket No. 50-266

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Docket No. 50-301

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Wisconsin Electric Puer Company

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ATTN:

Mr. Sol Burstein

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Executive Vice President

Power Plants

231 West Michigan

Milwaukee, WI 53201

Gentlemen:

Subj ect: 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 licensee action to correct

deficiencies and effect improvements, but also for effecting improvements

in NRC requirements and guidance.

During the period of January 4-15, and 20,1982, the NRC conducted a

special appraisal of the emergency preparedness program at the Point

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Beach Nuclear Power Plant and the Wisconsin Electric Power Company

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Corporate Office. This appraisal was done in lieu of certain routine

inspections normally conducted in the area of emergency preparedness.

Areas examined during this appraisal are described in the enclosed

report (50-266/82-02; 50-301/82-02). Within these areas, the appraisal

team reviewed selected procedures and representative records, inspected

emergency facilities and equipment, observed work practices, and inter-

viewed personnel.

Significant deficiencies for which you have made acceptable commitments

to resolve are discussed in the Confirmation of Action Letter dated

January 21, 1982, enclosed as Appendix A and in summary include:

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a.

Shift staffing and augmentation capability 's unacceptable with

respect to the regulatory positions of Table B-1, of NUREG-0654.

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We have reviewed your April 14, 1981, letter fror Mr. C. W. Fay to

Mr. Harold R. Denton in which you address NUREG-L654 Table B-1

minimum shift staffing and 30 to 60 minute shift augmentation. The

position you take is unacceptable. Table B-1 specifies that in addi-

tion to the shift complement you describe, a communicator, a health

physics technician and a rad / chem technician be on shift at all times.

This item is addressed in Section 2.0 Emergency Organization of the

attached report.

Deficiencies in the minimum plant operations crew are currently

being examined by NRR.

b.

No schedule for the development and documentation of an approved

emergency plan training / retraining program, formal lesson plans

or means for determining student performance have been provided.

c.

The Point Beach Emergency Plan and Emergency Plan Implementing Pro-

cedure Emergency Action Levels (EAL's) are not consistent with those

given in NUREG-0654, Appendix 1.

The licensee's ability to notify

a

State and Local authorities within 15 minutes of the declaration of

an emergency is questionable, and the identity of individuals respons-

ible for the notification of State and Local authorities is unclear.

d.

The meteorological program is unacceptable with respect to the

regulatory position of Regulatory Guide 1.23.

No provisions have been

made for dose calculation methodology to compensate for potential

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uncertainties associated with plume trajectories. There are no pro-

cedures to accommodate lake effect.

The findings of this appraisal also indicate that there are areas in need

of improvement in your emergency preparedness program. These areas are

discussed in Appendix B, " Appraisal Improvement Items."

In conjunction with the emergency prepare ( iess appraisal, emergency plans

for your facility were reviewed. The res.lts of this review indicate that

deficiencies exist in your Emergency Plra

These are discussed in Appendix

C, " Emergency Preparedness Evaluation ".epart."

Several areas in your emergency preparedness program were not completed

at the time of this appraisal and therefore were not examined. These

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areas are identified as Open Items and are listed in Appendix D.

These

will be examined by our staff at a future date.

Please notify our office

relevant to your completion schedule of these items for re-examination

by our staff.

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Wisconsin Electric Power Company

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We recognize that an explicit regulatory requirement pertaining to each

item identified in Appendices A, B, and C may not currently exist. Not-

withstanding 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 of each of the items in Appendix B.

This descrip-

tion 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 requested to provide changes to the

emergency plan correcting each deficiency. Copies of these changes are

to ve submitted in accordance with the procedures delineated in 10 CFR 50.54(q).

This is to inform you that should the deficiencies addressed in the

Confirmation of Action letter of January 21, 1982, not be corrected by

the commitment dates provided, the Commission will determine whether

the reactor shall be shut down until such deficiencies are emedied

or whether other 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 this report contains 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 tele-

phone within ten (10) days from the date of this letter of your intention

to file a request for withholding; and (b) submit within twenty-five (25)

days from the date of this letter a written application to this office to

withhold such information.

If your receipt of this letter has been

delayed such that less than seven (7) days are available for your review,

please notify this office promptly so that a new due date may be estab-

lished. Consistent with Section 2.790(b)(1), 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

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contains a full statement of the reasons which are the bases for the

claim that the information should be withheld from public disclosure.

This section further requires the statement to address with specificity

the considerations listed in 10 CFR 2.79C(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 Electric Power Company

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The responses directed by this letter and the accompanying enclosures are

not subject to the clearance procedures of the Office of Management and

Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this appraisal, we will be pleased

to discuss them with you.

Should you have any questions, please contact

Mr. Jess

A. Pagliaro, Emergency Preparedness Section at (312) 932-2538.

Sincerely,

Original signed by

Jam 2s G. Kappler

James G. Keppler

Regional Administrator

Enclosures:

1.

Appendix A, Significant

Appraisal Deficiencies

Confirmation Action Letter

dtd 1/21/82

2.

Appendix B, Appraisal

Improvement Items

3.

Appendix C, Emergency Plan

Evaluation Report

4.

Appendix D, Open Items

cc w/encts:

C. W. Fay, Assistant

Vice President, Wisconsin

Power & Electric Co.

G. A. Reed, Manager

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII

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John-J. Duffy, Chief Boiler

Inspector

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Peter Anderson, Wisconsin's

Environmental Decade

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Stanley York, Chairman

Public Service Commission

Dan Bement, FEMA RV

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