ML20042A410
| ML20042A410 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/21/1982 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fay C WISCONSIN ELECTRIC POWER CO. |
| Shared Package | |
| ML20042A399 | List: |
| References | |
| TASK-3.A.2.1, TASK-TM TAC-46259, TAC-46260, NUDOCS 8203230397 | |
| Download: ML20042A410 (12) | |
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Appendix A
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Docket No. 50-266 Docket No. 50-301 Wisconsin Electric Power Company ATTN:
Mr. C. W. Fay Assistant Vice President 231 West Michigan Milwaukee, WI 53201 Gentlemen:
This letter is to confirm the agreements reached between you and other members of your staff, and Messrs. S. Schwartz, Headquarters NRC, W. Axelson, Region III, and other members of the Nuclear Regulatory Commission staff on January 14, 1982, during the management exit in-terview following the NRC Emergency Preparedness Appraisal of Point Beach Nuclear Plant, Units 1 and 2.
Immediate corrective actions are required for the significant Appraisal findings. The exact nature of the required actions, as well as the agreed upon dates for such actions, are as follows:
1.
Onsite Emergency Organization A.
Required Action The licensee shall provide a description of how they intend to 3
i meet the minimum shift staffing guidance of NUREG-0654, Table B-1.
This description shall clearly indicate how each major functional area and task will be implemented at all times. Alternate mea-sures shall be described for those major functional areas not maintained 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. Further, the licensee shall provide a description of a timely shift augmentation system meeting the goals of Table B-1.
The description of the minimum shift staffing and augmentation system shall clearly indicate dates for imple-mentation.
(266/82-02-01; 301/82-02-01)
B.
Agreed Upon Dates for Completion This shall be completed by February 18, 1982.
i 2.
Emergency Plan Training / Retraining A.
The licensee shall provide a schedule for developing and docu-menting an approved emergency plan training / retraining program 4
to include formal lesson plans with clearly stated performance objectives and provisions for student performance evaluation.
(266/82-02-02; 301/82-02-02)
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Appendix A 2
B.
Agreed Upon Date of Completion This shall be completed and sent to the NRC by February 18, 1982.
3.
Implementing Instructions A.
Required Action The licensee shall (1) modify the PBNP Emergency Plan and Imple-menting Procedure EAL's to agree with those given in NUREG-0654, Appendix 1, and (2) have the capability to notify the State and local governmental agencies within 15 minutes of declaration of an emergency. This shall include delegation of authority to the Shift Supervisor to promptly (15 minutes) notify responsible State and county agencies of an emergency if he cannot reach the Duty and Call Supervisor. Training shall be provided to all Shift Supervisors relevant to this authority. This delegation of authority shall be formalized in a procedure. (266/82-02-03; 301-82-02-03)
B.
Agreed Upon Date of Completion This shall be completed by March 18, 1982.
4.
Meteorological Instrumentation A.
Required Action The licensee shall establish a meteorological measurements program in accordance with RG 1.23 (February 17, 1972) and identify techniques to be incorporated into dose calculational methodology to compensate for potential uncertainties associated with plume trajectories. This shall include procedures to accommodate lake effect.
(266/82-02-04; 301/82-02-04)
B.
Agreed Upon Date of Completion This shall be completed by May 18, 1982, depending on equipment procurement problems.
If these problems arise, the licensee shall notify the NRC-Region III within 5 working days.
Procedure corrections shall be incorporated within 60 days of the date of this letter including dose assessment methodology described above.
In addition to the above agreements, the licensee shall provide to the NRC by February 18, 1982, the State and counties' position regard-ing prompt notification to them for an Unusual Event emergency at Point Beach.
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Appendix A
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If our understanding of the actions as'~ described in this letter are not correct, you should contact this office within-24 hours.
Further, please provide our office written notification upon completion of your corrective actions.
4 Sincerely, l
JamesG$Keppler Regional Admihistrator
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G. A. Reed, Manager DMB/ Document Control Desk (RIDS)
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John J. Duffy, Chief Boiler Inspector Peter Anderson, Wisconsin's' Environmental Decade Stanley York, Chairman
., ' h, Public Service Commission
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s Appendix B Appraisal Improvement Items Based on the results of the NRC's appraisal of the Point Beach Nuclear Plant, Unit Nos. L and 2, conducted January 4-15 and 20, 1982, the following items should be considered for improvement:
1.
Provide professional development courses in emergency prepared-ness for the Emergency Planning Coordinator to maintain state-of-the-art capability.
(Section 1.0) 2.
Formal selection and qualification criteria for personnel assigned emergency preparednes's functions should be established and in-cluded in the plan and procedures for onsite shift staffing and augmentation.
(Sections 1.0 and 2.0) 3.
Address provisions for training of non-licensee augmentation personnel (e.g., Kewaunee support, contractors and vendors).
(Section 3.1) 4.
Determine by testing if individuals understand information that has been presented in training / retraining program.
(Section 3.2) 5.
Emergency equipment and supplies currently located in the control room should be consolidated in a central location.
'Section 4.0) 6.
Specify assembly / reassembly areas for nonessential plant personnel, visitors, and contractors for limited plant evacuation.
(Sectirn 4.1.2) 7.
Provide an alternate site evacuation assembly area should the Two Creeks Town llall become radiologically unacceptable during a limited plant evacuation.
(Section 4.1.2) 8.
First aid kits should be contained inside Stokes stretchers on the 66 ft. level, outside containment personnel hatches, and at the level Unit 1 truck access.
(Section 4.1.2.2) 9.
Develop procedures for receiving, transporting and handling injured / contaminated personnel.
(Section 4.1.2.2) 10.
Conduct periodic drills for search and rescue teams.
(Section 4.1.2.2) 11.
Victoreen Thyac survey meter and mini-rad survey instrument should be removed from the Two Rivers Community llospital supplies list.
(Section 4.2.1.1)
Appendix B 2
12.
Clearly establish means for obtaining 15 minute averaged meteoro-logical conditions for use in dose projection process.
(Section 4.2.1.4) 13.
Prioritize alternate meteorological data source access, identify this source on appropriate forms and identify the data and appropriate adjustments to the data, if necessary.
(Section 4.2.1.4) 14.
Provide, in your method for estimating the dose to the popula-tion in the plume EPZ, a conservative assumption for plume re-lease duration and meteorology when the duration is unknown.
(see " Manual of Protection Action Guides and Protection Actions for Nuclear Incidents", EPA-520/1-75-001, page 5.14, section 5.4.1) (Sc. tion 4.2.1.4) 15.
Formalize the data review process to assure meteorological systems are functioning properly and initiate a QC surveillance program.
(Section 4.2.1.4) 16.
Document the means for providing direct access to the individual responsible for dose calculations by NRC personnel.
(Section 4.2.1.4) 17.
Document the technical bases for the upgraded dose calculation methodology and provide the document as an appendix to the plan.
(Section 4.2.1.4) 18.
IIalf-face respirators designated for emergency use should be replaced with full-face respirators.
(Section 4.2.2.1) 19.
Ensure coumunication checks are canducted in accordance with the frequency prescribed in EPIP 14.1 and the requirements of Appendix E to 10 CFR 50.
(Section 4.2.3) 20.
Improve control measures for protective door seals for equipment and supply cabinets in the Interim OSC and TSC.
(Section 4.2.5) 21.
Provide check sources for all instruments in emergency kits to ensure operability.
(Section 4.2.5) 22.
Revise Emergency Operating Procedures (EOPs) to direct the user to the specific Emergency Plan Implementing Procedure where appropriate. This should be accomplished in accordance with the schedule for completion of the generic Westinghouse E0P's.
(Section 5.2) i
Appendix B 3
23.
Revise EPIPs to include provisions for trend analysis for radiological data and continuous update (15 minutes) of radio-logical assessment information to offsite agencies who are i
responsible for radiological assessment and protective actions.
(Section 5.4.2) 24.
Provide additional training for personnel involved in radiological dose assessment to assure accuracy and timeliness.
(Section 5.4.2) 25.
Provide a simplified methodology of initial dose calculations performed in the Control Room by operations personnel.
(Section 5.4.2) 26.
Provide the proper potassium iodide (KI) dose for emergency personnel or implement procedures to assure that personnel do not overdose.
(Section 5.4.3.1) 27.
Establish a formalized audit program for the emergency prepared-ness program.
(Section 5.5.4) 28.
Compare your dose assessment methodology with the State of Wisconsin's methodology.
(Section 6.0) 29.
Revise existing letters of agreement from offsite support groups to identify emergency measures to be provided and criteria for implementation and ensure these agreements are updated at least every two years.
(Section 6.0) 30.
Incorporate a defined training program for offsite agencies into the PBNP training program. (Section 6.0) i f
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Appendix C Emergency Preparedness Evaluation Report Emergency Plan Dated October 23, 1981 Revision 17 Docket 50-266 and 50-301 A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL) (266/82-02-05; 301/82-02-05) 0654 PLAN 3
Appendix D There are 10 letters of agreement having dates of October 1979 or before. There are no letters of agreement for the Wisconsin Department of Natural Resources, Wisconsin Department of Transportation, Wisconsin Department of Agriculture, Wisconsin Department of Military Affairs, Manitowoc County, Kewaunee County, Bechtel Corporation, Westinghouse, and the ambulance service.
B.
ONSITE EMERGENCY ORGANIZATION (266/82-02-06; 301/82-02-06) 0654 PLAN 2
An individual with the authority and responsibil-ity to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations has not been designated in the plan.
4 Appendix A The plan does not clearly list the responsibilities and authorities of the Emergency Support Manager, Site Manager and Shift Supervisor, which can not be delegated.
(e.g., classification of event, recommenda-tion for protective measures for the public, and exceeding 10 CFR 20 exposure limits).
5 Figure 5-1 Shift staffing does not meet the regulatory positions of Table B-1 of NUREG-0654. Also, the plan does not meet the shift augmentation goals of Table B-1.
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7b The plan does not clearly indicate which personnel meet the requirement for providing technical support t
for planning and re-entry / recovery operations.
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Appendix C 2
0654 PLAN 5
The plan does not describe the means or capabilities available to ensure that shift augmentation can be achieved in a timely manner.
C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES (266/82-02-07; 301/82-02-07) 0654 PLAN 1
The person, by title, authorized to request DOE Radiological Assistance has not been designated in the plan.
2b Provide more, detail as to who is to be sent to represent WEPCO at the principal offsite govern-mental emergency operations centers, at which emergency stage the person will be sent, and by whom.
E.
NOTIFICATION METHODS AND PROCEDURES (266/82-02-08; 301/82-02-08) 0654 PLAN 2
Provide a more detailed description of the pro-cedures for alerting and mobilizing emergency response personnel.
3 and 4 Copies of the initial notification and followup message forms should be readily available to personnel in the Control Room, TSC, the Emergency Support Center, and in the various county and State EOCs.
6 The time required to notify and provide instruc-tions to the public within the EPZ is not speci-fied in the plan.
Further, a description of the current system shall be provided in the plan.
F.
EMERGENCY C0HNUNICATIONS (266/82-02-09; 301/82-02-09) 0654 PLAN 1
Specify organizational titles and alternates for both ends of the communications links. Describe the specific location for the EOCs in Kewaunee and Manitowoc Counties.
2 Provide specific information on communications for l
fixed and mobile medical support facilities.
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Appendix C 3
0654 PLAN 3
Section 7.2 Provide a testing schedule frequency for communica-tions systems including all licensee communications systems.
G.
PUBLIC EDUCATION AND INFORMATION (266/82-02-10; 301/82-02-10) 0654 FLAN 4
Provide an explicit statement in the position des-cription of Emergency News Center Director that he/she will have accesa to all necessary informa-tion and that exchange of information is timely.
Provide arrangements for dealing with rumors.
5 Modify the description of the news media informa-tion program to include specific details regarding emergency plan information and points of contact for release of public information.
H.
EMERGENCY FACILITIES AND EQUIPMENT (266/82-02-11; 301/82-02-11) 0654 PLAN 1
The plan does not indicate that timely activation of the TSC and EOF will been ensured. This shall include provisions to activate the TSC within 30-60 minutes and the EOF within one hour.
I.
ACCIDENT ASSESSMENT (266/82-02-12; 301/82-02-12) 0654 PLAN 3
Not addressed 4
Not addressed 5
Make meteorological data available to the Emergency l
Support Center (ESC used as EOF), TSC offsite NRC Center, and to the State.
6 Not addressed.
8 Not addressed except communications and equipment.
10 Not addressed.
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Appendix C 4
J.
PROTECTIVE RESPONSE (266/82-02-13; 301/82-02-13) 0654 PLAN 5
. No assurance of accountability of onsite personnel within 30 minutes is given.
7 The mechanism for recommending protective actions to the responsible offsite authorities is not explained in the plan.
10a Maps showing preselected radiological monitoring and sampling points are not provided.
K.
RADIOLOGICAL EXPOSURE CONTROL (266/82-02-14; 301/82-02-14) 0654 PLAN 1
Thyroid emergency exposure guides are not provided.
L.
MEDICAL AND PUBLIC HEALTH SUPPORT (266/82-02-15; 301/82-02-15) 0654 PLAN 4
Appendix D The letter of agreement with the City of Two l
Rivers does not provide for an emergency vehicle for the transportation of victims of radiologi-cal accidents and no letter of agreement is in-cluded with the Two Rivers Fire Department regard-ing this matter.
M.
RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS (266/82-02-16; 301/82-02-16) 0654 PLAN 4
Provide a method for periodically estimating total population exposure in the post-accident phase.
N.
EXERCISES AND DRILLS (266/82-02-17; 301/82-02-17) 0654 PLAN la Make provisions for providing correspondence to the NRC regarding exercises.
Ib Modify the plan to include conducting of exercises under various weather conditions and conducting some exercises unannounced.
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Appendix C 5
0 0654 PLAN 2a Upgrade the frequency for testing communications with State and Federal emergency response organi-zations to quarterly from annually.
2c Provide for the participation of the ambulance services with the biannual medical drill.
2d Include testing of communications and record keep-ing in Radiological Monitoring Drills.
3 Describe how drill critiques will be used as formal evaluations.
O.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING (266/82-02-18; 301/82-02-18) 0654 PLAN 3
Specify that individuals on the first aid team will receive training equivalent to Red Cross Multi-media training.
P.
RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS (266/82-02-19; 301/82-02-19) 0654 PLAN 1
4 Provide a mechanism which provides for the annual certification that the plan is current.
8 Provide a cross-reference for NUREG-0654 criteria to sections of the plan.
9 Provide an audit program covering interfaces with State and local governments. Reports of audits shall be sent to the involved Federal, State, and local organizations.
10 The Emergency Plan does not provide for quarterly i
updating of telephone numbers in emergency procedures.
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I Appendix D Open Items The following is a list of Open Items identified in the area of emergency preparedness which will be re-examined by the staff.
1.
Completion of the exercise scheduled for March 1982.
(Section 5.5.2)
(266/82-02-20; 301/82-02-20) i 2.
Completion of the Permanent Technical Support Center.
(Section 4.1.1.2) 266/82-02-21; 301/82-02-21) 3.
Completion of the Permanent Emergency Operation Facility.
(Section 4.1.1.4)
(266/82-02-22; 301/82-02-22) 4.
Installation of the Post Accident Sampling System, including upgrading of (1) the primary coolant sampling (2) containment atmosphere sampling and (3) various station effluent sampling.
(Sections 4.1.1.5 and 4.1.1.6)
(266/82-02-23; 301/82-02-23) 5.
Installation of steam line monitors and calculation of EALs for these monitors.
(Section 4.1.1.7) (266/82-02-24; 301/82-02-24) 6.
Installation of the high range containment dome monitor including calculations of EALs for this monitor.
(Section 4.2.1.2)
(266/82-02-25; 301/82-02-25) 7.
Completion of the permanent Operational Support Center.
(Section 4.1.1.3)
(266/82-02-26; 301/82-02-26) s d
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