ML20050C739

Discusses Util Response Re Emergency Plan Training, Emergency Plan Implementing Instructions,Meteorological Instrumentation & Unusual Event Notification Procedures. Response Appears Acceptable

ML20050C739
Person / Time
Site:	Point Beach
Issue date:	03/31/1982
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Burstein S WISCONSIN ELECTRIC POWER CO.
References
TASK-3.A.1.2, TASK-TM TAC-46115, TAC-46116, NUDOCS 8204090317
Download: ML20050C739 (2)

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UNITED STATES NUCLEAR REGULATURY COMMISSION n

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E REGION 111 e

799 ROOSEVELT ROAD CLEN ELLYN, ILLINOIS 80137 March 31, 1982 Docket No. 50-266 m

OJ Docket No. 50-301 9

[J Wisconsin Electric Power Coepany

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ATTN:

Mr. Sol Burstein S'

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Executive Vice President 9

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231 West Michigan 9

Milwaukee, WI 53201 x

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Gentlemen:

/m This is in reference to letters of February 18, 1982, from Mr. C. W. Fay, Assistant Vice President of WEPCO, in response to our Emergency Prepared-ness Appraisal of the Point Beach Nuclear Plant. Your response relevant to emergency plan training, emergency plan implementing instructions, meteorological instrumentation, and Unusual Event Notification procedures appears to be acceptable and will be examined by our staff during a subsequent inspection.

The NRC staff finds your position regarding minimum onsite emergency organization staffing to be unacceptable in that your proposed minimum staff will not meet the requirements of 10 CFR 50.47(b)(2) as delineated in NUREG-0654 by July 1, 1982, the date currently set by the Commission for full implementation in this area. While your compensatory measures now in place provide adequate protection for the miblic health and safety for the interim period up to July 1, 1982; thet

.cer, the NRC staff l

requires full compliance with 10 CFR 50.47(b)(2). We are particularly I

concerned that during the Emergency Preparedness Implementation Appraisal exit interview on January 15, 1982, Mr. Fay clearly stated that WEPC0 does not intend to change its position regarding minimum shift staffing.

Specifically, on July 1,1982, your minimum shift staffing will fail to comply with 10 CFR 50.47(b)(2) in the following areas:

(1) it does not l

provide qualified personnel for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day coverage of Chemistry /

Radiochemistry Accident Assessment to ensure timely impicmentation of l

post-accident sampling and analyses; (2) it does not provide a qualified person, who is not assigned any other emergency function, for prompt notification / communication to offsite authorities; (3) it does not provide three control room operators for plant operations and accident assessment 1

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MAR 3 0 G82 of operational aspects (only two control room operators are provided);

and (4) it does not provide for maintaining two Senior Reactor Operators (SR0s) onshift at all times (Operating Supervisors may or may not be SR0s under your plan).

NRC requires that the licensee must maintain enough expertise onsite at all times to implement the major functional areas required by 10 CFR 50.47(b).

The criteria the staff uses for adequate minimum staffing for nuclear power plant emergencies is listed in Table B-1 of NUREG-0654. These criteria have been generally met throughout the nuclear industry and the information you have given us to date provides no basis for applying lesser criteria than those of Table B-1 of NUREG-0654.

As a result of the above noted deficiencies, we will not be able to find, subsequent to July 1, 1982, that there is adequate assurance that the licensee will have sufficient resources (expertise and " hands") available to initially manage an emergency.

If these shift staffing deficiencies are not corrected by July 1, 1982, or other adequate measures implemented to ensure required shift staffing is maintained at all times, the NRC staff will find that the state of emergency preparedness does not provide reason-able assurance that appropriate protective measures can and will be taken in the event of a radiological emergency.

This is to inform you that the NRC intends to issue a Show-Cause or other appropriate Order to assure that adequate onshift staffing is provided.

We, therefore, believe it necessary to meet with you to resolve this impasse.

Please contact my office to arrange a meeting.

Sincerely, James G. Keppler Regional Administrator cc:

G. A. Reed, Manager DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII John J. Duffy, Chief Boiler Inspector Peter Anderson, Wisconsin's Environmental Decade Stanley York, Chairman Public Service Commission RIII RII A RIII)

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