ML20053A212
| ML20053A212 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 05/19/1982 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20053A197 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654, TASK-1.A.1.1, TASK-1.A.1.3, TASK-1.C.5, TASK-1.C.6, TASK-3.A.2.1, TASK-TM TAC-44117, TAC-44118, TAC-46259, TAC-46260, TAC-48851, TAC-48852, NUDOCS 8205250087 | |
| Download: ML20053A212 (4) | |
Text
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I Wisconsin Electnc paara coupan 231 W MICHIGAN, P.O. BOX 2046. MitWAUKEE. WI 53201 May 19, 1982 Mr.
J.
G. Keppler, Regional Administrator Office of Inspection and Enforcement U. S.
NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
STAFFING LEVELS FOR EMERGENCY SITUATIONS POINT BEACH NUCLEAR PLANT On May 6, 1982, a meeting was held in Glen Ellyn with you and members of the NRC staff to discuss our letter of February 18, 1982 and to provide further details of the staffing at the Point Beach Nuclear Plant.
Three particular concerns of the NRC were discussed as follows:
1.
The need for the operating supervisor to have a SRO license in contrast to a RO license.
2.
The role of the fourth auxiliary operator during an accident.
3.
The need for a chemistry technician on shift at all times.
Regarding the license for the operating supervisor, Wisconsin Electric is committed to a goal of having the operating supervisor hold a SRO license and thus provide two SRO's on shift, the other being the shift supervisor.
However, there may be interim situations where a RO-licensed control operator has recently been promoted to the management position of operating supervisor and has not had the opportunity to be examined and granted a SRO license.
We will attempt to minimize such situations by appropriate advance planning but such interim situations cannot be ruled out.
In the event such a circumstance occurs where the operating supervisor holds a RO rather than a SRO license, the NRC will be notified and informed of actions being taken to return to a two SRO-on-shift situation.
- 8205250087 620519 PDR ADOCK 05000266 P
4 Mr. J. G. Keppler May 19, 1982 We are committed to the use of a third RO-licensed person on shift; this will be implemented as soon as necessary licenses are obtained.
However, on May 6 your staff informed us that it is the NRC's position thr.t this person is to be utilized in the control room to assist the control operator assigned to the unit affected by an accident in carrying out emergency procedures.
We pointed out that this basis had not previously been made clear to us nor do we agree that exclusive assignment to the control room is a necessary or best utilization of this individual.
As you are aware, the requirement for a third RO on shift was established in Mr. Eisenhut's letter of July 31, 1980 which stated that an additional licensed reactor operator (RO) shall be on site at all times and available to serve as relief operator for that control room".
(emphasis added)
Table B-1 to NUREG-0654 does not appear to establish the allocation of this third RO license to the affected unit as a second control
~
operator.
However, in an effort to resolve these staffing issues, we will commit to use of the third RO to assist the control operator on the affected unit.
Further, we agreed at the May 6 meeting to evaluate the feasibility of having the auxiliary operator assigned to the unaffected unit available, if necessary,
.o assist in coping with an accident.
We have further reviewed the situation and can now make such a commitment.
This commitment recognizes that with an emergency on one (affected) unit and the other Nnaffected) unit in normal power operation, there is no need or station requirement for the unaffected unit turbine building auxiliary operator to stay with his unit since all protective actions on the unaffected unit can be accomplished in and from the control room.
The real purpose of the unaffected unit turbine building auxiliary operator is to monitor the equipment for proper operation, perform required valve manipulations (infrequent during normal operating conditions), take local readings on selected parameters, do periodic testi.ng, and operate auxiliary systems (which can be
" abandoned" in an emergency), such as water treatment, potable water, circulating water pumphouse screens, service air, and gas turbine.
If a situation were to arise in the unaffected unit's turbine building which places the unit in jeopardy, the licensed reactor operator in the control room has the equipment to reduce load including turbine generator shutdown.
The ultimate shutdown would be to close the main steam stops, which takes main steam out of the turbine hall.
There would be no need for auxiliary operator attendance or follow-up to secure the turbine building located equipment.
In fact, some shutdowns (by trips) have occurred at Point Beach Nuclear Plant where little if any auxiliary operator attention was needed to be given to turbine and supporting secondary equipment for hours.
d Mr.
J.
G. Keppler May 19, 1982 You advised us that a person designated as notifier /
communicator must be on shift at all times; you will recall that during the meeting we proposed using the third RO-licensed person in this capacity.
You further stated that this requirement could be satisfied by assigning these duties to a non-operating shift person such as a security person.
We have further evaluated this concept and are willing to commit a security person to serve as notifier during the stages of an accident, approximately one hour, until appropriately relieved by augmentation personnel to act as communicator (s).
We believe that this will resolve your conLern on this matter.
It will, of course, take time to train such personnel.
We, therefore, expect to implement this concept sometime late in 1982.
We discussed at length the need for a rad / chem technician on shift.
We pointed out that 10 CFR 50.47 (b) (2), referred to in Mr.
J.
A. Hind's letter of April 26, 1982, specifies that adequate staff be maintained at all times but makes no reference to a rad /
chem technician nor to any other specific job description.
- Further, we also noted that NUREG-0654 and its references to minimum staff requirement is not regulation.
You advised us of current Commission and ACRS review of this matter which could, of course, alter this present situation.
Basically, we disagreed with the assumed need to perform chemistry analyses of primary coolant or other samples during early stages of an accident, particularly in view of the installation of additional radiation monitoring equipment required by the NRC as a result of the Three Mile Island accident.
We continue to believe that a rad / chem technician on shift at all times is not warranted and plan to continue with rad / chem technician coverage on the day shift six days per week plus the evening shift five days per week.
Finally, we reiterated comments from our February 18, 1982 letter that we believe that the NRC has not adequately considered differences between plant designs, locations, or arrangement in imposing Table B-1 as a minimum requirement on all licensees.
We also pointed out that little, if any, credit was apparently given by the NRC to the elaborate call-in system described in our February 18 letter.
In summary, we have provided detailed information to you concerning our position which, in our-opinion, supports our belief that the present on-site staff requirements at Point Beach are entirely adequate to protect public health and safety in the event of an accident.
Nonetheless, we hope that the additional
l I
i Mr. J.
G. Keppler May 19, 1982 commitments in this letter, which result in an on-shift comple-ment averaging 10-88/168 persons available to cope with emergencies, adequately resolve your concerns and that we may receive your prompt concurrence.
I Very truly yours, l
O.-
[L' I
Assistant Vice Pr sident C. W.
Fay Copies to NRC Resident Inspector D. G. Eisenhut, NRC /
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