ML20058C720

Presents Rationale for Not Committing to Meet NUREG-0654, Section N.1.b in Emergency Plan

ML20058C720
Person / Time
Site:	Kewaunee
Issue date:	06/25/1982
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	Grimes B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
Shared Package
ML20058C693	List: ML20058C720
References
CON-NRC-82-101, RTR-NUREG-0654, RTR-NUREG-654, TASK-3.A.2.1, TASK-TM TAC-46241, NUDOCS 8207260430
Download: ML20058C720 (2)

Text

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NRC-82-101 WISCONSIN PU B LIC S ERVICE CO RPORATION P.O. Box 1200, Green Bay, Wisconsin 54305

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June 25, 1982 Mr. Brian Grimes Director of Emergency Preparedness U. S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014

Dear Mr. Grimes:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Off-Hours Exercises Recently WPS has been requested to address guidelines that were presented in NUREG-0654 " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." Specifically, Section N.l.b which requires " start an exercise between 6 P.M. and midnight, and another between midnight and 6 A.M. once every six years...Some exercises should be unannounced."

We feel that exercises conducted during off-normal hours do not provide an increase in the level of preparedness coimaensurate with the risks and inconvenience it causes.

The risk of serious injury to responding personnel is increased during off-normal hcurs due to travel required under limited visibility conditions.

This point is of great concern to Wisconsin Public Service Corporation (WPS).

WPS has established a fine working relationship with the affected counties (Manitowoc and Kewaunee) which may be jeopardized by imposing further inconveniences on voluntary emergency response personnel.

WPS believes that this exception to Item N.l.b of NUREG-0654 is justified since mr emergency preparedness is assured during off-normal hours. This assurance is

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demonstrated by the following:

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1) Diverse communication networks are in place which are checked frequently and demonstrated annually, o

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2) The counties have shown their willingness and ability to respond and there is no reason to assume they would not during off-normal

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3) Potential problems caused by off-normal hours have been considered Oo in development _of Jhe R1an and_ proc.ed.uresL (off.tce phone. home pho,ne m a.tt JUN2b M Emergency Hotline number, etc.)

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Mr. Brian Grimes June 25, 1982 Page 2

4) WPS personnel are available to respond and can be reached through normal telephone channels or through a pager system.

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Reference:

Procedures EP-AD-7 thru 10)

To assure communications links, unannounced "1st level" communications checks will be performed on a quarterly basis. The communication check will require plant personnel to notify the Manitowoc and Kewaunee county sheriff's dispatcher and the State Department of Emergency Government -Duty Officer and provide a message. The communication check would be complete and successful when the respective dispatcher /

duty officer returns our initiating call (within a 15-minute period) and demonstrates an understanding of the original message. We believe proof of this initial notification capability will assure a path of further off-site agency activation if warranted.

WPS does not intend to mobilize any personnel during these checks and does not expect mobilization of any of the support agency personnel. The purpose of the check is to test the notification mechanism to appropriate support agency directors who in turn could mobilize their personnel if necessary.

We believe our emergency preparedness program has been proven successful, including off-site agencies who have proven their competence whenever called upon. Therefore, we feel that we are in compliance with the regulation as stated in 10CFR50, Appendix E,Section IV.F.1 thru 3.

In keeping with the fact that NUREG-0654 is a guidance document our commitment, as explained in this letter, exceeds the requirements stated in 10CFR50, Appendix E.

This method of compliance has been discussed with our Region III reviewer and we will make it effective within thirty (30) days after receipt of review or resolution of outstanding items.

Very truly yours,

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Carl W. Giesler Vice President - Nc;I ar Power js l

cc - Mr. C. Paperiello - NRC, Region III Mr. J. A. Pagliaro - NRC, Region III Mr. Robert Nelson - NRC Sr. Resident Inspector l

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