ML20081H059

Comments on SALP 3 Rept for Apr 1982 - Mar 1983.Disagrees W/Conclusion That Number of Personnel Errors Attributed to Operations Personnel Have Increased.Class a Meteorological Model Not Finalized Due to NRC Changes

ML20081H059
Person / Time
Site:	Kewaunee
Issue date:	07/18/1983
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20081H039	List: ML20081H059
References
CON-NRC-83-138 NUDOCS 8311070292
Download: ML20081H059 (5)

Text

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, a NRC-83-138 WISCONSIN P U B LI C S ERVICE CO RPORATIO N PO. Box 1200, Green Bay, Wisconsin 54305 July 18, 1983 Mr. J. G. Keppler, Regional Administrator Region III U.S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Keppler:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Comments on SALP 3

Reference:

Letter from J. A. Hind, US NRC, to C. W. Giesler, WPSC dated June 20, 1983 This letter provides our comments on the Systematic Appraisal of Licensee l

Performance (SALP) report transmitted to WPS with reference 1.

l l Most of our comments were discussed with you at the meeting held on June 24,

! 1983, in Glen Ellyn. We wish to thank you for the chance to meet and discuss the report, and as you know, we are in general agreement with this I favorable appraisal. As such, our comments are minor; yet, we feel they serve to clarify the respective discussions.

1. Operations Section b., Conclusion, points out that the number of personnel errors increased significantly and notes that, "Those errors, in conjunction with concerns regarding attentiveness of licensed operators to shift operations indicate that management including shift supervisors, needs to become more assertive and involved in the conduct of operations." Based on our review of Licensee Event Reports (LER's) which occurred over the SALP 2 and SALP 3 assessment periods, we disagree with the conclusion that the number of personnel errors attributed to operations personnel have increased.

During the SALP 2 assessment period of 17 months, 12 of 52 total LER's 8311070292 831104 \, N $@

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Mr. J. G. Keppler July 18, 1983 Page 2 were attributed to personnel error. Of these, we feel that four resulted from operations personnel error which is an annual rate of approximately three per year. (This conculsion agrees with the SALP 2 report--page 20 of that report tabulates the LER's for the assessment period, and page 5 notes that four were attributed to operations personnel.)

In comparison, during the SALP 3 assessment period of 12 months, 7 of 41 LER's were caused by personnel error; the SALP 3 report indicates that of these, 5 were attributed to operations personnel (page 5 of the SALP 3 report). However, our review of these seven LER's indicates that only 4 can be attributed to operations personnel error. We do not believe that this figure represents a trend towards an increase in the rate of LER's because the absolute number is so small (that is, 3 or 4 per year).

Furthermore, we feel it is important to note that SALP 3 covers a period during which we have increased our operations staff size significantly in order to comply with NRC staffing requirements. Generally, our program to provide a second SR0 on shift involved hiring about 20 additional people, and qualifying them as control room operators. They would then relieve the existing control room operators to allow this latter group the time to prepare for an SR0 exam. This has resulted in a dramatic decrease in the average experience level of the operations staff, including people who had a considerable amount of KNPP experience but were promoted to a different job. We feel that two LER's of the four attributed to operations person-nel error were due in part to this inexperience. Additionally, we do 3 not feel that these personnel errors are due generally to inattentiveness by the operations staff. While there may have been isolated cases of inat-tentiveness, we don't believe that these are pervasive or representative of the operations group as a whole.

The SALP 2 report concluded that for operations The licensee is rated a category 1 in this area primarily because of the excellent performance noted in the operations area which is attributable to aggressive and effective management, experienced and dedicated personnel, a low personnel turnover rate, and the effective maintenance of equipment operability.1 During the SALP 3 assessment period, we have continued the practice of aggressive management.

Specifically, we have placed knowledgeable individuals in key positions to enable a con' tant management overview of plant activities by individuals intimately familiar with plant operations. This involved placing seasoned shift supervisors into the operations (in a non-shift position), main-1L etter from J. G. Keppler to E. R. Mathews transmitting the SALP 2 report dated July 20, 1983, section 1.6., page 6.

.(

Mr. J. G. Keppler-

-July 18, 1983 Page 3 tenance and technical support groups. .If anything, we feel that we have increased management involvement in the operation of the plant during the SALP 3 assessment period.

. .Accordingly, we feel.that the following wording would be more appropriate for the last three sentences of the first paragraph of section 1.b.:

While the rate of personnel errors remained about the same, several were in part due to the licensee's continuing program to increase the operations staff size in order to comply with the NRC's Post-TMI

-requirement to provide two licensed Senior Reactor Operators on each L shift. This program has resulted in a decrease in the average experience level for each job in the on-shift complement. Management should continue its aggressive involvement in the conduct of opera-tions in order to minimize the number of these and all errors and to continue to promote a proper level of attentiveness to shift opera-tions by all personnel.

} 6. Emergency Preparedness Section a., Analysis, discusses our performance in regards to the 43 defi-cient items noted in various Emergency Preparedness inspection reports.

I The SALP report notes that: Of the 43 identified items reviewed, the

> licensee had corrected 27, 14 were only partially _ completed, and two 4

items concerning the installation of an upgraded meteorological F measurements system and Class A meteorology model were not completed.

It was felt that the licensee could have adequately resolved the 14 incomplete items if they had given more attention to such details as l

follow-up procedure changes and training of personnel...

r In our opinion, some of the 14 partially completed items referenced in the SALP report should have been closed out at the time of the last emergency l preparedness inspection on the basis that our actions, while different

from NRC suggested guidelines, formed an acceptable alternative to meeting l the basic requirement. More importantly, however, is the fact that we

! have not finalized our Class A meteorological model because the NRC's

! requirements have been changing in this area.

4 For example, as recently as December 17, 1982, after the inspection of

November 29 - December 3, 8-10, and 13,1982 (which was referenced in the SALP. report), the NRC issued Supplement 1 to NUREG 0737 (Generic letter 82-33) which revised the requirements with respect to meteorological data.

Prior to Generic letter 82-33, the meteorological requirements were spe-cified by NUREG 0737, Item III.A.2.2, which included the Class A and Class B model and. instrumentation requirements discussed in Proposed Revision 1 to Regulatory Guide 1.23. Generic letter 82-33 significantly changed these requirements: it no longer required a Class A or Class B model, or the instrumentation requirements of Regulatory Guide 1.23. (Reference sections 6.1.b, 8.4.1.a, and 8.4.1.g of Generic letter 82-33) In regards

Mr. J. G. Keppler July 18, 1983 Page 4 to meteorological data, Generic letter 82-33 states, "These requirements supersede the clarification of NUREG 0737, Item III.A.2.2."

Furthermore, at the regional meeting to discuss Generic letter 82-33 held at Arlington Heights, Illinois on March 4,1983, we sought additional clarification from this item. The following quote is taken from the transcript of the meeting prepared by Alderson Reporting:

MR. WALLACE: John Wallace, Wisconsin Public Service Perhaps we've covered this, but I want to ask a specific question. Do the requirements of 737 supplement I with regard to meteorological data processing supersede the recommendations of 0654 Appendix Z as a requirement?

19. MIRAGLIA: I believed we've answered that before, and the answer was yes.

We feel this item is important since, at our meeting on June 24, certain members of your staff indicated that in their opinion the requirements on meteorology have not changed over the last few years. It is important that we agree on the basic criteria to assure that future inspections in this area are based on a common level of understanding.

It is worthy to note that WPS has moved forward in the area of meteoro-logy, at risk, given that the requirements have been in a state of flux.

For example, we have procured and installed a new meteorological system (which, incidentally, has more instrumentation than currently required, since its design was based on the guidance of regulatory guide 1.23). We have also procured the necessary equipment for an inland tower (this is no longer a firm requirement). Finally, we have developed a model used for dose prediction.

Our actions and status on meteorology have been the subject of several conversations and letters to your staff. Based on our actions in meteoro-logy, which we feel easily exceed regulatory requirements, the fact that we have kept you apprised of our status, and the recent change in regula-tory requirements, we feel that the reference to meteorology in the SALP 3 report is inaccurate. We feel the reference should either be deleted, or would be more appropriately worded as follows:

.. 0f the 43 identified items reviewed, the licensee had corrected 27 and 14 were partially completed or awaiting further NRC review.

Implementation of two items concerning the installation of an upgraded meteorological measurements system and a Class A meteorology model is in progress, but completion has been delayed pending final clarification by NRC of the basic requirements.

9. Licensing Activities Section a. (3) discusses WPSC's responsiveness to NRC issues. The discussion notes that for a few issues, which are listed in the report,

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Mr. J. G. Keppler July 18, 1983 Page 5 the ND.C feels that WPS has been unresponsive. We would note only that a closer review of the history of these issues reveals that all are several years old. In this most recent SALP period, WPS has endeavored to resolve these issues to our mutual satisfaction, or has tried to clearly define those areas where a technical disagreement with the staff exists.

We appreciate the opportunity to comment on this report and the effort you have taken to appraise our performance.

As always, we will be happy to discuss these comments with you.

Very truly yours, C. W. Giesler Vice President - Nuclear Power js cc - Mr. S. A. Varga, US NRC Mr. Robert Nelson, US NRC f