ML20083D844

Responds to NRC Re Violations Noted in IE Insp Rept 50-305/83-13.Corrective Actions:Procedures EP-AD-3, Unusual Event, EP-AD-4, Alert, EP-AD-5, Site Emergency & General Emergency, Revised

ML20083D844
Person / Time
Site:	Kewaunee
Issue date:	11/17/1983
From:	Giesler C WISCONSIN PUBLIC SERVICE CORP.
To:	Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20083D828	List: ML20083D844
References
CON-NRC-83-205 NUDOCS 8312280311
Download: ML20083D844 (3)

Text

. 7

,- NRC-33-205 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 November 17, 1983 Mr. J. A. Hind, Director Division of Radiological and Materials Safety Programs U. S. Nuclear Regulatory Commissior.

Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Hind:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant IE Inspection Report 83-13 (DRMSP)

References:

1) IE Inspection Report 83-13 (DRMSP)

2) Letter f rom C. W. Giesler to J. G. Keppler dated September 12, 1983 j 3) Letter from J. A. Hind to C. W. Giesler dated l October 18, 1983 The attachment to this letter details our response to the unresolved item iden-tified in Inspection Report 83-13 (DRMSP) and further determined to be an item

, of noncompliance in Reference 3.

l Very truly yours, ,

(A b- k z C. W. Giesler Vice President - Nuclear Power DWS/js Attach.

cc - Mr. Robert Nelson, US NRC Mr. S. A. Varga, US NRC

\

e312gO311[hh$$5 PDR OCW PDR 0 NOV 211983

NRC6-16.2 ATTACHMENT Response to Item of Noncompliance IE Inspection Report No. 83013 (DRMSP)

Violation:

10CFR50.54(q) requires that nuclear power reactor licensees follow and maintain in effect emergency Plans which meet the requirements of Appendix E to 10 CFR Part 50 and the planning standards of 50.47(b).Section IV.B of Appendix E requires that a licensee's energency plans shall include information to demonstrate compliance with the following:

The means for determining the magnitude and for continually assessing the impact of the release of radioactive material shall be described, including emergency action levels that are to be used as criteria for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and shat type of protective measures should be considered within and outside the site boundary to protect health and safety.

10CFR50.47(b)(15) requires that those who may be called on to assist in an emergency be provided radiological emergency response training.

Section 6.4.2 of the Kewaunee Nuclear Power Plant Emergency Plan states in part -

that the Emergency Director has the authority to recommend protective actions to offsite authorities. Section 5.2.1 states in part that in the event of an inci-dent, the Shift Supervisor is initially the Emergency Director.

Contrary to the above, Shift Supervisors, initially the Emergency Directors, were incapable of determining when and what type of protective measures should i be considered outside the site boundary to orotect health and safety due to ina-dequate training in the procedures.

. .m

Response

Wisconsin Public Service accepts the violation as described and furthermore agrees tnat weaknesses in emergency procedures as identified in the inspection report could have hindered responsible personnel from initiating timely Protective measures. To correct these deficiencies, actions as described in reference 2 have been taken. Specifically, procedures, EP-AD-3 Unusual Ever t, EP-AD-4 Alert, EP-AD-5 Site Emergency, and EP-AD-6 General Emergency, nave been revised to include guidance for the Shif t Supervisor in making initial protec-

s'* - ..

Mr. J. A. Hind }

November 17, 1983

) Page 2 tive action recommendations to offsite authorities if dose projections or field sample analyses are not available. Additionally, a new procedure, EP-AD-19 Protective Action Guidelines, was issued to consolidate the initial protective action recommendations, the EPA protective action guidelines, and the HEW guide-lines for protection against ingestion of contamination. These procedural changes were completed September 29, 1983.

Training in these procedures and protective action guidelines for Shift Supervisors and staff SR0's has been completed with the exception of the simu-lator Supervisor who has been unavailable due to simulator start-up and valida-tion testing. His training will be completed prior to his next scheduled duty as Shift Supervisor, with the completion of these actions, WPS considers itself in full compliance.

To prevent recurrence, emergency plan and implementing procedures training is being incorporated into the licensed operator requalification training Program.

This will provide increased confidence that operators have received the required emergency training.

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