ML20112G126

Responds to NRC Re Weaknesses Identified in Insp Rept 50-305/84-07 Concerning Min Shift Crew Size.Corrective Actions:Emergency Plan Will Be Revised to Include Description of Shift Augmentation Drill

ML20112G126
Person / Time
Site:	Kewaunee
Issue date:	09/20/1984
From:	Hintz D WISCONSIN PUBLIC SERVICE CORP.
To:	Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20112G104	List: ML20112G126 ML20112G135
References
CON-NRC-84-156 NUDOCS 8501160197
Download: ML20112G126 (8)

Text

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NRC-84-156 WISCONSIN PUBLIC S ERVICE CO RPORATIO N P.O. Box 1200, Green Bay, Wisconsin 54305 September 20, 1984 Mr. J. A. Hind, Director Division of Radiological and Materials Safety Programs U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Hind:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Inspection Report 84-07

Reference:

Letter from J. A. Hind (US NRC) to C. W. Giesler (WPSC) dated June 6, 1984, transmitting Inspection Report 50-305/84-07 The attachments to this letter detail our response to Emergency Preparedness weaknesses identified in Inspection Report 50-305/84-07 (DRSS), and to your stated concern regarding the minimum shift crew size at KNPP.

Very truly yours, D. C. Hintz Manager-Nuclear Power CAS/js Attach, cc - Mr. Robert Nelson, US NRC Mr. S. A. Varga, US NRC 8501160197 850109 SEP 2 4 sg4

$DRADOCK 05000305 PDR

Mr. 'J. A. Hind N1-24.0A September 20, 1984 Attachment 1 Emergency Preparedness Weaknesses

-1. Provide a description of the shift augmentation drills and the frequency -

with which they will be conducted in the Kewaunee Emergency Plan'(0 pen Item No. 305/84-07-01) (Section 6).

2. Incorporate time-averaged meteorological parameters into the dose assessment calculations (0 pen Item No. 305/84-07-02) (Section 8).

Response

The Emergency Plan for Kewaunee Nuclear Plant will be revised to include a description of our shift augmentation drill including the frequency with

- which they are conducted. This change will be incorporated in the annual review of the Emergency Plan which will be completed by March 1985. It should be noted that procedures are in place and implemented which provide for these drills.

Time averaged meteorological parameters, windspeed and wind direction, will be added as data points on the Honeywell Plant Process Computer. These parameters will also be included in the EPIP's. The wind speed parameter has already been added to the computer data base and displays, and the procedures are being ,

revised to include average wind speed at this time. These revisions will be completed by December 1, 1984. The wind direction parameter requires significantly more programming time, but will be added to the computer by June 1, 1985. The EPIP's will also be revised to include this parameter by June 1, 1985.

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Attachment 2 4

Shift Staffing .-

WPSC was surprised to learn of the NRC's unawareness of our actions regarding shift staffing. As you noted in inspection report 50-305/84-07, we informed i you of our intended actions well in advance by letter dated April 15, 1983, *

'from D. W. Giesler-(WPSC) to D. G. Eisenhut (NRC). In addition, revision 3

' - of'KNPP emergency plan clearly identified this change. Our letter of May 11, 4

1984,efrom C. W. Giesler to J. G. Keppler, transmitted several documents which -

5 noted this change:

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Attachment I to that letter provided a description of the 1984 annual review of the~ Emergency Plan. Page 1 of attachment 1, under "Section 5",

item b. notes, "The Communicator has been removed as a designated position and made-an assigned position."

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-Attachment 2 to_that letter provided our safety evaluation of the proposed

changes.

Theisafety evaluation for shift staffing changes begins on page 2, and notes as -'

follows:.

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1 Description of Change

Theifollowing changes were made due to the addition of the Control Room-Supervisor to the plant operating shift staff

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1.. ..The Control Room Supervisor.will assume the responsibilities

. of the Emergency Director if for some reason the Shift

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5:ptember 20, 1984

'Page 2 Supervisor becomes incapacitated. This responsibility previously belonged to the Shift Technical Advisor.

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2.: The on-shift communicator position has been deleted and it

. is-now the responsibility of the Shift Supervisor to assign a member of the operating staff to perform the initial off s

site notifications if necessary.

Safety Evaluation The Control Room Supervisor will be trained in the responsibilities of the Emergency Director and will be qualifie'd to fill the position if required.

-The intent to have an on shift staff member available for initial notifica-tions is still maintained. The Shift Supervisor will designate.a staff member as the communicator as the situation dictates. The reassignment of responsibilities does not decrease the effectiveness of.the plan.

Finally attachment 3-of the May 11 letter included the pages affected'by revi-sion 3. Pages 5-2 and 5-3 discuss the Operating Shift Organizations:-

5.1;l Plant Operating Shift Organization-a The plant operating' shift _ staff no'rmally consists of eight plant staff personnel-and an appropriate number of security personnel. The Shift

. Supervisor, who holds a Se.nfor Reactor Operator (SRO) license, is in direct charge of all plant operations.during his assigned shift and is-

, responsible'for the supervision and actions of.the operating personnel

'on the shift. The Shift. Supervisor will be assisted by-a Control Room

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- . September 20, 1984 Page 3 Supervisor who also holds an SR0 license. [ Effective after the 1984

.KNPP refueling outage]. Additional shift personnel include: a Control -

. Operator "A" and Control Operator "B" who hold Reactor Operator (RO) licenses, an Auxiliary Operator, an Equipment Operator, a Radiation

. Technologist, a Chemistry Technologist (per the shift schedule stated in 5.1 above), and a Shift Technical Advisor who will be available within 10 minutes to the Control Room during plant operation and a Security Shift Captain with supporting security officers. FIGURE 5-2 shows the composition of the plant operating shift organization. Duties and responsibilities of the operating staff are defined in the Plant's Administrative Control Directives. A member of the operating staff will be designated the communicatior should the need arise.

The basis for the revision is better understood through a review of the shift .

manning " requirement". WPSC initially committed to the staffing levels of Table B-1 in April of 1981. However, as implementation began (and the shift staff' size increased) we became concerned about having too many people on shift --

and the effect this could have on morale and productivity. Then, in his letter of December 17, 1982 (Generic Letter 82-33), Mr. D. G. Eisenhut stated that

. . . the staffing levels in Table 2 to the enclosure are only goals, and are not strict requirements."

'Our, interpretation of this statement was that it gave licensees the flexibility

'to determine the optimum staffing levels for their plants as determined on a case-by-case basis. It was in response to this letter that WPSC performed its t

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, September 20, 1984 Page 4-review of staffing and concluded that the levels as currently stated in our emergency plan are sufficient to ensure emergency preparedness. The NRC was then notified of our intent-in our April 15, 1983 letter.

, The justification for our current level of on-shift staffing is that it is sufficient to implement the actions described in the KNPP Emergency Plan.

In general, the responsibilities of the shift staff during the early phases of'an accident-are controlling plant response, initial notifications and protec-

~ tive action recommendations.by the Shift Supervisor (acting as the Emergency Director), if necessary. These responsibilities are guided by the emergency operating procedures and the emergency plan implementing procedures.

Notification are made using prepared messages. The procedures have been written in'a manner such that they can be implemented by the currently implemented staff.

Furthermore, in the past several years WPSC has exercised the procedures and emergency plan on at least four occasions (graded exercises and drills) utilizing an on shift staff.that is equal in number to the currently described staff.

! (Recall that the removal of the Communicator position has been offset by the- '

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. .' addition of the Control-Room Supervisor). WPSC demonstrated the ability to implement the required provisions of the emergency plan on'each of these' occasions thusfdemonstrating the sufficiency of the current staffing level.

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, Finally, in the longer term following an emergency connunications responsibility  !

will;be assumed ny the Technical Support Center staff, as noted in section

.L5.2.2.(2) of the KNPP emergency plan (page 5-8): ,

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5.2.2 (2) Notification / Communication Initial notification of emergency response personnel and the appropriate Federal, State, and local agencies will be directed by the Shift Supervisor

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upon the declaration of an emergency. The Shift Supervisor will designate a communicator and direct that individual to conduct the initial plant and corporate notifications and initial notifications of offsite emergency response agencies. These initial notifications will be sent using prepared messages. Upon the arrival of additional plant and corporate personnel and the activation of emergency response facilities, key notifications and com-munications are conducted-by personnel assigned as communicators at the Technical Support Center and the Emergency Operations Facility. ,

[ Communicators will be assigned by the Technical Support Center Director and the Emergency Response Manager.

In conclusion, WPSC has implemented an on-shift organization which is sufficient to carry out the actions required by the emergency plan. Although organized differently, the current number of on-shift staff has not changed since LJanuary,1983; this number (seven people on all shifts, plus the Chemistry *

, Technician on " augmented shift rotation" and the Shift Technical Advisor) ,

s was approved by NRC, at least on an interim basis.

'10 CFR 50.54(q) allows licensees to make changes to emergency plans,without Comission approval if the changes do not decrease the effectiveness of the-plans. .We encourage you to not consider " effectiveness" in terms of aggregate numbers, but in terms of the ability of the licensee to carry out o - his. Emergency Plan. -We do not believe that "more" is necessarily "better".

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' 5eptember 20, 1984 Page 6 Table B-l'of NUREG-0654'provided a guideline to compare staffing levels against without providing any justification for the numbers it recommended or for determining plant specific staffing levels. We believe we have provided sufficient justification for our staffing levels, and trust that it alleviates

=the concerns stated in your letter of August 6, 1984 (inspection report 7

50/305/84-07).

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