ML20138B548

Requests Overtime Deferment of Annual Requirements for Emergency Plan Exercise to Period Between Jan-Feb 1987. Schedule Results in Exercise Being Conducted During Refueling Outage.Situation Undesirable.Fee Paid

ML20138B548
Person / Time
Site:	Wolf Creek
Issue date:	03/20/1986
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
KMLNRC-86-047, KMLNRC-86-47, NUDOCS 8603250101
Download: ML20138B548 (4)

Text

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KANSAS GAS AND ELECTRIC COMPANY TI E ELECT AC COMPANY GLENN L KOESTER wsCE P8tES10ENT esvCLE Am March 20, 1986 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 KMLNRC 86-047 Re: Docket No. STN 50-482 Ref: 1. KMLNRC 85-174 from GLKoester, KG&E to HRDenton, NRC, dated 07/08/85

2. Letter from JEGagliardo, NRC to GLKoester, KG6E, dated 01/16/86 Subj : Temporary Exemption to 10 CFR 50, Appendix E, Section IV.F.2

Dear Mr. Denton:

The purpose of this letter is to request a one time exemp_ ion to 10 CFR 50, Appendix E, Section IV.F.2 pursuant to the requirements of 10 CFR 50.12.

Kansas Gas and Electric Company (KG&E) requests the granting of a one time deferment of the annual requirements for an emergency plan exercise from our currently scheduled date of November 5, 1986 to a time period between January 1 and February 28, 1987.

Appendix E, Section IV.F.2 of 10 CFR 50 requires each Licensee at each site to annually exercise its emergency plan. As stated in Reference 1, KG&E had reserved November 5, 1986 as the date for the Wolf Creek Generating Station 1986 Emergency Plan Exercise. When the November date was established, the first refueling outage for Wolf Creek Generating Station was scheduled for April 1987. However, due to better than expected plant performance during Cycle 1, the re. fueling outage has now been rescheduled for October 1986 with a duration of approximately 6 to 8 weeks. However, if unanticipated problems arise during the outage, it could potentially extend beyond the end of the calander year. Therefore, the current schedule results in the Emergency Plan Exercise being conducted during the refueling outage. KG6E believes this situation is extremely undesireable for the reasons discussed below.

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Mr. H. R. Denton KMLNRC 86-047 Page 2 March 20, 1986 Conducting the emergency plan exercise coincident with the outage would dedicate plant personnel to the emergency exercise who would normally perform vital functions during the outage. A significant number of these people are key supervisory and management personnel. The dedication of approximately 130 nuclear department personnel to the pre-exercise and exercise during Refuel I would reduce plant coverage during a time when workload demand is heavy. In addition, removing personnel from their normal duties may impact personnel safety during the outage, especially in the areas of health physics and security. The large number of health physics personnel involved in an emergency plan exercise would place an undue burden on the health physics staff required for an outage. Also, additional contract personnel on site during an outage as well as increased security coverage required for special outage activities would place an additional burden on security personnel. Therefore, the outage may have to be extended under these circumstances in order for KG&E to provide the necessary coverage to the emergency plan exercise and to assure a safe and controlled refueling outage. This, combined with the added workload on the remaining plant staff and the economic impact from an outage extention, makes the performance of the 1986 exercise during Refuel 1 undesirabic.

The Commission has provided that special circumstances must be present for an exemption request to be considered. They have further provided that.

special circumstances exist when, "The exemption would provide only temporary relief from the applicable regulation and the Licensee or Applicant has made good faith efforts to comply with the regulation;". This temporary exemption request fully complies with this example of "special circumstances".

After the decision was made to reschedule Refuel 1, efforts have been made to comply with 10 CFR 50, Appendix E, Section IV.F.2 by evaluating the rescheduling of the Emergency Plan Exercise to September 1986. Discussions with offsite agencies determined that the field exercise could not be held prior to October 1. This determination was based on the State of Kansas" discussions with FEMA in which FEMA stated they already had exercises scheduled for August and September , and FEMA's fiscal years 1986 travel funds had already been allocated. Wolf Creek Generating Station 1986 emergency exercise was allocated in FEMA's 1987 fiscal year budget. FEMA could, per the State of Kansas, support an exercise af ter November, 1986 and prior to June, 1987.

In addition, conducting the pre-exercise and exercise just prior to the outage would impact outage preparation by taking key personnel away from outage planning and other pre-outage activities. Procedure planning is one of the keys to a safe and successful outage. Therefore, KG&E believes it is undesireable to conduct the exercise just prior to Wolf Creek Generating Station's first refueling outage.

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Mr. H. R. Denton KMLNRC 86-047 Page 3 March 20, 1986 The emergency response organization in the performance of the November 1985 Emergency Plan Exercise demonstrated that the Emergency Plan program is ". .

adequate to protect the health and safety of the public" (Reference 2). The Emergency Plan program remains in place and plant personnel and equipment are in a continued state of. readiness to fully implement the Emergency Plan should the need arise. The proposed change involves only the timing of the performance of the Wolf Creek Generating Station 1986 emergency plan exercise and does not modify or increase the probability or consequences of an accident, or present a significant safety hazard. The delay in the schedule will also not present an undue risk to the public health and safety.

Since this is a temporary exemption, the 1987 Emergency Exercise will be performed in 1987 also.

Enclosed is a check (No. 2159) for the $150.00 application fee required by 10 CFR 170.21. If you have any questions concerning this matter, please contact me or Mr. O.L. Maynard of my staff.

Very truly yours, Glenn L. Koester Vice President - Nuclear GLK:see Enclosure cc: P0'Connor (2)

JCummins CHackney l

STATE OF KANSAS )

) SS CITY OF WICHITA )

s Glenn L. Koester,- of lawful age, being first duly sworn upon oath . .

says that he is Vice President - Nuclear and an Officer of Kansas Gas and Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed that same for and on behalf of said Company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

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By Glenn L. Koestet Vice President - Nuclear SUBSCRIBED and sworn to before me this 1 day of kGJ\(.h 1986.

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