ML20205P393

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Responds to NRC Re Exercise Weakness Noted in Insp Repts 50-266/88-21 & 50-301/88-19.Concepts of Operation Discussed W/Persons Qualified to Fill Plant Operations Manager & Site Manager Positions
ML20205P393
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 10/31/1988
From: Fay C
WISCONSIN ELECTRIC POWER CO.
To:
NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
CON-NRC-88-098, CON-NRC-88-98 VPNPD-88-516, NUDOCS 8811080112
Download: ML20205P393 (3)


Text

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%%SC00 Sin Electnc m cova 231 W VICHIGAN.P O BOX 2046,MrLWAUKEE.W15320I (414)221 2345 VPNPD-88-516 NRC-88-098 october 31, 1988 l

l U.

S. NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station P1-137 l

Washington, D. C.

20555 Gentlement l

DOCKETS 50-266 AND 50-301 INSPECTION REPORT 50-266/88021(DRSS)

AND 50-301/88019(DRSS)

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Your letter of October 6, 1988 forwarded Inspection Report 50-266/88021 and 50-301/88019, which described results of a routine, announced inspection of the Point Beach Nuc1 car Plant emergency preparedness exercise by members of your staff on September 12-16, 1988.

The letter requested that we advise you, within 45 days of the letter date, of corrective actions we have taken, or plan to take, with regard to the weakness identified in your report.

Although a written reply regarding the exercise weakness is not normally required, we have provided a written response as an attachment to this letter.

Very truly yours, G

hv C. W.

Fhy Vice President Nuclear Power Enclosure topies to NRC Regional Administrator, Region III (Attention: W.

D. Shafer)

NRC Resident Inspector R.

S.

Cullen, PSCW g!OB0122881031 O

A OCK 05000266 of PNu

ATTACHMENT WEAKNESS:

"Licensee poisonnel failed to declare a General Emergency when scenario plant conditions requiring this classification, por the Emergency Action Lovels (EALs), were reached during the latter part of the exerciso.

These conditions were:

(1) primary coolant leak exceeding 1000 gallons por minutos (2) loss of containment integrity, cither visually or por control board status lights; and (3) coro exit thermoccupies exceeding 700 degrecs F.

These conditions were not recogni:cd and a contir.gency message was issued by a Contro11cr to prompt the declaration of a General Emergency."

ITEM NUMBER:

266/88021-01 DISCUSSION:

It is recogni:cd that exerciso players did not, as a result of their own observations and decision-making, declare a General Emergency during the September 14, 1988 Emergency Plan exerciso.

The failure to declare a General Emergency during the exercise is not, however, indicative of a generic problem.

it is one which applies to the specific scenario and to

Rather, the particular group of players responding to that scenario.

Scenario writers were aware that the General Emergency declaration might not be made by players for the following Category 1 of the Emergency Classification table reasons:

describes, as a General Emergency, an event in which (1)

"primary system leakage is greater than 1000 gpm as indicated by mass balance," and (2) "containment integrity is lost as indicated by visual observation or containment status lights "core exit thermocouples >700 degrees F, average."

dim," and (3)

The scenario did not provide for all conditions required for declaration of a General Emergency.

Specifically, (1) Primary system leak rate was icss than 1000 gpm but, due to scenario conditions, the Icak rate was not easily quantifiabic.

Although the leak rate was less than 1000 gpm, this point of the scenario was particularly serious because events resulted in a condition where all sources of make-up water to the reactor coolant system (RCS) had been disabled.

Scenario writers expected exercise players to follow a conservative path and assume that the "greater than 1000 gpm" condition had been (2) Containment integrity was not actually lost; however, met.

scenario events resulted in a condition which gave control room indication of lost integrity.

Finally, (3) Only four of the thirty-nine thermocouples for which scenario data were presented indicated temperatures exceeding 700 degrees F.

The instantaneous core temperature average remained below 700 degrecs F.

Attachment October 31, 1988 Page 2 Given this set of simulated conditions, declaration of a General Emergency was not required.

Doing so, however, would certainly have been the conservative approach, especially in view of the fact that some of the simulated plant conditions were, by scenario design, unknown to the players.

The scenario writers expected a General Emergency declaration as the conservative choice, but anticipated the possibility that the General Emergency declaration might not be made.

The latter, of course, was how the event played out.

This discussion indicates that a declaration of General Emergency was not absolutely required when all portinent details of the scenario are considered.

Our review of player actions during the subject scenario period, however, identified a weakness in the communication and management of these details.

Accordingly, the following responso describes a correctivo action which will be taken to address the weakness identified by both your inspection team and our observers.

RESPONSE

Although the Plant operations Manager (POM) is responsible for deciding on event classification, there is no single position in the Technical Support Conter (TSC) assigned the task of continuously monitoring Emergency Action Levels (EALs).

In response to this exercise weakness, the task of EAL monitoring will be specifically assigned to a technical persan in the TSC.

Following activation of the TSC, this person would be responsibic for continuously evaluating event classification by verifying that the existing EAL is appropriate, based upon availabic data.

In addition, this person would (1) identify key data "trigger points" which could result in a change in EALs, (2) serve as a clearing house for information pertaining to EALs, and (3) serve as the primary advisor to the POM concerning EALs.

We have discussed this concept of operation with all persons qualified to fill the POM and Site Manager positions and consider the practice to be fully impicmented.

Formal implementation, however, may require a revision to the EPIPs or the development of position "task lists" similar to those now in use at the EOF.

Procedure revision and/or "task list" development will be completed by Marc:5 1,

1989, i

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