ML20245F298
| ML20245F298 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/03/1989 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-89-093, CON-NRC-89-93 VPNPD-89-427, NUDOCS 8908140227 | |
| Download: ML20245F298 (5) | |
Text
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x I u7 ', e WISCORSin Electnc ma coum 231 W. MICHIGAN,P.O. BOX 2046 MILWAUKEE.WI53201 (414) 221-2345 VPNPD-89-427 NRC-89-093 August 3, 1989 U.'S.
NUCLEAR REGULATORY COMMISSION Document Control Desk Mail Station Pl-137 Washington, D. c.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 REPLY TO ' INSPECTION REPORTS 50-266/89013;50-301/89012
' POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Your letter of June 21, 1989 forwarded Inspection Reports 50-266/89013;50-301/89012, which described results of a special inspection conducted by Mr. G. Shear on May 22-25 and June 14, 1989.. Your letter indicated that our May 10,.1989 response to open Item 266/89008-02 did not adequately address the exercise weakness cited in Inspection. Reports 50-266/89008;50-301/89008.
Specifically, you indicated that our "... training program may not be training personnel as well as intended."
You asked that we respond again to that exercise weakness within 45 days.
In light of Mr. Shear's inspectI.on, we have reevaluated our response to the exercise weakness and have provided, as to this letter, a revised-written response to the weakness.
i In addition, we wish to inform you of progress made on other emergency planning open items (see Attachment 2).
If you han any questions regarding matters discussed in this letter or its attachments, please contact our Emergency Planning Coordinator, David Stevens, at 414-755-2321.
Very trul
- yours,
[Wf V d.. Fay C -
e President 8908140227 890B03 n
DR ADOCK 0500 6{
uclear Power G
Attachments
-Copies to NRC Regional Administrator - Region III N
NRC Resident Inspector p
g
ATTACHMENT 1 RESPONSE TO INSPECTION REPORTS 50-266/89013;50-301/89012 Weakness:
" Licensee personnel did not recognize and aggressively pursue the existence of the (scenario) con".ainment release path.
Additional time elapsed before an in-plant team was dispatched with the specific mission to actively identify and correct the condition.
As a consequence, a radiological release to the environment would have existed for more than three hours that was correctable, per the scenario, by local closure of a single valve.
Failure to close this valve would have resulted in an unnecessary exposure to the public."
OPEN ITEM 266/89008-02
Response
The PBNP Emergency Plan Training Course (TRCR 80.0) has been revised so that persons identified as requiring specialized training will participate annually in at least one of two types of training activities.
Classroom training (focusing on organizational matters such as facility activation, communications, and accident classification) should be alternated annually with participation in a drill activity.
The drill activity (drill, exercise, table-top drill, or walkthrough) will focus on data analysis and problem solving.
This change to the emergency plan training course was issued on August 1, 1989, and will be implemented beginning l
September 15, 1989.
l In addition, as noted in our earlier response to this open item, we will provide an opportunity for the PBNP Emergency Response g
Organization (ERO) to participate in a drill or exercise scenario in which effective player response can result in a release termination.
Timely recognition of the release path and aggressive termination response will be specified as evaluated drill or exercise i
objectives.
This action will be completed by April 1, 1990.
i
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ATTACHMENT 2 Open' Item 266/88007-1 regarding annual training for all personnel assigned duties in the Emergency Plan
'The PBNP Emergency Response Course (TRCR 80.0) was revised on September 15, 1988 to provide for annual training'of persons assigned to the Emergency Response Organization (ERO).
A revision
.to the PBNP Emergency Plan (Section 8.0) was issued on January 19, 1989, which reflected'the commitment to conduct, on an annual basis, specialized training for persons having specific duties associated
.with the Emergency Plan.
The PBNP Training Group has been conducting specia?.ized training, and it is our intent to have all members of the Emergency Response Organization (ERO) included under the annual training definition by September 15, 1989.
Open Item 266/88021-02 regarding EOF management review of hard-copy status updates to state and county officials We have revised appropriate forms to provide for review by management prior to transmittal off site.
Resolution of this matter was successfully demonstrated during our in-house dril? of-February'22, 1989 and our observed exercise of March 15, 1989.
.Oggn Item 266/88023-01 regarding the October 1988 failure o,f_the siren monitoring system
.The siren status monitoring system which failed in October 1988 is
.not a. required system, and failure-of the monitoring system did not 1
adversely affect the ability to activate the sirens.
Sho.itly after the failure, our siren contractor' replaced circuit boards in the sensing / telemetry devices at a number of siren, sites.
Replacement i
of the circuit boards has apparently resolved the problem.
1 Open Item 266/89008-01 regarding coordination of the flow of information from the control room tu off-site agencies In our response to Inspection Report 266/89008, we requested that i
you reevaluate and consider closing this open item.
Our request was based upon statements in the inspection report which suggested a misunderstanding of how a number of EPIP forms and procedures are j
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used.
This item was discussed with Ms. M.
Smith immediately following receipt of the inspection report and again with l
Mr. J. Foster during his inspection of July 1989.
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4 Open Item 266/89008-03' regarding activation of the Osc concurrently with the TSC Revision 31 of EP 5.0, " Organizational Control of Emergencies",
and Revision 26 of EP 4.0
" Emergency Conditions", were issued on July-28, 1989.
The revisions provide for activation of the Operations Support Center (OSC) concurrent.with the TSC.
Revisions have also been made to a number of implementing procedures which will be issued in the near future.
Open Item 266/89008-04 regarding revision j
of emergency kit inventories j
Based upon your recommendations, the quantity of anti-contamination-clothing in OSC emergency kits has been increased and the checklists (EPMPs-1.lc, -1.lf, -1.11, and -1.11) used for periodic inventories have been revised to reflect the changes made.
Open Item 266/89008-05 regarding poor sample handling techniques by off-site field teams Under the provisions of our Training Needs Analysis (TNA) program, the Training Group has evaluated the existing training course for health physics technologists and has concluded that contamination control issues identified in the inspection report are adequately addressed.
The actions observed do not represent a performance norm, but rather were isolated cases of individual performance by less experienced health physics technologists.
This has not been a problem in previous drills and exercises.
To address this issue, however, each of the "... poor sarcple handling techniques..." described in your inspection report was discussed in detail at a Health Physics Group meeting on June 28, 1989.
The meeting was attended by virtually all members of the Health Physics Group.
We anticipate closure of this item following our next observed Emergency Plan exercise.
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i Unresolved Item 266/89008-06 regarding the inability to obtain a containment air sample when containment air pressure exceeded 5 psig We are evaluating our post-accident containment atmosphere sampli system to determine which component (s) result in the 5 psig pressure limitation.
We are working with the equipment supplier and manufacturer on this matter.
If the existing systems prove, in fact, to be limited to a sample side pressure of 5 psig, a modification to the system will be initiated such that samples can be obtained and analyzed within three hours of the request for such data.
Several options are being evaluated.
Unresolved Item 266/89008-07 regarding the lack of a procedure for counting an air sample having elevated levels of radioactive iodine A draft procedure has been developed which will allow for a rapid estimation of nuclide activities in air samples having elevated iodine levels.
Our approach to this procedure was discussed with Mr.
J. Foster during his inspection of July 1989.
We are continuing our review and verification of the procedure and anticipate closure of this item fo31owing the procedure's initial issue.
Open Item 266/89013-01 regarding discrepancies in training records Emergency response training records for the last two years have been reviewed and several discrepancies were noted.
The discrepancies, however, involved date entry errors which, in me.;t cases, were incorrect by only one day.
This concern was discussed with the training records clerk and she displayed a clear understanding of her responsibilities.
She also demonstrated knowledge of Clerical i
Guideline 11.15, " Training Record Entries and File Maintenance."
This guideline provides clear direction on entering training dates on training records.
Open Item 266/89013-02 regarding records being easily auditable and to verify that the requirements of the training program are being met l
We are currently developing a PC-based tracking system to easily identify qualifications for members of the Emergency Response Organization (ERO).
Development is about 25% complete, and we anticipate implementation by September 15, 1989.
In addition, responsibilities have been assigned for long-term resolution of this mhtter.
It is anticipated that a comprehensive computerized training records system will be procured during fiscal year 1990.
In the interim, a number of improvements to the manual system are being considered for implementation.
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