ML20247E409

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Responds to NRC Re Violations Noted in Insp Repts 50-266/89-08 & 50-301/89-08.Corrective Action:Timely Recognition of Release Path & Aggressive Termination Response Will Be Specified as Evaluated Drill or Exercise
ML20247E409
Person / Time
Site: Point Beach  NextEra Energy icon.png
Issue date: 05/10/1989
From: Fay C
WISCONSIN ELECTRIC POWER CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-89-056, CON-NRC-89-56 VPNPD-89-273, NUDOCS 8905260246
Download: ML20247E409 (4)


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. Wisconsin Electnc eom coww 231 W. MICHIGAN, P.o. BOX 2046, MILWAUKEE,Wl 53201 (414) 221-2345 VPNPD-89-273 NRC-89-056 May 10, 1989 U.

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

. Washington, D.

C.

20555 Gentlemen:

DOCKETS 50-266 AND 50-301 INSPECTION REPORT 50-266/89008(DRSS);

50-301/89008(DRSS)

POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 Your letter of April 13, 1989, forwarded Inspection Report 50-266/89008;50-301/89008, which described results of a i

routine, announced inspection of the Point Beach Nuclear Plant emergency preparedness exercise by members of your staff on March 14-16, 1989.

Your 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 weakress identified in your report.

We have provided'a written response to the weakness identified as open' Item 266/89008-02 as an attachment to this letter.

The comments relative to Open Item 266/89008-01 suggest a misunderstanding that Forms EPIP-13

(" Status Update Form") and EPIP-14 ("NRC Event Notification Worksheet") are used in conjunction with Procedure EPIP-1.1, " Plant Operations Manager

- Initial Response."

Neither form is associated with use of Procedure EPIP 1.1.

Instead, Forms EPIP-13 and EPIP-14 are associated with Procedures EPIP 2.1, " State and County Agency Notification," and EPIP 2.2, "NRC Notification," respectively.

This open item referred to "...the NRC communicator, with a 50.72 report in hand, and the off-site authority communicator with an Alert message in hand, commencing notifications to their respective listeners concurrently."

We understand your concern that dissimilar messages were being concurrently transmitted to different off-site agencies (i.e., NRC and local authorities).

The problem observed, however, was a " drill" problem and not a real response problem in that the j

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NRC Document Control Desk May 10, 1989 Page 2 communicator to the NRC during a real event would not have left the control room to make the Emergency Notification System (ENS) call.

Leaving the " drill control room" was required because it is not equipped with an ENS handset.

In a real event, the communicator to the NRC would have been in the control room; would, therefore, have been aware of the classification change; and would have been able to obtain the Plant operations Manager's approval to transmit that classification change to the NRC duty officer.

In that light, we request that you re-evaluate this open item and consider closing out this issue.

During the course of the inspection, we were advised that open Item 266/88021-02 regarding management review of message forms prior to transmittal to local off-site agencies would likely be closed, based upon performance observed during the March 15, 1989 exercise.

This item is very similar to open Item 266/88021-03 concerning management review of message forms prior to transmittal to the NRC.

That item was closed during this inspection.

Corrective actions taken for both these items were similar.

We request, therefore, that you also reconsider closure of this item or advise us of any additional corrective action you believe may be necessary.

If you have any questions regarding matters discussed in this letter and attachment, please contact our Emergency Planning Coordinator, David Stevens, at 414-755-2321.

Very truly yours, i

hbU b C. W.

Fay j

Vice President Nuclear Power Copies to NRC Regional Administrator, Region III (Attention: W. D. Shafer)

NRC Resident Inspector R.

S.

Cullen, PSCW

Attachment

-Response to Inspection Report 50-266/89008(DRSS);50-301/89008(DRSS)

Weakness:

" Licensee personnel did not recognize and aggressively pursue the existence of the (scenario) containment 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."

Discussion:

It is recognized that about three hours passed from the time the containment release began until the release path was finally secured by drill players.

Failure to secure the release in a more timely manner, however, is not indicative of a generic problem.

Rather, it is one which applies to the specific scenario and to the particular group of players responding to that scenario.

We also believe that failure to terminate the release more quickly would not have resulted in

...an unnecessary exposure to the public", as was indicated in your report.

Immediately following initiation of the release, player actions were directed toward:

1.

Reclassification of the emergency action level (EAL) 2.

Re-evaluation of protective action recommendations (PAR) 3.

Notification of local authorities regarding EAL and PAR changes 4.

Evacuation and accountability of on-site personnel 5.

Establishment of containment sump recirculation to assure long-term core cooling and prevent a severe core-melt accident 6.

Implementation of on-site and off-site procedures in response to a bomb threat which was injected into the scenario without licensee's knowledge by the NRC just minutes before the scenario release began Page 1 of 2 Pages

)

Attachment Response to-Inspection Report 50-266/89008(DRSS);50-301/89008(DRSS)

It is.our contention that the actions taken were appropriately, timely, and properly prioritized in terms of protecting on-site personnel, the off-site public, and the reactor-core.

The report stated that failure to secure the release path would have resulted in an unnecessary exposure to the public.

Drill documentation shows that actions taken by the licensee and local and state officials resulted in implementation of public evacuations in all sectors potentially impacted by the simulated plume.

These actions alone were effective in eliminating or reducing potential exposu'es to the public.

In r

fact, the U.

S. NRC Status Summary Number 7, issued during the exercise, indicated that "The State of Wisconsin, as of 11:08 CST, has completed evacuation of all non-essential people out to 5 miles from the site and downwind areas out to 10 miles from the site."

We believe it is unlikely, given the scenario conditions at the time, which included evaluation of the NRC-inserted bomb threat, that the release point could have been identified and corrective actions developed and implemented prior to 11:08, while still adequately protecting the health and safety of plant workers.

That being the case, failure to secure the release path would not have resulted in

" unnecessary exposure to the public", the public having already been evacuated and, therefore, unlikely to receive additional exposures after 11:08.

Licensee actions (identification and recommendation of appropriate protective actions to off-site authorities) were timely and, as indicated in your report, "would have been sufficient...to protect public health and safety."

Response

As noted in the discussion above, the delay in securing the simulated release path was a performance matter and is not indicative of a generic problem; therefore, specific corrective actions can neither be identified nor implemented.

Notwithstanding, we will provide an opportunity for the Point Beach Nuclear Plant emergency response organization 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 objectives.

This action will be completed by April 1, 1990.

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