ML20010C215
| ML20010C215 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 07/20/1981 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20010C209 | List: |
| References | |
| NUDOCS 8108190251 | |
| Download: ML20010C215 (4) | |
Text
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4 WISCONSIN Elecinc mia cown 231 W. MICHIGAN. P.O. B012046, MILWAUKEE, WI 53201 July 20, 1981 Mr. J. G. Keppler, Regional Director -
Office of Inspection and Eaforcement, Region III U. S. NUCLEAR REGULATORY COMMISSION 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
DOCKET NOS. 50-266 AND 50-301 CLARIFICATION OF NRC REPORTING REQUIREMENTS 10 CFR 50'.72 POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 This letter is in response to your letter of June 3, 1981 in which specific comments were provided on our guide DCS 1.12.1, entitled " Requirements and Guidance for Immediate Notification to NRC of 'Significant Events' at PBNP". It should be noteil at the onset of this discussion that with the revision of tl.e Point Beach Emergency Plan on April 1, guide DCS 1.12.1 has been revised to conform with the revised Emergency Plan. This revision has the effect of fulfilling comment numbers 2, 3, and 5 of your June 3 letter. Specific replies to other comments are presented below on a corresponding item-by-item basis.
- 1. Comment No. 1 requested a revision to Section 2.1 of our guide to reflect the one-hour reporting limitation and to specify that'the clock starts upon discovery, not following internal notifications and discussions. The one-hour requirement is clearly spelled out in the guide. Personnel chargad with reporting responsibilities under this procedure are well aware of this time limitation. It has been our policy that an event is determined to be reportable following a reasened recognition of the initiating indications. This concept has been held as valid through 10 CFR 21 and licensee event reporting.
Reactor safety is, and must remain, however, of paramount importance. It is expected that this reporting process will always allow initial NRC contact l within a one-hour time from the initiation of a 8108190251 810911 i PDR ALOCK 05000266 S PDR g 2 \9@
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Mr. J. G. Keppler July 20, 1981 1
reportable event; however, no compromise of reactor
- . safety will be allowed. Thus, no revision to
- Section 2.1-is anticipated or warranted.
- 2. In Comment No. 4 you state that the parameters which determine the DNB safety limit should be reflected in the procedure. It must be remembered that the small print in our procedure is intended to only provide guidelines and interpretations of the 10 CFR 50.72 sections. It'is not the intent, nor should it be the intent, of this guidance to j attempt to encompass the. wide variety of' potential
- 1. indicators of DNB. The Technical Specification I
section is referenced for the specific purpose of providing information as to where the indicative
- parameters of DNB can be found and reviewed.
- 3. In Comment No. 6 of your letter you implied that ,
security event reporting should be in accordance !
with 10 CFR 73.71. Such reporting is beyond the scope of DCS 1.12.1 and is covered by other administra-tive means. l t
- 4. We believe'those serious events noted in your Comment j No. 7 which could have an impact on public health j and safety are covered in our interpretation of 10 CFR 50.72, . Item (3) . Reporting under this provision
~
would. ensue should the use of any of the reactor plant-related emergency operating procedures (EOP's) become '
necessary. To change the wording of this section to 4
encompass all the potentially reportable events would be contrary to the guide format.
l
~
S. Based upon your Comment No. 8, excluding partial ~
actuations of safeguards or reactor protective systems would support our statement that " Turbine runbacks '
are not considered as being reportable in accordance j with this item." Therefore, no further revision to ,
j this item is considered necessary.
I t
- 6. Your Comment No. 9 again states that the one-hour
- reporting requirement applies to our comments on !
, 10 CFR 50.72, Item 10, serious personnel radicactive !
t contamination. It is not anticipated that once such an event has been evaluated as being reportable that delay would be incurred. It should be pointed ,
out that this type of event falls into a category requiring review and analysis to determine reportability.
Personnel health and safety is always first priority.
L l
f e =mmm ~en n~ - -. - - . . ~ - -
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Mr. J. G. Keppler July 20, 1951
- 7. We do not agree with your interpretation of L 10 CFR 50.72, Item 11, in Comment No. 10 which would require immediate (one-hour) reporting of events which under 10 CFR 20.403 require only 24-hour notification. This example serves to under-score the original request included in our June 4, 1980 letter to Mr. Samuel J. Chilk, secretary of the Commission, to provide some measure of consistency to the growing multitude of NRC-required reports.
We continue to maintain, in the absence of other
[ directives, that only those events falling under the immediate notification provisions of 10 CFR 20.403 are included in the reporting requirements of 10 CFR 30.72.
6, Your Comment No. 11 requiring reporting of strikes which prevent shift relief of either operating or ;
security personnel within four hours of the normal
- shift relief time would-be covered under our inter-pretation.
- 9. Comment No. 12 states that transport means to an off-site medical facility should not be limited to conveyance by an ambulance. The procedure used at Point Beach Nuclear Plant in the event of the transport of an injured person off site (Emergency Plan Implementing Procedure EPIP 11.1) states specifically that the dedicated, company-owned emergency vehicle is to be used. This vehicle is designated as an ambulance for the purposes of reporting under this provision and no further clarification is necessary.
- 10. Your Comment No. 13 is noted and accepted.
4 The reactor trip during low-power physics testing referenced it our letter dated May 26, 1981 which resulted in
! a Notice of Violation dated June 17, 1981 occurred at 0029 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br /> on May 21, 1981. The reactor automatically tripped due to a low-low steam generator level while steam generator level was
- in manual control. This occurred while performing rod worth measurements via the rod swap method, utilizing test procedure WMTP2 4.3. When this trip occurred, it was evaluated as not falling within the intent of 10 CFR 50.72 since this trip failed the test of " serious events that could result in an impact in public health and safety" as stated in the implementing Federal Register notice for 10 CFR 50.72. Your letter of June 3 acknow-ledges this interpretation -in stating that this trip "may not be 5 w e e p %,e_ w yy -+~g y eg aw e5 *yre .op p po_ ww , % y
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Mr. J. G. Keppler July 20, 1981 of particular significance". To eliminate future misunder-standings, the concept of " serious events that could result in an impact on public health and safety" should be more clearly de'ineated.
- While the comments you have provided to our guide 1.12.1 have been of value, the basic concerns of our letters to you of March 31 and May 26, 1981 and to Mr. Denton of December 8, 1980 remain unresolved. Since our first letter to Mr. Chilk dated June 4, 1980, over one year ago, we have identified various in;;onsistencies An in the multitude example of these of reports inconsistencies which are required by the NRC. i is the differences in acthods of reporting 10events CFF 50.72affecting the requires security of special nuclear materials.
immediate reporting to the Nuclear OperaticuS 10 CF3 !) T1 requires an a: enter in Bethesda via the dedicated telcphone line.
immediate report via telephone to the NRC Ecqsonal Office. Another example of inconsistency and conflict was dis.2ussed under item 7 above.
These reporting inconsistencies have served to increase the burden on an operating plant staff and have the potential to divert operating personnel from attention to. reactor plant safety. What is needed is a review of all the reporting require-ments now in effect followed by removal of those not necessary for reactor plant safety or the protection of public health and safety. Further, a consolidated listing of necessary reports should be prepared. Only in this manner can useful, consistent reporting of significant events be assured.
Very truly yours,
,Y
- 2 - ;";
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C. N. Fay, Director Nuclear Power Department Copy to NRC Resident Inspector r
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