ML20112G135

Responds to NRC Re Weaknesses Identified in Insp Rept 50-305/84-17.Corrective Actions:Procedure Will Be Revised to Provide Dedicated Use of Pager Sys & Negate Use of Sequential Telephone Calls

ML20112G135
Person / Time
Site:	Kewaunee
Issue date:	12/14/1984
From:	Hintz D WISCONSIN PUBLIC SERVICE CORP.
To:	Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20112G104	List: ML20112G126 ML20112G135
References
CON-NRC-84-193 NUDOCS 8501160204
Download: ML20112G135 (3)

Text

NRC-84-193' WISCONSIN P U B LIC S ERVICE CO RPORATIO N RO. Box 1200, Green Bay, Wisconsin 54305 i

December 14, 1984 Mr. L. R. Greger, Chief Emergency Preparedness and Radiological Protection Branch

.U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137

Dear Mr. Greger:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Inspection Report 84-17

Reference:

Letter from L. R. Greger (US NRC) to D. C. Hintz (WPSC) dated November 14, 1984, transmitting Inspection Report 50-305/84-17 (DRSS)

The attachment to this letter details our response to Emergency Preparedness weaknesses identified in Inspection Report 50-305/84-17 (DRSS).

l Very truly yours, c A A, a. W A D. C. Hintz Manager - Nuclear Power s DSN/js Attach, cc - Mr. S. A. Varga, US NRC Mr. Robert Nelson, US NRC

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C501160204 050109 PDR ADOCK 05000305

-O PDR DECy7ggg

/, a' Ar. L. R. Greger

. N1-58.2 December 14, 1984 Page 1 ATTACHMENT Emergency Preparedeness Exercise Weakness

1. The current practice of making shift augmentation notifications prior to the notification of offsite agencies of an emergency classification does not

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ensure that offsite agencies will be notified within 15 minutes as required by 10 CFR Part 50, Appendix E, Section IV.D.3. Changes should be made in the notification procedure to ensure offsite agencies will be r,attfied within 15 minutes. (0 pen Item No. 305/84-17-01) (Section 4.a)

Response

This weakness was a result of the communicator being required to make all the shift augmentation notifications prior to notifying offsite authorities.

The procedures will be revised to require notification of offsite authorities prior to the staff augmentation notifications. This will ensure that offsite agencies will be notified within 15 minutes.

The procedure will be revised in accordance with our annual procedure revision program. The procedure revision is expected to be completed by February 15, 1985.

Emergency Preparedness Exercise Weakness

2. The current practice of using sequential telephone calls in lieu of the pager system, and of having all personnel initially report to the Site Access Facility resulted in an excessive amount of time to activate the Technical Support Center. The licensee should re-examine the methodology for shift augmentation. (0 pen Item No. 305/84-17-02) (Section 4.b)

Response

Procedure revisions will be made to provide more dedicated use of the pager system and negate the use of sequential telephone calls when a rapid activation of the Emergency Response Organization is required. This change will require substantial procedure revisions and may necessitate the recoding of pagers.

- IMr. L. R. Greger -

December 14, 1984 Page 2 The revised procedures will be incorporated into the annual Emergency Plan Training Program prior to implementation. We will complete training and imple-ment the revised procedures by October 1, 1985.

The procedures for processing personnel through the Site Access Facility (SAF) prior to entering the plant site are currently under review. A procedure revi-sion to " streamline" the activities at the SAF will be performed in accordance with our annual procedure revision program. We expect the streamlined access pro-cedures to be completed by February 15, 1985.

Emergency Preparedness Exercise Weakness

3. To solve recurring problems with the post accident sampling system, the following changes should be incorporated into EP-RET-3C, " Post Accident Operation of the High Radiation Sampling Room":

--Include in the procedure a method to ensure that the vacuum in the sample bottle is not lost before the sample and dilution volumes are injected into the bottle.

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--Include in the procedure a method to obtain different dilution factors for the sample as desired or require 0.

Response

Procedure revisions will be made to ensure that the vacuum in the sample bottle is not lost before the sample and the dilution volumes are injected into the

= bottle. This procedure change will be implemented by February 28, 1985.

5 The sampling system is designed such that a predetermined dilution will be i

obtained if the vacuum in the sample bottle is maintained. Therefore, the pro-cedure revision mentioned above should ensure that the proper dilution is per-formed. As a precautionary measure, we will modify the procedure to provide

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operator guidance in the event of an " incorrect" dilution. This change will be implemented by Feburary 28, 1985.

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< '. NRC-84-194 WISCONSIN PUBLIC SERVICE CORPORATION k RO. Box 1200, Green Bay, Wisconsin 54305 December 17, 1984 U. S. Nuclear Regulatory Coninission Document Control Desk Washington, D.C. 20555 Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant Emergency Preparedness Communicator Position

References:

1) Letter from C. W. Giesler to D. G. Eisenhut dated April 15, 1983

2) Letter from J. A. Hind to C. W. Giesler dated August 6, 1984

3) Letter from D. C. Hintz to J. A. Hind dated September 20, 1984

4) Letter from L. R. Greger to D. C. Hintz dated November 14, 1984

.In reference 1 we informed you of our plans to add an additional Senior Reactor Operator (3RO) to the shift control room staff by January 2, 1984. It was also noted that with the addition of the extra SR0 on shift, that the dedicated com-municator position would be eliminated.

A routine safety inspection was conducted by Mr. W. Snell and others from the NRC Region III office on July 9-13, 1984. The resulting Inspection Report (Reference 2) indicated that information regarding the elimination of the Communicator position was not reviewed as part of the April 15,1983 submittal and therefore the Commission Order dated June 12, 1984 did not address the issue

-of minimum staffing levels. The Inspection Report stated, "the licensees pro-posed shift staffing levels are under review by the NRC staff."

In our letter dated September 20, 1984 (reference 3), we responded to the Emergency Preparedness weaknesses identified in reference 2 and also addressed your concerns regarding the minimum shift crew size at KNPP. We concluded that "WPSC has implemented an on shift organization which is sufficient to carry out the actions required by the emergency plan".

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A. X Document Control ~Dask. -

December 17, 1984 Page 2-n a Inspection Report 84-17 (reference 4) provided results of a routine safety l inspection conducted at KNPP on October 22-24, 1984 during the implementation of  !

our annual emergency preparedness exercise. The report recommended that we

-reevaluate the practice of designating the Control Room Supervisor as the Communicator =during emergency evolutions as it appeared to be an under utiliza-tion of his expertise.

L We have reevaluated our position and have developed a method to perform initial notification to-offsite authorities in a timely manner and not utilize on-shift

- control room personnel except for short term technical related communication.

Our proposed notification scheme will include the use of designated security personnel to. provide immediate support to the Shift Supervisor in;the event of 5

an emergency declaration, except when the emergency is declared for security

- reasons.

1 The Shift Supervisor will be responsible for the immediate communications which" must be made based on current plant conditions (i.e. NAWAS notification including protective action recommendations, briefing Emergency Director idesignate on plant status, notifying fire team if warranted, etc.) A designate y from the security Force will immediately report to the Control Room and perform

-non-technical notifications such as pager activation for staff augmentation.

The staff augmentation process will be revised to include the notification of a designated Communicator. We have evaluated our personnel availability and expertise and have developed a list of personnel with plant operations experience who can be contacted to relieve the Shift Supervisor and the Security Force notifier of any long term communications. The personnel selected to fill the. designated Communicator position have plant operations experience and live

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in:close proximity to the plant, therefore response time should be minimal.

Should emergency declaration occur due to a security related event, the

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i designated. security force notifier position will not be activated. It is anti-

, cipatert that'during security r' elated events the on shift control room staff will be~ av. ..able to' perform the _ initial notifications until relieved by a designated Communicator.

In 'all cases, the. Technical Support Center (TSC) Staff will relieve the Control Room Staff of the offsite communication responsibilities following TSC activa-tjion.

'Since these procedural and organizational changes are major:in nope, the . .

, - revised procedures will be-incorporated into the annual Emergency Plan Training

Program prior to-implementation. We will complete training and implement the

procedures.by October!1, 1985.

WPSC has exercised our procedures'and emergency plan on several occasions (graded exercises and: drills) utilizing an on shift staff'that is equal in -

number to the current staff level. We have demonstrated the ability:to imple-ment:the; required provisions of the emergency plan on each of these occasions Lthus demonstrating the. sufficiency of the current staffing level. We feel the

. proposed ~ revisions -will ' provide additional capabilities to our existing effec-tiveiprogram..

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December 17,.1984 Page 3 Ver truly yours,

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D. C. Hintz Manager - Nuclear Power DSN:jks-cc - Mr..S. A.- Varga,l'S NRC Mr

'Mr[. Robert Nelson,,US William?Snell,' NRC-US NRC

Mr. C. F.-Riederer, PSCW e

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