05000482/FIN-2014504-01
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Finding | |
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| Title | Licensee-Identified Violation |
| Description | Title 10 CFR 50.54(q) requires, in part, that licensees follow and maintain in effect an emergency plan that meets the requirements of 50.47(b). Planning Standard 50.47(b)(2) requires on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times. Procedure AP 06-002, Radiological Emergency Response Plan, Revision 15, Attachment D, WCGS Minimum Staffing for Emergencies, identifies two chemists for on-shift staffing. Procedure AP 21-001, Conduct of Operations, Revision 69, Step 6.6.2, states that the off-going SM [Shift Manager] shall ensure that the on-coming watchstanders are qualified to stand the watches assigned to them. The failure to have the required qualified chemistry technicians on staff is a performance deficiency. The performance deficiency is more than minor because it impacts the emergency response organization readiness attribute of the Emergency Preparedness Cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using the examples in Table 5.2-1, Significance Examples 50.47(b)(2), of Appendix B to Inspection Manual Chapter 0609, "Emergency Preparedness Significance Determination Process," issued June 2, 2011, the inspector concluded that this finding represents a degradation of the planning standard function. It meets the degraded planning standard function example, Staffing processes would permit a shift to go below E-plan minimum staffing requirements, but there were no actual instances in which such shortages occurred. It is not Greater-than-Green because they had the required number of personnel on shift and they were capable of completing the required functions, albeit task qualified. The licensee had the required minimum staff and could perform the function; however, their processes could have failed if they had not identified this condition and could have not met functional requirements in the future by the use of unqualified personnel. It is not a loss of planning standard function because it was personnel error that caused the finding. An acting chemistry manager did not understand that two qualified chemistry technicians were required one for sampling and one for dose assessment. The licensee identified a broken process in that the watchstander bill did not require verifying qualifications for staff other than for operations personnel. Contrary to the above, on 21 shifts, between May 24 and July 14, 2014, the licensee used two unqualified chemistry technicians for on-shift staffing. Specifically, the licensee had an on-shift unqualified chemistry technician along with a qualified chemistry technician. The emergency plan specifies two tasks for the technicians; sampling and dose assessment. For the time period in question, the licensee had placed two technicians on back shift, one fully qualified technician, who could perform sampling and dose assessment, and one not fully qualified technician for the fire brigade. The licensee missed the fact that one technician was needed for sampling and one technician for dose assessment. Although the technicians were not both fully qualified, their skills and abilities allowed for the required emergency preparedness functions to be completed. The licensee has entered this into their corrective action program as Condition Report CR86306. |
| Site: | Wolf Creek  |
|---|---|
| Report | IR 05000482/2014504 Section 4OA7 |
| Date counted | Dec 31, 2014 (2014Q4) |
| Type: | NCV: Green |
| cornerstone | Mitigating Systems |
| Identified by: | Licensee-identified |
| Inspection Procedure: | |
| Inspectors (proximate) | G Guerra M Haire |
| Violation of: | 10 CFR 50.54 10 CFR 50.54(q) |
| INPO aspect | |
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Finding - Wolf Creek - IR 05000482/2014504 | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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Finding List (Wolf Creek) @ 2014Q4
Self-Identified List (Wolf Creek)
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