IR 05000482/1986006
| ML20205N774 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 04/21/1986 |
| From: | Baird J, Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20205N772 | List: |
| References | |
| 50-482-86-06, 50-482-86-6, IEB-85-080, IEB-85-80, NUDOCS 8605020293 | |
| Download: ML20205N774 (8) | |
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APPENDIX U.S. NUCLEAR REGULATORY C0fMISSION
REGION IV
NRC. Inspection Report:
50-482/86-06 License: NPF-42 Docket:
50-482 Licensee:
Kansas Gas and Electric. Company (KG&E)
P. O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At:
Burlington, Kansas Inspection Conducted:
March 10-14, 1986 Inspectors:
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C. A. Hackney, Emergency Prepargness Analyst Date 0 b baus2 4b2 /)74 J. 4. Saird, Emergency Preparedness Analyst Da t'e'
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Approved:
hdNk 4hi d6 L. A. Yandell, Chief, Emergency Preparedness Date
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and Safeguards Programs Section Inspection Summary Inspection Conducted March 10-141986 (Report 50-482/86-06)
Areas Inspected:
Routine, unannounced inspection of the licensees emergency preparedness program in the areas of changes to the emergency preparedness program, knowledge and performance of duties and review of the emergency preparedness program.
Results:
Within the emergency preparedness areas inspected, no violations or deviations were identified.
8605020293 860424 PDR ADOCK 05000402 G
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DETAILS l
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Persons Contacted (
j Principal Licensee Personnel i
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- G. L. Koester, Vice President, Nuclear
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- F. Rhodes, ri tnt Manager l
- K. Moles, Su ervisor, Emergency Planning
- R. Hoyt. Se ior Planning Specialist l
- G. R.nbun, Manager, Licensing and Radiological Services l
D. Moseby,-Snift Supervisor L
- J. Goode, Engineer Licensing T. Johnson, Shift Clerk l
- J. Dagenette, Training Specialist, Emergency Plan l
- A. Mah, Superir.tendent of Training
- M. Nichols, Superintendent, Plant Support l
D. Melville, Supervisor, Document Control J. Zell, Manager, Nuclear Training
- S. Devena, Emergency Planning Administrator M. Hall, lead Engineer l
E. McDougall, Document Configuration Supervisor l
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D. Hooper, Clerk III l.
C. Morgan, Supervisor, Document Control i
H. Schrieber, Engineering Specialist R. Stambaugh, QA Supervisor, Audits W. Randolph, Manager, QA (WCGS)
C. Weber, QA Auditor l
C. Reekie, QA Auditor l
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- B. Bartlett, Resident Inspector l
Federal Emergency Management Agency i
- R. Leonard, Program Manager j
- M. Carroll, Senior Technological Hazards Specialist The NRC inspector also held discussions with other station and corporate personnel in the areas of quality assurance communications, document control, changes to the emergency preparedness program, and emergency response.
- Denotes those present at the exit interview.
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- Denotes those contacted via telephone.
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2.
Licensee Action on Previous Inspection Findings
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(Closed) Deficiency (482/8540-01): A modification to the Radiological Release Information System software had been made to correct the monitor off-scale alarm problem.
This item is closed.
(Closed) Deficiency (482/8540-02): A procadure change was made to include the review of raw and calculated data for accuracy, and the procedure was implemented for the March 5, 1986, health physics drill.
This item is closed.
(Closed) Deficiency (482/8540-03):
Procedure EPP-01-8.2 was revised to specify that four teams are to be dispatched for offsite radiological monitoring. This procedure was implemented during the Harch 5, 1986, health physics drill. This item is closed.
(Closed) Deficiency (482/8540-04): Procedure EPP 01-2.4 was written and approved to provide a methodology for determining the extent of core damage.
This item is closed.
(Closed) Violation (482/8533-01): The NRC inspectors reviewed document control Procedure KP-1032, Revision 2 and transmittal letter of revised procedures. The NRC inspectors determined that recently revised procedures had been distributed and acknowledged as having been received according to the procedure.
In addition, the NRC inspectors reviewed revised Procedure EPP-01-7.1 and determined that appropriate forms had been completed. A statement was written attesting to a 50.54(q) review having been performed for the procedure.
This item is closed.
3.
Notifications and Communications The NRC inspector reviewed the licensee's emergency plan notification procedures as they pertained to emergency action level schemes, offsite notification, emergency classification, and notification verification.
The licensee had an emergency action level scheme for determining emergency classifications and making offsite protective action recommendations.
Further, a call-back code system was in place for the offsite law enforcement agency to verify licensee messages.
The off-duty emergency response personnel would be notified by a call out from designated communicators.
The communicators are to be telephoned at home or notified by pager to initiate a call out for assigned emergency response personnel during off-duty hours.
The NRC inspector reviewed selected maintenance records for the prompt public notification system.
It was noted that in cases where a siren had been reported malfunctioning, there appeared to be timely repair initiated.
Further, compensating measures had been taken to alert the public until the siren was repaired.
The licensee had installed telephone and radio communications for communicating with offsite agencies.
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telepnone communication system consisted of a regular commercial system and a licensee microwave system. Either or both systems may be used for offsite communications.
The NRC inspector verified operability of the
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emergency notification system by requesting that a licensee employee call the emergency operations center in Washington, D.C..
Additionally, other emergency telephones were verified to be operable by requesting different licensee personnel to perform communication checks.
The NRC inspector
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' reviewed the call out procedures for emergency response personnel and l
noted that emergency response personnel were to be notified at different emergency classes for emergency response.
The NRC inspector determined during personnel interviews that some confusion existed as to who would be making state and county calls (10 CFR 50, Appendix E.IV.d.3.) and who would be the person talking to the NRC as required in 10 CFR 50.72 and as addressed in Information Notice 85-80.
The NRC inspector discussed the prompt public notification system adequacy test with the Federal Emergency Management Agency Regional Assistance Committee Chairman. The adequacy test and documentation had not been completed.
The following are observations the NRC inspectors called to the licensee's
attention. These observations are neither violations nor unresolved items.
l These items were recommended for licensee consideration for improvement, l
but they have no specific regulatory requirement.
Monthly radio checks to the sheriff's office should be conducted from
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A system should be developed for checking the OSC, TSC, and the EOF
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multicolor telephone system.
Two communicators should be routinely assigned in the control room.
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The first should be a reactor operations technical type as discussed in the I&E Notice 85-80, to meet the requirements in 10 CFR 50.72 for communicating with the NRC. The second communicator would make initial and followup notification to the state and county governments as required in 10 CFR 50, Appendfx E.IV.d.3.
No violations or deviations were identified 4.
Changes to the Emergency Prepareoness Program The NRC inspector reviewed selected procedures that had been revised since the last inspection.
It was determined that revised Procedures EPP-01-7.1, and EPP-01-7.2, had been reviewed and approved by the plant safety review committee on February 25, 1986.
Further, the revised procedures had been reviewed and stated that the review met the requirements of 10 CFR 50.54(q).
The licensee had made a recent minor change to the Emergency Operations i
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The change had not been submitted to the NRC at the time of the inspection.
The licensee had made recent changes to the emergency response organization.
There were staff changes due to a key team member leaving the company. Additionally, the Emergency Preparedness Administrator (EPA) was laterally transferred to another functional organization. The transfer did not appear to have removed ti,e EPA from station management interface.
The NRC inspector reviewed a distribution list for emergency response plans and procedures.
It appeared that changes to the emergency plan and procedures had been distributed and a document receipt returned to document control.
The NRC inspector did not find any plans or procedures that had been submitted to the NRC for a review that decreased the effectiveness of the plan. The licensee did not issue any temporary emergency plan procedures.
The NRC inspector reviewed selected revised procedures to determine that revised procedures had been submitted to the NRC in the required 30-day period following licensee implementation.
Selected procedures were reviewed and the licensee had submitted the revised procedures within the required 30 days.
The NRC inspector conducted an inspection of the licensee's emergency response facilities and determined that no significant changes had occurred to equipment or instrumentation.
The NRC inspector held discussions with the epa and determined that his areas of responsibility had not changed with the recent organizational change.
Review of personnel assigned to the emergency response organization appeared to meet the licensee's training requirements, however, one area of an apparent violation was discovered during a Quality Assurance audit.
The audit is discussed in Section 6 of this report.
No violations or deviations were identified.
5.
Shift Staffing and Augmentation The NRC inspector reviewed Table 1.1-1 of the emergency response plan and discussed shift staffing and augmentation with licensee representatives.
Additionally, selected personnel qualification records were to determine if the goals and criteria of Table B-1 of NUREG-0654 could be met. A review of an augmentation call-out drill conducted May 29, 1985, indicated that the licensee had made adequate provisions for shift staffing and augmentation to deal with emergencies.
The NRC inspector determined that contact of emergency response personnel needed to augment the onshift staff would be by telephone fan-out through l
nonresponding emergency communicators, in addition, certain key personnel were assigned personal pagers; however, no policy statement or procedure
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was in place to control the pager issuance or use.
The NRC inspector l
noted that an emergency response organization telephone book had been
maintained with home telephone and pager numbers for station staff.
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-6-The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for improvement, but they have no specific regulatory requirement.
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A poiicy statement and/or procedure should be issued to control the issuance, use and maintenance of pagers assigned to key emergency response staff.
EPP 02-1.3 should be revised to include a requirement for
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augmentation call-out drills on an established frequency consistent with the other drills specified in the procedure.
No violations or deviations were identified.
6.
Licensee Audits The NRC inspector reviewed reports, auditor certification records and held discussions with station Quality Assurance (QA) personnel to determine compliance with 10 CFR 50.54(t) requirements for independent review of the emergency preparedness program.
Reports reviewed included the following:
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QA Audit Report TE:
50140-K061, August 20, 1985
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I QA Audit Report TE:
50140-K080, December 27, 1985
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QA Audit Report TE:
50140-K097, March 6, 1986
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KG&E Internal Audit Report 50130-K019, November 5, 1985
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QA Surveillance Report TE:
53359 S-1400, November 5, 1985
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QA Surveillance Report TE: 53359 S-1403, November 25, 1985
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QA Surveillance Report TE:
53359 S-1413, December 31, 1985
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Independent Review of the WCGS E-Plan, September 16, 1985
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The NRC inspector's review and discussions revealed that an independent review of the program had been completed within the 12-month period required by qualified auditors in a part of the organization which had no direct responsibility for implementation of the program.
The review further showed that'an evaluation of licensee drills, exercises, capabilities, emergency plan and procedures, and interfaces with state and local government agencies had been performed. However, it was noted that the coverage of state and local government interfaces was at a minimum,
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additional broad emergency preparedness training would be beneficial in evaluating the adequacy of program elements.
The NRC inspector determined that audit reports and findings were transmitteo to management and that audit records were to be retained for the lifetime of the. plant.
It was noted that audit findings were identified to responsible personnel and tracked for corrective actions.
During a review of audit findings QPD 8/85-209, it was noted that an apparent ' violation of-10 CFR 50.47(b)(15) had been identified in that two individuals had been assigned to the emergency organization without receiving the required training.
This finding had been entered in the QA corrective action tracking system.
The NRC inspector subsequently determined that corrective action had been implemented and all the provisions of 10 CFR 2. Appendix C,Section IV.A had been met, therefore, a notice of violation was not issued.
The NRC inspector verified that sections of the audit reports identified above dealing with the adequacy of interfaces with state and local government agencies had been transmitted to these agencies.
The NRC inspector also reviewed the licensee's open action item tracking I
system and discussed the system with KG&E personnel to determine if a program had been implemented to identify deficiencies and weaknesses
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observed during exercises, and to track the items for corrective actions
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in accordance with the requirements of 10 CFR 50.47(b)(14) and Appendix E l
to Part 50, Paragraph IV.F.5.
It was noted that emergency preparedness deficiencies and items for improvement were entered into the tracking
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system, including deficiencies and weaknesses identified during post exercise critiques.
However, it was also noted that not all of the entries were clearly identified as to the classification of the item and whether or not the item resulted from an exercise observation.
This made it difficult to separate the deficiencies and weaknesses from improvement l
items of lesser corrective action priority.
In addition, the NRC inspector found that it was difficult to follow deficiencies reported in NRC inspection reports as identified by the licensee's staff during exercises.
l The NRC inspector also determined that corrective actions for items in the i
tracking system were being taken in an appropriate time frame.
This included corrective actions for weaknesses and deficiencies identified during the critique following the previous e:nergency exercise.
The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for improvement, but they have no specific regulatory requirement.
Consider providing an emergency preparedness (EP) expert resource
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person for the QA audit teams and/or providing additional broad EP r
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Provide an additional mechanism for classifying audit findings in
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terms of compliance with NRC requirements and handle corrective actions in the same way as NRC identified items.
Provide more attention in the program reviews to the adequacy of
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state and local government interfaces, and consider including the exercise observations in the evaluation.
Consider adding a classification identifier to the action item
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tracking system which indicates which items are deficiencies, improvement items, QA findings, etc.
Give additional attention to the tracking and disposition of
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deficiencies identified in the exercise critique section of NRC exercise inspection reports.
No violations or deviations were identified.
7.
Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on March 14, 1986.
The NRC inspector summarized the purpose and the scope of the inspection and the findings.
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