IR 05000482/1989006
| ML20236C594 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 03/07/1989 |
| From: | Everett R, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236C592 | List: |
| References | |
| 50-482-89-06, 50-482-89-6, NUDOCS 8903220216 | |
| Download: ML20236C594 (6) | |
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' APPENDIX
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U.S. NUCLEAR REGULATORY' COMMISSION
REGION IV
NRC Inspection Report:
50-482/89-06 License: NPF-42:
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Dockets:
50-482 Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)
P.O. Box 411 Burlington, Kansas 66839 Facility'Name: WolfCreekGeneratingStation(WCGS);
Inspection At: WCGS, Burlington, Kany,as.
-Inspection Conducted-January 30 through February 2,1989'
L In;pector:
2 * '#I
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Nemen M. Terc, Emergency Prepar/dness Specialist Date Security and Emergency Preparedness Section Accompanying Personnel:
D. H. Schultz,' Comex Corporation Approved:
[h. 4&p[-
' M7d9 dm ncy Preparedness Section curi a
Inspection Summary Inspection Conducted January 30 through February 2, 1989 (Report 50-482/89-06)
Areas Inspected:
Routine, announced inspection of the operational status of the emergency preparedness program,-including changes to-the Emergency Plan:and-implementing procedures and, in particular, the licensee's'. newly revised Emergency Action Levels '(EALs) procedure; changes to emergency facilities; equipment; instrumentation; and supplies.- The inspection also,. included organization and management control, independent audits of the' emergency preparedness program, training of. emergency response personnel, and'their
, proficiency.
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Results: Within the areas inspected, no violations or deviations'were identi fied.
Three open items were identified.(paragraphs 6,'7, and 8).
The-licensee's revision of their EAL proceuure, in the direction of symptomatic EALs, was found to be an improvement over previous EAL's schemes',: However,':some
' improvements are necessary.to provida the scope and-timely detection 1 desired.
l The licensee has committed to comp;
, these changes in the near future.
0ther l
areas inspected were found to be adequate.
$322o216890309 L
O ADocK 05000482
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v DETAILS-I.
Persons Contacted WCNOC
- B. Withers, President, Nuclear Operations
- Ra Grant, Vice-President,' Quality'
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- F. Rhodes, Vice-President, Engineer.ing and Technical Support l-
- J. Bailey, Vice-President, Nuclear. Operations
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- G. Boyer,: Plant Manager
- C. Parry, Manager, Site Quality
- W. Lindsay, Manager, Quality Assurance (QA)
- B. McKinney, Manager, Operations
- K. Moles, Manager, Emergency Planning-
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- 0. Maynard, Manager, Licensing.
- J. Zell, Manager, Training
- M. Williams, Manager, Plant Support
- W. Norton, Manager,' Technical Support
- S. Hatch, Supervisor, Quality System
- D. Parks, Supervisor, General Training
- C. Hoch, QA Technologist
- S. Wideman, Licensing Specialist III-
- R. Andrews, QA Specialist III l
- R.
Hoyt, Operations Specialist III l
- L. Stevens, Engineer
- R. Logdson,. Chemist
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- T.
Morrill, Health Physicist
- K. Craighead, Emergency Planning Specialist N_RC
- B. Bartlett, Resident Inspector i
- Denotes those present at exit. interview.
The NRC inspector also held discussions with other station an'd corp' orate personnel in the areas of security, health physics, operations, training, and emergency' response.
2.
Follow-up on Previous Inspection Findings (Closed) Exercise Weakness (482/8840-01)i Inadequate Data for Shift Supervisor (S/S)
The NRC inspector noted that' Procedure CllM-03-02, Revision 2, dated October 29, 1988, " Determination of Radioactive Iodine-and' Dose Equivalent Iodine Analysis," gives instructions on how?to calculate dose equivalent iodine and requires the generation of a.
computerized iodine equivalence report. -The results'are to be provided to-the S/S during accident situations.
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I 3.
Emergency Plan and Implementing Procedures (82701-02.01)
The NRC inspector review 9d changes to the Emergency Plan and implementing a
procedures that may have adversely affected the overall emergency program, j
The NRC inspector noted that Revision 23 effective January 19, 1988, and l
I Revision 24 of WCGS's Emergency Plan effective June 10, 1988, were submitted to the NRC on February 17 and July 7,1988, respectively.
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In addition, the NRC inspector determined that Licensing i
Procedure KP-L2201, "NRC Correspondence Processing," established i
instructions and deadlines for submittal and transmittal of licensee's
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Emergency Plan and procedure changes to the NRC, as required by i
i 10 CFR 50.54(g) and Appendix-E.
The NRC inspector reviewed the effective dates versus the submittal date to the NRC of changes to 72 emergency-implementing procedures during 1988, and found that they had been submitted to the NRC within the required time.
1 No violations or deviations were identified in this area.
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4.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701-02.02)
The NRC inspector visited facilities and examined inventories of equipment, instrumentation, and supplies to determine compliance with the
requirements of the Emergency Plan, and to determine the state of i
readiness.
l The NRC inspector noted that emergency response facilities were equipped l
in accordance with the licensee's emergency procedures; equipment was in
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place and operable, and adequate supplies were available.
No violations or deviations were identified in this area.
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Organization and Management Control (82701-02.031 The NRC inspector reviewed the number and qualifications of the emergency preparedness staff and verified that no changes were made to the staff l
since the last inspection.
No violations or deviations were identified in this area.
6.
Training (82701-02.04)
The NRC inspector examined records and conducted interviews to verify that emergency response personnel had been properly trained and understood I
their emergency responsibilities and training commitments in the Emergency Plan had been met.
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~The NRC inspector conducted interviews of three on-shift teams.
These; teams consisted.of a S/S Supervising.0perator, Reactor Operator, and
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Chemistry Technician.
Interviews were performed.in thel Control Room'(CR)
u and in~ the Technical Support Center using ' reference materials normally available to to'the CR staff. The interviews'were of one hour duration and covered the' subjects of:
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duties andiresponsibilities b.
classification of accident conditions c.
dose assessment of.given' radiological conditions'.
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d.
formulation of protective' action recommendationsefor radiological releases.
The following results were noted:
a.
Two of three S/S experienced difficulty.in determining the' downwind sector due to confusion of-reciprocal wind directions (from/to).
b.
Three of three S/S experienced difficulty in determining Subzones within sectors in which to implement protective actions.
c.
Two of three Chemistry' Technicians required approximately 30 minutes to manually compute a dose rate and integrated dose at the exclusion-
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area boundary for a set of parameters provided by the NRC inspector.
j d.
One of three Chemistry Technicians used a whole body dose conversion factor for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> rather than-0 hours (time since start of.
accident)..thus computing a value in. error, e.
One of three Chemistry Technicians used a Stability Class of A (correct class B), and an incorrect iodire. release rate (used iodine / noble gas [I/NG] ratio directly rathe'r than multiplying the ratio times the NG), and thus computed values.more than an order of magnitude in error in the non-conservative direction.
f.
EPP 01-7.3, Manual Dose Projection Determination (Revision 9),
Step 4.2.1.3, requires the person performing the procedure to obtain a " programmable calculator;" Step 4.2.2 lists the methods'of performance as "a) Programmable calculator... and b) Manual Calculation Worksheets....." The NRC inspector noted~that a-programmable calculator was not available to.the on-shift chemistry technician in the emergency kits'(lockers)' thus the technician had
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to use the less accurate, non-historical, manual worksheets of Attachment 3.0.
The NRC inspector noted that. procedures did not facilitate determination of Subzones and expedite dose assessment calculations-(see Items b and c above).
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This'is considered an open item pending' further inspector review.
'(482/8906-01)
No viulations or deviations were ~ identified' in this ' area.
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7.
Independent Audits (82701-02.05)-
The NRC inspector reviewed auditsLof the licensee's emergency: preparedness's program performed in the last 12 months.in order to determine compliance with 10 CFR 50.54(t).
The NRC inspector noted that the 0A Division performed 'one audit-duririg i
July / August 1988, and six. surveillance were performed throughoutc1988.
l Additionally, QA evaluated licensee performance during the'1988-exercise. The NRC. inspector also noted that training. interviews.were not included ~during the period June.1987 to June 1988, and that. interviews conducted af ter. June 1988 found that five out_ of seven Emergency-Operating Facility (EOF) Coordinators were not"able to document-sufficient knowledge of their duties.
Even after these findings, QA auditors performed.no further. interviews'at that. time to find out whetherf there.were other members of the' emergency response organization'who did'-
not have enough knowledge to. perform-their duties.
Furthermore, the NRC inspector determined that lesson plans and tests used to~ teach and qualify the EOF Coordinators were not audited by QA.
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The licensee stated that training interviews would be conducted during l
the coming audit, and in addition, QA will_use the resources of emergency preparedness specialists from other facilities to strengthen'their audit'
team.
This is considered an open item pending further inspector review.
(482/8906-02)
l No violations or deviations were identified in this program area.
8.
Emergency Action Levels The NRC inspector examined the EALs utilized by the State,and local authorities to assure that agreement between the licensee and the offstte authorities existed and had been annually reviewed.
The NRC inspector noted that the State and local authorities utilized the same EALs as
listed in the licensee's Emergency Plan.
However, the EALs in the
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Emergency Plan were significant1y 'different from those in the-licensee's emergency. implementing procedu'res.
Thus, the state and: local authorities
'l EALs differed from those in the procedures used by the licensee.
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example, primary leakage 1n excess of Technical Specifications =was cause-for declaring'a NOUE by the implementing procedure, while this:NOUE was-
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not listed in the Emergency Plan, nor in the state / local plans,.
The WCGS Radiological Emergency Response Plan (Revision 25, dated September 1988, and released November 29, 1988) included Table's 2.2-2 I
and 2.2-3, "NOUE Action Levels" and " Fission Product StatusLIndicators,"
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respectively. These tables were duplicated.in each.of the state of Kansas and Coffey County Emergency Plans, last revised and issued in-
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November 1988.
This duplication was cited by the licensee as evidence that offsite authorities annually agreed to the licensee's EALs. The licensee stated that the new revision of the EAL procedure willibe referenced in
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their. Emergency Plan'and will be given to.offsite authorities' eliminating.
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any source of discrepancy.
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The NRC inspector had a series of observations that need to be considered by the licensee for.imprcving Procedure IPP 01-2.1, Revision A (Draft),
" Emergency Classification." These observations. pertain to the EALs.
The licensee agreed that the observations would improveLtheir procedure', and-
. stated that they will evaluate them in the near future..These observations will be forwarded to the licensee as a separate: report prepared by an NRC contractor.
.This is considered an open item pending licensee action.
(482/8906-03)
9.
Open Items Identified During.This Inspection An open item is an item that requires further review and evaluation by the NRC inspector. Open items are used to document, track, and ensure adequate followup on matters o" concern to the NRC inspector. Open items are identified in paragraphs 6, 7,'and 8 of this report.
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Exit Interview The NRC inspector met with the NRC resident inspector and licensee i
representatives in paragraph I above on February. 2,1989, and
.l summarized the scope and findings of the inspection as-presented in this report.
Licensee representatives acknowledged their understanding of the inspection findings. Tree licensee agreed to revise and implement the changes specified in this report by' April 1989.
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