IR 05000482/1994017
| ML20149J222 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/27/1994 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20149J213 | List: |
| References | |
| 50-482-94-17, NUDOCS 9501050081 | |
| Download: ML20149J222 (18) | |
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, U.S. NUCLEAR REGULATORY COMMISSION
l REGION IV Inspection Report: 50-482/94-17 Operating License: NPF-42
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l Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)
l P.O. Box 411 4 l
Burlington, Kansas 66839 l
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Facility Name: Wolf Creek Generating Station (WCGS)
Inspection At: Burlington, Kansas l Inspection Conducted: December 5-8, 1994 Inspectors: D. Blair Spitzberg, Ph.D., Senior Emergency Preparedness i Analyst (Lead Inspector)
S. L. McCrory, Licensing Examiner A. McQueen, Emergency Preparedness Analyst
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Approved: II//M Blaine Murray, thief, Fa lities Inspection /
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l Programs Branch l
l Inspection Summary l l Areas inspected: Routine, announced inspection of the operational status of j the emergency preparedness program, including changes to the emergency plan !
and implementing procedures; emergency facilities, equipment, and supplies; l organization and management control; training; and internal reviews and i
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audit Results:
l = The licensee had reviewed and properly submitted to NRC changes in the
- emergency plan and implementing procedures. The licensee had maintained a close relationship with offsite radiological emergency response organizations (Section 2.1).
- Emergency facilities, equipment, and supplies had been maintained in a l state of operational readiness. The conversion of the Technical Support '
and Operational Support Centers into a combined, dedicated facility
! represented an improvement in operational function and readiness l (Section 3.1).
t l * The Emergency Response Organization was comprised of qualified personnel at each position and had good overall staffing depth. The emergency l 9501050081 941230-
$DR ADOCK 05000482 PDR
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-2-planning organization was well staffed with qualified personnel (Section 4.1).
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- Emergency response personnel had been trained as required, and l improvements were noted in the emergency response training program and drills (Section 5.1.1).
- During the simulator scenario walkthroughs, a staff crew was slow to declare a Site Area Emergency and failed to properly assess and classify a General Emergency. The two shift crews evaluated, properly classified all scenario events (Section 5.1.3).
- During the simulator scenario walkthroughs, a weakness was identified for the failure of one crew to inform plant personnel of necessary protective measures following Site Area and General Emergency classifications (Section 5.1.3).
- During the simulator scenario walkthroughs, notifications were timely; however, some inconsistencies were noted among the crews as they relateu plant status information in the messages. Protective Action Recommendations and dose assessments were timely and appropriate (Sections 5.1.4 - 5.1.6).
- The inspectors concluded that a negative trend was exhibited in the operations training function. The trend stemmed from lax application of
! the systems approach to the training process on which the operations training programs were based (Section 5.1.7).
- Audits of emergency preparedness had been conducted in accordance with 10 CFR 50.54(t). Quality assurance audits and surveillances of
! emergency preparedness and planning had been performed by qualified personnel and were of proper scope, depth, and effectiveness. A special self assessment of emergency planning and preparedness had been conducted in addition to the required annual audit (Section 6.1).
- The licensee had maintained an effective system of controls pertaining i
to safety issues, events, or problems. No long standing, uncorrected
- safety issues existed in the emergency planning and preparedness areas (Section 7.1).
- Since the last emergency preparedness inspection, one Unusual Event was classified. Timely notifications were made to the appropriate local and l state agencies and to the NRC (Section 8.2).
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Summary of Inspection Findings:
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Weakness 50-482/9417-01 was opened (Section 5.1.3).
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Weakness 50-482/9326-02 was closed (Section 9.2).
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-3-Attachments:
Attachment 1 - Persons Contacted and Exit Meeting Attachment 2 - Operator Walkthrough Scenario Narrative Summary l
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4 1 PLANT STATUS During this inspection, the reactor operated at full powe EMERGENCY PLAN AND IMPLEMENTING PROCEDURES (82701-02.01)
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} The inspectors reviewed changes in the licensee's emergency plan and 4 implementing procedures to verify that these changes had not decreased the i effectiveness of emergency planning and that the changes had been reviewed
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j 2.1 Discussion i Since the previous inspection, five emergency plan revisions had been implemented. For each emergency plan revision, the licensee had performed a j documented review in accordance with 10 CFR 50.54(q) to determine that the revisions did not decrease the effectiveness of emergency preparedness. The
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- inspectors also reviewed documentation pertaining to selected Emergency Plan i Implementing Procedure (EPIP) revisions implemented since the last routine
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j The inspectors reviewed selected changes in procedures and noted that the i changes were consistent with regulatory requirements and licensee commitments.
j No instances of emergency preparedness degradation were noted. Inspectors q also reviewed correspondence to verify that plan and procedure changes were reviewed and forwarded to the NRC within 30 days of becoming effective as j required by 10 CFR Part 50, Appendix E. The licensee had maintained a close i' relationship with offsite agencies and had coordinated changes in emergency action levels with those agencies as appropriate. The inspectors reviewed Letters of Agreement established with support agencies and determined that they were current and had been reviewed annually and updated as require .2 Conclusion l The licensee had reviewed and properly submitted to NRC changes in tra emergency plan and implementing procedures. The licensee had maintained a close relationship with offsite radiological emergency response organization EMERGENCY FACILITIES, EQUIPMENT, INSTRUMENTATION, AND SUPPLIES l (82701-02.02) :
The nspectors toured onsite emergency facilities and reviewed the licensee's emerge,cy equipment inventories and maintenance to verify that facilities and equipment had been maintained in a state of operational readines .1 Discussion The inspectors toured each nearsite emergency response facility and inspected designated emergency equipment, instrumentation, and supplies. The emergency response facilities were observed to be well maintained and ready for
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-5-emergency us Random inspections were performed of radiation monitoring and respiratory protection equipment at each emergency response facility. All items inspected were verified as being in calibration or had been appropriately inspected on a scheduled basis. Equipment and supplies maintained in response facilities and in emergency equipment lockers matched established inventories. Current copies of the emergency plan, implementing procedures and emergency telephone directories were maintained in all facilitie The inspectors reviewed documentation of inventories of emergency response facilities and noted that they had been performed as required by procedure A major change since the last routine inspection was the consolidation of the Technical Support Center and the Operations Support Center into a single facility. This change was reviewed by the NRC as an emergency plan revision and was determined to be acceptable. This facility is in the same structure that previously housed the Technical Support Center and some unrelated offices. The combined Technical Support / Operational Support Center was now a dedicated facility whereas before, both were dual use facilities. This ,
represents an improvement in the operational status of each facility. In the !
consolidation, the engineering support function which had been split between the Technical Support Center and the Emergency Operations Facility was ;
combined into the new facilit '
3.2 Conclusion Emergency facilities, equipment, and supplies had been maintained in a state i of operational readiness. The conversion of the Technical Support and l Operational Support Centers into a combined, dedicated facility represented an :
improvement in operational function and readines !
4 ORGANIZATION AND MANAGEMENT CONTROL (82701-02.03)
The inspectors reviewed the emergency response organization staffing levels to i determine whether sufficient personnel resources were available for emergency l response. The emergency planning organization was reviewed to ensure that an I effective programmatic management system was in plac .1 Discussion The inspectors reviewed the staffing of the emergency response organization and the selection process for those position Initial selections of personnel for positions in the emergency response organization had been made by the various managers at the site in coordination with the emergency planning supervisor. Since the previous routine inspection, the emergency response organization had been reorganized into five crews, each capable of responding to emergency events. The crews had trained as single units and each had participated in a quarterly drill during April - May 199 Upon activation of the emergency response organization, the callout of staff will cycle through the five crews until each emergency response position is manne Overall responsibility for emergency response was assigned to the site Chief Administrative Officer. The emergency planning staff reported through the
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.nanager of regulatory services. The emergency planning supervisor had a staff of about ten personnel for emergency preparedness and planning functions. The inspectors found that the emergency planning group was staffed with an excellent number of qualified personne .2 Conclusions The Emergency Response Organization was comprised of qualified personnel at each position and had good overall staffing depth. The emergency pl ann in organization was well staffed with qualified personnel .
5 TRAINING (82701-02.04)
The inspectors reviewed the emergency response training program and met with personnel responsible for conducting the program to determine whether adequate emergency response training had been given to personnel designated to respond to emergencies, and to determine compliance with the requirements of 10 CFR 50.47(b)(15); 10 CFR Part 50, Appendix E.IV.F; and the emergency pla .1 Discussion 5.1.1 Emergency Response Training The inspectors reviewed the site emergency response training program with responsible manager The emergency response training program had been improved since the previous inspection by increasing the frequency of emergency preparedness drills, increasing hands on training, and by achieving a higher level of participation by response personnel. The licensee also provided annual training for offsite response agency personnel of the state and local agencies as requested. Randomly selected individual training records were inspected and verified to be up to date with required training accomplished. With the exception of Emergency Action Level training conducted by the operations training staff, emergency preparedness training had twen conducted by members of the emergency planning staf The inspectors reviewed selected documentation of seven emergency drills and exercises conducted since the last routine inspection. Drill and exercise reports were appropriate and identified areas for improvement. Emergency preparedness drills had been conducted quarterly, rotating between the five crews of the emergency response organization, items identified for improvement or as weaknesses had been documented and tracked in the site Performance Improvement Report (PIR) syste .1.2 Walkthroughs with Operating Crews The inspectors conducted a series of emergency response walkthroughs with operating crews to evaluate the adequacy and retention of skills obtained from the emergency response training program. Three crews were observed in the facility simulator while responding to a scenario that presented rapidly degrading plant conditions and exercised emergency action levels up to and including a General Emergenc The scenario was developed by the licensee l
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-7-l with input from the inspectors and is described in Attachment The i following sections contain the walkthrough results and conclusion l 5.1.3 Assessing Plant Conditions and Classifying Emergency Events Crew performance during the walkthroughs was inconsistent. One crew failed to identify and declare a General Emergency and was slow to classify a Site Area i Emergency, one crew unnecessarily created an additional release path, and one I crew failed to notify site personnel of further plant degradation and direct site evacuation. The following discussions relate to the performance of the operating crews:
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- Crew 1 At scenario reference time 21 minutes, the Crew I shift supervisor announced an Alert classification upon receipt of indications of greater than 1 percent fuel failure with a steam generator tube leak of approximately 50 gallons per minute. At reference time 29, the steam line leak was introduced and it was detected and reported to the shift supervisor at reference time 31. These conditions exceeded the emergency action level for a Site Area Emergency. Despite this, at reference time 41, the shift supervisor remarked to the shift engineer l that the emergency action level classification was still at an Aler I At reference time 43, the steam generator tube leak was further degraded to a 250-gallon per minute rupture which was in excess of available charging make-up capacity. This degradation exceeded the emergency l action level for a General Emergency. At reference time 57, a Site Area i Emergency was declared and site evacuation directed. The scenario was i terminated at reference time 68 without a General Emergency declaration '
having been mad The shift supervisor's declaration of a Site Area Emergency was made 26 minutes after known plant conditions exceeded the emergency action level for a Site Area Emergency. The inspectors also concluded that a General Emergency was not declared during a 25-minute period from the time when known plant conditions exceeded the emergency action level for a General Emergency to the time of scenario terminatio In follow-up questioning of the shift supervisor, the inspectors determined tnat the shift supervisor failed to properly read or understand a decision block in the emergency action level classification flow-chart contained in Radiological Emergency Response Plan Implementing Procedure 01-2.1, Attachment 1, Revision 13, page 3. The block required assessment of steam generator tube rupture flow rate versus centritugal charging pump make-up capacity. Even after the steam generator tube rupture flow rate was reported to be greater than charging make-up capacity, the shift supervisor appeared to have continued to exit the decision box in error as if tube rupture flow rate was within charging make-up capacit . _ - -- . . - -. .- - -
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-8-In addition to the errors made by the shift supervisor in properly classifying events, the individual performing the duties of the shift engineer for the crew did not independently verify the emergency action level classification as a back-up to the' shift supervisor. This observation was contrary to management expectations that the shift engineer perform independent, parallel classifications to compare with '
the classifications of the shift supervisor. This strategy was communicated informally to operations staff in an internal memorandum dated September 12, 1994 (this item is discussed further under operations training below).
, Despite the potential significance of the classification problems noted above, the inspectors concluded that the observations were not indicative of a programmatic weaknes The considerations supporting this conclusion are the following:
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The classification errors resulted from the shift supervisor incorrectly assessing a single decision box on a classification flowchart. When he referenced the flowchart on subsequent occasions during the scenario, the same error was repeated. As a result, the failure to classify appeared to be an isolated case of a single error repeated by one person on several occasions'during the i scenario. Immediate corrective feedback was given to the shift
! supervisor following the walkthrough. The inspectors verified through a review of training records, that the. shift supervisor on the staff crew had no prior history of problems of the sort observed during the walkthroug Crew I was a composite staff crew. The staff crew's performance
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the composed crew is fully capable of implementing the Emergency l
Plan in accordance with management expectations of individual crew j performance. Nonetheless, the staff crew was not representative of l
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a normal shift crew. Specifically, the person filling the role of ,
shift engineer en the staff crew was qualified as a Shift Technical i Advisor but had not been qualified at the lower qualification standard of a shift engineer. As a result, he had not trained or practiced in the role of shift engineer to perform independent, parallel classifications to compare with the classifications of the l shift superviso The two regular shift crews evaluated by the inspectors properly classified all event The licensee initiated a Programmatic Improvement Request in response to the staff crew's performance to examine potential causes of the classification error, the need for corrective action, and to track followup to the observations.
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. Crew 2 Crew 2 promptly and accurately classified all scenario events. Actions taken by crew 2; however, resulted in unnecessarily creating a second unmonitored release path. Specifically, at scenario reference time 30, the crew received the report of the unisolable steam leak at the i juncture of the B steam generator main steam line and its supply to the l turbine driven auxiliary feedwater pump. Within seconds, the shift l supervisor and control room supervisor concurred on a course of action to manually trip the reactor and then fast close all four main steam line isolation valves. This course of action was initiated at reference time 31. Immediately upon fast closure of the main steam line isolation l valves, the atmospheric relief valves on all four steam generators '
modulated open. The atmospheric relief valve on the B steam generator was observed to c'ontinue to cycle open for at least 15 minutes following the closure of the main steam line isolation valves. The consequences of this action were to initiate flow though an additional unfiltered radiological release path and to increase the release rate through the existing steam line brea l When questioned following the scenario, the crew defended its actions as appropriate to limit the amount of high energy steam released into occupied or potentially occupied spaces. The crew's rationale included the belief that having flow paths from all four steam generators to the steam line break increased the flow rate through the break. The crew failed to recognize that the leak rate through the steam line break was dependent only on the break size and geometry and the differential pressure across the break opening. Since all four steam generators were at the same pressure, the fact that they were all connected to the break was irrelevant with respect to break flow rate. Conversely the actions of the crew resulted in increased steam pressure in the line in which the break existed such that not only did break flow increase, but the setpoint of the atmospheric relief valve was exceeded which led to a significant net increase in radiological releas Crew 3 Crew 3 promptly and accurately classified all scenario events. Crew 3 also performed well in identifying a means of reconfiguring the ventilation in the affected space such that the release was largely redirected via a monitored release path through the plant vent stac This effectively changed the release from a ground level to an elevated release which may have reduced the onsite exposure dose rat Crew 3 failed to make plant announcements following the classification of both the Site Area Emergency and General Emergency as required by EPP 01-1.0 Attachment 3.0 and 4.0. Protective measures which would have accompanied these announcements would have been to order the evacuation of station personnel who had been instructed to assemble in the parking lot following the Alert classificatio The failure to inform plant personnel of necessary protective measures following the Site Area and
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-10-General Emergency classifications was identified as a weakness (482/9417-01).
.5.1.4 Notifications
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-Notifications were made in a timely manner by all' crews evaluated. Some l inconsistencies were noted between the crews in the information contained in the notification messages for the same events and conditions. Examples j included the following ,
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- In the Notification of Unusual Event notification message, Crews 1 and 2 l indicated that fuel cladding had been breached or challenged while i Crew 3 indicated only that Reactor Coolant System activity was greater than Technical Specification * In the Alert notification message, Crews 1 and 2 indicated that the fuel i
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cladding and reactor coolant system had been breached or challenged l while crew 3 indicated only steam generator tube rupture with dose equivalent iodine greater than 300 uCi/g I
- In the Site Area Emergency notification message, Crew 1 indicated fuel
- cladding and reactor coolant system breached or challenged, Crew 2 l indicated all three fission product barriers breached or challenged,. I
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while crew 3 indicated containment and fuel-cladding breached or challenged with a reactor coolant system leak to the B steam generator l and a leak to the auxiliary buildin In addition, 2 crews indicated )
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actual or imminent release, and one crew indicated no releas * For the General Emergency notification, Crew 2 used an out-of-date 1 I
l revision of the notification for Consistent indication of the reasons for the classification as noted in notification messages was identified as an area of potential improvemen .1.5 Protective Action Recommendations All crews issued appropriate protective action recommendations at the Site l
Area and General Emergency classification .1.6 Dose Assessment l
The chemistry technicians performed well to generate prompt dose assessments using information available. Good communications were observed between the chemistry technicians and the shift supervisors regarding dose assessment ,
input parameters, assumptions, limitations, and models used. One technician ;
was innovative in his approach to use coolant activity and the estimated steam '
generator leak rate to calculate an estimated release rate for the unmonitored release. The following observations were identified as areas for potential improvement:
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One technician failed to enter the time since shutdown into the dose assessment program. For the scenario evaluated, this oversight did not i result in a significant error in the dose projections generated and would not have resulted in a change of protective action i recommendation * One technician was unable to execute a dose projection on three j successive attempts, because an input value was too small to be accepted by the program. He was finally able to execute the calculation only l after switching to the backup dose projection computer which was using an earlier revision to the dose assessment progra All computers that- !
could be used for dose projections should be loaded with the current '
revision of the dose assessment program. In addition, the dose assessment program should provide an input error message if it cannot- 1 accept certain input parameters, and/or operators should be trained in !
the limitations of the program to accept certain input parameter .1.7 Operations Traininq )
The licensee's' staff has made errors in~ emergency action level classification during several recent NRC inspections and evaluations of this area including emergency preparedness exercises, licensed operator requalification -
examinations, and other emergency preparedness status inspections. The inspectors interviewed management and supervisory individuals from the operations and operations training staffs to better understand the licensee's ]
response to this on-going performance concern. Those individuals pointed to two areas that were intended to address this problem:
- The licensee had revised its emergency action level classification procedure to conform to recent industry developed guidelines (NUMARC).
The previous textual guidelines were replaced by diagnostic flow chart '
The licensee had determined in September 1994 that the potential for classification errors could be significantly reduced by training the shift engineers to act as an independent backup to the shift superviso The shift engineer was expected to independently use the emergency action level classification guidelines to confirm the determination made by the shift superviso The inspectors agreed that the revised classification procedure was an improvement over its predecessor. However, the particular error made by the individual who failed to declare a general emergency indicated a need to evaluate the training effectiveness in the use of the revised procedur With respect to the classification support role of shift engineers, the inspectors noted that the individual functioning as the shift engineer in the crew that failed to declare a general emergency did not normally function as the shift engineer and, therefore, was apparently unaware of operations management expectations. The individuals interviewed expressed to the inspectors that the training and communication of expectations regarding this duty of the shift engineer were both handled informally. Prior to being
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l-12-interviewed, the operations manager had assessed the awareness of all the current shift engineers regarding this management expectation. He concluded that all the currently active shift engineers were appropriately aware of this expectation but stated that this expectation had only been communicated l informally and to the best of his knowledge was not sr.ecified in the duties I and responsibilities of the shift engineer as contained in the site's ,
administrative procedure I The operations training organization was responsible for training operations !
shift personnel, including shift engineers, in emergency plan implementatio However, training supervision was vague on how the expectation to use the '
shift engineer to backup the shift supervisor was being supported through continuous training. The requalification training supervisor stated that all l shift engineers participated in the same requalification training as the licensed operators on the shift of which they were a part. On further questioning, the supervisor disclosed that the requalification training i program had not been revised to reflect this performance expectation. No l
formal training objectives had been developed to assure consistent on-going i training of shift engineers to perform independent emergency action level classifications. Further, there were no formal evaluation criteria to assess shift engineer performance or training effectiveness with regard to this tas The operations training programs were based on a systems approach to trainin However, the inspectors concluded that the operations training organization failed to implement elements of the systems approach to training process to assure that shift engineers could properly perform and remain proficient in emergency action level classification. The failure related to Elements 2, 3, 1 and 4 (Le.rning Objectives, Design and Implementation, and Trainee Evaluation)
of a systers approach to trainin (The elements of a systems approach to training are defined in 10 CFR 55.4 and further described in NUREG-1220, j " Training Review Criteria and Procedures." The regulatory requirement
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regarding a systems approach to training as part of the training process for
the shift technical advisor {the role filled by the shift engineer at Wolf Creek} is contained in 10 CFR 50.120[b]).
The inspectors developed a separate concern with regard to the initial licensee response to the observed classification problems observed with Crew 1. The inspectors confirmed with the training supervisor that both he
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and the inspectors had observed the same classification problems on the part t
of the shift superviso The inspectors then asked licensee representatives how the licensee intended to respond to that performance. The training supervisor remarked that if the performance had been observed as a part of the annual requalification examinations, the individual would have been evaluated
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as unsatisfactory and required to participate in remedial training. He went on to state that if the performance had been observed in a structured training session, the individual would have been given extra instruction to understand the nature of the performance weakness. However, the supervisor stated that the performance demonstrated in this inspection activity did not trigger a formal corrective training response. He added that unless the performance weakness was contained in the final inspection report, no specific action on the part of the licensee was assured. The inspectors concluded that this was not responsive to Element 4, " Trainee Evaluation," of a systems approach to
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training. As noted above, the licensee did finally initiate a Programmat n Improvement Request in response to these observations ;
NRC regulations require training programs for shif t crew members to be based on a systems approach to training (10 CFR 50.120[b] and 10 CFR 55.59[c])
unless the licensee obtains specific agency approval for a different type-of training program. The classification problems noted above reflect a lack of rigor in applying the principles of a systems approach to training. Since the shift engineers were included in the licensed operator requalification training with respect to emergency action level classification, these problems are attributed to the licensed operator requalification training program. The concerns related to these problems are further heightened by the findings in the recent NRC Inspection Report 50-482/94-07. That report identified a training evaluation weakness in that licensed operators could be evaluated as satisfactory during dynamic simulator scenarios on the basis of nonperformanc In the framework of a systems approach to training, all of these findings exhibit overlapping concerns with regard to trainee evaluation. The NRC concludes that these concerns represent a negative trend in at least one aspect of the operations training programs. The NRC identified as an area of potential improvement the licensee's activities relating to the systems approach to training as it applied to operations training program Particular emphasis is recommended with regard to assessment of operations +
shift personnel performance in all operations related context .2 Conclusions i The inspectors determined that training conducted by the emergency preparedness organization was being accomplished as requ Ped and exhibited improvements in some areas. However, during walkthroughs with operating crews, personnel continued to commit errors with regard to emergency plan implementation in emergency action level classification and protective measures for site personnel. During the walkthroughs, a weakness was I identified for the failure of one crew to inform plant personnel of necessary
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protective measures following Site Area and General Emergency classifications.
l The inspectors concluded that informality and lax adherence to the principles of a systems approach to operations training, on the part of operations management and the operations training department, have contributed to these performance errors. Further, the inspectors concluded that the causal factors could have a significantly broader implication beyond emergency preparedness
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since the operations training department has responsibility for assuring that j operations shift personnel are competent in all aspects of safe plant operation. Therefore, the adherence to the principles of systems appyoach to training was identified as an area of potential improvemen INDEPENDENT AND INTERNAL REVIEWS AND AUDITS (82701-02.05)
The inspectors met with quality assurance personnel and reviewed independent and internal audits of the emergency preparedness program performed since the last inspection to determine compliance with the requirements of l 10 CFR 50.54(t).
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, The inspectors reviewed at d discussed with quality assurance personnel, the i most recent annual audit (TE: 50140 K-422) of the emergency preparedness program which had been performed from July 1 through July 29, 1994. The audit team members were determir,ed to be qualified, and the team leader was an ANSI l certified auditor with current Lead Auditor Annual Recertification as set l forth in licensee Administrative Procedure AP 30F001, " Training, l
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Qualification, and Certification of Audit Personnel." The audit team included personnel familiar with. and experienced in emergency planning, including an individual from the emergency planning organization at another reactor sit The inspectors reviewed the audit plan, scope of the audit, and the audit check list. The audit appeared to be thorough and complete and included a meeting with offsite emergency response organizations of the state and local jurisdiction The audit report had been issued to appropriate levels of management. The "
licensee had developed a tracking system for items identified in a report that required correction or improvement. Programmatic Improvement Requests had been issued for tracking each audit finding and improvement item. The quality assurance organization was reviewed and it was confirmed that it was separate and independent from line management for emergency planning. The quality assurance organization also had conducted a periodic surveillances of emergency preparedness since the last routine inspection (Surveillance Report TE: 53359 5-2059, dated September 17, 1993, titled " Simulator Classification and Immediate Notifications").
In addition to the required annual audit, the licensee had completed a special self assessment of the emergency planning and preparedness program at the
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Preparedness Program Performance Evaluation," was thorough and detailed in its i review of all elements of the program and its documentation. The report identified strength areas, areas for improvement and two program weaknesse Nine Programmatic Improvement Requests were issued to address weaknesses and l correction item .2 Conclusion Audits of emergency preparedness had been conducted in accordance with 10 CFR 50.54(t). Quality assurance audits and surveillances of emergency preparedness and planning had been performed by qualified personnel and were of proper scope, depth and effectiveness. A special self assessment of emergency planning and preparedness had been conducted in addition to the required annual audi EFFECTIVENESS OF LICENSEE CONTROLS (82701-02.06)
The inspectors reviewed the adequacy of the licensee controls system pertaining to safety issues, events, or problems. The review included discussions with quality assurance and emergency preparedness staff personnel and review of procedures and documentation of problem identification, root
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-15-cause analysis, management review of problem identification and solution, and corrective action .1 Discussion The licensee's controls were effective in identifying, resolving, and preventing problems by reviewing such areas as corrective action systems, root cause analyses, safety committees, and self assessment in the area of emergency preparedness. A principal tool in managing corrective actions is the PIR system. All personnel had been instructed in the use of the PIR in their site general employee training. PIR forms had been made available throughout the site and could be submitted by any employee regarding any item perceived as being a problem or safety issue. The organizational element for managing this program was the PIR Group, which was a fulltime site organization. Each PIR was subject to screening by the grcup to determine priority and urgency. During the review process, PIRs had been documented, assigned to a responsible manager, assigned a suspense date, and tracked through action completion. The inspectors noted that no long standing, uncorrected PIRs existed in the emergency planning and preparedness area .2 Conclusions The licensee had maintained an effective system of controls pertaining to safety issues, events, or problems. No long standing, uncorrected PIRs existed in the emergency planning and preparedness area ONSITE FOLLOWUP OF EVENTS AT OPERATING POWER REACTORS (993702)
One licensee event was reviewed during this inspection wherein the licensee had declared an emergency event since the last routine emergency preparedness inspectio .1 Event j On January 27, 1994, the licensee telephonically notified the NRC Headquarters Operations Officer that an Unusual Event had been declared at the site when the plant began a shutdown to Mode 3 due to Technical Specification 3.1. ,
requirements that "all full-length control rods be operable and positioned I within 12 steps of their group step and counter demand position." That
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condition had not been met at 2:44 a.m. (CST) when control bank rod "M12" was declared inoperable due to an electrical problem. The unusual event was terminated at 4:23 a.m. (CST) due to the plant entering Mode 3. The inspectors reviewed records of this event and determined that the classification and notifications were accurate and timely (Event No. 26689).
8.2 Conclusion A review of this event verified that the event classification was appropriate and that timely notifications were made to state and local emergency response agencies and the NRC in accordance with approved procedure ._ - _ ._= _ . . _ _ _ _ - . . _ _ _ _ _ _ _ _ _
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i 9 FOLLOWUP ON PREVIOUS INSPECTION FINDINGS (92702)
9.1 10 pen) Violatio'n 9326-01 Failure to correct weaknesses in the area of
emergency classification. The following specific corrections actions 4 were verified and found to be effective:
l * Immediate tabletop sessions on classification had been conducted.
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- * Simulator sessions had been conducted with operating crews, chemistry j technicians, and health physics technicians.
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j * Revised Procedure EPP 01-2.1 " Emergency Classification" was implemented t on August 2,1994 incorporating the new NUMARC emergency action levels.
I i The following corrective action had been implemented but the effectiveness was
- not demonstrated during the walkthroughs conducted during the inspection.
i * Shift engineers were added to Control Room staff on June 1,199 ,
However, during the walkthroughs, the actions of the shift engineers on i the two shift crews was not conspicuous enough to determine its impact
> on the successful classification mode. The independent or parallel use j of the classification flow charts by the shift engineer had been
identified as a corrective action strategy in internal documentation of j classification failures. The inspectors did not, however, observe i successful implementation of this measure. In addition, in the case of
- the staff crew evaluated during walkthroughs, the shift engineer clearly ,
did not perform independent, parallel classifications, and as a result, 1
) classification errors made by the shift supervisor went unchallenged and
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uncorrected. Consequently, the full impact of the shift engineers l acting in support of the shift supervisors in making prompt and accurate
- classifications could not be confirmed. This item will remain open i pending verification that shift engineers can be effective in support of
the shift supervisors in classifying emergencie i (Closed) Weakness 50-482/9326-02: Failure to make initial notifications 2 to the NRC in accordance with EPP 01- During the walkthroughs i conducted during the week of December 5-8, 1994, effective notifications j were simulated to the NRC and NRC Notification Form 361 was completed by the crews observed.
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ATTACHMENT 1 1 PERSONS CONTACTED 1.1 Licensee Personnel 4 S. Austin, Auditor
- G. Boyer, Manager, Training
- T. Conley, Superintendent, Radiation Protection
- *K. Craighead, Emergency Planner i
- J. Dagenette, Emergency Planner J
l l *T. Damashek, Supervisor, Regulatory Compliance
- T. East, Supervisory Instructor, Chemistry l *D. Fehr, Superintendent, Operations Training i *R. Flannigan, Manager, Regulatory Services
- W. Gosham, Wolf Creek Coordinator, KEPC0 i *R. Hagan, Vice President, Nuclear Assurance
- *R. Hubbard, Shift Supervisor
- J. Lilmore, Supervisor, Operations
- Lindsay, Manager, Performance Assessments
- R. Logsdon, Superintendent, Chemistry j i *P. Martin, Superintendent, Operations I
- B. McKinney, Manager, Operations
- 0. Maynard, Vice President, Plant Operations -
G. McClelland, Auditor
- T. Morrill, Manager, Quality Control-
- D. Moseby, Supervisor, Operations Training
- W. Norton, Manager, Nuclear Engineering E. Peterson, Quality Audits
- C. Redding, Compliance Specialist J. Roush, Emergency Technician
, *M. Schreiber, Supervisor, Emergency Planning l *G. Smith, Licensed Supervising Instructor l *K. Thrall, Emergency Planner l *S. Teal Emergency Planner l *J. Weeks, Assistant to the Vice President of Plant Operations l *S. Wideman, Supervisor, Licensing l * Williams, Manager, Plant Support I
- B. Winaearied, Emergency Planner The inspectors also held discussions with and observed the actions of other station and corporate personne * Denotes those present at the exit intervie EXIT MEETING The inspectors met with the licensee representatives indicated in Section 1 of this attachment on December 8, 1994, and summarized the scope and findings of the inspection as presented in this report. The licensee did not identify as proprietary any of the materials provided to, or reviewed by, the inspectors during the inspection.
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ATTACHMENT 2 EMERGENCY PREPAREDNESS INSPECTION SCENARIO NARRATIVE SUMMARY
- Simulation Facility
- Wolf Creek i
The scenario began with indication of elevated reactor coolant radioactivit l Gross' activity of 130 micro-curies per. milliliter was reported to the crew t which was above Technical Specification limits and met the criteria for
! Notification of an Unusual Event.
J j A 50-gallon per minute steam generator tube leak was then introduced into the ;
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B steam generator. This had no impact on the emergency action level 1 classification. After a short interval, the crew was notified that dose
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equivalent iodine was 420 micro-curies per gram which represented about l 2-5 percent core damage and exceeded the threshold for upgrading the emergency l
action level classification to an Aler A relatively small unisolable steam leak (0.1 percent of rated steam flow) was j then introduced at the juncture of the B steam generator main steam line and
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its steam supply line to the turbine driven auxiliary feedwater pump. In i addition to being unisolable, the release path was essentially unmonitored.
l The aggregate conditions of fuel damage, a steam generator tube leak, and an
- unisolable release from the affected steam generator exceeded the threshold ,
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for the declaration of a Site Area Emergency and site evacuation.
i The steam generator tube leak in the B steam generator was further degraded to i
a leak rate of 250 gallons per minute, greater than available make-up i capacity. This was sufficient to require upgrading the emergency action level
classification to a General Emergency. The total scenario run time was about
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