IR 05000482/1999009

Insp Rept 50-482/99-09 on 990830-0903.No Violations Noted. Major Areas Inspected:Events,Emergency Preparedness Facilities & Equipment,Emergency Plan & Implementing Procedures & Emergency Response Organization Training

ML20217C183
Person / Time
Site:	Wolf Creek
Issue date:	10/07/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217C175	List: IR 05000482/1999009 ML20217C172
References
50-482-99-09, NUDOCS 9910130184
Download: ML20217C183 (17)

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ENCLOSURE-U.S. NUCLEAR REGULATORY COMMISSION

. REGION IV Docket No.: 50-482 License No.: NPF-42 Report No.: 50-482/99-09

' Licensee:- Wolf Creek Nuclear Operating Corporation

' Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane, NE Burlington, Kansas Dates: August 30 through September 3,1999 Inspectors: Harry A. Freeman, Senior Emergency Preparedness Analyst Plant Support Branch Paul J. Elkmann, Emergency Preparedness Analyst Plant Support Branch

- Approved By: Gail M. Good, Chief, Plant Support Branch Division of Reactor Safety Attachment: SupplementalInformation

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I 9910130184 991007 PDR O ADOCK 05000482 PDR J

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EXECUTIVE SUMMARY

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Wolf Creek Generating Station NRC inspection Report No. 50-482/99-09 A routine, announced l'nspection of the operational status of the licensee's emergency preparedness program was performed. The inspection included the following areas: events, emergency preparedness facilities and equipment, emergency plan and implementing procedures, emergency response organization training, organization and management controls, audits, and effectiveness of corrective actions. Emphasis was placed on events and changes that had occurred since the last routine emergency preparedness inspectio Plant Suocort

Overall, the emergency preparedness program was effectively implemente Emergency response facilities were operationally maintained, and appropriate equipment and supplies were readily available. The emergency preparedness staff j were knowledgeable and conscientious individuals with appropriate expertise. Senior station management strongly supported emergency preparedness involvement by all station personnel. Comprehensive and in-depth program audits were conducted by qualified personnel using detailed matrices (Sections P2, PS, P6, P7.1).

The licensee recently implemented a complex change to the emergency pla Procedures for conducting reviews of changes to the emergency plan were detailed, well understood, and followed during the recent plan change. Documentation related to the plan revision was readily available. The inspectors determined that changes to the emergency plan did not constitute a decrease in effectiveness (Section P3).

NRC and licensee staff identified a number of pre-existing emergency plan elements that did not clearly or fully address information required by 10 CFR Part 50, Appendix Inspectors determined that licensee procedures contained the information that was 4 unclear or missing from the emergency plan and that actual program performance was l acceptable. No adverse impact on the licensee's emergency preparedness program )

was identified. The licensee committed to revise the emergency plan to resolve the identified issues (Section P3).

Two crews performed well during the simulator walk-throughs. The crews demonstrated i good operational awareness, generally good communication practices, and effectively I responded to the emergency problems. The shift supervisors exhibited good awareness of emergency preparedness requirements and effectively fulfilled the role of emergency coordinator. The licensee conducted appropriate critiques following each simulator session (Section P4).

Training records documented that emergency response training was completed in a timely manner. All emergency response organization members maintained required qualifications. Emergency drills and exercises were conducted at the required frequency (Section PS).

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• . The licensee's corrective actions for a selected sample' of performance improvement l- requests were appropriately determined and implemented (Section P7.2).

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Report Details IV. Plant Support P1 Conduct of Emergency Preparedness Activities (93702)

The inspectors reviewed licensee event reports to determine whether events occurred that rsquired classification. All events reported to the NRC operations center since March 1998 were properly evaluated and c!assified. There were no emergency declarations between April 3,1998, and September 3,199 P2 Status of Emergency Preparedness Fecilities, Equipment, and Resources s

insoection Scope (82701-02.02) \

'N The inspectors reviewed emergency response facilities, equipmEhQnstrumentation, supplies, and surveillance / test procedures to determine whether facifiligs, were maintained in a state of readiness. The following locations were assess &d(s

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Control Room 'N

• Technical Support Center / Operational Support Center (combined facility) \x\

Emergency Operations Facility xN s

b. Observations and Findinas A s

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The inspectors found the emergency response facilities orderly and capable of operation. Appropriate equipment, procedures, forms, and supplies were available and N

easily accessible. Radiological monitoring instruments in emergency kits were

, calibrated, and various sized self-contained breathing apparatus face pieces were available. The inspectors ensured that special respirator glasses were available for licensed operators who required prescription lense On September 1,1999, the inspectors identified that the licensee had failed to accomplish a self-imposed monthly inspection of respirators at all of the emergency facilities for the month of August 1999. The licensee immediately sent an individual to inspect the respirators and wrote a performance improvement report (corrective action program report) to address the missed inspection. The licensee responded appropriately to this oversigh c. Conclusions Emergency response facilities were operationally maintained, and appropriate equipment and supplies were readily availabl . .. .. .

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-5-P3 Emergency Preparedness Procedures and Documentation a. Inspection Scope (82701-02.01)

The licensee had implemented Procedure AP 06-002, Radiological Emergency

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i Response Plan, Revision 0, on January 5,1999, and submitted Procedure AP 06-002 to the NRC on February 4,1999, based on their determination that changes to the previous plan (Radiological Emergency Response Plan, Revision 58, December 1997)

did not decrease the effectiveness of the plan and the plan continued to meet the standards of 10 CFR 50.47(b). The licensee had identified potential decreases in the effectiveness of the plan prior to implementation and had submitted the identified changes to NRR for prior approval. The inspectors identified potential decreases in the effectiveness of the plan and severalissues involving 10 CFR 50, Appendix E requirements during an in-office review. These issues were discussed with licensee i staff on April 12, April 16, June 10, and August 6,1999. Based on the in-office review and discussions with the licensee, a decision was made to review the details of the .

emergency plan change during this inspection. The inspectors reviewed the previously approved emergency plan in effect during initial licensing (Revision 15, January 1985)

during the inspectio The inspectors evaluated the following areas to determine whether the emergency plan and implementing procedures were being maintained:

• Emergency plan changes

• Annual emergency action level reviews by off-site authorities ,

= 50.54(q) review packages

• Required ernergency plan and procedure submissions to the NrlC

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b. Observations and Findinas l

The licensee's emergency plan was recently extensively revised with complex changes to the following areas of the plan:

. Definitions i . Titles and positions in the emergency response organization

. Descriptions of emergency response equipment

. Descriptions of emergency response facilities

. Description of emergency classification methodology i The licensee discussed in detail the process for reviewing changes and the basis for the

, decisions. The emergency preparedness and licensing staffs stated that the current emergency plan revision improved the plan for the following reasons:

- Redundant information was eliminated

. Explanatory and background material was eliminated

. Scattered information was consolidated l

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Plant procedure format was immediately recognized by all responders

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Information was reduced to reflect regulatory requirements The inspectors focused the discussion of changes to the risk-significant areas of facility activation, duties of the emergency directors (nondelegable duties), classification, offsite notification, and protective action recommendations. The inspectors determined, that while some changes resulted in greater ambiguity in the plan and the level of detail concerning the licensee's program was considerably reduced, the level of detail remained sufficient. The inspectors determined that the effectiveness of the revised plan was not reduced and that the licensee's 50.54(q) determination was appropriat The inspectors identified several examples where the revised emergency plan did not fully or clearly describe information required by 10 CFR Part 50, Appendix E, as discussed below. The inspectors reviewed the previously approved emergency plan in effect during initial licensing (Revision 15, January 1985) and concluded that the issues noted in the revised emergency plan were also not discussed in that revision. This supported the licensee's position that some Appendix E requirements had never been included in the emergency plan. These issues are considered to be adminNtrative in nature and do not affect the implementation of the emergency pla *

Although the emergency organization was described, a description of the normal, non-emergency, onshift station organization was not include * A time requirement for notifying offsite agencies following an emergency classification or protective action recommendation was not specifically mentioned in the emergency plan. Time requirements for completing offsite notifications were contained in applicable licensee procedure * The personnel responsible for dose projections during the period that the control room shift supervisor is acting as emergency manager was not clearly described in the plan. Plant procedures describe personnel called to the control room to perform dose assessment. Control room dose assessment was correctly  !

performed during simulator walk-through * A requirement to annually review emergency action levels with offsite officials was not mentioned in the emergency plan. Inspectors determined that the i

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reviews had been performed and that the requirement continued to be me !

• Facilities for personnel decontamination were not fully described in the emergency plan. Inspectors determined that adequate facilities did exist to provide for decontamination of emergency workers, as require * Backup onsite and offsite communications systems were not fully and clearly l described in the emergency plan. Inspectors determined that an adequate l emergency response facilities communications capability did exist and was being appropriately maintained.

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The emergency plan did not fully describe backup communications for environmental monitoring teams. Inspects rs determined that an adequate ,

communications capability did exist for environmental teams and was being l appropriately maintaine j

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Periodic requirements for emergency response organization members to participate in drills and exercises were not described in the emergency nia l Inspectors determined that the licensee frequently exercised the emergency organization and that all emergency responders had participated in a timely manne *

Requirements for periodic retraining of emergency response organization members were not described in the emergency plan. Requirements for l continuing training were contained in licensee procedures, inspectors determined that periodic retraining of the emergency response organization was being performed as reauire *

A requirement for periodic provMon of radiological training to offsite emergency responders was not described in the emergency plan. Inspectors determined l

that appropriate radiological training was being provided by the licensee to c1 site l responders and that all requirements were being me * A requirement for conducting an off-year functional drill between biennial I exercises was not clearly described in the emergency plan. Inspectors  ;

determined that the licensee's drill program included drills of a sufficient scope to meet the off-year requirements and that all required drills were conducte * A requirement to provide the opportunity to participate in off-year drills to offsite responders was not included in the emergency plan. Inspectors determined that the licensee provided sufficient notice and opportunity to offsite agencies to allow them the opportunity to participate during the off-yea * Although the emergency plan addressed the conduct of critiques following training and drills, there was a lack of clarity pertaining to whether critique results were considered as inputs to the licensee's general corrective action program. Inspectors reviewed current corrective action items for emergency planning and determined that critique results were being used appropriately as corrective action program input The licensee performed a detailed review of the plan and identified four additional Appendix E requirements that were not fully addressed:

• The use of licensee headquarters staff used as emergency responders was not discussed in the emergency plan. The licensee stated that headquarters staff were not a routine part of the emergency responder organizatio ,

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• The communications steps to be taken by the licensee following each level of emergency classification were not fully and clearly defined in the emergency plan. Appropriate communications steps were described in licensee procedures and communications capabilities were appropriately maintained.

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• The offsite position that receives emergency notification calls was not clearly j

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listed in the emergency plan. Inspectors determined that the licensee's system f for making offsite notifications was adequate and reliabl * A requirement or criteria to conduct remedial exercises as necessary was not discussed in the emergency plan. Inspectors determined that all exercises had been appropriately evaluated and that all requirements were me The superintendent of emergency planning stated that the licensee would resolve these issues in a future emergency plan revision. The licensee documented these issues in its corrective actions program as Performance Improvement Request 99-210 )

I c. Conclusions The licensee recently implemented a complex change to the emergency pla Procedures for conducting reviews of changes to the emergency plan were detailed, well understood, and followed during the recent il an change. The inspectors determined that the recent changes to the emergency plan did not constitute a decrease in effectivenes NRC and licensee staff identified a number of pre-existing emergency plan elements I that did not clearly or fully address information required by 10 CFR Part 50, Appendix Inspectors determined that licensee procedures contained the information that was unclear or missing from the emergency plan and that actual program performance was acceptable. No adverse impact on the licensee's emergency preparedness program was identified. The licensee committed to revise the emergency plan to resolve the identified issue P4 Staff Knowledge and Performance in Emergency Preparedness a. Inspection Scoce (82701-02.04)

The inspectors observed two operating crews perfctm emergency response activities for I a simulated accident scenario that led to a general emergency condition with an offsite

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release of radioactive material. The simulated accident scenario evaluation was l

performed on the plant-specific simulator in a dynamic scenario progression. The l

scenario was developed by the licensee and designed to evaluate the onshift emergency response organization's performance in the following risk-significant j emergency preparedness functions: I

• Event assessment and classification

• Offsite agency notification

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• Assessment of offsite dose consequences of radioactive material releases

Development and communication of approprbte protective action recommendations for both onsite and offsite personne i i

b. Observations and Findinas l The license ; .:mulated accident scenario involved a progressively larger

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primary to-secondary leak in a steam generator combined with the inability to supply

! auxiliary feedwater. The scenario was designed to be classified at the notification of q unusual event, site area emergency, and general emergency levels without an intermediate alert classification. The projected protective action recommendation was for a 2-mile radial evacuation and additional 2-5 miles downwind evacuatio The first crew classified a notification of unucual event, an alert, a site area emergency, and a general emergency. The first crew also recommended a 2-mile radial evacuatio The second crew classified a notification of unusual event, a site area emergency, and a general emergency. The second crew also recommended an evacuation in geographical areas equivalent to 2-miles radially and also 2-10 miles in the downwind direction. The inspectors noted that the chemistry technician performing the onshift dose assessment for the second crew completed the dose assessment analysis while the shift supervisor was using the protective action procedure and did not provide the dose assessment results to the shift superv;sor until after the protective action procedure was complete The inspectors discussed procedures for classification and protective action recommendations with licensee staff following the walk-through simulated accident

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scenario in order to understand the actions taken by both crews. Licensee staff stated that while the observed classification and protective action decisions were surprising, ,

the decisions were correct based on the information available to the shift supervisor at l the time the decisions were made. The inspectors determined that the shift supervisors l of both crews properly followed classification and protective action recommendation !

procedures based on the available informatio c. Conclusions

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Two crews performed well during the simulator walk-throughs. The crews demonstrated l good operational awareness, generally good communication practices, and effectively )

responded to the emergency problems. The shift supervisors exhibited good awareness !

of emergency preparedness requirements and effectively fulfilled the role of emergency coordinator. The licensee conducted appropriate critiques following each sin.ulator l session.

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P5 Staff Training and Qualification in Emergency Preparedness Inspection Scope (8270102.04)

The inspectors reviewed the emergency response organization training program, training records for selected individuals, lesson plans, and training documents. The inspectors also reviewed files and records associated with drills and exercise b Observations and Findinos Training records indicated that individuals were properly trained, and all records examined were complete and up to date. Expiration dates for required training were i easy to determine, and training status was tracke ' The inspectors interviewed selected members of the emergency response organization concerning their training. The inspectors determined that the individuals were

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knowledgeable of their emergency response duties. Training on changes to procedures was effectively tracked by required reading lists and discussed during periodic table top drill The inspectors confirmed that required radiological, chemistry, and medical drills were properly conducted. Critiques were performed following each drill, and appropriate action items were identified and tracked. Elements from these specific drills were included in many site-wide drill Conclusions Training records doct,nented that emergency response training was completed in a timely manner. All emergency response organization members maintained required qualifications. Emergency drills and exercises were conducted at the required frequenc P6 r;mergency Preparedness Organization and Administration Inspeption Scope (82701-02.03)

To evaluate emergency planning department staffing changes, emergency response j organization staffing, and overall management program support, the inspectors i reviewed the emergency response organization roster and interviewed the emergency ;

plannin0 superintendent, training manager, and several emergency facility manager I Q_bservations and Findinas  !

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In order to promote better team work within each of the emergency response faciiities, the licensee had reorganized all of its emergency response teams since the previous inspection. Four offsite and four onsite emergency managers were selected by senior i licensee officials to form the four emergency response teams. The emergency preparedness organization supplied listings of all qualitieo individuals for each team

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position required by the emergency response organization. The emergency managers )

selected the team members in a site-wide draf Through discussions with the emergency planning superintendent, the inspectors noted that the licensee had moved the dose assessment function from the technical support i center to the emergency operations facility. This functional move was a logical change

! since dose assessment provided the basis for protective action recommendations developed in the emergency operations facilit The inspectors interviewed several members of the emergency response organization to determine the levei of importance placed on emergency preparedness. Each individual

)j stated that they had three jobs of equalimportance. These were their normal job, )

outage job, and emergency preparedness jo Conclusions Senior station management strongly supported emergency preparedness involvement by all station personne P7 Quality Assurance in Emergency Preparedness P7.1 Independent and Internal Reviews and Audits Inspection Scope (82701-02.05)

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The inspectors reviewed the independent reviews of the emergency preparedness program (Audit Reports K-495 and K-515) performed during the past 2 year Observations and Findinas

The inspectors determined that the audits met the requirements of 10 CFR 50.54(t).

The audit teams included qualified members from the licensee's staff and technical specialists from other nuclear power facilitie The auditors reviewed selected aspects of the emergency preparedness program using audit matrices. These matrices included reviews of the emergency plan and procedures, facilities and equipment, organization and management, training, and the annual effectiveness revie As a result of these audits, the licensee initiated several performance improvement ,

i requests. Issues included the identification: that the Updated Safety Analysis Report l description of the emergency plan needed updating, that emergency preparedness

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equipment was being used for non-emergency plan activitics, that an unapproved draft

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procedure was located in the phone team room at the emergency operations f acility, that the required number of pocket ion chamber dosimeters were not located at the emergency operations facility, and concerns related to the adequacy of training. The inspectors reviewed the corrective actions to these deficiencies and found them to be promptly resolved and appropriate to the issue.

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-12- Conclusions Comprehensive and in-depth program audits were conducted by qualified personnel -

using detailed matrices. Issues raised by the audits were appropriately documented in

. the licensee's corrective actions program. The corrective actions to the audit-identified deficiencies were prompt and appropriat P Effectiveness of Licensee Controls , !nsoection Scoce (82701-02.06)

The inspectors reviewed a listing of emergency preparedness related performance improvement requests generated since April 1998 and selected sevctal reports to evaluate the effectiveness of the licensee's controls in identifying, resolving, and preventing problems, . Observations and Findinas The performance improvement request process was used to track issues identified during c. rills, other forms of training, and audits. The inspectors reviewed five performance improvement requests and determined that the system was effectively implemented for emergency planning and that appropriate actions were taken to address identified issuc Conclusions The licensee's corrective actions for a selected sample of performance improvement requests were appropriately determined and implemente P8 Miscellaneous Emergency Preparedness issuer,(92904)

P (Closed) Inspection Followuo item (50-482/9807-01): Failure to properly assess plant

. conditions and declare a general emergency. While observing a simulator scenario

' during the 1998 inspection, the inspectors observed that one crew failed to identify a containment breach and, consequently, failed to declare a general emergency. During this inspection, the inspectors reviewed the licensee's corrective actions and observed two control room crew's performance during the sirnulated accident scenarios. Both

. shift operations crews demonstrated correct performanc !

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b-13-V. Manaaement Meetinas X1 . Exit Meeting Summary The inspectors presented the inspection results to members of licensee management at an exit meeting on September 3,1999. The licensee acknowledged the findings presented. During the exit meeting, appropriate licensee management stated that the station's emergency plan would be revised to resolve differences identified between the plan and 10 CFR Part 50, Appendix E, and that the licensee would provide to the NRC a proposed date for completion of the plan revision. No proprietary or confidential information was identifie l

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ATTACHMENT SUPPLEMENTAL INSPECTION INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee M. Angus Manager, Licensing and Corrective Action D. Birk Senior Emergency Planner, Er.iergency Planning M. Dale Emergency Plan Specialist, Emegency Planning M. DeLaCruz Superintendent, Mechanical Maintenance T. East Superintendent, Emergency Planning R. Flannigan Manager, Nuclear Engineering T. Garrett Manager, Design Engineering B. Goshorn KEPCO M. Guyer Superintendent, Operations Support T. Harris Superintendent, Licensing S. Hedges Superintendent, Operations D. Hooper Engineering Specialist, Licensing K.Hughes Engineering Specialist, Licensing D.Jacobs Manager, Support Engineering J. Johnson Manager, Resource Protection l C. Jones Superintendent, Maintenance Support {

D. Knox Manager, Maintenance S. Koenig Manager, Performance Improvement and Assessment R. Kopecky Superintendent, Outage G.Lawson Superintendent, Maintenance Planning O. Maynard " resident and Chief Executive Officer R. Muench Vice President, Engineering and Information Services

J. Pippin Manager, Training C. Rich J Superintendent, Instrumentation & Electrical R. Sims Manager, System Engineering K. Thrall Emergency Planner, Emergency Planning C. Warren Vice President and Chief Operating Officer B. Winzenried Senior Emergency Planner, Emergency Planning

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C. Younie Manager, Operations J. Zell Manager, Engineering Performance NRC l F. Brush Senior Resident inspector INSPECTION PROCEDURES USED IP 82701: Operational Status of the Emergency Preparedness Program IP 93702: Prompt On-site Response to Events at Power Reactors IP 92904: Followup - Plant Support

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l -2-ITEMS OPENED, CLOSED, AND DISCUSSED Ooened None Closed 50-482/9807-01 IFl Failure to properly assess plant conditions and declare a general emergency (Section P8.1).

Discussed None LIST OF DOCUMENTS REVIEWED EPP 06-005 Emergency Classification Revision 1, 3-31-99 EPf- 06-006 Protective Action Recommendations Revision 0,1-5-99 EPP 06-007 Emergency Notifications Revision 1,3-2-99 EPP 06-008 Re-Entry, Recovery and Termination Revision 0,1-5-99 Operations EPP 06-010 Personnel Accountability and Evacuation Revision 1, 8-20-99 AP 06-002 Radiological Response Plan Revision 0,1-5-99 Radiological Response Plan Revision 58,12-23-97 Radiological Response Plan Revision 15, Jan.1985 Al 26A-003 Regulatory Evaluations (Other than Revision 0 10 CFR 50.59)

Form APF 26A-003-01 Regulatory Screening #59 (AP 06-002, Revision 0 Revision 0)

Form APF 26A-003-02 Evaluation of Proposed Change (Other Revision 0 l I

than 10 CFR 50.5), for AP 06-002, Radiological Emergency Response Plan l Forro APF 26A-003-003 50.59 Unreviewed Safety Question #59 Revision 0 l 98-0148, for AP 06-002, Radiological Emergency Response Plan l

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Form APF 15C-004-01 Document Revision Request, for Revision 9 AP 06-002, Radiological Emergency Response Plan

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RERP! Appendix E Cross Reference Matrix l

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