ML20058K371

Insp Rept 50-482/90-24 on 900514-18.Violation Noted.Major Areas Inspected:Operational Status of Emergency Preparedness Program,Including Changes to EPIPs & Review of Emergency Facilities

ML20058K371
Person / Time
Site:	Wolf Creek
Issue date:	06/15/1990
From:	Powers D, Spitzberg D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058K365	List: ML20058K361 ML20058K368 ML20058K371
References
50-482-90-24, NUDOCS 9007050069
Download: ML20058K371 (10)

See also: IR 05000482/1990024

Text

. .

-

.

APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

Y

-

REGION IV i

NRC Inspection Report:

^

50-482/90-24 Operating License: NPF;42

Docket: 50-482

-

Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

N

P.O. Box 411

-

-

Burlington, Kansas 66839

Facility Name: Wolf Creek Generating Station (WCGS)

Inspection At: Burlington, Kansas

Inspection Conducted: May 14-18, 1990 I

3

-

7

Inspector: b ,

c/ W L 5'/6'90 d

Dr. D. B. Spitzberg, Emergency Pre 5aredness Date j

Analyst --

Approved: Ol& N '[0

Dr. D. A. Powers, Chief, Security and Date -

Emergency Preparedness Section g

M

R

I <pection Summary =

Inspection Conducted May 14-18, 1990 (Report 50-482/90-24)

4

_=

Areas Inspected: Routine, unannounced inspection of the operational status of j

the emergency preparedness program, including changes to the emergency plan anti =1

implementing procedures, and review of emergency facilities, equipment, "

management control, independent audits of the emergency preparedness program, g

and training of emergency response personnel. g

_

Results: Within the areas inspected, one apparent violation was ide,1ti fied. I

The violation involved the failure to provide adequate training to dose .

assessmrnt personnel in order to maintain their proficiency in generating j

accurate of f site dose assessments (paragraph 6). m

One unresolved item and one open item were identified for further review and 5

follewup. The unresolved item pertains to an apparent inconsistency between -'

the emargency plan and an emergency plan implementing procedure over minimum ,

protective action recommendations that will be made at a general emergency 2

(paragraph 3). The open item involves the QA corrective action program ano

1

en

^

. ..

gh l

pg pm & ( c a'n n'4 7

c, es -

--

. .

• "

.

. .

~2- .

. .

closure of two licensee identified quality assurance program

deficiencies (paragraph 7).

The licensee's emergency response ofganization was well staffed with qualified

individuals. The emergency planning function has been moved up to a hight)

IcVel in the management organization, Facilities and emergency equipment were

found to be secure and functional, Surveillances and the quality assurance

audits were extensive and well targeted in the emergency preparedness area;

however, certain quality assurance findings were not promptly corrected. The

licensee has promptly and properly processed changes to the emergency plan and

its implementing procedures. The licensee's computer based offsite dose

assessment method was found to be slow and difficult for assessors to use. The

licensee's emergency preparedness program was found to be in a state of

operational readiness,

. .

1. -

• t -,  %* e

a. .

, .

-3--

DETAILS

1. Persons Contacted

!

• G. Boyer, Plant Manager

F. Rhodes, Vice President, Engineering and Technical Support  ;

• J. Bailey, Vice President, Nuclear Operations l

• M. Williams, Manager, Plant Support i

• W. Lindsay, Manager, Quality Assurance

• C, Parry, Director, Site Quality

• K. Moles, Manager, Emergency and Radiological Services

• K. Craighead, Emergency Response Planner

"J. Zell, Manager, Training i

• R. Logsdon, Manager, Chemistry

[

• H. Chernoff, Supervisor, Licensing

• D. Moseby, Supervisor Operations

• M. Schreiber, Senior Engineering Specialist

• 0. Parks, Supervisor, Corporate Training  ;

i

The inspector also held discussions with other station and corporate

personnel in the areas of . security, health physics, operations, training,

and emergency response.

• Denotes those present at the exit briefing. 1

2, Followup on Previo nly Identified Inspection Findino (9270)Q

(Closed) Open Item (482/8906-01): The licensee's procedures did not -p

facilitate the determination of emergency planning subzones nor expedite'

the dose assessment calculations. The inspector reviewed Emergency Plan ,

Procedure (EPP) EPP-01-101, " Protection Action Recommendations," which was-  !

revised in May 1989, The revised procedure clarified dose assessment l

calculations to better ensure propor use of wind direction data. The L

procedure also clarified the designation of the proper emergency planning i

subzone and protective action recommendations. The inspector noted that

'

responsible emergency personnel were well trained in the selection of

subzones,.use of protective action recommendations, and did not appear to

be hindered by the procedure in performing dose assessment calculations.

It was noted, however, that errors were made in the calculation of offsite  ;

doses during the walkthrough interviews described in paragraph 6. This I

finding was similar to two of the previous observations described in this

open item. Consequently, this item will be considered closed with the

continuing dose assessment problem to be t m.kea witn tne  !

violation (Appendix A).

(Closed) Open Item (482/8906-02): The licensee made a commitment to

upgrade quality assurance audits of emergency preparedness by conducting  !

training interviews and by using emergency preparedness specialists from I

other facilities to strengthen audit teams. The inspector determined that

an emergency preparedness specialist from River Bend Station was used i

during the 1989 annual audit of the emergency preparedness program. In l

3

4

~

, .

@

.

-4-

addition a number of training interviews with emergency response personnel

was conducted as part of the annual audit.

3. Emergency Plan and Implementing Procedures (82701-02.01)

The inspector reviewed changes to the emergency plan and implementing ,

'

procedures to verify that these channes have not adversely affected the

licensee's overall state of emergency preparedness. The inspector also

reviewed the licensee's emergency preparedness program to verify if major

or significant changes to the emergency plan and implementing procedures

had been reviewed, approved, and distributed in accordance with licensee's

procedures and 10 CFR 50.54(q) requirements.

Since March 1989, the licensca had submitted to NRC changes to 26 EPPs

'nvolving a total of 31 revisions. In addition, there was one

rsvision (No. 26) submitted to the radiological emergency response

plan (RERP). The revisions had been submitted to NRC within the 30-day

time frame required by 10 CFR 50.54(q) and 10 CFR 50 Appendix E.V. The

inspector reviewed the revisions submitted and determined that the changes

did not decrease the effectiveness of the RERP.

The inspector reviewed EPP 02-1.1, " Emergency Planning Program," which

includes the procedures for issuing and revising EPPs and the RERP. From

this review, it was determined that the revisions implemented during the

period inspected were properly reviewed, approved, and distributed in

accordance with the guidance procedure.

The inspector reviewed the content of a number of EPPs to determine their

consistency with the emergency plan. It was noted that an apparent

inconsistency exited between EPP 01-10.1, Revision 6, " Protective Action

Recommendations," and Section 3.3.2 of the plan entitled, "Offsite

Protective Actions." According to the plan, at the General Emergency (GE)

classification, either an evacuation, c shelte ring will be recommended ,

for affected offsite areas of the emergency p'anning zone, This is

consistent with federal guidance contained in Appendix 1 of NUREG-0654 and '

Information Notice 83-23, " Criteria for Protective Action Recommendations

for General Emergencies," May 4, 1983. The inspector found, however, that

Attachment 1 of EPP 01-10.1 contained a decisionmaking flowchart for the

l GE which did not recommend a minimum of sheltering if projected doses were

'

available and were less than protective action guidelines. The rinimum

-recommendation to shelter the center subzone out to 2 miles, and 5 miles

downwind should be made at the time a GE is detected, and should be

independent of.any dose projections available. This will be considered an

unresolved item pending the review of licensee information requested

concerning this observation (482/9024-01)

l

The inspector reviewed the most recent copies of letters of agreement

between WCNOC and assist organizations and found them to be current for

1990.

1 s

No violat.ons or deviations were identified in the program area.

L

-

-

-' #

.

. .

.$.

4. Emergency Facilities, Equipment, Instrumentation, and

Supplies (82701-02.~02)

The inspector toured key emergency facilities and inspected dedicated

emergency equipment to verify that they were adequately maintained and to

determine if changes made since the last inspection were technically

adequate, met NRC requirements, met licensee commitments, were

-appropriately incorporated into the emergency plans and implementing

procedures, and had no adverse effect on the licensee's emergency

readiness.

The facilities were noted to be secure, orderly, and stocked with adequate

equipment and supplies. A number of emergency radiation survey

instruments and air samplers were verified to be operational and

calibrated. The inspector reviewed records of routine surveillances

conducted by the emergency planninn staff of emergency facilities and

equipment. These surveillances included equipment inventories, emergency

vehicle checks, communications equipment tests, and siren tests. Based on

this review, the inspector determined that emergency facilities,

equipment, and supplies had been maintained in an operational state.

No violations or deviations were identified in this program area.

5. Organization and Management Control (82702-02.03J

The inspector reviewed the emergency organization and management control

system to determine if changes have been properly incorporated into the-

emergency plan and implementing procedures and have not adversely affected

the licensee's emergency response readiness.

Emergency response organization (ERO) staffing was reviewed and it was-

determined that personnel assigned to the designated positions were

qualified, trained, and that adequate staffing depth was available to

implement-the emergency plan and implementing procedures. Since the

previous inspection the ERO had been modified with the transfer of

responsibilities of two public information positions from the KG&E Wichita

office to the WCNOC Wichita office. No other ERO additions or deletions

had been made.

The inspector reviewed the organization responsible for emergency planning

to determine whether adequate resources and management attention had been

placed on this area and to verify that the organization was consistent

with the emergency plan Section 0.1-1. Since the previous inspection, the

emergency planning function had been changed from reporting to the manager

of health physics to reporting to the manager of plant support. This

change eliminated one management level and moved the emergency planning

function to a higher level in the WCNOC management scheme. In addition,

the emergency planning staff has added one professional staff member and

one technical staff position. The emergency planning management is

divided among two individuals. The manager of emergency and radioloaical

services is based in Wichita and is responsible for offsite emergency

1

,

-,

" -

.' ,

<

,

,

. .

.

-6- i

planning. Approximately 50 percent of his-time is allocated to emergency

planning. The onsite emergency planning effort is managed by an emergency

, planning specialist based onsite. The inspector reviewed the job >

description and qualifications of the emergency planning staff and found

them to be appropriately qualified.

No violations or deviations were identified in this program area.

6. Training (82701-02.04)

The inspector met with training staff personnel, reviewed training

procedures, and documentation of training of personnel assigned.to the

emergency organization to determine compliance with the requirements of

10 CFR 50.47(b)(15); 10 CFR 50, Appendix E.IV.F; and the emergency plan

and implementing procedures.

The emergency preparedness training organization is nested in the training

department and comes under the responsibility of the manager of. training

who reports to the vice president of nuclear operations. The emergency

preparedness training is coordinated by the supervisor of corporate

training and is carried out by two emergency planning instructors. The

inspector met with the responsible training staff personnel and reviewed

the training, qualifications, and certifications of the training staff.

It was determined that these individuals met the requirements of

Procedure ADM 06-230, " Instructor Training Qualification, Continuing

Training and Certification."

The inspector reviewed Procedure EPP 02-1.2, " Emergency Plan Training

Program," which specifies the training requirements for.ERO personnel.

Each member of the ERO had been provided initial training'and annual i

requalification training as specified in EPP 02-1.2 in accordance with

'

their assigned responsibilities. Written examinations were administered

following each training segment. The inspector reviewed a number of -

emergency training course lesson plans and found them to be well

organized, comprehensive, and to include task oriented classroom training.

The lesson plans had been developed by the training department and

approved by emergency planning.

. The training department has been responsible for the scheduling of

emergency preparedness training and for ensuring that ERO training status

is current. The inspector reviewed a number of individual training

. records for key ERO positions selected randomly and found that these-

records reflected that required emergency response training was properly

tracked and current.

The inspector conducted a series of walkthrough interviews of teams of

critical emergency response personnel to determine whether the basic level

of training, understanding of emergency preparedness, and their abilities

to implement emergency actions were adequate to satisfy the requirements

of the emergency plan.

.,

+

e<  : .

.

J i ,.

,c ..

. .

7

.

The-inspector interviewed four teams. Three of the teams were interviewed

in the technical support center and, at a minimum, each team consisted of-

a shift supervisor, a supervising senior reactor operator, a chemistry

technician, and a health physics technician. The fourth team was

interviewed in the emergency operations facility and consisted of a duty

emergency manager, an administrative resource: manager, a technical

resources manager, and radiological assessment manager, and a dose

assessment supervisor.

Each interview last about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and consisted of two parts. One part

presented 15 questions of a technical nature pertaining to fundamental

knowledge decisionmakers need to know in order to perform their duties

efficiently. The other part of the interview consisted of presenting an

accident scenario developed by the inspector, which was designed to prompt

the interviewees to classify, notify, perform dose assessment, and make

protective action recommendations (PARS). The scenario was based on an

interfacing system loss-of-coolant accident involving a degraded core,

steam generator tube rupture, and failure, in the lif ted position, of a

power operated relief valve coming off the affected steam generator.

Radiological parameters were provided for containment high-range radiation

monitors, the auxiliary feedwater turbine discharge monitor, and for the

steam line monitors upstream of the release point. In addition, necessary

meteorological data was provided. Prior to the interviews, the scenario

was reviewed by a licensed operator training instructor with the inspector

to ensure that the scenario was technically accurate, and that sufficient

information was provided to adequately test interviewees' assessment

capabilities.

The inspector noted that all teams demonstrated a good general

understanding of the emergency plan as~ evidenced by the responses ~to

questions presented by the inspector. In responding to the scenario,

three of the teams made offsite dose assessment errors which resulted,uor

could have resulted, in improper emergency classification or protective

action recommendations. The specific errors were all simple mistakes made

when obtaining values from tables contained in Procedure EPP 01-7.3,

Revision 9, " Manual Dose Projection Determination." The following

problems were noted:

Two teams used the wrong table from A'ttachment 4.0 of EPP 01-7.3 in

obtaining the atmospheric stability class. This resulted in the

incorrect stability class being used in calculating atmospheric

dispersion'and offsite dose rates. The teams erred when they used

the table for obtaining stability class from 60-10 m delta T in C,

when the data was provided on paper in F and for which there was

another table in Attachment 4.0.

Another team made an error in determining stability class when,

apparently, the wrong line was read from the tables contained in

EPP 01-7.3, Attachment 4.0, Section 2.0.

- - _ _ . _ _ . _ . .

(

. .

.

-8-

'

One of the teams, which made errors in determining the proper

stability class, also made an error in obtaining a correct conversion

factor from EPP 01-7.3, Attachment 5.0. This conversion factor

becomes the numerator in the calculations of X/Q dispersion factors,

and is proportional to the offsite dose rates. The error was made by

using the Table B' values instead of Table A values, which is the

correct table for use_when windspeed is in mph as was presented in

the scenario.

1

10 CFR 50,47(b)(15) states that radiological emergency response training  !'

shall be provided for those who may be called to assist in an emergency.

Contrary to the above, the inspector determined that three of four dose

assessment personnel interviewed had not been adequately trained to o

accurately provide offsite dose assessments in accordance with

Procedure EPP 01-7.3. This was identified as an apparent violation of

10 CFR 50,47(b)(15). (482/9024-02)  !

.i

In additions to the problems noted above, the inspector made the following

observations relative to the determination of offsite doses: -l

The dose assessment personnel expressed a preference for, and stated i

that they would use either the manual or calculator dose assessment

methods instead of the method utilizing the radiological release

information system (RRIS) computer model for early determination of ,

offsite doses. This observation appeared to the inspector to be in

conflict with wording in the procedures which indicated that the RRIS

system was intended to be the primary dose assessment method.

Section 1.1 of EPP 01-7.3, " Manual Dose Projection Determination,"

states, in part, that the procedure will be used in the event of a

release of airborne radioactive material and the RRIS becomes

inoperable._ Section 2.0 of EPP 01-7.1, " Radiological Release

-Information System," states, in part, that this procedure shall be

utilized after the RRIS is operable to automatically project or i

calculate the radiological doses and dose rates to the public, Upon-

further questioning concerning this observation and demonstration of

the use of the RRIS, the inspector. perceived that the RRIS is widely

considered to be slow and difficult to use and is in need of

upgrading in order to make it a more useable tool for performing

early dose assessments.

All four dose assessors failed to communicate information calculated

early in their dose assessment which could have prompted a change in

the emergency classification and protective action recommendations.

Three of the teams initially classified the emergency as a Site Area

L Emergency while awaiting the results of offsite doses. The doses

were being projected bned on the steam line radiation monitor

readings of 65 mR/h. Such readings were not interpreted by the teams

as being indicative of a loss of three fission product barriers

corresponding to a GE. The results of the dose assessments which

ultimately did lead to the reclassification to a GE, required from

!

i-

... .:

,

. .

.

-9- i

17 to 30 minutes to generate. The inspector noted, however, that

approximately 3-5 minutes into the dose assessment

Procedure EPP 01-7.3, the dose assessors had calculated a release

rate of about 230 C1/s. Such a release rate is clearly indicative of

loss of three fission product barriers. Had this information been

communicated at the time it was determined, the GE could have been

-

declared 15-25 minutes earlier.-

One apparent violation and no deviations were identified in this program ,

area.

7. Independent Audits (82701-02.05)

The inspector examined independent and internal auditreports prepared for

the licensee's emergency preparedness program since the last inspection to

determine compliance with the requirements of 10 CFR 50.54(t), and to

determine whether licensee commitments and protective actions were

implemented in a timely manner. The inspector also examined the-

licensee's audit program to determine if it had a corrective action system

for deficiencies and weaknesses identified during drills and exercises,

and to ascertain whether appropriate corrective actions were implemented-

in a timely manner.

The last annual audit conducted in emergency preparedness was conducted

from June 12 through July 31, 1989 (QA Audit TE-50140-K255). The

inspector reviewed this report and found that the scope and depth of the

audit ' appeared to meet the requirements of 10 CFR 50.54(t). The audit was

performed by-five audit team members which included an emergency planning

supervisor from another facility. A large expenditure of manpower and

' time was utilized in the planning, execution, and documentation of the

audit. 'The audit surfaced three findings classified at the quality

program deficiency level, which is the second tier of finding-

classification, beneath a violation. These findings are defined in Audit

Procedure QAP-18.2 as a condition adverse to quality that-if left

unattended could result in a violation, but at the time of discovery has

only marginal impact on program essentials. -The condition requires-

written communication of corrective action. The inspector noted that two

.of the findings had not been corrected at the time of the inspection,

nearly 10 months after they were identified. Because the QA procedures do

not delineate specific guidelines for timeliness of corrective actions,

the projected dates of corrective actions are agreed upon jointly.by QA

management and the responsible department for taking corrective actions.

In the case of the two uncorrected deficiencies, the corrective action

completion date was set at August 1990.

One uncorrected deficiency involved the lack of procedurally defined

radiological control areas in the E0F. The second uncorrected finding

involved the lack of procedures for emeracr.c, vehicle monitoring and

decontamination. Despite the abser,me of specific corrective action

timeliness guidelines, the inspector viewed 1 year to be an unnecessarily

long period to correct deficiencies which have potential radiological

consequences. This is considered an open item (482/9024-03) pending

b.

,y ,

' -

,_

-10-

,

further NRC review of the QA corrective action program, and in particular

of Quality Program Deficiencies 7/89-063 and 7/89-064. '

The inspector reviewed QA surveillances conducted since the previous  ;

inspection and.found these to be well targeted and documented.  :

Discussions were held with QA auditors in emergency preparedness to

determine whether they were adequately trained, qualified, and familiar

with QA audit procedures. The inspector reviewed documentation of QA

auditor training and certification for individuals involved in emergency

'

preparedness audits and found them to be qualified in accordance with

Procedure QP 14.4, " Qualifications and Certification of Quality Department

Audit Personnel," ANSI N45.2.23 (1976), and Regulatory Guide 1.146.

No violations or deviations were identified in this program area.

8. Exit Interview

The inspector met with licensee representatives denoted in paragraph 1 on

May 18, 1990, and summarized the scope and findings of the inspection as

presented in this report. The licensee did not identify as proprietary

any of the material provided to, or reviewed by, the inspector during the

inspection.

1