ML20059M962
| ML20059M962 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 11/12/1993 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-93-0159, WM-93-159, NUDOCS 9311300020 | |
| Download: ML20059M962 (7) | |
Text
.
WOLF CREEK
' NUCLEAR OPERATING CORPORATION i
Ned S
- Buzz" Carns Predent and Noveniber 12, 1993 Chief Emcutive offics WM 93-0159 U.
S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 Washington, D.
C 20555
References:
1)
Letter dated July 20, 1992 from A. B.
Beach, NRC, to B. D.
Withers, WC:JOC 2)
Letter WM 92-0135 dated August 21, 1992 from B.
D. Withers, HCNOC, to USNRC 3)
Letter dated October 14, 1993 from D.
D.
Chamberlain, NRC, to N. S. Carns, WCNOC.
Subject:
Docket No. 50-482: Reply to Notice of Violation 482/9326-01 and Ueakness 482/9326-02 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC)
" Reply to Notice of Violation 482/9326-01" and " Reply to Weakness 482/9326-02" which were documented in Reference 3
(NRC Inspection Report 50-482/93-26).
Violation 482/9326-01 was cited for a repeat of Weakness 482/9213-01, as documented in' Reference 1, concerning the failure to promptly and accurately classify plant emergency conditions. Weakness 482/9326-02 concerned a failure to make initial emergency notifications to the NRC Operations Center in accordance with procedures.
Reference 2 respondud to Weakness 482/9213-01.
If you have any questions concerning this matter, please contact me at (316) 364-8831 extension 4000 or Mr. Kevin J. Moles at extension 4565.
Very truly yours, Neil S.
Carns President and-Chief Executive Officer NSC/jan Attachment cc:
J. L. Milhoan (NRC), w/a G. A.
Pick. (NRC), w/a W.
D. Reckley (NRC), w/a L. A. Yandell (NRC), w/a Jf J
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Attachment to WM 93-0159 Page 1 of 6 Reply to Notice of Violation 482/9326-01 Violation 482/9326-01:
Reoeat Weakness concernino the failure to accurately or oromotiv classify olant emeroency conditi.QD L Findinq:
10 CFR Part 50, Appendix E.IV.F specifies the requirements for emergency preparedness training programs including the conduct of drills and exercises to ensure that employees of the licensee are familiar with their specific emergency response bties.
10 CFR Part 50, Appendix E.IV F.5 requires, in part, that any weakness or deficiency identified shall be corrected.
During emergency preparedness walkthroughs conducred by the NRC during the period July 6-9, 1992, weakness 482/9213-01 was identified for the failure.of two out of three crews evaluated to accurately classify plant conditions corresponding to a Site Area Emergency.
Contrary to the above, during the inspection conducted September 20-24, 1993i inspectors determined that weakness 482/9213-01 had not been corrected.
A
. repeat weakr.ess was identified when two of three crews evaluated again failed to accurately or promptly classify plant conditions corresponding to a General
~
Emergency.
Arbission of Violation:
dolf Creek Nuclear Operating Corporat ion (WCNOC) agrees that a violation of 10 CFR'Part 50, Appendix E.IV.F.5 occut7ud.
Reason for Violation:
During an inspection of the Emergency Preparedness Program, conducted July 6-9, 1992, and documented in Reference 1, the inspectors observed and evaluated the ability of each crew to detect, assess, and classify abnormal and. accident.
conditiorr.
It was observed that two Shift Supervisors did not' declare a Site Area Emergency when they became aware of plant conditions that indicated a breach of, or challenge to the integrity of two fission product. barriers.
Specifically, fuel cladding was challenged as the result of 'an anticipated transient without trip, and containment was breached. because of a steam generator atmospheric relief valve that was. stuck open and was unisolable.
These conditions met the Emergency Action Level for a Site ' Area Emergency contained in procedure. EPP
.01-2.1,
" Emergency Classification" and-.was identified'as Weakness 4B2/9213-01.
~
o Attachment to WM 93-0159 Page 2 of 6 Subsequent observations of walkthrough scenarios were performed during the-September 20-24,.993, inspection of the Emergency Preparedness Program.
The
'I inspectors observed three crews during a sequence of events requiring. an -
escalation of emergency classifications, culminating in a General Emergency.
It was observed however, that one crew failed to classify plant conditions.at the General Emergency level, as required by procedure EPP 01-2.1, Rev. 11,
" Emergency Classification,"
Attachment 1,
when containment high range radiation monitor (CHARMS) readings exceeded the Emergency Action' Level of 10.,000 R/hr.
Also, a second crew was observed to classify these 'same conditions as a General Emergency 10 minutes after receiving CHARMS readings.
In response to Weakness 482/9213-01 (Reference 2), WCNOC attributed confusion contained in procedure EPP 01-2.1, as the root cause of the failure to classify a Site Area Emergency.
Corrective actions to this weakness included a revision to EPP 01-2.1 and classroom training.
A subsequent Quality Assurance surveillance conducted in July and August, 1993, identified that classification weaknesses still existed.
An investigation was performed to identify the failure of the corrective actions to adequately address Weakness 482/9213-01.
It was determined 'that the specific revision to procedure EPP 01-2.1, in response to Weakness 482/9213-01, 'was not instrumental in this event. The cause of _ the failed corrective actions has buan attributed to the following:
Classroom training was not thoroughly supported by ' practical simulator.
'I training for all appropriate' personnel on the use of. Emergency' Action-
. Levels.
correctly id'entified, Although the root cause of Weakness 482/9213-01 was contributing factors were not recognized and appropriately addressed.
Contributing factors include:
? Existing Emergency Action Levels are not user-friendly and contain too 4
much subjectivity.
- Shift Supervisors are burdened by performing both a. Shif t Supervisor rolo and assuming Shitt Technical Advisor responsibilities.
J The f ailt re to accurately or promptly classify plant conditions as documented j
in Reference 2 is a repeat weakness in the area of classifications of plant emergency conditions, and is therefore recognized as a violation.
j Corrective Steos Taken and Resultc Achieved:
Because one Shift Supervisor did not recognize that the 10,000 R/hr CHARMS reading was associated with an Emergency Action Level and another Shift Supervisor acknowledged this indication but did not immediately declare. a General Emergency, the Manager Operations issued Required Reading for all j
Shift Supervisors to review the Emergency Action Levels for specific setpoints and defined values.
This Required' Reading has heightened Shift Supervisor awareness of numerous defined values in the Emergency. Action Levels which require immediate response.
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' Attachment to WM 93-0159 Page 3 of 6 i
Corrective Stens That Will Be Taken tc Avoid Further violations:
As an immediate corrective action, table-top sessions, which include classifications were conducted with Shift Supervisors, and offered to Duty Emergency Directors, and Duty Emergency Managers.
These sessions began on October 4, 1993 and will be completed by December 1, 1993.
Simulator training has been sched' ' ad to provide more practical drills on scenarios to challenge operatir aws in the area of classification of plant emergency conditions.
L aing will be more coordinated between operating crews, Chemistry Technicians, Health Physics personnel, and the shift clerks to offer more practical hands-on experience to those groups not normally trained in control room activities during emergency conditions.
This training will commence on November 11, 1993, and will be completed by December 31, 1993.
WCNOC is in the process of converting to the NUMARC Emergency Action Levels and is presently coordinating this change with the Office of Nuclear Reactor Regulation (NRR)
The revised Emergency Action Levels will be submitted to NRR for approval by necember 31.
1993.
Upon approval, procedure EPP 01-2.1 will be revised accordingly and training on the procedure revision will subsequently follow.
- WCNOC is in the process of implementing the Engineer-on-Shift concept to complement the operating crews.
Candidates for these positions have been selected.
Initial training (equivalent to Shift Technical Advisor training) has commenced and is scheduled to be completed with the personnel functioning on shift by March 31.
1911 In the long-term, it is WCNOC's intent to have these individuals licensed as Senior Reactor Operators performing the Shift Technical Advisor function ad administratively assisting the Shift Supervisor to relieve undue burden.
Date. When Full _Gpmollance Will Be'Achievmj:
An increased awareness of the Emergency Action Levels will be instrumental in increasing Shift Supervisor awareness of specific setpoints and defined values contained in Emergency Action Levels.
Initial table-top trailing will be completed prior to the Annual Emergency Preparedness Exercise ncheduled for December 1,
1993.
Integrated simulator training on classification of emergencies will be completed by December 31, 1993, It is expected that this training and heightened Shift Supervisor awareness will strengthen the operating crews' ability to accurately and promptly classify plant emergency conditions and should preclude additional weaknesses in this area.
The' implementation of the Engineer-on-Shift position and conversion to NUMARC Emergency Action Levels are considered enhancements to the degree of' engineering support on shif t. for the operating crews and to the Emergency Preparedness Program, respectively.
As noted above, the Engineer-on-Shift position will provide administrative assistance to the Shift Supervisors in the performance of routine and emergency assessment activities.
The Engineer-on-Shift position will be implemented by March 31, 1994.
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' i Attachment to WM 93-0159 j
Page 4-of 6 Actual or Potential Consecuences of This Violation:
WCNOC recognizes the significance of promptly and adeqlately addressing.
corrective action issues, both hardware and personnel relatsd.
There were no actual consequences to the public's health and safety since this. violation -
occtrred during a drill scenario.
However, we understand that weaknesses in
)
th. Emergency Preparedness Program require prompt attention so that vital-information related to emergency situations will be quickly identified and subsequently relayed to state, local and federal authorities.
Failure in this area could result in delays in evacuation or sheltering which ' potentially could result in unnecessary exposure to members of the public, F
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Attachment to WM 93-0159 Page 5 of 6 Weakness (482/9326-02)r Failure to make init ial notifications to the NRC Operations Center.
Weakness:
During emergency preparedness walkthroughs conducted by the NRC during, the period September 20-24, 1993, the inspectors observed three operating crews using the control room simulator in the dynamic mode.
Observations. included.'
the ability of the control room staff to make timely 'and complete notifications to offsite authorities.
Initial notifications to the NRC Operations Center were made by Nuclear Station Operators performing the_ task of shift communicator.
It was noted that two crews made initial notifications without using Form NRC 361, " Event Notification Worksheet" - as required _ by procedure EPP 01-3.1, Rev. 15 "Immediate Notifications," Step 4.1. 8.1',
and -
procedure EPP 01-1.0, Rev. 9,
" Control Room Organization,". Attachment 2.1.
Failure to make initial notifications to the NRC in accordance with procedure was identified as a weakness.
Admission of Weakness p
WCNOC agrees that a weakness in the area of initial notifications occurred as i
a result of failures to complete Form NRC 361.
Reason for Weakness:
Initial-notifications to. the NRC Operations Center were made by Nuclear Station Operators. (NSOs) performing the task of Emergency Notification System (ENS) Communicator.
Although ' NSOs are responsible for contacting the '_NRC -
Operations Center, the Shift Supervisor is responsible for completing NRC Form-361.
The reasons-for the identified weakness are: (1) ' the Shif t; Supervisors are heavily burdened with plant response during an emergency while also.
required to perform the administrative duties associated with - filling out.
various emergency response procedural -forms; and (2)' the NSOs have not participated with the operating crews on the simulator during the conduct'of
' training in! emergency scenarios.
Nuclear Station Operators receive classroom-training on their responsibilities (as contained in procedure EPP 01-3.1) as ENS Communicators, but are n ot included in simulator training for emergency _.
scenarios.
During scenarios, the less experienced NSOs lacked the practical control room experience to effectively ensure all.necessary input 'was identified prior to contacting the NRC Operations Center.
This was compounded by. their desire to not interrupt the Shift ' Supervisor during accident-mitigation to complete NRC Form 361.
- 2. -
ctive'Steos Taken and Results Achieved:
Discussions were held between the. Manager Operations and Shift Supervisors to counsel them Lon their responsibility to complete NRC Form 361 promptly_ and accurately.
Attachment to WM 93-0159
-Page 6 of 6 Corrective Steos That Will Be Taken to Avoid Further Weaknesses In response to the previously received Weakness 482/9213-03, dated July 20, 1992, concerning inaccurate dose assessment, Chemistry Technicians were included in simulator emergency scenarios to provide hands-on, control room experience during emergency situations.
This corrective action has been very successful in familiarizing Chemistry Technicians with their responsibilities in the control room and enhanced communication with the operating crew. Similarly, NSOs will be included in future simulator training to provide hands-on experience during emergency scenarios.
In addition, all NSOs and licensed operators will receive Required Reading concerning their responsibilities in reporting events to the NRC Operations Center. The required reading will be completed by December 6, 1993.
To decrease the administrative burden on the Shift Supervisor, WCNOC is implementing the Engineer-on-Shift concept to complement the operating crews.
In the long-tertr, these individuals'will be licensed Senior Reactor Operators performing the Shift Technical Advisor function and administrative 1y assisting
- the Shift Supervisor to relieve undue burden.
Date When Corrective Actions Will Be Comoleted:
Integrated Emergency Preparedness simuldtor training will be conducted and will include at least one NSO during each session. 'This training'is' scheduled to begin the week of November 15, 1993 in Licensed Requal Cycle 94-1 and will" continue through subsequent Requal Cycles, as needed.
The Engineer-on-Shift position will be ' implemented by March 31, 1994.
- As ncted above in the response to Violation 482/9326-01,.this ' action :is considered to be an enhancement, i
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