ML20083E338
| ML20083E338 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 09/27/1991 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-91-0136, WM-91-136, NUDOCS 9110020304 | |
| Download: ML20083E338 (1) | |
Text
?
M W@LF CREEK
~
' NUCLEAR OPERATING CORPORATION sert c. witners Presit.ent and Chief Exeevnve omeee September 27, 1991 VM 91-0136 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Mail Station P1-137 Washington, D. C.
20555 Reference Letter dated August 28, 1991 from S. J. Collins, NRC to B. D. Withers, WCNOC
Subject:
Docket No. 50-482:
Response to Violation 482/9116-01 and Exercise Weakness 482/911u-02 Gentlemen This letter provides Wolf Creek Nuclear Operatirg norporation's (WCNOC) response to Violation 482/9116 01 and Exercise Weakness 482/9116-02.
Violation 482/9136-01 involved changes to the emergency plan which decreased the effectiveness of the plan that should not ha're been implemented without prior approval by the Commission.
Exercise Weakness 482/9116-02 involved the -failure of operating crews to demonstrate the capability to provide accurate dose assessments eatly in a simulated emergency using information and assets available.
If you have any questions concerning this mstter, please contact me or Mr. H. K. Chernoff of my-st.aff.
Very.truly yours, t
Bart D. Withers President and gy Chiaf Executive Officer i c4 c o.
$8 BDW/aem W8 l
Attachment ex l
ou l-Q cc:
L. L. Gundrum (NRC), w/a i Fac A. T. Howell (NRC), w/a R. D. Martin (NRC), w/a l
l $
W. D. Reckley (NRC), w/a l 0 O_ o D. B. Spitzberg (NRC), w/a
,// y 0
/ j' #d
}
' 0 f + 9 G PO. On 411/ Burimgion, KS 66839 / Phone: (316) 364 8831
!.r. Eoual Opportswty Ernptoyer MF.HCIVET
L
[*l.
e i
- Attacbment to WM 91-0136 o
L Page 1 of 3 Violation.(482/9116-01):
Failure to Determine NRC Approval was Recuired for an Emergency Plar; Channe Findin2:
10 CFR 50.54(q) requires, in part, that the licensee may make changes to the emergency plan without Commission approval only if the changes do not j.
decrease the effectiveness of the plan, and the plan, as changed, continues to meet the requirements of Appendix E to this part.
Proposed changes that decrease the effectiveness of the approved emergency plan may not be implemented without application to and approval by the Commission.
Contrary to the above, t.he inspectors determined that changes made to the licensee's emergency classification scheme' in the emergency plan change submittal of Januury 3, 1991, decreased the.ffectiveness of the plan that should not. have been implemented without prior approval by the Commission.
Specifically, the change to the emergency classification scheme asd.gned a significantly lower classification than required for conditions involving an explosion in a vital area effecting safe shutdo*m equipment.
i Re, son for Violation:
a The change to the Emergency Action Level (EAL) was initiated as a procedure change to EPP 01-2.1,
" Emergency Classification," at the re7uest of operations personnel to clarlfy the Notice of Unusual Event (NUE) EAL for an explosior in a vital area,- The 10 CFR 50.54(q) evaluation for the procedure did not identify.a decrease to the effectiveness of-the plan.
The enange was then incorporated into the annual revision of the Radiological Emergency Response Plan (RERP) and again failed to identify it as a decrease to the offectiveness of the plan.
Therefore,.the revision to the EAL wac not thoroughly reviewed in accordance with 10 CFR 50.54(q). Changes to the RERP
.or procedures were requit M,
by procedure EPP 02-1,1,
" Emergency Planning Program." to receive a 10 CFR 50.54(q) evaluation.
This was accomplished and documented on form EP 02-1, "E-Plan /EPP Revision Form."
Item C, on the form provided a place for the Manager Emergency Planning to indicate'a yes or no answer that the proposed revision decreased the effectiveness of the plan.
--Use of this form by Emergency Planning personnel to conduct the 10 CFR 50.54(q) review for-procedure or RERP changes did not adequately foster the review-process nor identify steps to be taken to ensure compliance with 10 CFR~50.54(q),
Instead, the Emergency Planning personnel relied on memory of. guidance and pest procedure or RERP revisions.
The absence of an item checklist format did not encourage an adequate 10 CFR 50.54(q) review.on procedures or RERP changes.
In addition, form EP02-1 relies on a singular check of the evaluation which places the entire respend bility fo::
the 10 CFR 50.54(q) review on one person.
1 I
l Attachmentito WM 91-0136 Page 2 of 5-i Corrective Steps Which Have Been Taken and Results Achieved:
The RERP and Procedure EPP 01-2.1 were revised to revert to the wording previously.spproved by the Commission.
Form EP 02-1, "E-Plan /EPP Revision Form,"
was revised to expand and provida guidance on the 10 CFR 50.54(q) review process.
The revised form will promote a more thorough review to ensure compliance with 10 CPR 50.54(q).
This form also assures procedure
- and RERP changes receive the same administrative controls, Previous RERP and procedure changes were reviewed again for changes to EALs which may_ have decreased the eftectiveness of-the plan.
This review determined no other changes to EALs have reduced the effectiveness of the plan.
In additio..,
procedure EPP 02-1.1 was revised to ensure procedure changes which effect the RERP are reflected in the plan prior to procedure issuance. This change assures reporting requirements of 50.54(q) are met.
Corrective Steps Which Will Be Taken to Avoid Further Violations:
In addition to procedure changes made previously to expand the 50.54(q) guidance it was decided to revise procedure EPP 01-2.1 and form EP 02-1 again to_ require -an.addicional review ~of the 50.54(q) evaluation.
This supplemental review will provide a higher degree of confidence that the 50.54(q) evaluation conclusions are correct.
Training will be provided on the 50.54(q) review process to appropriate personnel.
Date When Full Compliance Will Be Achieved:
Procedure EPP_ 02-1.1 and Form EP 02-1 will be revised and issued on November-1, 1997 to. reflect the additional 50.54(q) review.
The 50.54(q) training will.be completed by November 15, 1991.
Exercise Weakness (482/9116-02):- Failure of Shift Crews to Provide Accurate Off-site Dose Assessments Usinn Aasets and Information Available it: the
' Control Room Responce
= The identified weakness was a result of an underdeveloped area in the
- program.
In past drills, guidance from EPP 01-10.1,
" Protective Action Recommendations,"
has been used as the - basis for protective action racommendations (PARS) made early-in the emergency, rather than actual practice of dose assessments.
An additiona1' contributing factor.to the
[
. identified weakness was the absence of joint. training in the simulator for Chemistry Technicians and Control Room crews to practice dose projections and develop communications skilic.
Chemistry Technicians were unfamiliar with the control room and were hesitant to disturb the Shift Supervisor.
I l
t l
9 9g
,o
_a
=
,..~_...,w
,p.,.
,.g,.
7
,.--_,,,y_-p..,,__.,.y.y_, _.,,.,.,,,,,. _ _
wy.,.,
y.,
___,,,_.7m,-.,.
+ -,",
3
-Attachment to WI 91 0136 Page 3 of 3 In the future Chemistry Technicians will be trained on the Simulator with the control Room crews.
'The objectives of this training will be - to familiarize-the Chemistry Technicians with-the control room setting, acquaint them with the location of pertinent data, improve enmmunication between Chemistry Technicianc and Control Room personnel, and educate the Control Room parsonnel of the information the Chemistry Technicians require.
In: addition, the program will be enhanced to simplify the dose assessment made prior to Technical Support Center Activation.
This-will be accomplished' through-procedure changes which establish a uniform set of questions designed to obtain nccessary and preferred information from the Control Room instrumentation or Control Room pecsonnel.
The procedure will also provide guidance in the absence of information, and in the use of conservative assumptions.
-The training discussed above in addition to trr.ining on procedural changes will be completed by March 31, 1992.
Program enhancements and orocedure changes will be completed by November 29, 1991.
I -
i d
l-I l
.. - -