ML20137B669

Insp Rept 50-482/97-02 on 970224-27.Violations Noted. Major Areas Inspected:Activities in Control Room Simulator, Technical Support Ctr/Operations Support Ctr & EOF

ML20137B669
Person / Time
Site:	Wolf Creek
Issue date:	03/14/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20137B646	List: ML20137B643 ML20137B669
References
50-482-97-02, 50-482-97-2, NUDOCS 9703240023
Download: ML20137B669 (22)

See also: IR 05000482/1997002

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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION  :

REGION IV

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Docket No.: 50-482

License No.: NPF-42

Report No.: 50-482/97-02

Licensee: Wolf Creek Nuclear Operating Corporation

Facility: Wolf Creek Generating Station

Location: 1550 Oxen Lane, NE

Burlington, Kansas

Dates: February 24-27,1997

Inspectors: Gail M. Good, Senior Emergency Preparedness Analyst

(Team Leader)

Stephen C. Burton, Resident inspector (Arkansas Nuclear One)

Jennifer L. Dixon-Herrity, Resident inspector

David M. Silk, Senior Emergency Preparedness Specialist (Region 1)

Nancy T. McNamara, Emergency Preparedness Specialist (Region 1)

Approved By: Blaine Murray, Chief, Plant Support Branch

Attachment: Supplemental Information

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9703240023 970314

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EXECUTIVE SUMMARY

Wolf Creek Generating Station

, NRC Inspection Report 50-482/97-02

A routine, announced inspection of the licensee's performance and capabilities during tne

full-scale, biennial exercise of the emergency plan and implementing procedures was

performed. The inspection team observed activities in the control room simulator,

technical support center / operations support center, and emergency operations f acility.

, Plant Suonort

• Overall, the control room staff's performance was good. Scenario emergency

events were properly analyzed and classified. Notifications to offsite agencies were

timely and accurate. Internal and external communications, as well as interactions

between the control room and technical support center, could be improved. One

plant announcement did not include a statement to prohibit eating and drinking, and

another plant announcement did not warn personnel to stay clear of the turbine

building (Section P4.2).

• Overall, the technical support center staff's performance was generally good. Less

than satisfactory performance was observed in the areas of internal and external

communications. An exercise weakness was identified for ineffective

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, communications which led to an untimely site area emergency declaration. Facility

priorities were not effectively established and tracked. While personnel

accountability, on the whole, was properly maintained the procedures for

accountability were confusing and sorne personnel did not understand how to use

the accountability form (Section P4.3).

• Overall, the operations support center staff's performance was good. Facility

activation was timely and orderly. Operations support center management

J demonstrated good command and control. Repair team accountability and

communications were generally good. In general, inplant teams performed well.

One team experienced significant, avoidable delays (Section P4.4).

• Overall, the emergency operations facility staff's performance was good. The duty

emergency manager exercised effective command and control. Offsite agency

notifications and interactions were generally correct and timely. The dose

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assessment team performed well. In general, field teams were efficiently and

effectively used and controlled. Field team usage was not effectively maximized to

determine doses beyond the 10-mile emergency planning zone (Section P4.5).

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The inspectors determined that the scenario was sufficiently challenging to test

emergency response capabilities and demonstrate onsite exercise objectives.

Exercise control was more effective than it was in the 1995 exercise; however,

there was still room for improvement (Section P4.6).

• Overall, the licensee's self-critique process effectively identified areas for corrective

action. The control room simulator exercise centroller was c'.allenged to perform

controller / evaluator duties. The technical support center pr4t-exercise critique

could have been more challenging. The emergency operat.ons facility post-exercise

critique was exceptionally thorough and self critical. A low threshold was used to

determine performance strengths in all facilities (Section P4.7).

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IV. Plant Support

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P4 Staff Knowledge and Performance in Emergency Preparedness  !

P4.1 Prooram Areas insoected (82301)

The licensee conducted a full-scale, biennial exercise on February 25,1997. The I

exercise was conducted to test major portions of the onsite (licensee) and offsite

emergency response capabilities. The licensee activated its emergency response

organization and all emergency response facilities. The Federal Emergency i

Management Agency evaluated the offsite response capabilities of the State of l

Kansas and Coffey county. The Federal Emergency Management Agency willissue

a separate report.

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The exercise scenario was run using the control room simulator in a dynamic mode. {

The exercise scenario began at 7:30 a.m. with the plant operating at 100 percent

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power. Normal weekday personnel were available for duties. At the start of the

exercise, Motor Driven Feedwater Pump A was out of service and multiple fuel

defects existed. Chemistry technicians were taking reactor coolant samples every

2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Meteorological data indicated that a front was expected to pass through

the area later in the day.

At 8:10 a.m., the control room received indication that an operational basis

earthquake had occurred. The appropriate alarm response procedures and the  ;

emergency plan were reviewed. An alert was declared at 8:21 a.m.

Shortly after the alert declaration, the control room received a report that a worker

had suffered a heart attack. The control room dispatched the fire brigade leader and

an emergency medical technician to respond to the medical emergency.

At 8:36 a.m., a leak was reported in the condensate storage tank supply to the

auxiliary feedwater pumps. In response, the shift supervisor declared the auxiliary

feedwater pumps inoperable. Emergency director duties were transferred to the

technical support center at 8:41 a.m. Subsequent conflicts batween the technical

specifications and the off-normal procedure for earthquakes were discussed with

the duty emergency director in the technical support center.

At 9:03 a.m., the reactor operator reported that reactor power was increasing

without operator action. The control room staff took actions for a steam leak and I

the accompanying safety injection signal. The control room staff determined that i

the cause of the power increase was an unisolable steam leak in Steam

Generator A.

During the next 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />, the control room staff responded to the steam leak and

associated complications. Post-earthquake system walkdowns were completed

after Steam Generator A boiled dry and the turbine building became accessible. 1

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At 10:07 a.m., the duty emergency director declared a site area emergency based

upon a main steam line break with failed fuel. At 10:31 a.m., the control room

operator reported that pressure was increasing on Steam Generator A. Operators

determined that the steam generator had experienced a tube failure and that an l

unisolable leak existed between the reactor and the turbine building via the steam

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generator. A safety injection signal was received and reactor pressure was  ;

j eventually stabilized. Actions were taken to determine the extent and magnitude of I

the radiological release. The duty emergency director declared a general emergency -l

at 10:48 a.m. due to a ruptured, faulted steam generator with defective fuel.

i At 11:32 a.m., a plant cooldown was commenced and continued until exercise l

termination (3:47 p.m.). The control room staff responded to other events and {

annunciators as required throughout the remainder of the exercise.

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P4.2 Control Room f

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l a. Insoection Scope (82301-03.02) . ,

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i The inspectors observed and evaluated the control room simulator staff as they  :

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performed tasks in response to the exercise scenario conditions. These tasks

included event detection and classification, analysis of plant conditions, offsite

agency notifications, and adherence to the emergency plan and implementing

procedures. The inspectors reviewed appliccble emergency plan implementing I

l procedures, logs, checklists, and notification forms generated during the exercise.

b. Observations and Findinas

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The control room operators correctly diagnosed and classified events through the

j use of control room annunciators, alarms, and instrumentation. Operators  !

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l accurately and promptly diagnosed the alert condition based upon an operational ,

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basis earthquake. Subsequently, the control room staff accurately identified and i

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. responded to numerous events including and unisolable steam generator tube leak  !

and an unisolable primary to secondary leak that resulted in a radiological release to

the environment. Notification of.offsite authorities was accomplished within  ;

prescribed time requirements. j

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Although the operators demonstrated the ability to maximize cooldown rates, the  !

cooldown was delayed due to communications and coordination problems between '

the technical support center and control room. Inspectors observed the following

examples:

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• First, a maximum cooldown ra'e t of 100 degrees per hour was established;

however, actual cooldown averaged approximately 65 degrees per hour.

The inspectors concluded that the control room did not fully understand the

urgency of increasing the cooldown rate, because the technical support

center and control room supervisory staff f ailed to communicate the 1

mc.gnitude and consequences of the offsite release.

Second, the control room slowed the cooldown and considered stopping the

cooldown to facilitate residual heat removal system sampling and safety '

injection pump tagging. These support activities were neither anticipated '

(prestaged) nor coordinated with the technical support center (see

Section P4.3 below for additional details).

• Finally, some technical support center activities delayed the shift to the

residual heat removal mode of cooldown. Inspectors observed the following

examples: (1) both trains of residual heat removal were not sampled initially,

(2) proceduralized sample points for the residual heat removal system had to

be reevaluated after chemistry and engineering personnel raised questions

about boron concentrations in nonsampled portions of the system, and 1

(3) the technical support center engineering staff did not receive prompt j

support to obtain poison graphs needet for shutdown margin calculations  !

(see Section P4.3 below for additional details).  !

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Although communications were generally good, some internal and external control  ;

room communications had the potential to degrade the response effort. The i

inspectors observed the following examples:

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• First, three-way communications were good during significant evolutions but

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were sometimes lax during other periods. Three-way communications I

involve information communication by provider, information restatement by j

receiver, and information confirmation by provider. Three-way '

communications broke down on the following occasions: (1) valve I

repositioning completion reports for residual heat removal were not l

acknowledged, (2) the order to isolate steam generators was not '

acknowledged although completion was reported back, and (3) the  ;

acknowledgment for repositioning the letdown isolation valves was j

accomplished while performing the task. l

• Second, Procedure EPP 01-9.1, " Personnel Accountability and Evacuation,"

Revision 12, did not allow eating, drinking, etc., until accountability was

completed. However, Form EP 01-1.0.9, " Alert Announcement," Fevision 0,

listed this requirement as an optional statement that could be made during

the announcement. The optional statement was not used wher the

announcement was made during the exercise. Given the scenuio plant

conditions (unknown due to the earthquake), the existence of an

unmonitored release was a possibility. The inspectors concluded that,

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despite the procedural inconsistencies, it would have been appropriate to

include the statement, since personnel could have received dose during the

accountability process, before plant conditions were assessed.

Third, announcements concerning the steam leak did not inform personnel to

stay clear of the turbine building (the location of the steam leak). As a

result, personnel could have attempted to evacuate through the turbine

building following the site accountability announcement.

I * Fourth, control room and technical support center personnel tasked to

perform NRC notifications were unfamiliar with some responsibilities. Some

efforts were duplicated after responsibilities transferred to the technical

support center. For example, since the control room communicator was not

confident that the technical support center communicator had completed the  ;

required site area emergency notification form, the control room

communicator duplicated the form and the associated report. ,

c. Conclusions  :

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Overall, the control room staff's performance was good. Scenario emergency

i events were properly analyzed and classified. Notifications to offsite agencies were

timely and accurate. Internal and external communications, as well as interactions .

between the control room and technical support center, could be improved. One  !

plant announcement did not include a statement to prohibit eating and drinking, and

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another plant announcement did not warn personnel to stay clear of the turbine

building

P4.3 Technical Sucoort Center

a. Insoection Scooe (82301-03.03)

The inspectors observed and evaluated the technical support center staff as they  :

performed tasks necessary to respond to the exercise scenario conditions. These

tasks included staffing and activation, accident assessment and event classification,

offsite agency notifications, personnel accountability, facility management and

control, offsite protective action recommendations, onsite protective action

decisions and implementation, internal and external communications, assistance and

support to the control room, and prioritization of mitigating actions. The inspectors

reviewed applicable emergency plan implementing procedures and logs. The

licensee's technical support center and operations support center are collocated;

however, independent command and control structures are maintained.

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b. Observations and Findinas

The technical support center had the minimum required staff and was activated

within 20 minutes after the alert declaration. The technical support center was

activated in a coordinated and efficient manner. Communications were promptly

established with the required onsite and offsite locations.

The duty emerger;cy director in the technical support center correctly classified the

site araa and general emergencies. In both cases, the duty emergency director

discussed the emergency classifications with the control room shift supervisor and

emergency operations facility management. Although both events were correctly

classified, the s;+e area emergency was not declared in a timely manner due to

internal communication problems and insufficient procedures. The communications

problems and the untimely site area emergency classification are discussed further

below. Offsite agency notifications and protective action recommendations were

correct and communicated within regulatory limits.

In general, the duty emergency director effectively communicated with the other

participants and maintained good command and control of the center. Staff

briefings were appropriately conducted when new information became available. All

activity stopped while the briefings occurred; however, the inspectors noted that

parts of the briefings were hard to hear because the duty emergency director did

not stop the' briefing during normal (nonexercise; plant announcements. Appropriate

logkeeping was observed throughout the facility. .

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Some internal and external technical support center communications were

ineffective and had a negative impact on the efficiency of the response effort. The

inspectors observed the following examples:  !

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• First, there were two instances where communications between the control

room and technical support center resulted in the technical support center

not being aware of plant conditions. One instance occurred after the duty

emergency director directed the shift supervisor to maintain the plant online

due to inoperability of auxiliary feedwater and incomplete plant tours

following the 8:45 a.m. earthquake. At 8:53 a.m., technical support center

personnel understood that the control room was shutting down due to entry l

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into Technical Specification 3.7.1.2 caused by loss of the condensate

storage tan' (suction source for auxiliary feedwater). The plant shutdown

was reportt d during the duty emergency director's briefing and technical

support center personnellogs documented that a plant shutdown had

commenced with a goal to complete the shutdown in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Control room

personnel documented entry into Technical Specification 3.7.1.2 but never

commenced a shutdown.

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The other instance occurred at 9:20 a.m. when engineering personnel

announced to the technical support center that auxiliary feedwater was being i

supplied by essential service water and that the condensate storage tank l

was isolated. At 9:35 a.m., after being questioned, engineering personnel l

discussed the status of auxiliary feedwater with the control room and were I

informed that the condensate storage tank was still the source for the

auxiliary feedwater system.

• Second, technical support center management did not brief center staff on

probable failure paths in the emergency action levels or conditions that

would cause event escalation. Moreover, the emergency action level

indicators (escalation criteria / thresholds) were not assigned a priority and

, placed on the priority board to inform personnel of the need to monitor these

< conditions. Technical support center management identified this information

and briefed emergency operations facility management on the probable

escalation paths. As a result, technical support center personnel were not

aware that management was interested in the dose equivalent iodine data

when the information became available.

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Specifically, the post-accident sampling system information needed to

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classify a site area emergency (dose equivalent iodine data) was available to

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the technical support center staff at approximately 9:30 a.m. but was not

immediately forwarded to the duty emergency director. it should be noted

that the duty emergency director had asked several personnel to provide

post-accident sampling data when it came in earlier in the exercise.

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To allow the scenario to progress as designed, controllers had to reintroduce

the information to the radiological emergency coordinator, the dose

assessment coordinator, and the nuclear engineer with the message to

provide the data directly to center management. The duty emergency

director did not receive the information until approximately 10 a.m.,

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approximately 30 minutes after the information first became available. Upon

receipt of the data, the duty emergency director promptly declared the site

area emergency at 10:07 a.m.

As a result of the technical support center's failures to identify, recognize,

and communicate dose equivalent iodine data, the site area emergency was  ;

i not declared in a timely manner. The licensee also identified this concern l

and noted that procedures did not provide sufficient guidance for personnel l

to report dose equivalent iodine information to technical support center

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• Third, the communication between the control room and technical support

center concerning the condensate storage tank damage was not clearly

communicated. The damage was reported to the technical support center as

an auxiliary feedwater supply line " break." The problem was identified to the

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control room as a big leak on the auxiliary feedwater supply line at

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Valve APVO15 (condensate storage tank outlet to auxiliary feedwater pumps

isolation). Without verifying the damage visually or discussing the damage i

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certain equipment was needed to repair the " break." As a result, the repair i

was unnecessarily delayed (see Section P4.4 below for additional details). {

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• Fourth, the terminology used to describe the main steam line break to

technical support center personnel caused some confusion. After the '

briefing that reported the faulted steam generator, the offsite field team '

communicator informed the teams that there was a fault (seismic) under the l

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steam generator. Later, the individual checked the inforrnation and corrected

the communication. If the miscommunication had not been corrected, the  ;

j field teams would have been unaware of the steam release in progress.  !

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! system was to be sampled, rather than the post-accident sampling system,

l further delayed the reactor coolant system cooldown and release termination.

I Specifically, after the Auxiliary Feedwater Pump B repair team arrived at the

job site, they found that the nuclear station operator assigned to tag the

_ pump was not there. The team reported this problem to the operations

! support center communicator. The operations support center communicator

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did not follow through on this report. After waiting approximately

30 minutes, the team called the control room to resolve the problem. The

l failure of the operations support center communicator to follow through on

the communication delayed the repairs.

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Collectively, these examples of ineffective internal and external technical support

j center communications were identified as an exercise weakness due to the negative

impact on the efficiency of the response effort (50-482/9702-01).

The inspectors noted that the priority board was not effectively used. Once

assigned at approximately 8:50 a.m., the priorities on the board were not addressed

for approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The priorities identified were appropriate, but the

inspectors noted other concerns that were not addressed as priorities.

For example, at 9:09 a.m., engineering personnel recognized the risk to the steam

generator tubes, due to the pressure differential, once the steam generator emptied,

Later, the operations emergency coordinator called a " time-out" to emphasize the

data elements specified in the emergency action levels that would indicate a steam

generator tube ruptura. This information was never addressed as a technical

support center priority.

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Moreover, an update time was not recorded on the priorities board to inform

personnel of priority status (current /not current). Similarly, an update time was not

recorded on the radiological status board and the engineering priorities status board.

The inspectors noted that center procedures did not discuss the priority board or its

maintenance.

Due to the diligence of assigned personnel, personnel accountability and access

control were generally well maintained. Initially, there was some confusion about

the accountability station location. The accountability clerk's desk was not placed

by the designated entry door. The inspectors observed that the accountability clerk

followed an individual who had entered through the correct door to ensure that the

individual signed-in on the accountability roster. The licensee identified that the

sign on the door near the accountability clerk's desk was poorly placed and that the

door should have been locked to prevent entry,

in addition, after reviewing the accountability log, tM inspectors noted that a  ;

number of individuals failed to document their dostination and that others failed to

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use the form properly (some entrance times were later than exit times). The

inspectors concluded that the current process was confusing and that personnel did

not understand how to use the accountability form.

c. Conclusions

Overall, the technical support center staff's performance was generally good. Less

than satisfactory performance was observed in the areas of internal and external

communications. An exercise weakness was identified for ineffective

communications which led to an untimely site area emergency declaration. Facility ,

priorities were not effectively established and tracked. The procedures for l

accountability were confusing and personnel did not understand how to use the

accountability form. {

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P4.4 Ooerations Suncort Center

a. Inspection Scone (82301-03.05)

The inspectors observed and evaluated the operations support center staff as they

performed tasks in response to the scenario conditions. These tasks included

functional staffing and inplant emergency response team dispatch and coordination

in support of control room and technical support center requests. The inspectors

reviewed applicable emergency plan implementing procedures, logs, checklists, and

forms generated during the exercise. The licensee's technical support center and

operations support center are collocated; however, independent command and

control structures are maintained.  ;

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b. Observations and Findinas

The operations support center was staffed in a timely manner. Following the

8:21 a.m. alert declaration, the control room made an 8:25 a.m. announcement to

staff the emergency response facilities. The technical support center / operations

j support center was declared activated at 8:41 a.m. when minimum required staffing

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leveis were met.

To expedite team deployment, arriving repair personnel and health physics

technicians signed-in on a " Task Board" and gathered full protective clothing in

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advance of any team formation. As a result of this process, the operations support

center supervisor was aware of the maintenance disciplines and health physics

technicians who were available and ready to be utilized.

Overall, command and controlin the operations support center was good. Noise

levels and distractions were kept to a minimurn throughout the exercise.

Habitability was regularly checked by conducting surveys and obtaining air samples.

Tasks were properly prioritized and modified according to changing simulated plant

conditions.

Inplant response teams were sufficiently briefed and debriefed for each assigned

task. The briefings were thorough and included a technical brief, a personnel safety '

brief, and a health physics brief. The debriefings included important information and

observations pertinent to dispatch of subsequent teams, such as the existence of

steam and radiological releases / conditions.

The operations support center inplant communicator properly maintained

accountability of teams and team members. The communicator generally

maintained good radio contact with the teams and relayed the team reports to the

operations support center supervisor for dissemination to personnel in the technical

, support center.

The process for dispatching teams was generally good. One team experienced

numerous delays, indicating room for improvement in the area of team

dispatch / planning. Specifically, Team 2, which was assigned to repair a leak in the

condensate storage tank, was dispatched from the operations su. , ort center

70 minutes after the center received the leak report. The delay w. primarily due to

the need to coordinate briefings; both inplant teams and offsite fiele monitoring

teams were being dispatched (i.e., both needed briefings).

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Once dispatched, Team 2 went to obtain the tools they thought would be needed to

repair the leak. After 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and visits to three different tool storage areas, the

team finally had the predetermined tools. Tne team did not have a key to the

turbine deck maintenance storage area. To gain access, the team simulated using

bolt cutters. When the team arrived at the condensate storage tank, they were

informed by the controller that the leak was at a flange (loosened by the simulated

earthquake). Team 2 did not have the necessary tools with them to tighten the  ;

flange bolts and had to return to a tool area to obtain the necessary equipment.

Finally, at 11:10 a.m. (2.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after the leak was reported), Team 2 stopped the

simulated leak. The inspectors attributed the additional delays to: (1) the failure to

initially assess the source of the leak to determine necessary tools, (2) the failure

provide sufficient information regarding tool location, and (3) the failure to provide

necessary keys prior to team dispatch. The inspectors concluded that these delays

did not constitute an exercise weakness because other teams did not encounter

similar delays. However, the experiences of Team 2 demonstrated areas where

improvements could be made to expedite repair team response.

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c. Conclusions

Overall, the operations support center staff's performance was good. Facility

activation was timely and orderly. Operations support center management

demonstrated good command and control. Repair team accountability and

communications were generally good. In general, inplant teams performed well.

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P4.5 Emeraencv Ooerations Facility i

a. Insoection Scooe (82301-03.04)

The inspectors observed the emergency operations facility's staff as they performed

tasks in response to the exercise. These tasks included facility activation,

notification of state and local response agencies, development and issuance of

protective action recommendations, dose assessment and coordination of field

monitoring teams, and direct interactions with offsite agency response teams. The  :

inspectors reviewed applicable emergency plan implementing procedures, logs,

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checklists, forms, and dose projections generated during the exercise.  ;

b. Observations and Findinas

The emergency operations facility coordinator readied the emergency operations

facility for operation following the 8:21 a.m. alert declaration. Emergency Plan

Procedure EPP 01-4.3," Emergency Operations Facility and Alternate Emergency

Operations Facility Activation," Revision 16, required facility set-up within

60 minutes following a site area or general emergency, or when directed by the

duty emergency director. As part of the set-up process, the emergency operations

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facility coordinator synchronized clocks, ensured that air lock doors remained l

locked, and established a radiological control point at the access door. The facility l

was efficiently and effectively readied for operation.

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Assigned facility emergency response organization personnel arrived shortly after

the 10:07 a.m. site area emergency declaration. Procedure EPP 01-4.3 required

activation by emergency response personnel within 90 minutes of a site area or

general emergency. The emergency operations facility was activated at 10:53 a.m.;

however, the technical support center retained emergency director duties until

notifications were completed for the general emergency (declared at 10:48 a.m.).

Emergency director duties transferred to the duty emergency manager in the

emergency operations facility at 11:06 a.m. Facility habitability was confirmed

following the initiation of the 10:35 a.m. radiological release. Activation and

transfer of essential emergency duties were conducted in an efficient and orderly

manner.

The duty emergency manager exerted effective command and control during the ,

exercise. Facility priorities were established and periodically updated. The duty ,

emergency manager conducted briefings at appropriate intervals or when conditions

changed. On several occasions, separate management briefings were held in an

adjacent conference room to ensure that current plant status and focus were

understood by key personnel, including participating state and local authorities. The

conference room contained telephone extensions to ensure that the duty emergency

manager was always capable of receiving important information from the technical

support center,

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The radiological assessment manager provided continuous information to the duty

emergency manager concerning offsite radiological conditions, offsite field survey  ;

team positions, and changing meteorological conditions. The radiological

assessment manager also assisted the duty emergency manager with protective

action recommendation determinations. Communications between the radiological

assessment manager and duty emergency manager were clear; however, the

radiological assessment manager could have been more vocal during management

briefings.

The dose assessment supervisor was very good at interpreting the licensee's

computerized dose projections. In addition, the supervisor routinely

communicated with technical support center counterparts regarding current

plant conditions and properly kept the radiological assessment manager

apprised of changes in radiological and meteorological conditions. l

Protective action recommendation changes were developed and communicated to

state / local authorities in accordance with procedures. However, the inspectors

identified a concern regarding protective action recommendations. Specifically,

Step 6.3 of EPP 01-10.1, * Protective Action Recommendations," Fevision 13,

required that the duty emergency director / manager notify state and county

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. authorities about doses that exceed the Environmental Protection Agency protective '

action guides beyond the 10-mile emergency planning zone. The procedure did not i

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require a licensee protective action recommendation.

During the exercise, projected doses (based on field team samples) at 10 miles f

exceeded the Federal limits at 1:35 p.m. Specific actions to protect the affected

public were formulated by offsite authorities at 3:42 p.m. (over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later). It ,

appeared that additional support from the licensee would have expedited the

process. Moreover, during the post-exercise critique, offsite authorities stated that  !

additional utility support would have been welcomed.

The inspectors concluded that procedural guidance concerning protective action  !

recommendations beyond the 10-mile emergency planning zone did not provide

offsite authorities with the level of support they would have liked, nor was it

consistent with Federal expectations outlined in NUREG-0654, " Criteria for

Preparation and Evaluation of Radiological Emergency Response Plans and  ;

Preparedness in Support of Nuclear Power Plants." The licensee acknowledged the j

difficulties experienced during the exercise and agreed to review the process and t

procedures with the State of Kansas. '

in general, field monitoring teams were efficiently and effectively controlled. Two  !

utility field teams were dispatched following the general emergency declaration. [

Upon arrival of state and county personnel, four joint (utility, state, and county) field '

monitoring teams were formed. The teams obtained plume centerline air samples

and defined plume edges. One team remained out of the plume to analyze field  ;

team samples.  ;

The inspectors concluded that the radiological assessment supervisor did not  !

effectively maximize the use of field teams for determining doses beyond the  ;

10-mile emergency planning zone. As indicated above, at 1:35 p.m., dose rates  !

beyond the 10-mile emergency planning zone were projected to exceed Federal

limits. Rather than send one of the existing field teams to confirm the doses

beyond 10 miles, a decision was made to form a fifth team. The fifth team was not  !

dispatched until approximately 2:50 p.m. (over an hour later). As a result, the

t information needed by the decisionmakers to make protective action

recommendations beyond the 10-mile emergency planning zone was delayed. The j

licensee acknowledged this finding and stated that the field team control process  !

l would be reviewed.

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The inspectors noted good cooperation and teamwork between the dose  !

assessment technicians from the licensee and the State of Kansas. The dose

j assessment supervisor frequently discussed questionable data with the

state's dose assessor, and the radiological assessment supervisor discussed  :

, and coordinated the effect of the offsite field teams with state and county .

A field team coordinators. _

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With one exception, visual aids, such as maps and status boards, were l

effectively used during the exercise. The inspectors noted that the isopleth

overlay on the emergency planning zone map (used to display plume and

field team locations) did not always coincide with the meteorological data l

recorded on the radiological status board. For example, at approximately l

1 p.m., the inspectors noted that the wind direction shifted from 40 degrees i

to 220 degrees. For approximately 90 rninutes, the licensee did not move

the isopleth overlay on the emergency planning zone map to properly reflect

the wind change.

-c. Conclusions

Overall, the emergency operations facility staff's performance was good. The duty

emergency manager exercised effective command and control. Offsite agency

notifications and interactions were generally correct and timely. Procedural

guidance concerning protective action recommendations beyond the 10-mile

emergency planning zone was not sufficient to support offsite officials. The dose

assessment team performed well in general, field teams were efficiently and .

effectively used and controlled. Field team usage was not effectively maximized to  !

determine doses beyond the 10-mile emergency planning zone.  !

P4.6 Scenario and Exercise Control j

a. Insoection Scooe (82301) l

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The inspectors made observations during the exercise to assess the challenge and

realism of the scenario and to evaluate exercise control.

! b. Observations and Findinas

The following observations detracted from the realism and training value of the  ;

exercise and were considered areas for improvement: l

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• A controller provided incorrect information to health physics technicians for

initial surveys. The controller switched area survey readings with smear j

sample results (7000 millirem per hour versus 260 disintegrations per minute  ;

per 100 square centimeters). The report that dose rates were 260 millirem i

per hour, instead of 7000 millirem per hour, contributed to the control

room's lack of urgency concerning plant cooldown.

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• Use of the firo brigade leader was not properly controlled. When the fire

brigade leader was dispatched (simulated) from the control room to assist -

with the heart attack victim, the individual actually remained in the control i

room to fulfill the NRC communicator role. Had this situation been properly l

controlled, a licensed control room operator would have had to complete the  :

NRC notifications since all of the other required nonficensed auxiliary {

operators were engaged with inplant activities associated with the seismic ,

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• Two simulator fidelity problems were observed. First, tables entered into the ,

! simulator caused radiation monitors to reset to zero. The zero readings  !

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confused control room operators. Second, the rate of change on the

feedwater heaters, while feeding with the condensate pumps, did not appear

to be modeled accurately,

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• The scenario developers failed to consider all possible release paths from the

main steam / main feed isolation valve compartment, the area where the  ;

steam line break occurred. Moreover, exercise participants did not question i

l- the apparent radiation monitor inconsistencies.

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This area of the auxiliary building has large missile doors in the overhead that

open to the 2065 footlevel of the turbine building. The doors are not sealed

and there are openings where steam would exit. The 20 main steam safeties l

for the 4 steam lines are located in this compartment. Each ufety has two '

12-inch standpipes that are open to the area through a drip catch at the base i

and to the atmosphere on the building roof. Neither of these paths were  :

considered in the scenario. The path that the developers used was a 20-inch  !

drainline in the floor that was installed to prevent room flooding in the event -

of a feed line break.  !

After the exercise, the inspectors discussed this concern with participants. 3

The dose assessment personnelindicated that all available radiation monitors 3

were reviewed to verify that there were no additional release paths. The }

inspectors noted that the release paths existed and that no one questioned  !

why radiation monitors on the roof were not alarming with such a high level  !

release. - At the inspectors' request, engineering personnel reviewed the  !

concern and found that, in addition to the identified release paths, two metal

blowout panels were located in the roof area. .

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• The operability of the post-accident sampling system was not addressed in l

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the scenario initial conditions. During the exercise, participants assumed  :

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thi t the post-accident sampling system was inoperable, because it was l

cunently inoperable in the plant. For exercise purposes, the system was  ;

assumed-to be operable. This situation caused confusion because the l

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scenario depended on post-accident sample results.

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• Although controllers appropriately passed information a second time when l

the scenario did not proceed as expected (the dose equivalent :odine data

issue discussed in Section P4.3 above), the method used to pass this

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information was inappropriate. Exercise participants were shown a data

matrix with two circled numbers. The matrix contained the post-accident

sampling system data for the entire exercise.

c. Conclusions

The inspectors determined that the scenario was sufficiently challenging to test

emergency response capabilities and demonstrate onsite exercise objectives.

Exercise control was more effective than it was in the 1995 exercise; however,

there was still room for improvement.

P4.7 Licensee Self Critiaue

a. Insoection Scope (82301-03.13)

The inspectors observed and evaluated the licensee's post-exercise f acility critiques

and the formal management critique on February 27,1997, to determine whether

the process would identify and characterize weak or deficie:nt areas in need of

corrective action.

b. Observations and Findinas

The inspectors determined that tho pust-exercise critiques were generally thorough,

open, and self critical with input from participants, controllers, and evaluators. The

inspectors observed the following exceptions:

• There was only one controller / evaluator stationed in the control room  !

simulator panel area. A second evaluator was stationed in the shift  !

supervisor's office to observe offsite agency notifications. Due to the need

to focus on simulator / scenario fidelity, the controller in the panel area was

challenged to also evaluate performance from an emergency preparedness

perspective.

• In the technical support center, the post-exercise critique could have been

more self critical. The points brought out were good, but communications )

problems were not sufficiently addressed. Those participating in the critique

focused on positive aspects of performance, rather than identifying problems

to capture for corrective action determination (lessons learned).

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• In the emergency operations facility, the post-exercise critique was

exceptionally thorough and self critical. The duty emergency manager

conducted the critique in a manner that encouraged participation and

problem identification. Input was also solicited from offsite agency

representatives.

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l During the February 27,1997, management critique, the emergency preparedness

l manager presented a compilation of comments from participants, controllers, and -

i evaluetors. The licensee's team identified several strengths and areas for - ,

imprevement. The issues identified by the licensee's team were generally

l conastent with those identified by the NRC inspection team. The inspectors

l concluded that the licensee used a low threshold to determine performance

, streng ths.

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c. Conclusions

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Overall, the licensee's self-critique process effectively identified e eas for corrective

action. The control room simulator exercise controller was challenged to perform ,

controller / evaluator duties. The technical support center post-exercise critique

could have been more challenging. The emergency operations facility post-exercise

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critique was exceptionally thorough and self critical. A low threshold was used to

l determine performance strengths in all f acilities.

l P8 Miscellaneous Emergency Preparedness issues (92904)

P8.1 (Closed) Inspection Followuo item 50-482/9512-01: exercise weakness for failures

l involving internal / external control room communications. During the 1995 exercise,

I the control room did not effectively use site-wide announcements and faci!!ty

briefings to inform the plant staff of major developments and the status of response

activities. The inspectors reviewed training records, lesson plans, simulator

scenarios, Administrative Procedure AP-21-001," Operations Watchstanding

Practices", Revision 1, and observed shift performance during the exercise to

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determine if corrective actions were complete and effective. Corrective actions

l were complete and exercise performance was satisfactory in this area; however,

l some similar issues were identified during this exercise, indicating continued room

for improvement.

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P8.2 (Closed) Insoection Followuo item 50-482/9512-02: exercise weakness for failure

of the operations support center to maintain accountability. During the 1995

exercise, accountability was not always maintained in the operations support

j center; several individuals left the facility without being tracked. The inspectors

i reviewed corrective actions and observed process implementation during the

exercise to determine if corrective actions were complete and effective.

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Corrective actions included providing training to personnel supervising the

accoentability process, distributing required reading to response personnel regarding

management's expectations for accountability, posting signs on the operations

support ceriter doors (reminding individuals to check with the accountability clerk

before exiting the facility), testing the accountability process during a subsequent

1995 drill, and including a review of accountability activities during drill critiques.

The inspectors noted that, since the 1995 exercise, there were two isolated

instances where individuals failed to follow the accountability process during drills.

During this exercise, accountability was continuously maintained. Individuals and

teams leaving the operations support center were tracked by either the

accountability clerk or the inplant communicator. As discussed in Section P4.3

above, the process for maintainirig accountability was somewhat awkward since

there were three entry points and only one accountability clerk. In addition,

personnel did not understand how to use the accountability form.

P8.3 (Closed) Inspection Followun item 50-482/9512-04: exercise weakness for failure

of the dose assessment staff to communicate dose assessment data to

decisionmakers. During the 1995 exercise, the unclear offsite dose information that

was provided to emergency operations facility managers inhibited the

decisionmakers' ability to interpret and develop proper protective action

recommendations. In response, the licensee revised its radiological status board

and the followup notification form (EPP 01-3.2-1, Revision 7) to specifically state

dose rates "(Calculated at Time)" and projected integrated dose from " Time . . . .

To Time." During this exercise, the licensee diligently ensured that both sets of

calculations were performed and recorded properly. There appeared to be no

confusion on the part of emergency operations facility managers.

P8.4 (Closed) Insoection Followuo item 50-482/9512-05: exercise weakness for weak

control of exercise activities. Corrective actions were completed as described in the

October 13,1995, response to the 1995 exercise report. Corrective actions

included developing a controller training manual, conducting controller training,

conducting more detailed scenario walkthroughs. and designating one of five

emergency response teams as a controller team for an entire year. As indicated in

Section P4.6 above, exercise control was more effective than it was in the 1995

exercise; however, the inspectors' observations indicated there was still room for

improvement.

V. Manaaement Meetings l

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X1 Exit Meeting Summary

The inspectors presented the inspection results to members of licensee management at the

conclusion of the inspection on February 27,1997. The licensee acknowledged the j

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findings presented. No proprietary information was identified, i

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ATTACHMENT

PARTIAL LIST OF PERSONS CONTACTED

Licensee

O. Maynard, President and Chief Executive Officer

D. Birk, Senior Operations Specialist

M. Blow, Superintendent, Chemistry

G. Boyer, Chief Administrative Officer

T. Conley, Superintendent, Radiation Protection

J. Dagenette, Emergency Planner

T. Damashek, Supervisor, Licensing

T. East, Emergency Planner

D. Fehr, Manager, Training

R. Flannigan, Manager, Nuclear Engineering, Safety, and Licensing

T. Garrett, Manager, Design Engineering

D. Gerreits, Superintendem, instrumentation and Electrical

N. Hoadley, Manager, Support Engineering

R. Hubbard, Superintendent, Operations

J. Johnson, Superintendent, Security

B. Loveless, Superintendent, Resource Protection

B. McKinney, Plant Manager

T. Morrill, Assistant to Vice President, Engineering

W. Norton, Manager, Perfnrmance Improvement and A.ssessment

C. Redding, Engineering Specialist, Licensing

K. Scherich, Supervisar, System Engineering

K. Thrall, Emergency Planner

J. Weeks, Manager, Emergency Planning

B. Winzenried, Emergency Planner

C. Younie, Manager, Operations

LIST OF INSPECTION PROCEDURES USED

IP 82301 Evaluation of Exercises at Power Reactors

IP 92904 Followup - Plant Support

LIST OF ITEMS OPENED AND CLOSED

Opened

50-482/97002-01 IFl Exercise weakness - Ineffective internal / external technical

support center communications (Section P4.3)

Closed

50-482/95012-01 IFl Exercise weakness - Failures involving internal / external control

room communications (Section P8.1)

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50-482/95012-02 IFl Exercise weakness - Failure of the operations support center to l

maintain accountability (Section P8.2)

50-482/95012-04 IFl Exercise weakness - Failure of dose assessment staff to i

communicate dose assessment data to decisionmakers

(Section P8.3) l

50-482/95012-05 IFl Exercise weakness - Weak control of exercise activities

(Section P8.4)

LIST OF DOCUMENTS REVIEWED

Emeroency Plan imolementina Procedures and Forms

EPP 01-1.0 Control Room Organization Revision 14

EPP 01-1.1 Technical Support Center / Operations Support Center Revision 17

Organization

EPP 01-1.2 Emergency Operations Facility Organization Revision 14

EPP 01-2.1 Emergency Classification Revision 16

i EPP 01-2.3 Accident Assessment and Mitigation Revision 6 l

EPP 01-3.1 Immediate Notifications Revision 20

EPP 01-3.2 Followup Notifications Revision 14

EPP 01-4.1 Technical Support Center / Operations Support Center Revision 15

Activation

l EPP 01-4.3 Emergency Operations Facility and Alternate Revision 16

Emergency Operations Facility Activation

EPP 01-6.1 Personnel Accountability and Evacuation Revision 12

EPP 01-7.2 Computer Dose Calculations Revision 18

EPP 01-10.1 Protective Action Recommendations Revision 13

l EPP 01-11.2 Status Boards Revision 9

Other Procedures

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AP-21-OO1 Operations Watchstanding Practices R ai ision 1

OFN SG-OO3 Natural Events Rnision 1

Other Documents

Exercise TIN GE-77-356-10,1997 Field Exercise 25 February 1997, Revision O

l Wolf Creek Nuclear Operating Corporation Emergency Plan, Revision 50

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October 13,1995, licensee letter; Subject: Docket No. 50-482: Reply to Weaknesses l

482/9512-01,482/9512-02,482/9512-04,and 482/9512-05

Performance improvement Request list for emergency preparedness organization dated

February 24,19S7

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