ML20206F524

Responds to NRC Re Deficiencies Noted in Insp Rept 50-482/87-04 Re 1986 Emergency Preparedness Exercise. Corrective Actions:Design Engineering Currently Underway to Incorporate Enhancements to Radiological Release Info Sys

ML20206F524
Person / Time
Site:	Wolf Creek
Issue date:	04/08/1987
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.F.1, TASK-TM WM-87-0117, WM-87-117, NUDOCS 8704140278
Download: ML20206F524 (4)

Text

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WOLF CREEK NUCLEAR OPERATING CORPORATION April 8,1987 U.S. Nuclear Regulatory Comission ATTN: Document Control Desk Washington, D.C. 20555 Letter: WM 87-0117 Re: Docket No. 50-482 Ref: Letter dated 03/06/87 from JE Gagliardo, NRC, to BDWithers, WCNOC Subj: Deficiencies Identified in Inspection Report 50-482/87-04 Gentlemen:

Attached are Wolf Creek Nuclear Operating Corporation's responses to the five deficiencies identified during the 1986 Emergency Preparedness Exercise conducted at Wolf Creek Generating Station. The responses, which also include a schedule for resolution of the deficiencies, are being submitted in response to Inspection Report 50-482/87-04 (Reference 1) .

If you have any questions concerning this sulnittal, please contact me or Mr. O.L. Maynard of tirf staf f.

Very truly yours, e70414 A

% y $ h e2 Bart D. Withers DR PDR President and Chief Executive Officer BDW:wbb Attachment i cc: PO'Connor (2)

RMartin Cilackney JCumins Po Box 411/ Durhngton KS 66839 i Phone: (316) 364 8831 MIWI Ot90rtumty Empk'yee M F HC VE7 j

l Attachment to WM 87-0117 Page 1 of 3 April 8, 1987 RESPONSE 'IU DEFICIENCIES IDENfIFIED IN INSPECTION REPORT 58-482/87-94 for WOLF CREEK GENERATING STATION

, Deficiency 59-482/8794-81:

TSC: The primary offsite dose calculation method used by the licensee was essentially a manual method, involving data entry into a matrix and operating in it with a hand-held calculator. Although the method was reasonable timely, it had a high potential for error (due to numerous arithmetic operations) and only addressed simple, straight-line gaussian dispersion conditions (50-482/8704-01) .

EOF: The principal dose assessment system used by the licensee was shown to be unreliable, and cumbersome. As a consequence, dose projections were based on hand held calculators and a simple straight-line gaussian model. These are similar concerns to those pertaining to dose assessment and measurement of iodine in the TSC as discussed in paragraph 5 (50-482/8704-01).

Response To Deficimcy 50-482/8794-01:

'Ihe principal or primsry offsite dose calculation method for Wolf Creek Generating Station (WCGS) is the Radiological Release Information System (RRIS). The manual method using hand-held calculators is used as a backup to RRIS. Due to their ease of usage, calculators have been used by some exercise participants to provide quicker dose assessments.

Design engineering is currently underway to incorporate identified enhancements into RRIS to improve ease of data entry and to generally irrprove the overall useability by the RRIS operator. In addition, the RRIS operator training lesson plan will be revised to provide more indepth hands-on training for the RRIS operators.

The engineering design of enhancements to the RRIS is scheduled for conpletion by October 3, 1987. Implementation of design changes and any required training are scheduled for conpletion by January 29, 1988.

Deficiency 59-482/8794-92:

TSC: The licensee did not appear to have the capability to directly measure, either in-line or via laboratory analysis, radioiodine concentrations in the plant vent under accident conditions.

Consequently, during the exercise, the licensee could only infer what the plant vent radioiodine releases were by using: (1) precalculated radiciodine values corresponding to analyzed accidents; (2) measured in-plant radioiodine concentrations which did not reflect reoval via filtration; and (3) semi-quantitative measurements of air samples with a frisker by field teams (50-482/8704-02).

Attachment to NM 87-0117 Page 2 of 3 April 8, 1987 EOF: The licensee did not appear to have the capability to directly measure, either in-line or via laboratory analysis, radioiodine concentrations in the plant vent under accident conditions.

Consequently, during the exercise, the licensee could only infer what the plant vent radioiodine releases were by using: (1) precalculated radioiodine values corresponding to analyzed accidents; (2) measured in-plant radioiodine concentrations which did not reflect removal via filtration; and (3) semi-quantitative measurements of air samples with a frisker by field teams. These are similar concerns to those identified in the TSC as discussed in paragraph 5.-(50-482/8704-02)

Response to Deficiency 59-482/8794-92:

WCGS design provides the capability to obtain a grab sanple from the unit vent to directly measure radiciodine concentrations. Plant procedures provide instructions for obtaining the grab sanple and analyzing the sanple. During the exercise the decision was made to not obtain a grab sample. In that case, the identified methods for inferring unit vent radiciodine releases are appropriate alternate methods.

The post accident radioiodine and particulate sampling design and d capabilities were submitted for NRC review as part of our response to NUREG 0737, Item II.F.1 (Wolf Creek USAR Section 18.2.12) . The NRC review and l acceptance of this design is documented in NUREG-0881 Supplement 4, " Safety l Evaluation Report Related to the Operation of Wolf Creek Generating Station, i Unit No. 1".

Deficiency 59-482/8794-93:

The access code number for placing telephone calls to state and local agencies were not initially available to the TSC Communicator, thus causing confusion and a slight delay in making the required initial notification from the TSC (50-482/8704-03) .

Response to Deficiency 59-482/8794-93:

The access code numbers for the Technical Support Center (TSC) telephones have been included in the latest revision of the Radiological Emergency Telephone Directory (RETD). Copies of the RE'rD are available in the TSC for use by all TSC personnel.

Deficiency 59-482/8794-94:

The DEM delayed making protective action reconnendations after plant conditions (e.g., clad failure and core uncovering at 9:59 a.m.; 3.5 percent concentration of hydrogen in the containment at 10:30 a.m.; continuous pressure buildup in the containment building; large LOCA and loss of coolant inventory) warranted it. The DEM postponed making protective action reconnendations for the public at risk, even after the NRC Emergency Response Team informed him that in their opinion general emergency _

conditions were present (10:23 a.m.) . The decision for sheltering personnel within the conter zone was not recommended by the DEM until 11:10 a.m. At that time, the county decided for evacuation of human populations at the center zone (50-482/8704-04) .

Attachment to NM 87-0117 Page 3 of 3 April 8, 1987 Rsponse to Deficiency 50-482/8794-94:

'Ihe decision to upgrade an emergency classification cannot always be totally objective. NCGS teaches the Duty Emergency Directors (DEDs) and Duty Dnergency Managers (DEMs) to make those decisions based upon the best available information and their knowledge of the plant. In an emergency exercise there is sometimes a tendency to try not to anticipate the scenario. This should be discouraged since in an actual emergency we would attenpt to anticipata future events to the fullest extent. Anticipation of future events during exercises and emergencies has been discussed with the Emergency Planning Coordinator and the DEM for future emergency planning activities.

Specific inprovements are being investigated to augment the decision making processes for the DDi. Improvement areas being evaluated are enhancements in the flow of technical information to the DEM, modifications to decision making aids such as flow charts, and possibly some changes in training associated with the decision making processes. One item being considered is changes to the Protective Action Recomendation Flow Chart to include additional information for use by the DEM and his managers.

l These improvement areas will be developed and then evaluated during the 1987 l Emergency Planning Exercise.

Deficiency 58-482/8794-95:

During the exercise the EOF experienced a tenporary loss of the telephone system. Communicators in the EOF had not received hands on training in the use of the radio. That lack of hands on radio training prevented the comnunicators from using the backup radio comunications for making offsite notifications to the State. The telephone service was restored in a matter of minutes and the offsite notifications were made within the 15 minute requirement. If the event had been a lasting telephone system failure, notifications could have been substantially delayed (50-482/8704-05).

Response to Deficiency 58-482/8794-95:

Harris-on training for backup radio communication is currently ongoing. In addition hands-on backup radio comunication training will be included as an initial training requirement for the positions requiring the use of these radios.

The required lesson plan or procedural changes and the required training for these positions will be completed prior to June 30, 1987.