IR 05000482/1986020
| ML20213E534 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/30/1986 |
| From: | Hackney C, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20213E524 | List: |
| References | |
| 50-482-86-20, NUDOCS 8611130208 | |
| Download: ML20213E534 (12) | |
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APPENDIX U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-482/86-20 License: NPF-42 Docket: 50-482 Licensee: Kansas Gas and Electric Company (KG&E)
P.O. Box 208 Wichita, Kansas 67201 Facility Name: Wolf Creek Generating Station
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Inspection At: Wolf Creek Site, Burlington, Kansas
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Inspection Conducted: August 25-29, 1986 Inspector: kY4Asf C. A. Hackney, Emergency Prepfredness Analyst
/4 - J-9 -14 Date Accompanying Inspectors: M. Good, Comex Corporation T. Lynch, Battelle Approved: Cind0 ID!Sodb'
L. A. Yandell, Chief, Emergency Preparedness
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Date and Safeguards Programs Section Inspection Summary r Inspection Conducted August 25-29, 1986 (Report 50-482/86-20)
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Areas Inspected: Routine, unannounced inspection of the licensee's emergency preparedness program, including the areas of emergency detection and classification, protective action decisionmaking, notifications and communications, changes to the emergency preparedness program, shift staffing and augmentation, knowledge and performance of duties, and licensee audits and quality assurance. .
Results: Within the emergency response areas inspected, no violations or l deviations were identifie l PDR ADOCK 05000482 G PDR l 1
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-2-DETAILS Persons Contacted Principal Licensee Personnel
- F. Rhodes, Plant Manager W. Rudolph, Manager, Quality Assurance L. S. Herhold, Engineering Specialist K. D. Craighead, Engineering Specialist G. Atwood, Licensing Engineer
- S. M. Devena, Emergency Planning Administrator A. A. Montague, Maintenance Communications Supervisor
- Nichols, Superintendent of Plant Support
- Rudolph II, Quality Assurance R. Grant, Quality Assurance M. Schreiber, Emergency Planning Coordinator C. Reekie, Quality Assurance Evaluation Coordinator C. Patrick, Superintendent, Quality Evaluation D. Hooper, Document Control Clerk l *J. Goode, Senior Licensing Engineer l J. Dagenette, Training Coordinator J. Zell, Manager, Nuclear Training
- R. Hoyt, Senior Engineering Specialist J. Houghton, Operations Coordinator D. Naylor, Shift Supervisor D. Wiltse, Supervisor Operator P. Martin, Shift Supervisor S. Walgren, Supervising Operator W. Drogemuller, Reactor Operator D. Neufeld, Shift Supervisor W. Weller, Supervising Operator 0. Korbelik, Shift Supervisor R. Schneider, Supervising Operator E. McDougall, Document Configuration Administrator D. Melville, Document Control Supervisor T. Johnson, Document Clerk 3
- G. Boyer, Deputy Plant Manager
- A. Mah, Superintendent of Training NRC
- Bartlett, Resident Inspector l
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, The inspector also held discussions with other station and corporate personnel in the areas of quality assurance communications, document control, changes to the emergency preparedness program, and emergency respons * Denotes those present at the exit intervie . Licensee Action on Previous Inspection Findings Closed (0 pen Item 482/8502-001) - Review of training records for the two reactor operators revealed that they had been given emergency classification trainin Closed (0 pen Item 482/8529-001) - Security procedure SEC-01-202 had been revised to require visitors entering the protected area to read and acknowledge by signature the instructions for siren and evacuation procedure in the protected area.
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Closed (0 pen Item 482/8529-002) - Review of selected time periods during 1986 revealed that monthly communication checks had been performe Additionally, quarterly communication checks had been performe Closed (0 pen Item 482/8425-007) - EPP 02-1.2 had been revised to clarify the areas of responsibilities for the Emergency Preparedness Coordinator (EPC) and the Emergency Preparedness Administrator (EPA).
Closed (0 pen Item 482/8425-030) - Assembly areas were specified in EPP 01-5.1 and had been included in general employee trainin '
Closed (0 pen Item 482/8425-041) - The auto-dial system had been installed and an operational verification conducted on August 6, 198 Closed (0 pen Item 482/8425-043) - Radio communicators training module had been revised and a video tape developed to assist in training radio communicator Closed (0 pen Item 482/8425-069) - Personnel accountability procedure EPP 01-6.1 and EPP 01-9.4 had been revised to include the Maintenance Emergency Coordinator and the Security Emergency Coordinator to perform the protected area and the exclusion area accountability checks.
- Closed (0 pen Item 482/8425-073) - EPP 01-5.1 listed 20 respirators as part of the security building emergency response equipmen Closed (0 pen Item 482/8425-078) - Editorial change had been made to correct duplicated section number Closed (0 pen Item 482/8425-080) - EPP 02-1.3, section 4.2, was revised to remove EPC and EPA dual assignment _ -. .. - -- - __- ..
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-4-Closed (0 pen Item 482/8425-081) - EPP 02-1.1, section 7.8, was revised to include the review of emergency response personnel telephone numbers every 3 month Closed (0 pen Item 482/8425-084) - Quality Assurance had been committed to perform a 50.54(t) review every 12 month Closed (0 pen Item 482/8425-085) - Quality Assurance had been included as required to perform audit Closed (0 pen Item 482/8447-009) - Transmission of media information to the media release center had been revised. Several steps requiring a duplication of effort was removed to expedite getting information to the publi . Emergency Detection and Classification The Emergency Plan Procedure EPP 01-2.1, Revision 2, " Emergency Classification," was reviewed for consistency and adherence to regulatory requirements and the guidance criteria of NUREG-0654. EPP 01-2.1 did not contain guidance requiring a declaration of a General Emergency on a loss of physical control of the facility or consideration of a precautionary 2-mile evacuation (NUREG-0654, General Emergency Condition No. 3). The licensee committed to revising the Emergency Classification Procedure to reflect this guidance. The inspectors prepared a scenario to conduct operator walkthroughs in the control room. The scenario was discussed with senior operations department personnel to ensure consistency and correct plant specific informatio The scenario used required recognition of Emergency Action Levels (EALs) and declaration of the emergency classe Each operations section was briefed that all documentation could be referenced and that normal procedures should be followed. Operators were required to justify actions taken, complete notification checklists, and in some cases make actual notifications (communication test). Each
section was cautioned not to discuss the scenario or interview questions with other sections. Specific walkthrough findings are discussed in appropriate sections of this report. Nine licensed operators were interviewed which included four shift supervisors, four supervising operators, and one reactor operator. During walkthroughs, it was noted that the EAL Procedure EPP 01-2.1, " Emergency Classification," attachments did not clearly address classification levels based on critical safety function fault trees being on red or orange paths. This delayed all sections interviewed in verifying classifications using the procedure as they had to refer to the definitions in the front of the procedure then return to the attachments. Reformatting the procedure may aid operators in making more timely classification The following are observations the NRC inspectors called to the licensee's attention. These observations are neither violations nor unresolved J
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-5-item These items were recommended for licensee consideration for improvement, but they have no specific regulatory requirement:
o Revise EAL to include NUREG-0654 guidance on declaration of a General Emergency on a loss of physical control of the facilit o Revise EAL to include consideration of a precautionary 2-mile evacuation when in a General Emergency due to a loss of physical contro o Review classification criteria with regard to critical safety function red and orange paths to ensure adequate information is present in attachments 1.0, 2.0, 3.0, and 4.0 to EPP 01-2.1,
" Emergency Classification."
No violations or deviations were identifie . Protective Action Decisionmaking During walkthroughs, two of four operator sections had difficulty in making automatic protective action recommendations for a General Emergency. The two sections that made correct recommendations of a 2-mile, 360 degree shelter and a 5-mile downwind shelter per attachment 2.0 to 01-10.1, " Protective Action Recommendations," were delayed by having to reference eight attachments to the procedure for a non-release General Emergency. The two other sections had more difficulty, with one section failing to make any protective action recommendation at the General Emergency leve The procedure did not clearly state which attachments should be referenced for different situations and the flow charts of attachments 1.0 and 2.0 may overla The following is an observation the inspectors called to the licensee's attention. The observation is neither a violation nor an unresolved ite The item was recommended for licensee consideration for improvement, but has no specific regulatory requiremen o EPP 01-10.1 should be revised to make it easier to us No violations or deviations were identifie . Notifications and Communications The inspector reviewed the licensee's emergency plan notification procedures as they pertained to emergency action level schemes, offsite notification, emergency classification, and notification verificatio Notification Procedure 01-3.1 "Immediate Notifications," was reviewed by the NRC inspector. The procedure contained adequate detail to effect notification of the NRC, state, and local agencies within the prescribed time restraints. Information required on preformatted message forms when filled in was of sufficient depth to describe the condition of the plant and make protective action recommendation The licensee had an emergency
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-6-action level scheme for determining emergency classifications and making offsite protective action recommendations. The licensee had installed telephone and radio communications for communicating with offsite agencies. The telephone communication system consisted of a regular commercial system and a licensee microwave syste Both systems may be used for offsite communications. The inspector verified operability of the emergency notification system by requesting that a licensee employee call the emergency operations center in Washington D.C. Additionally, other emergency telephones were verified to be operable by requesting different licensee personnel to perform communication checks. The inspector reviewed the call out procedures for emergency response personnel and noted that emergency response personnel were to be notified at different emergency classes for emergency response. Further, a call back code system was in place for the offsite law enforcement agency to verify licensee messages. The off-duty emergency response personnel would be notified by a call out from designated communicators. The communicators are to be telephoned at home or notified by pager to initiate a callout for assigned emergency response personnel during off-duty hours. The inspector reviewed selected maintenance records for the prompt public notification system. It was noted that in cases where a siren had been reported malfunctioning, there appeared to be timely repair initiated. Further, compensating measures had been taken to alert the public until the siren was repaired. Procedures for maintenance of the siren system, including siren location and the 2-week growl test, had not been written. The inspector discussed the prompt public notification system adequacy test with the Federal Emergency Management Agency (FEMA) Regional Assistance Committee Chairman. Concern over the capability to notify persons in the immediate vicinity of Lake John Redmond resulted in the licensee installing two additional sirens in the vicinity of the lake area. Installation, testing, and documenting the test results had not been completed as of this inspection. Testing results will be submitted to FEMA for revie During walkthroughs, it was noted that one of four sections was not familiar with a change to the procedure which had an auxiliary operator designated for making the initial NRC notification. The change to the procedure had been promulgated as required readin The following are observations the inspectors called to the licensee's attention. These observations are neither violations nor unresolved items. These items were recommended for licensee consideration for improvement, but they have no specific regulatory requiremen o EPP 02-1.7 should address what the EPC does with form 40-5 from the offsite agenc The form should be filed and retained for 5 year o EPP 02-1.7 should reference county procedure number 40 dealing with tone alert radio maintenance, o Develop procedure for conducting 2-week growl test and include the present test report form in EPP 02- . .
-7-o EPP 01-3.1, section 4.1.3 should be revised to reflect current words in 10 CFR 50.72 for notifying the NR No violations or deviations were identifie . Changes To The Emergency Program The inspector reviewed selected Emergency Plan Procedures (EPP) and revisions 17, 18, and 19 to the Emergency Plan. Management review and approval as required by EPP 02-1.1 appeared adequate for the procedures reviewed which included EPP 01-7.1 (Revision 3), 01-7.2 (Revision 5),
01-7.3 (Revision 5), 01-8.1 (Revision 4), 03-1.2 (Revision 4), and 03- (Revision 5). The above changes to the Emergency Plan and EPP were submitted by the licensing group to the NRC within 30 days of the procedure release date as noted belo Revision Revision Date NRC Transmittal Emergency Plan Rev. 17 03-03-86 03-14-86 Emergency Plan Rev. 18 04-08-86 04-10-86 Emergency Plan Rev. 19 05-28-86 06-04-86 Revision Release Date NRC Transmittal EPP 01-7.2 Rev. 5 02-28-86 03-14-86 EPP 01-8.1 Rev. 4 02-28-86 03-14-86 EPP 02-1.2 Rev. 4 05-30-86 06-04-86 EPP 02-1.5 Rev. 5 05-30-86 06-04-86 Quality Assurance Audit Report TE:50140-K124 dated August 15, 1986, indicated that Emergency Plan and EPP revisions are effected through the use of Temporary Change Notices (TCN) which do not receive a 10 CFR 50.54(a) review. Corrective actions identified by the licensee include revisions to the TCN form to accommodate the documentation of a 10 CFR 50.54(q) review and a review of previously issued TCN. Procedure revisions are required when five TCNs are written against a procedur All procedures reviewed by the inspector had fewer than five TCNs attached. The inspector checked the physical layouts of the Technical Support Center and the Emergency Operations Facility against the diagrams contained in the respective activation procedures (EPP 01-4.1 and EPP 01-4.3). The diagrams accurately depicted the actual arrangements in both facilities. There did not appear to be any modifications to the facilities which would decrease their effectiveness. It was noted that the descriptions of the Technical Support Center and the Emergency Operations Facility contained in the Emergency Plan were consistent with the inspector's observations. Based on a review of Administrative Procedure EPP 02-1.1 and discussions that the inspector held with the Emergency Planning Administrator and the Emergency Planning Coordinator,
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it did not appear that they had any responsibilities outside of the emergency preparedness area that would interfere with their primary
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-8-were changes to the licensee's onsite or corporate emergency planning staffs, or offsite support agencies that would appear to decrease the effectiveness of the emergency preparedness program. The inspector reviewed the licensee's system for distribution of revisions to the Emergency Plan and Emergency Plan Procedures per EPP 02-1.1 (Revision 3).
The Configuration Status Accounting Record System (CSARS) is utilized to maintain the distribution matri Revisions to the distribution matrix are provided to document control by the Emergency Planning Coordinator on form KMF-3, "WDCC Df stribution Control List Change Request." The distribution of revisions is controlled by Procedure KB 1032,
" Distribution Control Procedure." TCNs are cross referenced to the applicable procedure and receive the same distribution. As noted under paragraph 9, certain emergency response personnel were not on distribution for changes to procedures pertinent to their emergency response functio No violations or deviations were identifie . Shift Staffing and Augmentation The inspector reviewed Table 1.1-1 of the emergency response plan, discussed shift staffing and augmentation with licensee representatives, and reviewed selected personnel qualification records to determine if the goals and criteria of Table B-1 of NUREG-0654 could be met. A review of the report of an augmentation callout drill conducted May 29, 1985, was also performed. These reviews indicated that the licensee had made adequate provisions for shift staffing and augmentation to deal with emergencies. The inspector determined that contact of emergency response personnel needed to augment the onshift staff would be by telephone fan-out through non responding emergency communicators. In addition, certain key personnel were assigned personal pagers; however, no policy statement or procedure was in place to control the pager issuance or us The inspector also noted that an emergency response organization telephone book was maintained with home telephone and pager numbers for station staf The following is an observation the inspectors called to the licensee's attention. The observation is neither a violation nor an unresolved ite The item was recommended for licensee consideration for improvement, but has no specific regulatory requirement:
o Develop and implement a procedure for distributing pagers and maintaining pagers in possession of key emergency response personne Implement a duty roster to ensure that personnel are availabl No violations or deviations were identifie . Licensee Audits The inspector verified that the licensee had conducted an independent review of the emergency preparedness program within the 12-month period J
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-9-required by 10 CFR 50.54(t). The following reports were reviewed: KG&E Quality Assurance Report TE:50140-K-124 dated August 15, 1986, and KG&E Quality Assurance Surveillance Report TE53359 S1449, dated July 28, 198 The comprehensive audit report evaluated the interfaces with the state and local agencies regarding training, document control, communications, and assistance agreements. Also included were reviews of the adequacy of emergency equipment, testing of communications equipment, dissemination of information to the public, review of Emergency Plan Implementing Procedures and their distribution control, and training of emergency response personnel. The report contained eight deviations and three violation One violation noted the presence of outdated forms in the Technical Support Center (TSC) cabinets, in player's handbooks located in the TSC and Emergency Operations Facility, and in the Ransom Memorial Hospital Emergency Response kit. A second violation pertained to the revision of the Emergency Plan Procedures using a TCN. The TCNs were not required to be reviewed or checked for compliance with 10 CFR 50.54(q) and 10 CFR 50.5 The third violation addressed the failure by the licensee to document the notification of the sheriff and the NRC per procedure EPP 02-1.7 during a test of the Emergency Broadcast System sirens where the sirens could not be activated. All the violations and deviations have appropriate corrective actions identified, corrective action responsibilities assigned, and scheduled completion date EPP 02-1.1 (Revision 3), " Emergency Preparedness Program Maintenance," was reviewed by the inspector. Section 6.1.4 required that the emergency preparedness program review be available to the appropriate state and local governments. The EPC was responsible for maintaining the offsite portion of the program. The EPC indicated that he regularly interfaced with the offsite agencie Distribution for the audit report included both corporate and plant management including the EPC and the Vice President for Nuclear Operations. Retention time for the report is 5 years as required by EPP 02-1.1 (Revision 3), Section 6.1.3. The inspector reviewed the " Radiological Emergency Field Exercise Report-1985" and the " Radiological Emergency Planning Semi-Annual Health Physics Drill Report-1986." Critiques were held after the exercise and drill in accordance with EPP 02 1.3, " Drills and Exercises." Deficiencies identified are noted as open items or improvement items and are entered into the respective tracking systems by the Emergency Planning Group. The open items are given the highest priority and are assigned an Open Item Tracking Number. The following information is maintained for each open item on the Open Item Tracking List: applicable source document, responsible individual, due date for corrective action, status, and descriptio It was noted that several open items had been closed. However, numerous open items had not been assigned corrective action due dates as of August 28, 1986. The " Semi-Annual Health Physics Drill Report" KLSWCP 86-089 TE:42952-C committed to have all open items corrected by the next dril None of these items had been assigned due dates. Improvement
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items are entered into the Improvement Item Tracking List and are deleted when corrective action is completed. Consideration should be given to retaining a file on closed items to provide a data base for trending purpose The following are observations the inspector called to the licensee's attention. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for improvement, but they have no specific regulatory requiremen o The Open Item Tracking List should be updated to include corrective action due dates for all open items. This would include the open items pertaining to the November 1985 Emergency Preparedness Exercise and the March 1986 Health Physics Dril o Consideration'should be given to maintaining a record of improvement items which have been closed to provide a data base for trending purpose . Knowledge and Performance of Duties The emergency preparedness training program requirements are delineated in EPP-02- The training procedure described training matrices for preliminary training, initial training, and retraining. The preliminary training matrix applied prior to the 1984 exercise. The initial training matrix applied after the 1984 exercis The cross-reference between matrices and computer training records was not proceduralized and was understood by only one member of the training organization. This made an audit of the system difficult and time consuming. Although lesson plans appeared to be used in emergency plan training, their use was not required by EPP 02-1.2, " Emergency Plan Training." The requirement for use of formal lesson plans would assist in ensuring more uniformity in trainin The periodic emergency preparedness retraining specified by EPP 02-1.2 to fulfill the requirements of 10 CFR 50, Appendix E, paragraph IV.F is required on an annual (calendar) basis. This meant that personnel in the !
Emergency Response Organization could go up to 23 months without training and still meet EPP-02-1.2 requirements. During discussions with the training management staff, the licensee committed to review requirements for conducting training on a 12-month basis. The required reading program used to inform and train emergency response personnel of changes to EPPs was audited by the inspectors. The emergency preparedness required reading program is referenced in EPP 01-2.1, " Training Program," and is controlled by the Records Management System. The system is computerized and a part of the CSARS and the Action Tracking Module (ATM) subsyste Changes and TCN required reading transmittals are sent to each individual on required reading distribution for that change. Individuals have 15 days to read the changes, sign, and return the transmittal. A 30-day delinquent notice is sent, paralleled with a letter to the training manager of delinquent individuals for his action. Transmittals reviewed by the inspector indicated response by individuals within the Emergency
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Response Organization was satisfactory. The administration of the required reading program was proceduralized and addressed in plant Procedure KGF-1032, " Distribution Control." The audit included verifying that appropriate Emergency Response personnel had received training on changes to procedures that affected their Emergency Response position. A sampling of ten changes was audited against one of the interviewed shift supervisor / duty emergency directors. The following was noted: The shift supervisor / duty emergency director (SS/DED) was not on distribution for changes to EPP 01-8.1, "Onsite Radiation Monitoring." The procedure specifically states it is applicable to the SS/DE SS/DED was not on distribution for changes to EPP 02-1.2, " Training Program." Changes to the training program should be applicable to duty emergency directors who direct overall emergency managemen Technical Support Center Activation Procedure EPP 01-4.1, Revision 4, step 4.2.10 states that the technical support center coordinator and engineering team shall initialize the Emergency Response Facility Information System (ERFIS) and SAS per EPP 01-4.7, " Emergency Response Facility Information System." However, no technical support coordinators or TSC engineering team members are on required reading distribution for changes to the ERFIS Procedure EPP 01- The following are observations the inspectors called to the licensee's attention. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for improvement, but they have no specific regulatory requirement:
o Recommend Emergency Plan periodic retraining on a 12-month (rather than annual) cycle similar to General Employee Training. Consider using t 3-month window or a not-to-exceed 15-month requirement to ensure Emergency Response members are current in their trainin o Recommend that the training procedure EPP-01-2.1 be reviewed and revised to include referencing the requirement to use training department instructions. This would link the use of testing, critiques, lesson plans, and effectiveness evaluations to Emergency Plan Trainin o Recommend that the Emergency Plan required reading list be reviewed and revised to require routing of EPP changes to appropriate members of the Emergency Response Organizatio o Recommend that SS/DED receive additional training in use of EPP 01-10.1, " Protective Action Recommendations," and specifically, automatic protective action recommendations that are appropriate for any General Emergenc No violations or deviations were identifie _- .. _
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1 Exit Interview The NRC inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on August 29,~1986. The NRC inspector summarized the purpose and the scope of the inspection and the findings. Mr. G. D. Boyer, Deputy Plant Manager, stated that the EAL's
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would be reviewed and the loss of physical control of the plant would be added to the General Emergency clas i r
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