ML22307A137

August 2022 Emergency Preparedness Exercise Inspection Unresolved Item - Request for Information

ML22307A137
Person / Time
Site:	Wolf Creek
Issue date:	11/02/2022
From:	Strittmatter H NRC/RGN-V
To:	Dekat M, Joseph Turner Evergy
References
Download: ML22307A137 (5)

Text

ADAMS Accession# ML22307A137 From: Henry Strittmatter To: Joshua Turner; Matthew Dekat Cc: Lisa Ketchum; Dustin Hamman; Ryan Alexander

Subject:

2022 WCNOC EP Exercise Inspection URI RFI Date: Wednesday, November 2, 2022 10:56:00 AM Attachments: WCNOC 2022 EP Exercise Inspection Unresolved Item Request for Information 11022022.pdf Mr. Turner, Mr. Dekat:

This e-mail serves to transmit a request for information to support the resolution of an Unresolved Item from the 2022 Biennial EP Exercise Inspection at Wolf Creek.

Details of the requested materials are included in the attachment to this e-mail. If possible, please make the requested materials available to me in electronic format using the online document portal of the stations choice, by the date stated within the attachment. If you are unable to complete the request by this date, please contact me at the phone number listed below to discuss alternative options.

This letter/e-mail does not contain new or amended information collection requirements subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection requirements were approved by the Office of Management and Budget under control number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or an information collection requirement unless the requesting document displays a currently valid Office of Management and Budget control number.

This email and its enclosures will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Henry J. Strittmatter Emergency Preparedness Inspector U.S. Nuclear Regulatory Commission, Region IV (817)200-1532

Request for Information for EP Exercise Inspection Unresolved Item Docket 05000482 (Wolf Creek Generating Station)

Inspection Report 2022501 Inspection Procedure 71114.01 In-Office Review: October 12, 2022 - December 31, 2022 Overall Goal of The Following Questions and Document Requests:

Given the performance during the exercise and the available information to the ERO in the period of 1100 - 1200, and in consideration of the inherent risk of evacuating any population, please explain how the PAR at 1132 which included evacuation 2-10 miles down wind reduced public risk and was protective of public health and safety consistent with Federal Guidance (in particular for those in the 5-10 miles down wind (i.e., SE-3, SE-4, & S-2)).

To address the above goal, please provide responses, documents, or other information to the following questions and requests by November 16, 2022:

Part 1: Dose Assessment The White Paper, under Question 1 states in part The GE declaration occurred at 1132 and was briefed to the EOF at 1140. The previous dose assessment was performed at 1054 and the next was performed at 1159. The minimum requirement from EPP 06-012 is to perform a dose assessment every hour. The logs taken by the Dose Assessment Tech clearly showed he was monitoring Met Tower conditions and changes in Unit Vent readings. He also documented at what Unit Vent readings he anticipated changes to PARS.

1.a. Acknowledging that EPP 06-012 states the following:

And What are the stations bases for stating in the White Paper that dose assessments at minimum must be performed every hour (step 6.1) when there appears to be additional minimum criteria for completing additional dose assessments when significant changes in key parameters occur (step 6.3)?

1.b. How are Dose Assessment staff trained as to these Precautions/Limitations in EPP 06-012? (Provide training materials used as objective evidence to support response, if available.)

1.c. In reviewing the EOF DACs logs, it shows that they were monitoring for meteorological changes (no change in met conditions entries at 0920, 0945,1030, 1103, 1135, etc.).

Additionally, the DACs 1054 log entry describes a hypothetical calculation that no change in PARs until 2.95E+8 uCi/s is reached, however there are no subsequent log entries demonstrating monitoring/trending the Unit Vent release rate until >30 minutes later (1133) with the entry UV release rate reached 4.50E+08.

(1) Provide a record, if available, of the hypothetical calculation that showed no change in PARs until 2.95e+8 uCi/s is reached.

(2) Was the DAC/Dose Assessment Team actively monitoring the Unit Vent Release Rate between 1054 and 1133? Was this value communicated within the EOF and with the Dose Assessment Team as a critical parameter for monitoring?

(3) Per the as run simulation during the exercise, at what time did the Unit Vent Release Rate exceed 2.95E+08 uCi/s?

Part 2: Fission Product Barriers 2a. Regarding the stations statements in the White Paper relative to the UFSAR Chapter 15 consideration of the Fuel Building as a barrier (starting at the bottom of PDF Page 6), provide any guidance, standard, or training provided to the ERO which states that when assessing the question Actual or imminent breach of all three fission product barriers?, not only are the usual three fission product barriers (fuel clad, RCS, and containment) to be considered, but also the Fuel Building when there is fuel in the spent fuel pool.

Part 3: Historical Bases for the Actual or Imminent Breach Diamond Wolf Creek Response to NRC Question 2, states in part (top of PDF page 2):

[continued on next page]

Further, WC RERP Rev 15 (1/1985), as approved by the NRC in the Wolf Creek Safety Evaluation Report (NUREG-0881, Supplement 5), states on Page 3.3-9:

And NUREG-0881, Supplement 5, section 13.3.2.8, states in part:

3.a - Please provide a copy of EPP 01-10.1, Revision 1, Protective Action Recommendations, as referenced in the Wolf Creek RERP, Rev 15 (as approved in the SER/NUREG-0881, Supplement 5), AND any evaluations completed to support that EPPs development (i.e.,

comparison to NRC Information Notice 83-28).

3.b - Given that the current PAR procedure is designated as EPP 06-006, please provide the final revision of the PAR procedure which was designated as EPP 01-10.1, the subsequent first revision of the procedure revision designated as EPP 06-006, and the related 50.54(q) evaluation conducted to support this change.

[continued on next page]

3.c - Given the concern is related to the bases and guidance associated with the decision diamond in EPP 06-006 which currently states Actual or Imminent breach of three fission product barriers, please provide change packages (i.e., prior and new procedure revision, and associated 50.54(q) evaluation) for:

(1) The FIRST revision which incorporates the decision diamond logic (if not previously included in responses to Q3.a or Q3.b); and (2) All subsequent revisions of the PAR procedure associated with changes to the statements or guidance related to that decision diamond. (This should be inclusive for when the PAR procedure was designated as EPP 01-10.1 or EPP 06-006.)

3.d - Provide copies of current training materials related to EPP 06-006 and the PAR process provided to those members of the ERO responsible for making the recommendations (Onsite and Offsite Emergency Managers) AND those responsible for directly supporting that decision making (e.g., Radiological Coordinator, Dose Assessment Coordinator, etc.).