ML14092A618: Difference between revisions
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| issue date = 04/02/2014 | | issue date = 04/02/2014 | ||
| title = IR 05000482-13-502; on 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05 | | title = IR 05000482-13-502; on 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05 | ||
| author name = Clark J | | author name = Clark J | ||
| author affiliation = NRC/RGN-IV/DRS | | author affiliation = NRC/RGN-IV/DRS | ||
| addressee name = Heflin A | | addressee name = Heflin A | ||
| addressee affiliation = Wolf Creek Nuclear Operating Corp | | addressee affiliation = Wolf Creek Nuclear Operating Corp | ||
| docket = 05000482 | | docket = 05000482 | ||
Line 15: | Line 15: | ||
| page count = 15 | | page count = 15 | ||
}} | }} | ||
See also: [[ | See also: [[see also::IR 05000482/2013502]] | ||
=Text= | =Text= | ||
{{#Wiki_filter:April 2, 2014 | {{#Wiki_filter:UNITED STATES | ||
NUCLEAR REGULATORY COMMISSION | |||
EA-14-024 | REGION IV | ||
1600 E. LAMAR BLVD. | |||
Chief Executive Officer | ARLINGTON, TX 76011-4511 | ||
April 2, 2014 | |||
EA-14-024 | |||
Adam Heflin, President and | |||
Chief Executive Officer | |||
Wolf Creek Nuclear Operating Corporation | |||
P.O. Box 411 | |||
Burlington, KS 66839 | |||
SUBJECT: WOLF CREEK GENERATING STATION - NRC BASELINE INSPECTION | |||
REPORT 05000482/2013502, PRELIMINARY WHITE FINDING | |||
Dear Mr. Heflin: | |||
This letter refers to the in-office and onsite inspections conducted September 3, 2013, through | |||
March 4, 2014, for the Wolf Creek Generating Station. The inspection was a baseline | |||
evaluation of your emergency preparedness program through observation of emergency | |||
response organization performance during the November 5, 2013, biennial exercise. The | |||
enclosed report presents the results of this inspection. The inspectors discussed the | |||
preliminary inspection findings with you and your staff at the conclusion of the on-site portion of | |||
the inspection. Additional telephone discussions occurred on September 30, 2013, and | |||
January 27, February 10, and February 20, 2014. A final exit briefing was conducted with you | |||
and your staff on March 4, 2014. | |||
This inspection examined activities conducted under your license as they relate to safety and | |||
compliance with the Commissions rules and regulations and with the conditions in your license. | |||
Within these areas, the inspection consisted of an examination of selected procedures and | |||
representative records, observations of emergency preparedness activities, and interviews with | |||
personnel. | |||
This inspection identified a finding that has preliminarily been determined to be a White finding | |||
with low to moderate safety significance that may require additional NRC inspection. The | |||
finding is associated with a failure to maintain adequate methods for assessing the potential | |||
consequences of a radiological emergency condition in accordance with the requirements | |||
of 10 CFR 50.47(b)(9). This deficiency was corrected on February 25, 2014. This finding is | |||
also an apparent violation of NRC requirements and is being considered for escalated | |||
enforcement action in accordance with the Enforcement Policy, which can be found on the | |||
NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce-pol.html. | |||
The preliminary low to moderate safety significance (White) finding was assessed based on the | |||
best available information, using the Emergency Preparedness Significance Determination | |||
Process (SDP) and the NRC Enforcement Policy. The basis for the NRCs preliminary | |||
significance determination is described in the enclosed report. The final resolution of this finding | |||
will be conveyed in separate correspondence. | |||
A. Heflin -2- | |||
In accordance with NRC Inspection Manual Chapter (IMC) 0609, we intend to complete our | |||
evaluation of the White finding using the best available information, and issue our final | |||
determination of safety significance within 90 days of the date of this letter. The significance | |||
determination process encourages an open dialogue between the NRC staff and the licensee; | |||
however, the dialogue should not impact the timeliness of the staffs final determination. Before | |||
we make a final decision on this matter, we are providing you with an opportunity to attend a | |||
Regulatory Conference where you can present to the NRC your perspective on the facts and | |||
assumptions the NRC used to arrive at the finding and assess its significance, or submit your | |||
response | position on the finding to the NRC in writing. | ||
the | If you request a Regulatory Conference, it should be held within 30 days of the receipt of this | ||
letter and we encourage you to submit supporting documentation at least one week prior to the | |||
Conference in an effort to make the Conference more efficient and effective. The focus of the | |||
Regulatory Conference is to discuss the significance of the finding and not necessarily what the | |||
root cause is or corrective action(s) associated with the finding. If a Conference is held, it will be | |||
open for public observation and a public meeting notice and press release will be issued to | |||
announce the conference. If you decide to submit only a written response, such submittal | |||
should be sent to the NRC within 30 days of your receipt of this letter. If you decline to request | |||
a Conference or to submit a written response, you relinquish your right to appeal the final SDP | |||
determination, in that by not doing either, you fail to meet the appeal requirements stated in the | |||
Prerequisite and Limitation Sections of Attachment 2 of IMC 0609. | |||
Please contact Mr. Mark Haire, Chief, Plant Support Branch 1, at 817-200-1527, within 10 days | |||
from the issue date of this letter to notify the NRC of your intentions. If we have not heard from | |||
you within 10 days, we will continue with our significance determination and enforcement | |||
decision. Since the NRC has not made a final determination in these matters, no Notice of | |||
Violation is being issued for these inspection findings at this time. In addition, please be | |||
advised that the number and characterization of the apparent violation may change as a result | |||
of further NRC review. | |||
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of | |||
this letter, its enclosures, and your response, if you choose to provide one, will be made | |||
available electronically for public inspection in the NRC Public Document Room or from the | |||
NRCs Agencywide Documents Access and Management System (ADAMS), accessible from | |||
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your | |||
response should not include any personal privacy or proprietary information so that it can be | |||
made available to the Public without redaction. | |||
A. Heflin -3- | |||
If you have any questions concerning this matter, please contact Mr. Mark Haire, Branch Chief, | |||
Plant Support Branch 1, at 817-200-1527, or Mr. Paul Elkmann, Senior Inspector, Plant Support | |||
Branch 1, at 817-200-1539. | |||
Sincerely, | |||
/RA/ | |||
Jeffrey A. Clark, Acting Director | |||
Division of Reactor Safety | |||
Docket No. 50-482 | |||
License No. NPF-42 | |||
Enclosure: | |||
Inspection Report 05000482/2013502 | |||
w/Attachment: Supplemental Information | |||
Electronic Distribution for Wolf Creek Generating Station | |||
A. Heflin -4- | |||
A. Heflin - 4 - | |||
Distribution | Distribution | ||
ADAMS (PARS) RidsOeMailCenter Resource; OEWEB Resource; (if public) | |||
RidsSecyMailCenter Resource; RidsOcaMailCenter Resource; RidsOgcMailCenter Resource; | |||
RidsEdoMailCenter Resource; | RidsEdoMailCenter Resource; EDO_Managers RidsOigMailCenter Resource; | ||
RidsOiMailCenter Resource; RidsRgn1MailCenter Resource; RidsOcfoMailCenter Resource; | |||
RidsRgn2MailCenter Resource; RidsRgn3MailCenter Resource; NRREnforcement.Resource | |||
RidsNrrDirsEnforcement Resource RidsOpaMail Resource; (if public) | |||
Marc.Dapas@nrc.gov; Karla.Fuller@nrc.gov; Roy.Zimmerman@nrc.gov; | |||
Steven.Reynolds@nrc.gov; Bill.Maier@nrc.gov; Nick.Hilton@nrc.gov; | |||
Jeff.Clark@nrc.gov ; Kriss.Kennedy@nrc.gov; John.Wray@nrc.gov | |||
R:\_REACTORS\_WC\2013\WC2013502 Choice Ltr PJE.docx | Vivian.Campbell@nrc.gov; Troy.Pruett@nrc.gov; David.Furst@nrc.gov; | ||
ADAMS ACCESSION NUMBER: | Christi.Maier@nrc.gov; Rachel.Browder@nrc.gov; Gerald.Gulla@nrc.gov; | ||
ADAMS: | Marisa.Herrera@nrc.gov; Victor.Dricks@nrc.gov; Kerstun.Day@nrc.gov; | ||
Lara.Uselding@nrc.gov; Lauren.Casey@nrc.gov; | |||
R4Enforcement DRP BC(s) Robert.Carpenter@nrc.gov; | |||
DRS BC(s) Add AAs Robert.Fretz@nrc.gov; | |||
Sr. Resident Inspector Resident Inspector Carleen.Sanders@nrc.gov; | |||
Regional Inspector(s) State Contact(s) OGC Attorney | |||
RIV ETA (Joseph.Nick@nrc.gov) | |||
R:\_REACTORS\_WC\2013\WC2013502 Choice Ltr PJE.docx | |||
ADAMS ACCESSION NUMBER: ML14092A618 | |||
ADAMS: No Yes SUNSI Review Complete Reviewer Initials: PJE | |||
SUNSI Review Complete: Yes Publicly Available Non-Sensitive | |||
Non-publicly Available Sensitive | |||
SEPI:PSB1 EPI:PSB1 C:PSB1 RI:WC/DRP/B C:DRP/B SES:ACES | |||
PElkmann GGuerra MHaire RStroble NOKeefe RBrowder | |||
/RA/ /RA/ /RA/ /RA/ E-mail /RA/ /RA/ | |||
03/12/14 03/12/14 03/14/14 04/02/14 03/27/14 03/31/14 | |||
C:ACES NSIR-BC D/DRP AD/DRS | |||
VCampbell R.Kahler KKennedy JClark | |||
/RA/ /RA/E /RA/ /RA/ | |||
03/31/14 04/01/14 04/01/14 04/02/14 | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION IV | |||
Docket: 05000482 | |||
License: NPF-42 | |||
Report: 05000482/2013502 | |||
Licensee: Wolf Creek Nuclear Operating Corporation | |||
Facility: Wolf Creek Generating Station | |||
Location: 1550 Oxen Lane NE, Burlington, Kansas | |||
Dates: September 3, 2013, through March 4, 2014 | |||
Inspectors: P. Elkmann, Senior Emergency Preparedness Inspector | |||
G. Guerra, CHP, Emergency Preparedness Inspector | |||
R. Stroble, Resident Inspector | |||
N. Okonkwo, Reactor Inspector | |||
Approved By: Mark S. Haire, | |||
Chief, Plant Support Branch 1 | |||
Division of Reactor Safety | |||
-1- Enclosure | |||
SUMMARY | |||
IR 05000482/2013502; 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional | |||
Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05 | |||
The report covered an announced baseline inspection by region-based and resident inspectors. | |||
One apparent violation was identified whose significance has not been determined. The | |||
significance of most findings is indicated by their color (Green, White, Yellow, or Red) using | |||
Inspection Manual Chapter 0609, Significance Determination Process. The cross-cutting | |||
aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross | |||
Cutting Areas. The NRC's program for overseeing the safe operation of commercial nuclear | |||
power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated | |||
December 2006. | |||
A. NRC-Identified Findings and Self-Revealing Findings | |||
monitor | Cornerstone: Emergency Preparedness | ||
* TBD. An apparent violation of 10 CFR 50.54(q)(2) was identified involving the | |||
failure to maintain adequate methods for assessing the actual or potential | |||
consequences of a radiological emergency between September 2012 and | |||
November 2013, in accordance with the requirements of 10 CFR 50.47(b)(9). | |||
During an exercise conducted on November 13, 2012, the licensee identified that | |||
the Electronic Dose Calculation Program did not accurately calculate the | |||
consequences of a radiological release through the main vent stack with the | |||
effluent monitor in accident mode. The inaccurate calculation was corrected on | |||
February 25, 2014. | |||
The inspectors determined the failure to maintain a dose assessment process | |||
capable of providing a technically adequate estimate of offsite dose was a | |||
performance deficiency within the licensees control. This finding is more than | |||
minor because it was associated with the emergency response organization | |||
performance and the Facilities and Equipment cornerstone attributes. This | |||
finding was evaluated using the Emergency Preparedness Significance | |||
Determination Process and was preliminarily determined to be of low to | |||
moderate safety significance (White) because it was a degraded risk significant | |||
planning standard function. The planning standard function was degraded | |||
because between September 13, 2012, and November 8, 2013, some | |||
calculations used to assess the offsite consequences of a radiological release | |||
were inaccurate. This issue has been entered into the licensees corrective | |||
action system as Condition Report 2013-0076247 (Section 1EP5). | |||
-2- | |||
REPORT DETAILS | |||
1. REACTOR SAFETY | |||
Cornerstone: Emergency Preparedness | |||
1EP1 Exercise Evaluation (71114.01) | |||
a. Inspection Scope | |||
The inspectors observed the biennial emergency preparedness exercise conducted, | |||
November 5, 2013, to determine if the exercise acceptably tested major elements of the | |||
emergency plan and provided opportunities to demonstrate key emergency response | |||
organization skills. The scenario simulated the following to demonstrate the licensee | |||
personnels capability to implement their emergency plan: | |||
* An earthquake with a strong aftershock | |||
* An automatic plant trip with control rods that fail to insert | |||
licensee | * A reactor coolant system leak inside containment that increases over time | ||
* Failures of primary and auxiliary feed pumps to the steam generators | |||
* A fire in a charcoal filter that causes the radiological release to be unfiltered | |||
* A failure of the containment purge system that creates a monitored release to the | |||
environment | |||
The inspectors evaluated exercise performance by focusing on the risk significant | |||
activities of event classification, offsite notification, recognition of offsite dose | |||
consequences, and development of protective action recommendations, in the Control | |||
Room Simulator and the following dedicated emergency response facilities: | |||
* Technical Support Center | |||
* Operations Support Center | |||
* Emergency Operations Facility | |||
The inspectors also assessed recognition of, and response to, abnormal and emergency | |||
plant conditions, the transfer of decision making authority and emergency function | |||
responsibilities between facilities, onsite and offsite communications, protection of | |||
emergency workers, emergency repair evaluation and capability, and the overall | |||
implementation of the emergency plan to protect public health and safety and the | |||
environment. The inspectors reviewed the facility emergency plan, the emergency plan | |||
implementing procedures associated with operation of the emergency response | |||
facilities, the procedures for the performance of associated emergency functions, and | |||
other documents as listed in the attachment to this report. | |||
The inspectors compared the observed exercise performance with the requirements in | |||
the facility emergency plan; 10 CFR 50.47(b); 10 CFR Part 50, Appendix E; and with the | |||
guidance in the emergency plan implementing procedures and other federal guidance. | |||
The inspectors attended the post-exercise critiques in each emergency response facility | |||
to evaluate the initial licensee self-assessment of exercise performance. The inspectors | |||
also attended a subsequent formal presentation of critique items to plant management. | |||
The specific documents reviewed during this inspection are listed in the attachment. | |||
-3- | |||
These activities constitute completion of one sample as defined in Inspection | |||
Procedure 71114.01-05. | |||
b. Findings | |||
No findings were identified. | |||
1EP5 Maintenance of Emergency Preparedness (71114.05) | |||
a. Inspection Scope | |||
The inspectors performed an in-office and on-site review of the licensees response to | |||
Condition Report 59832, dated November 13, 2013, which documented a potential | |||
inaccuracy in the Emergency Dose Assessment Program identified during an exercise | |||
conducted November 13, 2012. | |||
b. Findings | |||
Introduction. An apparent violation was identified involving the failure to maintain | |||
adequate methods for assessing the actual or potential consequences of a radiological | |||
emergency as required by 10 CFR 50.54(q)(2) and 10 CFR 50.47(b)(9). Specifically, the | |||
licensees dose assessment model incorrectly calculated the concentration of iodine and | |||
particulate radioactive material released through the main vent stack when the effluent | |||
monitor was in accident mode. This resulted in inaccurate dose assessments between | |||
September 13, 2012, and November 8, 2013. | |||
Description. A deficiency was identified that degraded the licensees ability to accurately | |||
assess the offsite dose consequences of a radiological release. The NRC determined | |||
that, on November 13, 2012, the licensee had identified that its Electronic Dose | |||
Calculation Program (EDCP, radiological assessment software) was potentially | |||
inaccurate, and as of November 5, 2013, had not evaluated or corrected the inaccuracy. | |||
The NRC observed that the licensee dose assessor participating in the November 5, | |||
2013, emergency preparedness exercise was knowledgeable about an inaccuracy in the | |||
Electronic Dose Calculation Program (licensees radiological assessment software). The | |||
inspectors subsequently reviewed Condition Report 00059832, E-Plan Drill, Potential | |||
Incorrect EDCP Dose Assessments, dated November 13, 2012, which documented a | |||
potential inaccuracy in EDCP calculations using the main vent stack radiation monitor | |||
that was identified during an exercise conducted November 13, 2012. | |||
In its normal operating mode, the main vent stack effluent radiation monitor reports | |||
separate release rates for total noble gasses, radioactive Iodine, and radioactive | |||
particulates. In accident mode the iodine and particulate release rates are not | |||
measured because the detectors are manually isolated. The inspectors determined that | |||
Control Room personnel place this monitor in accident mode when the noble gas | |||
channel reaches a value of 3530 microCuries per second (µCi/s) and goes into Alert | |||
Alarm. When the main vent stack radiation monitor is in accident mode, EDCP | |||
compensates by calculating assumed iodine and particulate release rates, using a noble | |||
gas to iodine ratio. A default ratio of 10 is assumed (e.g., the iodine release rate is set to | |||
10 percent of the measured noble gas release rate). Users identified that during the | |||
November 13, 2012, exercise; EDCP did not appear to be applying the expected noble | |||
gas to iodine ratio when the vent stack radiation monitor was in accident mode. On | |||
-4- | |||
November 7, 2013, the licensee confirmed that EDCP was not correctly applying the | |||
EDCP is a licensee-written program, maintained by the | default noble gas to iodine ratio when the monitor was in accident mode, resulting in an | ||
calculations and, if confirmed, to correct the problem. | overestimate of the concentration of iodine and particulates by a factor of 10, and an | ||
November 7, 2013, that the Information Systems Department had not performed any work on Service Request 126710, and that an analyst and due date were not currently assigned. | overestimate of the Thyroid Committed Dose Equivalent. The licensee put interim | ||
compensatory measures in place on November 8, 2013, to ensure that inaccurate | |||
information was not used in the determining protective action recommendations; the | |||
licensee directed that dose assessment be considered as not available when a | |||
radiological release was through the main stack with the effluent radiation monitor in | |||
accident mode. The licensee determined this problem existed in EDCP, Version 4.7, | |||
implemented on September 13, 2012, and in EDCP, Version 4.8, implemented on | |||
October 28, 2013. | |||
EDCP is a licensee-written program, maintained by the licensees Information Systems | |||
Department. The licensee initiated Service Request 126710 to the Information Systems | |||
Department on January 10, 2013, to investigate the apparent inaccuracies in EDCP | |||
calculations and, if confirmed, to correct the problem. The licensee reported on | |||
November 7, 2013, that the Information Systems Department had not performed any | |||
work on Service Request 126710, and that an analyst and due date were not currently | |||
assigned. The licensee corrected the inaccurate calculation in EDCP, Version 4.9, | |||
implemented on February 25, 2014. | |||
The inspectors determined that Chemistry Technicians were trained as Dose Assessors | |||
and Chemists were trained as Radiological Assessment Coordinators. Training for these | |||
individuals was conducted during routinely scheduled chemistry department training | |||
sessions. The licensee informed the chemistry technicians and chemists about the | |||
apparent inaccuracy in EDCP calculations during training cycles 13-Q2, April 15 through | |||
May 21, 2013, and 13-Q3, July 8 through August 15, 2013. | |||
Analysis. The inspectors determined that the failure to maintain a dose assessment | |||
process capable of providing a technically adequate estimate of offsite dose is a | |||
performance deficiency within the licensees control. This finding is more than minor | |||
because it affected the licensees ability to implement adequate measures to protect the | |||
health and safety of the public. The finding also affected the facilities and equipment | |||
and emergency response organizations performance cornerstone attributes. The finding | |||
was associated with a violation of NRC requirements. This finding was evaluated using | |||
IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process, | |||
and was evaluated in accordance with Attachment 2. The finding was preliminarily | |||
determined to be of low to moderate safety significance (White) because it was a failure | |||
to comply with NRC requirements and was a degraded risk significant planning standard | |||
function. The planning standard function was degraded because methods to assess the | |||
offsite consequences of a radiological release via the main vent stack pathway were | |||
inaccurate between September 13, 2012, and November 8, 2013. However, these | |||
errors did not affect other calculations performed by the EDCP. This issue has been | |||
entered into the licensees corrective action system as Condition Report 2013-0076247. | |||
A cross-cutting aspect of evaluation in the problem identification and resolution area was | |||
assigned to this finding because the finding is representative of current performance and | |||
the licensee failed to promptly evaluate whether a problem existed with the Electronic | |||
Dose Calculation Program after an issue was raised following the November 13, 2012, | |||
EP exercise. The licensee failed to verify the existence of a safety-significant problem | |||
and subsequently, failed to resolve the problem within a timeframe appropriate to its | |||
safety significance [P.2]. | |||
-5- | |||
Enforcement. Title 10 of the Code of Federal Regulations (CFR), Part 50.54(q)(2), | |||
requires, in part, that the holder of a nuclear power reactor operating license shall follow | |||
and | and maintain the effectiveness of an emergency plan that meets the planning standards | ||
of 10 CFR 50.47(b). Title 10 CFR Part 50.47(b)(9) requires, in part, that the onsite and | |||
offsite emergency response plans must use adequate methods for assessing and | |||
monitoring actual or potential offsite consequences of a radiological emergency | |||
condition. | |||
Contrary to the above, between September 13, 2012, and November 8, 2013, the | |||
licensee failed to maintain an emergency plan that used adequate methods for | |||
assessing and monitoring the actual or potential offsite consequences of a radiological | |||
emergency condition. Specifically, a calculational error in the licensees Electronic Dose | |||
Calculation Program resulted in inaccurate offsite doses for the main vent stack pathway | |||
when the effluent radiation monitor was in the accident mode: AV 05000482/2013502-01 | |||
(Failure to Maintain Accurate Methods for Dose Assessment). | |||
1EP8 Exercise Evaluation (71114.08) | |||
a. Inspection Scope | |||
The licensee submitted the preliminary scenario for the 2013 biennial emergency | |||
preparedness exercise on September 3, 2013, in accordance with the requirements of | |||
Appendix E to 10 CFR 50, Part IV.F(2)(b). The inspectors performed an in-office review | |||
of the preliminary exercise scenario to determine whether the scenario would acceptably | |||
test the major elements of the licensees emergency plan and provided opportunities to | |||
demonstrate the key emergency response organization skills. | |||
b. Findings | |||
No findings were identified. | |||
4. OTHER ACTIVITIES | |||
4OA1 Performance Indicator Verification (71151) | |||
.13 Drill/Exercise Performance (EP01) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the Drill and Exercise Performance, | |||
performance indicator for the period July 2012 through September 2013. The definitions | |||
and guidance of Nuclear Energy Institute Document 99-02, Regulatory Assessment | |||
Performance Indicator Guideline, Revision 6, were used to determine the accuracy of | |||
the performance indicator data reported to the NRC. The inspectors reviewed the | |||
licensees records associated with the performance indicator to verify that the licensee | |||
accurately reported the indicator in accordance with relevant procedures and the | |||
Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee | |||
records and processes including procedural guidance on assessing opportunities for the | |||
performance indicator; assessments of performance indicator opportunities during | |||
predesignated control room simulator training sessions, performance during the 2013 | |||
biennial exercise, and performance during other drills. The specific documents reviewed | |||
are described in the attachment to this report. | |||
-6- | |||
These activities constitute completion of the drill/exercise performance sample as | |||
defined in Inspection Procedure 71151-05. | |||
to | b. Findings | ||
No findings were identified. | |||
.14 Emergency Response Organization Drill Participation (EP02) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the Emergency Response | |||
Organization Drill Participation performance indicator for the period July 2012 | |||
through September 2013. The definitions and guidance of Nuclear Energy Institute | |||
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6, | |||
were used to determine the accuracy of the performance indicator data reported to the | |||
NRC. The inspectors reviewed the licensees records associated with the performance | |||
indicator to verify that the licensee accurately reported the indicator in accordance with | |||
relevant procedures and the Nuclear Energy Institute guidance. Specifically, the | |||
inspectors reviewed licensee records and processes including procedural guidance on | |||
assessing opportunities for the performance indicator, rosters of personnel assigned to | |||
key emergency response organization positions, and exercise participation records. The | |||
specific documents reviewed are described in the attachment to this report. | |||
These activities constitute completion of the emergency response organization drill | |||
participation sample as defined in Inspection Procedure 71151-05. | |||
b. Findings | |||
No findings were identified. | |||
.15 Alert and Notification System (EP03) | |||
a. Inspection Scope | |||
The inspectors sampled licensee submittals for the Alert and Notification System | |||
performance indicator for the period July 2012 through September 2013. The definitions | |||
and guidance of Nuclear Energy Institute Document 99-02, Regulatory Assessment | |||
Performance Indicator Guideline, Revision 6, were used to determine the accuracy of | |||
the performance indicator data reported to the NRC. The inspectors reviewed the | |||
licensees records associated with the performance indicator to verify that the licensee | |||
accurately reported the indicator in accordance with relevant procedures and the | |||
Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee | |||
records and processes including procedural guidance on assessing opportunities for the | |||
performance indicator and the results of periodic alert notification system operability | |||
tests. The specific documents reviewed are described in the attachment to this report. | |||
These activities constitute completion of the alert and notification system sample as | |||
defined in Inspection Procedure 71151-05. | |||
-7- | |||
b. Findings | |||
No findings were identified. | |||
4OA6 Meetings | |||
Exit Meeting Summary | |||
On September 30, 2013, the inspectors discussed the preliminary scenario for the 2013 biennial | |||
exercise with Mr. T. East, Superintendent of Emergency Planning, and other members of the | |||
licensees staff. The licensee acknowledged the issues presented. | |||
On November 8, 2013, the inspectors presented the results of the onsite inspection of the | |||
of | licensees biennial emergency preparedness exercise to Mr. M. Sunseri, President and Chief | ||
Executive Officer, and other members of the licensees staff. The licensee acknowledged the | |||
issues presented. The inspector asked the licensee whether any materials examined during the | |||
inspection should be considered proprietary. No proprietary information was identified. | |||
On March 4, 2014, the inspectors discussed an apparent violation identified as a result of the | |||
November 5, 2013, biennial exercise with Mr. A. Heflin, President and Chief Executive Officer, | |||
and other members of the licensees staff. The licensee acknowledged the issues presented. | |||
-8- | |||
SUPPLEMENTAL INFORMATION | |||
KEY POINTS OF CONTACT | |||
Licensee Personnel | |||
P. Bedgood, Manager, Radiation Protection | |||
J. Broschak, Vice President, Engineering | |||
A. Broyles, Manager, Information Systems | |||
A. Camp, Plant Manager | |||
R. Clemens, Vice President, Strategic Projects | |||
D. Dees, Superintendent, Operations Support | |||
T. East, Superintendent, Emergency Preparedness | |||
D. Erbe, Manager, Security | |||
R. Flannigan, Manager, Nuclear Engineering | |||
A. Heflin, President and Chief Executive Officer | |||
S. Henry, Manager, Operations | |||
R. Hobby, Licensing Engineer | |||
W. Muilenburg, Supervisor, Licensing | |||
L. Ratzlaff, Manager, Maintenance | |||
E. Ray, Manager, Training | |||
R. Rumas, Manager, Quality | |||
R. Smith, Site Vice President | |||
M. Sunseri, President and Chief Executive Officer | |||
M. Westman, Manager, Regulatory Affairs | |||
J. Yunk, Manager, Corrective Actions | |||
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED | |||
Opened | |||
05000482/2013502-01 AV Failure to Maintain Accurate Methods for Dose Assessment | |||
LIST OF DOCUMENTS REVIEWED | |||
Section 1EP1: Exercise Evaluation | |||
Number Title Revision/Date | |||
APF 06-002-01 Emergency Action Levels 17 | |||
AP 17C-028 Emergency Response Duties and Responsibilities 13 | |||
EP 06-001 Control Room Operations 19 | |||
EP 06-002 Technical Support Center Operations 34A | |||
EP 06-003 Emergency Operations Facility Operations 20A | |||
-1- Attachment | |||
P. Bedgood, Manager, Radiation Protection | |||
J. Broschak, Vice President, Engineering A. Broyles, Manager, Information Systems A. Camp, Plant Manager | |||
R. Clemens, Vice President, Strategic Projects | |||
D. Dees, Superintendent, Operations Support | |||
T. East, Superintendent, Emergency Preparedness D. Erbe, Manager, Security R. Flannigan, Manager, Nuclear Engineering | |||
A. Heflin, President and Chief Executive Officer | |||
S. Henry, Manager, Operations | |||
R. Hobby, Licensing Engineer W. Muilenburg, Supervisor, Licensing L. Ratzlaff, Manager, Maintenance | |||
E. Ray, Manager, Training | |||
R. Rumas, Manager, Quality | |||
R. Smith, Site Vice President | |||
M. Sunseri, President and Chief Executive Officer M. Westman, Manager, Regulatory Affairs J. Yunk, Manager, Corrective Actions | |||
Section 1EP1: Exercise Evaluation | |||
Number Title Revision/Date | |||
EP 06-005 Emergency Classification 7 | |||
EP 06-006 Protective Action Recommendations 9 | |||
EP 06-007 Emergency Notifications 20A | |||
EP 06-009 Drill and Exercise Requirements 8 | |||
EP 06-011 Emergency Team Formation and Control 8 | |||
EP 06-012 Dose Assessment, Oct-28-2013 13 | |||
EP 06-012 Dose Assessment, Sep-13-2012 12B | |||
EP 06-015 Emergency Response Organization Callout 12B | |||
Follow-up Assessment and Report, January 13, 2012, Event | |||
Follow-up Assessment and Report, March 4, 2013, Event January 26, | |||
2012 | |||
Follow-up Assessment and Report, March 16, 2013, Event March 5, 2013 | |||
Follow-up Assessment and Report, April 13, 2013, Event March 16, 2013 | |||
2009 Biennial Exercise Scenario Timeline April 23, 2013 | |||
11-EVAL-EX Exercise Scenario Timeline | |||
13-PRE-01 Exercise Scenario Timeline | |||
13-PRE-02 Exercise Scenario Timeline | |||
Evaluation Report for the August 9, 2012, Exercise | |||
Evaluation Report for the October 23, 2012, Exercise | |||
Evaluation Report for the November 6, 2012, Exercise | |||
Evaluation Report for the November 13, 2012, Exercise | |||
Evaluation Report for the July 8, 2013, Exercise | |||
Evaluation Report for the July 10, 2013, Exercise | |||
Evaluation Report for the August 20, 2013, Exercise | |||
Evaluation Report for the August 22, 2013, Exercise | |||
Evaluation Report for the October 9, 2013, Exercise | |||
Section 1EP5: Maintenance of Emergency Preparedness | |||
Number Title Revision/Date | |||
CE 22 356 10 Workbook: Offsite Dose Projection using EDCP Workbook, 1 | |||
June 26, 2012 | |||
CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, 11 | |||
June 26, 2012 | |||
GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for 2 | |||
Chemistry Technicians, April 2, 2013 | |||
Email, Ken Thrall, to Shift Managers, Technical Support November 7, | |||
Center Site Emergency Managers, and Emergency 2013 | |||
-2- | |||
Section 1EP5: Maintenance of Emergency Preparedness | |||
Number Title Revision/Date | |||
Operations Facility Offsite Emergency Managers | |||
Unit Vent, Table of Ranges and Alarm Set Points November 7, | |||
2013 | |||
Service Request EDCP issues documented in CR 59826 and CR 59832 January 8, | |||
126710 2013 | |||
Weekly Schedule, Chemistry Continuing Training | |||
Cycle 13-Q2, April 15 to May 21, 2013 | |||
Weekly Schedule, Chemistry Continuing Training | |||
Cycle 13-Q3, July 8 to August 15, 2013 | |||
Condition Reports (Corrective Action System) | |||
48268 49240 50872 51428 54279 55060 55066 | |||
55071 59554 59832 67808 68404 70209 70212 | |||
70220 70229 70876 70899 71332 71347 72965 | |||
73101 73735 74632 | |||
Miscellaneous | |||
Section 4OA1: Performance Indicator Verification | |||
Number Title Revision | |||
EP 06-019 Alert and Notification System Sirens 7 | |||
EP 06-022 Tone Alert Radio Maintenance/Compensatory Actions 5 | |||
AI 26A-004 Emergency Planning Performance Indicators 6 | |||
AP 34-003 Performance Indicator Program 0A | |||
Miscellaneous Documents | |||
Number Title Revision | |||
AP 06-002 Wolf Creek Station Radiological Emergency Response 15 | |||
Plan | |||
-3- | |||
70220 70229 70876 70899 71332 71347 72965 | |||
73101 73735 74632 | |||
Plan | |||
}} | }} |
Latest revision as of 07:05, 4 November 2019
ML14092A618 | |
Person / Time | |
---|---|
Site: | Wolf Creek ![]() |
Issue date: | 04/02/2014 |
From: | Clark J Division of Reactor Safety IV |
To: | Heflin A Wolf Creek |
References | |
71114.01, 71114.05, EA-14-024 IR-13-502 | |
Download: ML14092A618 (15) | |
See also: IR 05000482/2013502
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION IV
1600 E. LAMAR BLVD.
ARLINGTON, TX 76011-4511
April 2, 2014
Adam Heflin, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION - NRC BASELINE INSPECTION
REPORT 05000482/2013502, PRELIMINARY WHITE FINDING
Dear Mr. Heflin:
This letter refers to the in-office and onsite inspections conducted September 3, 2013, through
March 4, 2014, for the Wolf Creek Generating Station. The inspection was a baseline
evaluation of your emergency preparedness program through observation of emergency
response organization performance during the November 5, 2013, biennial exercise. The
enclosed report presents the results of this inspection. The inspectors discussed the
preliminary inspection findings with you and your staff at the conclusion of the on-site portion of
the inspection. Additional telephone discussions occurred on September 30, 2013, and
January 27, February 10, and February 20, 2014. A final exit briefing was conducted with you
and your staff on March 4, 2014.
This inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions in your license.
Within these areas, the inspection consisted of an examination of selected procedures and
representative records, observations of emergency preparedness activities, and interviews with
personnel.
This inspection identified a finding that has preliminarily been determined to be a White finding
with low to moderate safety significance that may require additional NRC inspection. The
finding is associated with a failure to maintain adequate methods for assessing the potential
consequences of a radiological emergency condition in accordance with the requirements
of 10 CFR 50.47(b)(9). This deficiency was corrected on February 25, 2014. This finding is
also an apparent violation of NRC requirements and is being considered for escalated
enforcement action in accordance with the Enforcement Policy, which can be found on the
NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce-pol.html.
The preliminary low to moderate safety significance (White) finding was assessed based on the
best available information, using the Emergency Preparedness Significance Determination
Process (SDP) and the NRC Enforcement Policy. The basis for the NRCs preliminary
significance determination is described in the enclosed report. The final resolution of this finding
will be conveyed in separate correspondence.
A. Heflin -2-
In accordance with NRC Inspection Manual Chapter (IMC) 0609, we intend to complete our
evaluation of the White finding using the best available information, and issue our final
determination of safety significance within 90 days of the date of this letter. The significance
determination process encourages an open dialogue between the NRC staff and the licensee;
however, the dialogue should not impact the timeliness of the staffs final determination. Before
we make a final decision on this matter, we are providing you with an opportunity to attend a
Regulatory Conference where you can present to the NRC your perspective on the facts and
assumptions the NRC used to arrive at the finding and assess its significance, or submit your
position on the finding to the NRC in writing.
If you request a Regulatory Conference, it should be held within 30 days of the receipt of this
letter and we encourage you to submit supporting documentation at least one week prior to the
Conference in an effort to make the Conference more efficient and effective. The focus of the
Regulatory Conference is to discuss the significance of the finding and not necessarily what the
root cause is or corrective action(s) associated with the finding. If a Conference is held, it will be
open for public observation and a public meeting notice and press release will be issued to
announce the conference. If you decide to submit only a written response, such submittal
should be sent to the NRC within 30 days of your receipt of this letter. If you decline to request
a Conference or to submit a written response, you relinquish your right to appeal the final SDP
determination, in that by not doing either, you fail to meet the appeal requirements stated in the
Prerequisite and Limitation Sections of Attachment 2 of IMC 0609.
Please contact Mr. Mark Haire, Chief, Plant Support Branch 1, at 817-200-1527, within 10 days
from the issue date of this letter to notify the NRC of your intentions. If we have not heard from
you within 10 days, we will continue with our significance determination and enforcement
decision. Since the NRC has not made a final determination in these matters, no Notice of
Violation is being issued for these inspection findings at this time. In addition, please be
advised that the number and characterization of the apparent violation may change as a result
of further NRC review.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice and Procedure," a copy of
this letter, its enclosures, and your response, if you choose to provide one, will be made
available electronically for public inspection in the NRC Public Document Room or from the
NRCs Agencywide Documents Access and Management System (ADAMS), accessible from
the NRC Web site at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your
response should not include any personal privacy or proprietary information so that it can be
made available to the Public without redaction.
A. Heflin -3-
If you have any questions concerning this matter, please contact Mr. Mark Haire, Branch Chief,
Plant Support Branch 1, at 817-200-1527, or Mr. Paul Elkmann, Senior Inspector, Plant Support
Branch 1, at 817-200-1539.
Sincerely,
/RA/
Jeffrey A. Clark, Acting Director
Division of Reactor Safety
Docket No. 50-482
License No. NPF-42
Enclosure:
Inspection Report 05000482/2013502
w/Attachment: Supplemental Information
Electronic Distribution for Wolf Creek Generating Station
A. Heflin -4-
Distribution
ADAMS (PARS) RidsOeMailCenter Resource; OEWEB Resource; (if public)
RidsSecyMailCenter Resource; RidsOcaMailCenter Resource; RidsOgcMailCenter Resource;
RidsEdoMailCenter Resource; EDO_Managers RidsOigMailCenter Resource;
RidsOiMailCenter Resource; RidsRgn1MailCenter Resource; RidsOcfoMailCenter Resource;
RidsRgn2MailCenter Resource; RidsRgn3MailCenter Resource; NRREnforcement.Resource
RidsNrrDirsEnforcement Resource RidsOpaMail Resource; (if public)
Marc.Dapas@nrc.gov; Karla.Fuller@nrc.gov; Roy.Zimmerman@nrc.gov;
Steven.Reynolds@nrc.gov; Bill.Maier@nrc.gov; Nick.Hilton@nrc.gov;
Jeff.Clark@nrc.gov ; Kriss.Kennedy@nrc.gov; John.Wray@nrc.gov
Vivian.Campbell@nrc.gov; Troy.Pruett@nrc.gov; David.Furst@nrc.gov;
Christi.Maier@nrc.gov; Rachel.Browder@nrc.gov; Gerald.Gulla@nrc.gov;
Marisa.Herrera@nrc.gov; Victor.Dricks@nrc.gov; Kerstun.Day@nrc.gov;
Lara.Uselding@nrc.gov; Lauren.Casey@nrc.gov;
R4Enforcement DRP BC(s) Robert.Carpenter@nrc.gov;
DRS BC(s) Add AAs Robert.Fretz@nrc.gov;
Sr. Resident Inspector Resident Inspector Carleen.Sanders@nrc.gov;
Regional Inspector(s) State Contact(s) OGC Attorney
RIV ETA (Joseph.Nick@nrc.gov)
R:\_REACTORS\_WC\2013\WC2013502 Choice Ltr PJE.docx
ADAMS ACCESSION NUMBER: ML14092A618
ADAMS: No Yes SUNSI Review Complete Reviewer Initials: PJE
SUNSI Review Complete: Yes Publicly Available Non-Sensitive
Non-publicly Available Sensitive
SEPI:PSB1 EPI:PSB1 C:PSB1 RI:WC/DRP/B C:DRP/B SES:ACES
PElkmann GGuerra MHaire RStroble NOKeefe RBrowder
/RA/ /RA/ /RA/ /RA/ E-mail /RA/ /RA/
03/12/14 03/12/14 03/14/14 04/02/14 03/27/14 03/31/14
C:ACES NSIR-BC D/DRP AD/DRS
VCampbell R.Kahler KKennedy JClark
/RA/ /RA/E /RA/ /RA/
03/31/14 04/01/14 04/01/14 04/02/14
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket: 05000482
License: NPF-42
Report: 05000482/2013502
Licensee: Wolf Creek Nuclear Operating Corporation
Facility: Wolf Creek Generating Station
Location: 1550 Oxen Lane NE, Burlington, Kansas
Dates: September 3, 2013, through March 4, 2014
Inspectors: P. Elkmann, Senior Emergency Preparedness Inspector
G. Guerra, CHP, Emergency Preparedness Inspector
R. Stroble, Resident Inspector
N. Okonkwo, Reactor Inspector
Approved By: Mark S. Haire,
Chief, Plant Support Branch 1
Division of Reactor Safety
-1- Enclosure
SUMMARY
IR 05000482/2013502; 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional
Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05
The report covered an announced baseline inspection by region-based and resident inspectors.
One apparent violation was identified whose significance has not been determined. The
significance of most findings is indicated by their color (Green, White, Yellow, or Red) using
Inspection Manual Chapter 0609, Significance Determination Process. The cross-cutting
aspect is determined using Inspection Manual Chapter 0310, Components Within the Cross
Cutting Areas. The NRC's program for overseeing the safe operation of commercial nuclear
power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated
December 2006.
A. NRC-Identified Findings and Self-Revealing Findings
Cornerstone: Emergency Preparedness
- TBD. An apparent violation of 10 CFR 50.54(q)(2) was identified involving the
failure to maintain adequate methods for assessing the actual or potential
consequences of a radiological emergency between September 2012 and
November 2013, in accordance with the requirements of 10 CFR 50.47(b)(9).
During an exercise conducted on November 13, 2012, the licensee identified that
the Electronic Dose Calculation Program did not accurately calculate the
consequences of a radiological release through the main vent stack with the
effluent monitor in accident mode. The inaccurate calculation was corrected on
February 25, 2014.
The inspectors determined the failure to maintain a dose assessment process
capable of providing a technically adequate estimate of offsite dose was a
performance deficiency within the licensees control. This finding is more than
minor because it was associated with the emergency response organization
performance and the Facilities and Equipment cornerstone attributes. This
finding was evaluated using the Emergency Preparedness Significance
Determination Process and was preliminarily determined to be of low to
moderate safety significance (White) because it was a degraded risk significant
planning standard function. The planning standard function was degraded
because between September 13, 2012, and November 8, 2013, some
calculations used to assess the offsite consequences of a radiological release
were inaccurate. This issue has been entered into the licensees corrective
action system as Condition Report 2013-0076247 (Section 1EP5).
-2-
REPORT DETAILS
1. REACTOR SAFETY
Cornerstone: Emergency Preparedness
1EP1 Exercise Evaluation (71114.01)
a. Inspection Scope
The inspectors observed the biennial emergency preparedness exercise conducted,
November 5, 2013, to determine if the exercise acceptably tested major elements of the
emergency plan and provided opportunities to demonstrate key emergency response
organization skills. The scenario simulated the following to demonstrate the licensee
personnels capability to implement their emergency plan:
- An earthquake with a strong aftershock
- An automatic plant trip with control rods that fail to insert
- A reactor coolant system leak inside containment that increases over time
- Failures of primary and auxiliary feed pumps to the steam generators
- A fire in a charcoal filter that causes the radiological release to be unfiltered
- A failure of the containment purge system that creates a monitored release to the
environment
The inspectors evaluated exercise performance by focusing on the risk significant
activities of event classification, offsite notification, recognition of offsite dose
consequences, and development of protective action recommendations, in the Control
Room Simulator and the following dedicated emergency response facilities:
- Operations Support Center
- Emergency Operations Facility
The inspectors also assessed recognition of, and response to, abnormal and emergency
plant conditions, the transfer of decision making authority and emergency function
responsibilities between facilities, onsite and offsite communications, protection of
emergency workers, emergency repair evaluation and capability, and the overall
implementation of the emergency plan to protect public health and safety and the
environment. The inspectors reviewed the facility emergency plan, the emergency plan
implementing procedures associated with operation of the emergency response
facilities, the procedures for the performance of associated emergency functions, and
other documents as listed in the attachment to this report.
The inspectors compared the observed exercise performance with the requirements in
the facility emergency plan; 10 CFR 50.47(b); 10 CFR Part 50, Appendix E; and with the
guidance in the emergency plan implementing procedures and other federal guidance.
The inspectors attended the post-exercise critiques in each emergency response facility
to evaluate the initial licensee self-assessment of exercise performance. The inspectors
also attended a subsequent formal presentation of critique items to plant management.
The specific documents reviewed during this inspection are listed in the attachment.
-3-
These activities constitute completion of one sample as defined in Inspection
Procedure 71114.01-05.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness (71114.05)
a. Inspection Scope
The inspectors performed an in-office and on-site review of the licensees response to
Condition Report 59832, dated November 13, 2013, which documented a potential
inaccuracy in the Emergency Dose Assessment Program identified during an exercise
conducted November 13, 2012.
b. Findings
Introduction. An apparent violation was identified involving the failure to maintain
adequate methods for assessing the actual or potential consequences of a radiological
emergency as required by 10 CFR 50.54(q)(2) and 10 CFR 50.47(b)(9). Specifically, the
licensees dose assessment model incorrectly calculated the concentration of iodine and
particulate radioactive material released through the main vent stack when the effluent
monitor was in accident mode. This resulted in inaccurate dose assessments between
September 13, 2012, and November 8, 2013.
Description. A deficiency was identified that degraded the licensees ability to accurately
assess the offsite dose consequences of a radiological release. The NRC determined
that, on November 13, 2012, the licensee had identified that its Electronic Dose
Calculation Program (EDCP, radiological assessment software) was potentially
inaccurate, and as of November 5, 2013, had not evaluated or corrected the inaccuracy.
The NRC observed that the licensee dose assessor participating in the November 5,
2013, emergency preparedness exercise was knowledgeable about an inaccuracy in the
Electronic Dose Calculation Program (licensees radiological assessment software). The
inspectors subsequently reviewed Condition Report 00059832, E-Plan Drill, Potential
Incorrect EDCP Dose Assessments, dated November 13, 2012, which documented a
potential inaccuracy in EDCP calculations using the main vent stack radiation monitor
that was identified during an exercise conducted November 13, 2012.
In its normal operating mode, the main vent stack effluent radiation monitor reports
separate release rates for total noble gasses, radioactive Iodine, and radioactive
particulates. In accident mode the iodine and particulate release rates are not
measured because the detectors are manually isolated. The inspectors determined that
Control Room personnel place this monitor in accident mode when the noble gas
channel reaches a value of 3530 microCuries per second (µCi/s) and goes into Alert
Alarm. When the main vent stack radiation monitor is in accident mode, EDCP
compensates by calculating assumed iodine and particulate release rates, using a noble
gas to iodine ratio. A default ratio of 10 is assumed (e.g., the iodine release rate is set to
10 percent of the measured noble gas release rate). Users identified that during the
November 13, 2012, exercise; EDCP did not appear to be applying the expected noble
gas to iodine ratio when the vent stack radiation monitor was in accident mode. On
-4-
November 7, 2013, the licensee confirmed that EDCP was not correctly applying the
default noble gas to iodine ratio when the monitor was in accident mode, resulting in an
overestimate of the concentration of iodine and particulates by a factor of 10, and an
overestimate of the Thyroid Committed Dose Equivalent. The licensee put interim
compensatory measures in place on November 8, 2013, to ensure that inaccurate
information was not used in the determining protective action recommendations; the
licensee directed that dose assessment be considered as not available when a
radiological release was through the main stack with the effluent radiation monitor in
accident mode. The licensee determined this problem existed in EDCP, Version 4.7,
implemented on September 13, 2012, and in EDCP, Version 4.8, implemented on
October 28, 2013.
EDCP is a licensee-written program, maintained by the licensees Information Systems
Department. The licensee initiated Service Request 126710 to the Information Systems
Department on January 10, 2013, to investigate the apparent inaccuracies in EDCP
calculations and, if confirmed, to correct the problem. The licensee reported on
November 7, 2013, that the Information Systems Department had not performed any
work on Service Request 126710, and that an analyst and due date were not currently
assigned. The licensee corrected the inaccurate calculation in EDCP, Version 4.9,
implemented on February 25, 2014.
The inspectors determined that Chemistry Technicians were trained as Dose Assessors
and Chemists were trained as Radiological Assessment Coordinators. Training for these
individuals was conducted during routinely scheduled chemistry department training
sessions. The licensee informed the chemistry technicians and chemists about the
apparent inaccuracy in EDCP calculations during training cycles 13-Q2, April 15 through
May 21, 2013, and 13-Q3, July 8 through August 15, 2013.
Analysis. The inspectors determined that the failure to maintain a dose assessment
process capable of providing a technically adequate estimate of offsite dose is a
performance deficiency within the licensees control. This finding is more than minor
because it affected the licensees ability to implement adequate measures to protect the
health and safety of the public. The finding also affected the facilities and equipment
and emergency response organizations performance cornerstone attributes. The finding
was associated with a violation of NRC requirements. This finding was evaluated using
IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process,
and was evaluated in accordance with Attachment 2. The finding was preliminarily
determined to be of low to moderate safety significance (White) because it was a failure
to comply with NRC requirements and was a degraded risk significant planning standard
function. The planning standard function was degraded because methods to assess the
offsite consequences of a radiological release via the main vent stack pathway were
inaccurate between September 13, 2012, and November 8, 2013. However, these
errors did not affect other calculations performed by the EDCP. This issue has been
entered into the licensees corrective action system as Condition Report 2013-0076247.
A cross-cutting aspect of evaluation in the problem identification and resolution area was
assigned to this finding because the finding is representative of current performance and
the licensee failed to promptly evaluate whether a problem existed with the Electronic
Dose Calculation Program after an issue was raised following the November 13, 2012,
EP exercise. The licensee failed to verify the existence of a safety-significant problem
and subsequently, failed to resolve the problem within a timeframe appropriate to its
safety significance [P.2].
-5-
Enforcement. Title 10 of the Code of Federal Regulations (CFR), Part 50.54(q)(2),
requires, in part, that the holder of a nuclear power reactor operating license shall follow
and maintain the effectiveness of an emergency plan that meets the planning standards
of 10 CFR 50.47(b). Title 10 CFR Part 50.47(b)(9) requires, in part, that the onsite and
offsite emergency response plans must use adequate methods for assessing and
monitoring actual or potential offsite consequences of a radiological emergency
condition.
Contrary to the above, between September 13, 2012, and November 8, 2013, the
licensee failed to maintain an emergency plan that used adequate methods for
assessing and monitoring the actual or potential offsite consequences of a radiological
emergency condition. Specifically, a calculational error in the licensees Electronic Dose
Calculation Program resulted in inaccurate offsite doses for the main vent stack pathway
when the effluent radiation monitor was in the accident mode: AV 05000482/2013502-01
(Failure to Maintain Accurate Methods for Dose Assessment).
1EP8 Exercise Evaluation (71114.08)
a. Inspection Scope
The licensee submitted the preliminary scenario for the 2013 biennial emergency
preparedness exercise on September 3, 2013, in accordance with the requirements of
Appendix E to 10 CFR 50, Part IV.F(2)(b). The inspectors performed an in-office review
of the preliminary exercise scenario to determine whether the scenario would acceptably
test the major elements of the licensees emergency plan and provided opportunities to
demonstrate the key emergency response organization skills.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151)
.13 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspectors sampled licensee submittals for the Drill and Exercise Performance,
performance indicator for the period July 2012 through September 2013. The definitions
and guidance of Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 6, were used to determine the accuracy of
the performance indicator data reported to the NRC. The inspectors reviewed the
licensees records associated with the performance indicator to verify that the licensee
accurately reported the indicator in accordance with relevant procedures and the
Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee
records and processes including procedural guidance on assessing opportunities for the
performance indicator; assessments of performance indicator opportunities during
predesignated control room simulator training sessions, performance during the 2013
biennial exercise, and performance during other drills. The specific documents reviewed
are described in the attachment to this report.
-6-
These activities constitute completion of the drill/exercise performance sample as
defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.14 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspectors sampled licensee submittals for the Emergency Response
Organization Drill Participation performance indicator for the period July 2012
through September 2013. The definitions and guidance of Nuclear Energy Institute
Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6,
were used to determine the accuracy of the performance indicator data reported to the
NRC. The inspectors reviewed the licensees records associated with the performance
indicator to verify that the licensee accurately reported the indicator in accordance with
relevant procedures and the Nuclear Energy Institute guidance. Specifically, the
inspectors reviewed licensee records and processes including procedural guidance on
assessing opportunities for the performance indicator, rosters of personnel assigned to
key emergency response organization positions, and exercise participation records. The
specific documents reviewed are described in the attachment to this report.
These activities constitute completion of the emergency response organization drill
participation sample as defined in Inspection Procedure 71151-05.
b. Findings
No findings were identified.
.15 Alert and Notification System (EP03)
a. Inspection Scope
The inspectors sampled licensee submittals for the Alert and Notification System
performance indicator for the period July 2012 through September 2013. The definitions
and guidance of Nuclear Energy Institute Document 99-02, Regulatory Assessment
Performance Indicator Guideline, Revision 6, were used to determine the accuracy of
the performance indicator data reported to the NRC. The inspectors reviewed the
licensees records associated with the performance indicator to verify that the licensee
accurately reported the indicator in accordance with relevant procedures and the
Nuclear Energy Institute guidance. Specifically, the inspectors reviewed licensee
records and processes including procedural guidance on assessing opportunities for the
performance indicator and the results of periodic alert notification system operability
tests. The specific documents reviewed are described in the attachment to this report.
These activities constitute completion of the alert and notification system sample as
defined in Inspection Procedure 71151-05.
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b. Findings
No findings were identified.
4OA6 Meetings
Exit Meeting Summary
On September 30, 2013, the inspectors discussed the preliminary scenario for the 2013 biennial
exercise with Mr. T. East, Superintendent of Emergency Planning, and other members of the
licensees staff. The licensee acknowledged the issues presented.
On November 8, 2013, the inspectors presented the results of the onsite inspection of the
licensees biennial emergency preparedness exercise to Mr. M. Sunseri, President and Chief
Executive Officer, and other members of the licensees staff. The licensee acknowledged the
issues presented. The inspector asked the licensee whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
On March 4, 2014, the inspectors discussed an apparent violation identified as a result of the
November 5, 2013, biennial exercise with Mr. A. Heflin, President and Chief Executive Officer,
and other members of the licensees staff. The licensee acknowledged the issues presented.
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SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
P. Bedgood, Manager, Radiation Protection
J. Broschak, Vice President, Engineering
A. Broyles, Manager, Information Systems
A. Camp, Plant Manager
R. Clemens, Vice President, Strategic Projects
D. Dees, Superintendent, Operations Support
T. East, Superintendent, Emergency Preparedness
D. Erbe, Manager, Security
R. Flannigan, Manager, Nuclear Engineering
A. Heflin, President and Chief Executive Officer
S. Henry, Manager, Operations
R. Hobby, Licensing Engineer
W. Muilenburg, Supervisor, Licensing
L. Ratzlaff, Manager, Maintenance
E. Ray, Manager, Training
R. Rumas, Manager, Quality
R. Smith, Site Vice President
M. Sunseri, President and Chief Executive Officer
M. Westman, Manager, Regulatory Affairs
J. Yunk, Manager, Corrective Actions
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000482/2013502-01 AV Failure to Maintain Accurate Methods for Dose Assessment
LIST OF DOCUMENTS REVIEWED
Section 1EP1: Exercise Evaluation
Number Title Revision/Date
APF 06-002-01 Emergency Action Levels 17
AP 17C-028 Emergency Response Duties and Responsibilities 13
EP 06-001 Control Room Operations 19
EP 06-002 Technical Support Center Operations 34A
EP 06-003 Emergency Operations Facility Operations 20A
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Section 1EP1: Exercise Evaluation
Number Title Revision/Date
EP 06-005 Emergency Classification 7
EP 06-006 Protective Action Recommendations 9
EP 06-007 Emergency Notifications 20A
EP 06-009 Drill and Exercise Requirements 8
EP 06-011 Emergency Team Formation and Control 8
EP 06-012 Dose Assessment, Oct-28-2013 13
EP 06-012 Dose Assessment, Sep-13-2012 12B
EP 06-015 Emergency Response Organization Callout 12B
Follow-up Assessment and Report, January 13, 2012, Event
Follow-up Assessment and Report, March 4, 2013, Event January 26,
2012
Follow-up Assessment and Report, March 16, 2013, Event March 5, 2013
Follow-up Assessment and Report, April 13, 2013, Event March 16, 2013
2009 Biennial Exercise Scenario Timeline April 23, 2013
11-EVAL-EX Exercise Scenario Timeline
13-PRE-01 Exercise Scenario Timeline
13-PRE-02 Exercise Scenario Timeline
Evaluation Report for the August 9, 2012, Exercise
Evaluation Report for the October 23, 2012, Exercise
Evaluation Report for the November 6, 2012, Exercise
Evaluation Report for the November 13, 2012, Exercise
Evaluation Report for the July 8, 2013, Exercise
Evaluation Report for the July 10, 2013, Exercise
Evaluation Report for the August 20, 2013, Exercise
Evaluation Report for the August 22, 2013, Exercise
Evaluation Report for the October 9, 2013, Exercise
Section 1EP5: Maintenance of Emergency Preparedness
Number Title Revision/Date
CE 22 356 10 Workbook: Offsite Dose Projection using EDCP Workbook, 1
June 26, 2012
CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, 11
June 26, 2012
GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for 2
Chemistry Technicians, April 2, 2013
Email, Ken Thrall, to Shift Managers, Technical Support November 7,
Center Site Emergency Managers, and Emergency 2013
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Section 1EP5: Maintenance of Emergency Preparedness
Number Title Revision/Date
Operations Facility Offsite Emergency Managers
Unit Vent, Table of Ranges and Alarm Set Points November 7,
2013
Service Request EDCP issues documented in CR 59826 and CR 59832 January 8,
126710 2013
Weekly Schedule, Chemistry Continuing Training
Cycle 13-Q2, April 15 to May 21, 2013
Weekly Schedule, Chemistry Continuing Training
Cycle 13-Q3, July 8 to August 15, 2013
Condition Reports (Corrective Action System)
48268 49240 50872 51428 54279 55060 55066
55071 59554 59832 67808 68404 70209 70212
70220 70229 70876 70899 71332 71347 72965
73101 73735 74632
Miscellaneous
Section 4OA1: Performance Indicator Verification
Number Title Revision
EP 06-019 Alert and Notification System Sirens 7
EP 06-022 Tone Alert Radio Maintenance/Compensatory Actions 5
AI 26A-004 Emergency Planning Performance Indicators 6
AP 34-003 Performance Indicator Program 0A
Miscellaneous Documents
Number Title Revision
AP 06-002 Wolf Creek Station Radiological Emergency Response 15
Plan
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