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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 A
| author name = Clark J
| author affiliation = NRC/RGN-IV/DRS
| author affiliation = NRC/RGN-IV/DRS
| addressee name = Heflin A C
| 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: [[followed by::IR 05000482/2013502]]
See also: [[see also::IR 05000482/2013502]]


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES
[[Issue date::April 2, 2014]]
                              NUCLEAR REGULATORY COMMISSION
                                                REGION IV
                                          1600 E. LAMAR BLVD.
                                        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.


EA-14-024 Adam Heflin, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
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.


SUBJECT: WOLF CREEK GENERATING STATION - NRC BASELINE INSPECTION REPORT 05000482/2013502, PRELIMINARY WHITE FINDING
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


==Dear Mr. Heflin:==
A. Heflin                                     -4-
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 Commission's rules and regulations and with the conditions in your license.
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


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 NRC's Web site at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce-pol.html.
                  U.S. NUCLEAR REGULATORY COMMISSION
 
                                    REGION IV
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 NRC's preliminary significance determination is described in the enclosed report. The final resolution of this finding will be conveyed in separate correspondence. 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 staff's 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.
Docket:     05000482
 
License:     NPF-42
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.
Report:     05000482/2013502
 
Licensee:   Wolf Creek Nuclear Operating Corporation
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.
Facility:   Wolf Creek Generating Station
 
Location:   1550 Oxen Lane NE, Burlington, Kansas
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 NRC's 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. 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.
Dates:       September 3, 2013, through March 4, 2014
 
Inspectors: P. Elkmann, Senior Emergency Preparedness Inspector
Sincerely,/RA/
            G. Guerra, CHP, Emergency Preparedness Inspector
Jeffrey A. Clark, Acting Director Division of Reactor Safety Docket No. 50-482 License No. NPF-42
            R. Stroble, Resident Inspector
 
            N. Okonkwo, Reactor Inspector
===Enclosure:===
Approved By: Mark S. Haire,
Inspection Report 05000482/2013502
            Chief, Plant Support Branch 1
 
            Division of Reactor Safety
===w/Attachment:===
                                        -1-                     Enclosure
Supplemental Information
 
Electronic Distribution for Wolf Creek Generating Station 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 NO'Keefe 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 Enclosure 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  
 
=SUMMARY=
IR 05000482/2013502; 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05


                                            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.
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-


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.
                                          REPORT DETAILS
 
1.    REACTOR SAFETY
===A. NRC-Identified Findings and Self-Revealing Findings===
Cornerstone: Emergency Preparedness
 
1EP1 Exercise Evaluation (71114.01)
===Cornerstone: Emergency Preparedness===
  a. Inspection Scope
* 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).
      The inspectors observed the biennial emergency preparedness exercise conducted,
 
      November 5, 2013, to determine if the exercise acceptably tested major elements of the
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 licensee's 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 licensee's corrective action system as Condition Report 2013-0076247 (Section 1EP5).
      emergency plan and provided opportunities to demonstrate key emergency response
 
      organization skills. The scenario simulated the following to demonstrate the licensee
=REPORT DETAILS=
      personnels capability to implement their emergency plan:
 
          *   An earthquake with a strong aftershock
==REACTOR SAFETY==
          *   An automatic plant trip with control rods that fail to insert
 
          *   A reactor coolant system leak inside containment that increases over time
===Cornerstone:===
          *   Failures of primary and auxiliary feed pumps to the steam generators
Emergency Preparedness
          *   A fire in a charcoal filter that causes the radiological release to be unfiltered
{{a|1EP1}}
          *   A failure of the containment purge system that creates a monitored release to the
==1EP1 Exercise Evaluation==
              environment
{{IP sample|IP=IP 71114.01}}
      The inspectors evaluated exercise performance by focusing on the risk significant
 
      activities of event classification, offsite notification, recognition of offsite dose
====a. Inspection Scope====
      consequences, and development of protective action recommendations, in the Control
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 personnel's capability to implement their emergency plan:
      Room Simulator and the following dedicated emergency response facilities:
* An earthquake with a strong aftershock
          *   Technical Support Center
* An automatic plant trip with control rods that fail to insert
          *   Operations Support Center
* A reactor coolant system leak inside containment that increases over time
          *   Emergency Operations Facility
* Failures of primary and auxiliary feed pumps to the steam generators
      The inspectors also assessed recognition of, and response to, abnormal and emergency
* A fire in a charcoal filter that causes the radiological release to be unfiltered
      plant conditions, the transfer of decision making authority and emergency function
* 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:
      responsibilities between facilities, onsite and offsite communications, protection of
* Technical Support Center
      emergency workers, emergency repair evaluation and capability, and the overall
* Operations Support Center
      implementation of the emergency plan to protect public health and safety and the
* 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.
      environment. The inspectors reviewed the facility emergency plan, the emergency plan
 
      implementing procedures associated with operation of the emergency response
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.
      facilities, the procedures for the performance of associated emergency functions, and
 
      other documents as listed in the attachment to this report.
The specific documents reviewed during this inspection are listed in the attachment.
      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
These activities constitute completion of one sample as defined in Inspection Procedure 71114.01-05.
      guidance in the emergency plan implementing procedures and other federal guidance.
 
      The inspectors attended the post-exercise critiques in each emergency response facility
====b. Findings====
      to evaluate the initial licensee self-assessment of exercise performance. The inspectors
No findings were identified.
      also attended a subsequent formal presentation of critique items to plant management.
{{a|1EP5}}
      The specific documents reviewed during this inspection are listed in the attachment.
==1EP5 Maintenance of Emergency Preparedness==
                                                  -3-
{{IP sample|IP=IP 71114.05}}
 
====a. Inspection Scope====
The inspectors performed an in-office and on-site review of the licensee's 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 licensee's 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 licensee's 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 (licensee's 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 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 licensee's 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 licensee's control. This finding is more than minor because it affected the licensee's 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 licensee's 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].
 
=====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 licensee's 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).
{{a|1EP8}}
==1EP8 Exercise Evaluation==
{{IP sample|IP=IP 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 licensee's emergency plan and provided opportunities to demonstrate the key emergency response organization skills.
 
====b. Findings====
No findings were identified.
 
==OTHER ACTIVITIES==
{{a|4OA1}}
==4OA1 Performance Indicator Verification==
{{IP sample|IP=IP 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 licensee's 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.
 
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 licensee's 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 licensee's 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.
 
====b. Findings====
No findings were identified.
 
{{a|4OA6}}
==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==
 
licensee's staff. The licensee acknowledged the issues presented. On November 8, 2013, the inspectors presented the results of the onsite inspection of the licensee's biennial emergency preparedness exercise to Mr. M. Sunseri, President and Chief Executive Officer, and other members of the licensee's 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 licensee's staff. The licensee acknowledged the issues presented.
 
=SUPPLEMENTAL INFORMATION=
 
==KEY POINTS OF CONTACT==


===Licensee Personnel===
    These activities constitute completion of one sample as defined in Inspection
: [[contact::P. Bedgood]], Manager, Radiation Protection
    Procedure 71114.01-05.
: [[contact::J. Broschak]], Vice President, Engineering
  b. Findings
: [[contact::A. Broyles]], Manager, Information Systems
    No findings were identified.
: [[contact::A. Camp]], Plant Manager
1EP5 Maintenance of Emergency Preparedness (71114.05)
: [[contact::R. Clemens]], Vice President, Strategic Projects
  a. Inspection Scope
: [[contact::D. Dees]], Superintendent, Operations Support
    The inspectors performed an in-office and on-site review of the licensees response to
: [[contact::T. East]], Superintendent, Emergency Preparedness
    Condition Report 59832, dated November 13, 2013, which documented a potential
: [[contact::D. Erbe]], Manager, Security
    inaccuracy in the Emergency Dose Assessment Program identified during an exercise
: [[contact::R. Flannigan]], Manager, Nuclear Engineering
    conducted November 13, 2012.
: [[contact::A. Heflin]], President and Chief Executive Officer
  b. Findings
: [[contact::S. Henry]], Manager, Operations
    Introduction. An apparent violation was identified involving the failure to maintain
: [[contact::R. Hobby]], Licensing Engineer
    adequate methods for assessing the actual or potential consequences of a radiological
: [[contact::W. Muilenburg]], Supervisor, Licensing
    emergency as required by 10 CFR 50.54(q)(2) and 10 CFR 50.47(b)(9). Specifically, the
: [[contact::L. Ratzlaff]], Manager, Maintenance
    licensees dose assessment model incorrectly calculated the concentration of iodine and
: [[contact::E. Ray]], Manager, Training
    particulate radioactive material released through the main vent stack when the effluent
: [[contact::R. Rumas]], Manager, Quality
    monitor was in accident mode. This resulted in inaccurate dose assessments between
: [[contact::R. Smith]], Site Vice President
    September 13, 2012, and November 8, 2013.
: [[contact::M. Sunseri]], President and Chief Executive Officer
    Description. A deficiency was identified that degraded the licensees ability to accurately
: [[contact::M. Westman]], Manager, Regulatory Affairs
    assess the offsite dose consequences of a radiological release. The NRC determined
: [[contact::J. Yunk]], Manager, Corrective Actions
    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-


==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
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-


===Opened===
      Enforcement. Title 10 of the Code of Federal Regulations (CFR), Part 50.54(q)(2),
: 05000482/2013502-01 AV Failure to Maintain Accurate Methods for Dose Assessment  
      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-


==LIST OF DOCUMENTS REVIEWED==
    These activities constitute completion of the drill/exercise performance sample as
==Section 1EP1: Exercise Evaluation Number Title Revision/Date==
    defined in Inspection Procedure 71151-05.
: APF 06-002-01 Emergency Action Levels 17
  b. Findings
: AP 17C-028 Emergency Response Duties and Responsibilities 13
    No findings were identified.
: EP 06-001 Control Room Operations 19
.14  Emergency Response Organization Drill Participation (EP02)
: EP 06-002 Technical Support Center Operations 34A
  a. Inspection Scope
: EP 06-003 Emergency Operations Facility Operations 20A  
    The inspectors sampled licensee submittals for the Emergency Response
   - 2 -
    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-


==Section 1EP1: Exercise Evaluation Number Title Revision/Date==
  b.  Findings
: EP 06-005 Emergency Classification 7
      No findings were identified.
: EP 06-006 Protective Action Recommendations 9
4OA6 Meetings
: EP 06-007 Emergency Notifications 20A
Exit Meeting Summary
: EP 06-009 Drill and Exercise Requirements 8
On September 30, 2013, the inspectors discussed the preliminary scenario for the 2013 biennial
: EP 06-011 Emergency Team Formation and Control 8
exercise with Mr. T. East, Superintendent of Emergency Planning, and other members of the
: EP 06-012 Dose Assessment, Oct-28-2013 13
licensees staff. The licensee acknowledged the issues presented.
: EP 06-012 Dose Assessment, Sep-13-2012 12B
On November 8, 2013, the inspectors presented the results of the onsite inspection of the
: EP 06-015 Emergency Response Organization Callout 12B
licensees biennial emergency preparedness exercise to Mr. M. Sunseri, President and Chief
: Follow-up Assessment and Report, January 13, 2012, Event Follow-up Assessment and Report, March 4, 2013, Event January 26, 2012
Executive Officer, and other members of the licensees staff. The licensee acknowledged the
: Follow-up Assessment and Report, March 16, 2013, Event March 5, 2013
issues presented. The inspector asked the licensee whether any materials examined during the
: Follow-up Assessment and Report, April 13, 2013, Event March 16, 2013
inspection should be considered proprietary. No proprietary information was identified.
: 2009 Biennial Exercise Scenario Timeline April 23, 2013
On March 4, 2014, the inspectors discussed an apparent violation identified as a result of the
: 11-EVAL-EX Exercise Scenario Timeline
November 5, 2013, biennial exercise with Mr. A. Heflin, President and Chief Executive Officer,
: 13-PRE-01 Exercise Scenario Timeline
and other members of the licensees staff. The licensee acknowledged the issues presented.
: 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
                                              -8-
: 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==
                              SUPPLEMENTAL INFORMATION
: CE 22 356 10 Workbook: Offsite Dose Projection using EDCP Workbook, June 26, 2012 1
                                  KEY POINTS OF CONTACT
: CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, June 26, 2012 11
Licensee Personnel
: GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for Chemistry Technicians, April 2, 2013 2
P. Bedgood, Manager, Radiation Protection
: Email, Ken Thrall, to Shift Managers, Technical Support Center Site Emergency Managers, and Emergency November 7, 2013 
J. Broschak, Vice President, Engineering
  - 3 -
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


==Section 1EP5: Maintenance of Emergency Preparedness Number Title Revision/Date Operations Facility Offsite Emergency Managers==
Section 1EP1: Exercise Evaluation
: Unit Vent, Table of Ranges and Alarm Set Points November 7, 2013 Service Request
Number         Title                                                     Revision/Date
: 126710 EDCP issues documented in
EP 06-005      Emergency Classification                                  7
: CR 59826 and
EP 06-006      Protective Action Recommendations                        9
: CR 59832 January 8, 2013
EP 06-007      Emergency Notifications                                  20A
: Weekly Schedule, Chemistry Continuing Training
EP 06-009      Drill and Exercise Requirements                          8
: Cycle 13-Q2, April 15 to May 21, 2013
EP 06-011      Emergency Team Formation and Control                      8
: Weekly Schedule, Chemistry Continuing Training
EP 06-012      Dose Assessment, Oct-28-2013                             13
: Cycle 13-Q3, July 8 to August 15, 2013  
EP 06-012      Dose Assessment, Sep-13-2012                              12B
===Condition Reports===
EP 06-015      Emergency Response Organization Callout                  12B
(Corrective Action System) 48268 49240 50872 51428 54279 55060 55066 55071 59554 59832 67808 68404 70209 70212
                Follow-up Assessment and Report, January 13, 2012, Event
: 220 70229 70876 70899 71332 71347 72965
                Follow-up Assessment and Report, March 4, 2013, Event    January 26,
: 73101 73735 74632
                                                                          2012
===Miscellaneous===
                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 4OA1: Performance Indicator Verification Number Title Revision==
Section 1EP5: Maintenance of Emergency Preparedness
: EP 06-019 Alert and Notification System Sirens 7
Number            Title                                                Revision/Date
: EP 06-022 Tone Alert Radio Maintenance/Compensatory Actions 5
                  Operations Facility Offsite Emergency Managers
: AI 26A-004 Emergency Planning Performance Indicators 6
                  Unit Vent, Table of Ranges and Alarm Set Points      November 7,
: AP 34-003 Performance Indicator Program 0A  
                                                                        2013
===Miscellaneous Documents===
Service Request  EDCP issues documented in CR 59826 and CR 59832      January 8,
: Number Title Revision
126710                                                                  2013
: AP 06-002 Wolf Creek Station Radiological Emergency Response Plan 15
                  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-
}}
}}

Latest revision as of 06:05, 4 November 2019

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
ML14092A618
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
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

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

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

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 automatic plant trip with control rods that fail to insert
  • 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.

-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

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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