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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
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)
	v • d • e

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

TBD. An apparent violation of 10 CFR 50.54(q)(2) was identified involving the

failure to maintain adequate methods for assessing the actual or potential

consequences of a radiological emergency between September 2012 and

November 2013, in accordance with the requirements of 10 CFR 50.47(b)(9).

During an exercise conducted on November 13, 2012, the licensee identified that

the Electronic Dose Calculation Program did not accurately calculate the

consequences of a radiological release through the main vent stack with the

effluent monitor in accident mode. The inaccurate calculation was corrected on

February 25, 2014.

The inspectors determined the failure to maintain a dose assessment process

capable of providing a technically adequate estimate of offsite dose was a

performance deficiency within the licensees control. This finding is more than

minor because it was associated with the emergency response organization

performance and the Facilities and Equipment cornerstone attributes. This

finding was evaluated using the Emergency Preparedness Significance

Determination Process and was preliminarily determined to be of low to

moderate safety significance (White) because it was a degraded risk significant

planning standard function. The planning standard function was degraded

because between September 13, 2012, and November 8, 2013, some

calculations used to assess the offsite consequences of a radiological release

were inaccurate. This issue has been entered into the licensees corrective

action system as Condition Report 2013-0076247 (Section 1EP5).

-2-

REPORT DETAILS

1. REACTOR SAFETY

Cornerstone: Emergency Preparedness

1EP1 Exercise Evaluation (71114.01)

a. Inspection Scope

The inspectors observed the biennial emergency preparedness exercise conducted,

November 5, 2013, to determine if the exercise acceptably tested major elements of the

emergency plan and provided opportunities to demonstrate key emergency response

organization skills. The scenario simulated the following to demonstrate the licensee

personnels capability to implement their emergency plan:

An earthquake with a strong aftershock

An automatic plant trip with control rods that fail to insert

A reactor coolant system leak inside containment that increases over time

Failures of primary and auxiliary feed pumps to the steam generators

A fire in a charcoal filter that causes the radiological release to be unfiltered

A failure of the containment purge system that creates a monitored release to the

environment

The inspectors evaluated exercise performance by focusing on the risk significant

activities of event classification, offsite notification, recognition of offsite dose

consequences, and development of protective action recommendations, in the Control

Room Simulator and the following dedicated emergency response facilities:

Technical Support Center

Operations Support Center

Emergency Operations Facility

The inspectors also assessed recognition of, and response to, abnormal and emergency

plant conditions, the transfer of decision making authority and emergency function

responsibilities between facilities, onsite and offsite communications, protection of

emergency workers, emergency repair evaluation and capability, and the overall

implementation of the emergency plan to protect public health and safety and the

environment. The inspectors reviewed the facility emergency plan, the emergency plan

implementing procedures associated with operation of the emergency response

facilities, the procedures for the performance of associated emergency functions, and

other documents as listed in the attachment to this report.

The inspectors compared the observed exercise performance with the requirements in

the facility emergency plan; 10 CFR 50.47(b); 10 CFR Part 50, Appendix E; and with the

guidance in the emergency plan implementing procedures and other federal guidance.

The inspectors attended the post-exercise critiques in each emergency response facility

to evaluate the initial licensee self-assessment of exercise performance. The inspectors

also attended a subsequent formal presentation of critique items to plant management.

The specific documents reviewed during this inspection are listed in the attachment.

-3-

These activities constitute completion of one sample as defined in Inspection

Procedure 71114.01-05.

b. Findings

No findings were identified.

1EP5 Maintenance of Emergency Preparedness (71114.05)

a. Inspection Scope

The inspectors performed an in-office and on-site review of the licensees response to

Condition Report 59832, dated November 13, 2013, which documented a potential

inaccuracy in the Emergency Dose Assessment Program identified during an exercise

conducted November 13, 2012.

b. Findings

Introduction. An apparent violation was identified involving the failure to maintain

adequate methods for assessing the actual or potential consequences of a radiological

emergency as required by 10 CFR 50.54(q)(2) and 10 CFR 50.47(b)(9). Specifically, the

licensees dose assessment model incorrectly calculated the concentration of iodine and

particulate radioactive material released through the main vent stack when the effluent

monitor was in accident mode. This resulted in inaccurate dose assessments between

September 13, 2012, and November 8, 2013.

Description. A deficiency was identified that degraded the licensees ability to accurately

assess the offsite dose consequences of a radiological release. The NRC determined

that, on November 13, 2012, the licensee had identified that its Electronic Dose

Calculation Program (EDCP, radiological assessment software) was potentially

inaccurate, and as of November 5, 2013, had not evaluated or corrected the inaccuracy.

The NRC observed that the licensee dose assessor participating in the November 5,

2013, emergency preparedness exercise was knowledgeable about an inaccuracy in the

Electronic Dose Calculation Program (licensees radiological assessment software). The

inspectors subsequently reviewed Condition Report 00059832, E-Plan Drill, Potential

Incorrect EDCP Dose Assessments, dated November 13, 2012, which documented a

potential inaccuracy in EDCP calculations using the main vent stack radiation monitor

that was identified during an exercise conducted November 13, 2012.

In its normal operating mode, the main vent stack effluent radiation monitor reports

separate release rates for total noble gasses, radioactive Iodine, and radioactive

particulates. In accident mode the iodine and particulate release rates are not

measured because the detectors are manually isolated. The inspectors determined that

Control Room personnel place this monitor in accident mode when the noble gas

channel reaches a value of 3530 microCuries per second (µCi/s) and goes into Alert

Alarm. When the main vent stack radiation monitor is in accident mode, EDCP

compensates by calculating assumed iodine and particulate release rates, using a noble

gas to iodine ratio. A default ratio of 10 is assumed (e.g., the iodine release rate is set to

10 percent of the measured noble gas release rate). Users identified that during the

November 13, 2012, exercise; EDCP did not appear to be applying the expected noble

gas to iodine ratio when the vent stack radiation monitor was in accident mode. On

-4-

November 7, 2013, the licensee confirmed that EDCP was not correctly applying the

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