ML14092A618: Difference between revisions

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{{#Wiki_filter:April 2, 2014  
 
   
April 2, 2014   
EA-14-024
EA-14-024   Adam Heflin, President and  
Adam Heflin, President and  
   Chief Executive Officer  
   Chief Executive Officer  
Wolf Creek Nuclear Operating Corporation  
Wolf Creek Nuclear Operating Corporation  
P.O. Box 411 Burlington, KS  66839   
P.O. Box 411 Burlington, KS  66839  
SUBJECT:  WOLF CREEK GENERATING STATION - NRC BASELINE INSPECTION REPORT 05000482/2013502, PRELIMINARY WHITE FINDING  Dear Mr. Heflin:   
   
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  
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  
March 4, 2014, for the Wolf Creek Generating Station.  The inspection was a baseline  
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the inspection.  Additional telephone discussions occurred on September 30, 2013, and  
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  
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.   
 
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.   
Within these areas, the inspection consisted of an examination of selected procedures and  
Within these areas, the inspection consisted of an examination of selected procedures and  
representative records, observations of emergency preparedness activities, and interviews with  
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  
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  
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  
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  
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  
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.     
 
NRC's 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 NRC's preliminary  
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  
significance determination is described in the enclosed report.  The final resolution of this finding  
will be conveyed in separate correspondence.  UNITED STATES NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX  76011-4511  
will be conveyed in separate correspondence.  UNITED STATES
A. Heflin - 2 -   
NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX  76011-4511
   
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  
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;  
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  
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  
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.   
 
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  
If you request a Regulatory Conference, it should be held within 30 days of the receipt of this  
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root cause is or corrective action(s) associated with the finding.  If a Conference is held, it will be  
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  
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.  
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  
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  
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  
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.   
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  
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  
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.  
 
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.  
 
    
    
A. Heflin - 3 -   
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.  
   
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,  
       Sincerely,  
   /RA/   
   /RA/   
       Jeffrey A. Clark, Acting Director   
       Jeffrey A. Clark, Acting Director   
       Division of Reactor Safety  
       Division of Reactor Safety  
   Docket No. 50-482  
   Docket No. 50-482  
License No. NPF-42  
License No. NPF-42  
   
   
Enclosure:  Inspection Report 05000482/2013502    w/Attachment:  Supplemental Information  
Enclosure:  Inspection Report 05000482/2013502    w/Attachment:  Supplemental Information  
   
   
Electronic Distribution for Wolf Creek Generating Station  
Electronic Distribution for Wolf Creek Generating Station  
    
    
A. Heflin - 4 -   
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)   
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.Ma
ier@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)  
    
   
   
   
   
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R:\_REACTORS\_WC\2013\WC2013502 Choice Ltr PJE.docx   
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    
ADAMS ACCESSION NUMBER:  ML14092A618  
- 1 - Enclosure  U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000482 License: NPF-42 Report: 05000482/2013502  
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
   
- 1 - Enclosure  
  U.S. NUCLEAR REGULATORY COMMISSION REGION IV  
Docket: 05000482 License: NPF-42  
Report: 05000482/2013502  
Licensee: Wolf Creek Nuclear Operating Corporation   
Licensee: Wolf Creek Nuclear Operating Corporation   
Facility: Wolf Creek Generating Station  
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  
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  
  Approved By: Mark S. Haire,  Chief, Plant Support Branch 1  
Division of Reactor Safety   
 
Division of Reactor Safety  
    
   - 2 -  SUMMARY   
   - 2 -  SUMMARY   
IR 05000482/2013502; 09/03/2013 - 03/04/2014; Wolf Creek Generating Station, Regional Report; Emergency Plan Biennial Exercise, 71114.01, 71114.05  
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.   
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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  
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  
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.  
 
power reactors is described in NUREG-1649, "R
eactor Oversight Process," Revision 4, dated December 2006.  
 
   
   
A. NRC-Identified Findings and Self-Revealing Findings   Cornerstone:  Emergency Preparedness  
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).   
  * 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  
During an exercise conducted on November 13, 2012, the licensee identified that  
the Electronic Dose Calculation Program did not accurately calculate the  
the Electronic Dose Calculation Program did not accurately calculate the  
consequences of a radiological release through the main vent stack with 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  
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  
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  
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  
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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  
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  
were inaccurate.  This issue has been entered into the licensee's corrective  
action system as Condition Report 2013-0076247 (Section 1EP5).     
action system as Condition Report 2013-0076247 (Section 1EP5).  
   - 3 -  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  
      
   - 3 -  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 personnel's capability to implement their emergency plan:  
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:  
  * 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  
  * 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:  
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  
 
  * 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  
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  
environment.  The inspectors reviewed the facility emergency plan, the emergency plan  
implementing procedures associated with operation of the emergency response  
implementing procedures associated with operation of the emergency response  
facilities, the procedures for the performance of associated emergency functions, and  
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  
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.  
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  
  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.  
also attended a subsequent formal presentation of critique items to plant management.  
The specific documents reviewed during this inspection are listed in the attachment.   
The specific documents reviewed during this inspection are listed in the attachment.   
    
    
   - 4 -  These activities constitute completion of one sample as defined in Inspection Procedure 71114.01-05.  b. Findings No findings were identified.   
   - 4 -  These activities constitute completion of one sample as defined in Inspection Procedure 71114.01-05.  
1EP5 Maintenance of Emergency Preparedness (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  
  b. Findings
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  
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 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  
licensee's dose assessment model incorrectly calculated the concentration of iodine and  
particulate radioactive material released through the main vent stack when the effluent  
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.   
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  
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  
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.   
Calculation Program (EDCP, radiological
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  
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 assess
or participating in the November 5,  
2013, emergency preparedness exercise was kn
owledgeable 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  
potential inaccuracy in EDCP calculations using the main vent stack radiation monitor  
that was identified during an exercise conducted November 13, 2012.  
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  
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  
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10 percent of the measured noble gas release rate).  Users identified that during the  
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 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   
   - 5 -  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  
   - 5 -  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  
compensatory measures in place on November 8, 2013, to ensure that inaccurate  
information was not used in the determining protective action recommendations; the  
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  
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.  
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  
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  
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.  
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  
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  
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  
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  
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  
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  
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  
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  
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.   
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  
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,  
assigned to this finding because the finding is representative of current performance and the licensee failed to promptly evaluate whet
her 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  
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].     
safety significance [P.2].  
    
   - 6 -  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  
   - 6 -  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  
offsite emergency response plans must use adequate methods for assessing and  
monitoring actual or potential offsite consequences of a radiological emergency condition.   
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  
  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  
assessing and monitoring the actual or potential offsite consequences of a radiological  
emergency condition.  Specifically, a calculational error in the licensee's Electronic Dose  
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).   
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  
   
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  
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.   
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.  
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  
  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  
and guidance of Nuclear Energy Institute Document 99-02, "Regulatory Assessment  
Performance Indicator Guideline," Revision 6, were used to determine the accuracy of  
Performance Indicator Guideline," Revision 6, were used to determine the accuracy of  
Line 194: Line 302:
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  
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.   
are described in the attachment to this report.   
   - 7 -  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  
   - 7 -  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  
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  
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  
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  
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.  
specific documents reviewed are described in the attachment to this report.  
   
   
These activities constitute completion of the emergency response organization drill  
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  
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  
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  
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  
Nuclear Energy Institute guidance.  Specifically, the inspectors reviewed licensee  
records and processes including procedural guidance on assessing opportunities for the  
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.   
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  
These activities constitute completion of the alert and notification system sample as  
defined in Inspection Procedure 71151-05.   
defined in Inspection Procedure 71151-05.  
   - 8 -  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  
   - 8 -  b. Findings
licensee's staff.  The licensee acknowledged the issues presented.  On November 8, 2013, the inspectors presented the results of the onsite inspection of the  
No findings were identified.  
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.   
   
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  
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,  
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.   
and other members of the licensee's staff.  The licensee acknowledged the issues presented.  
  - 1 - Attachment SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT  Licensee Personnel     
    
  - 1 - Attachment SUPPLEMENTAL INFORMATION
  KEY POINTS OF CONTACT  
   Licensee Personnel     
P. Bedgood, Manager, Radiation Protection  
P. Bedgood, Manager, Radiation Protection  
J. Broschak, Vice President, Engineering A. Broyles, Manager, Information Systems A. Camp, Plant Manager  
J. Broschak, Vice President, Engineering A. Broyles, Manager, Information Systems A. Camp, Plant Manager  
Line 230: Line 362:
R. Smith, Site Vice President  
R. Smith, Site Vice President  
M. Sunseri, President and Chief Executive Officer M. Westman, Manager, Regulatory Affairs J. Yunk, Manager, Corrective Actions  
M. Sunseri, President and Chief Executive Officer M. Westman, Manager, Regulatory Affairs J. Yunk, Manager, Corrective Actions  
   
   
   LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED  
   LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
 
Opened  05000482/2013502-01 AV Failure to Maintain Accurate Methods for Dose Assessment  
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  
 
   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   
EP 06-001 Control Room Operations 19 EP 06-002 Technical Support Center Operations 34A EP 06-003 Emergency Operations Facility Operations 20A   
   - 2 -  Section 1EP1:  Exercise Evaluation Number Title Revision/Date EP 06-005 Emergency Classification 7 EP 06-006 Protective Action Recommendations 9  
   - 2 -  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 06-007 Emergency Notifications 20A  
EP 06-009 Drill and Exercise Requirements 8  
EP 06-009 Drill and Exercise Requirements 8  
Line 241: Line 381:
EP 06-015 Emergency Response Organization Callout 12B  
EP 06-015 Emergency Response Organization Callout 12B  
  Follow-up Assessment and Report, January 13, 2012, Event   
  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, 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  
  Follow-up Assessment and Report, April 13, 2013, Event March 16, 2013  
  2009 Biennial Exercise Scenario Timeline April 23, 2013  
  2009 Biennial Exercise Scenario Timeline April 23, 2013  
Line 251: Line 392:
  Evaluation Report for the August 20, 2013, Exercise   
  Evaluation Report for the August 20, 2013, Exercise   
  Evaluation Report for the August 22, 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, June 26, 2012 1 CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, June 26, 2012 11 GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for Chemistry Technicians, April 2, 2013 2  Email, Ken Thrall, to Shift Managers, Technical Support Center Site Emergency Managers, and Emergency November 7, 2013   
  Evaluation Report for the October 9, 2013, Exercise
   - 3 -  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 126710 EDCP issues documented in CR 59826 and CR 59832 January 8, 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  
Section 1EP5:  Maintenance of Emergency Preparedness
Number Title Revision/Date
CE 22 356 10 Workbook: Offsite Dose Projection using EDCP Workbook, June 26, 2012  
1 CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, June 26, 2012 11 GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for Chemistry Technicians, April 2, 2013  
2  Email, Ken Thrall, to Shift Managers, Technical Support Center Site Emergency Managers, and Emergency November 7,  
2013   
   - 3 -  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  
126710 EDCP issues documented in CR 59826 and CR 59832 January 8,  
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  
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 Plan 15  
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  
Plan 15
}}
}}

Revision as of 23:00, 1 July 2018

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 A
Division of Reactor Safety IV
To: Heflin A C
Wolf Creek
References
71114.01, 71114.05, EA-14-024 IR-13-502
Download: ML14092A618 (15)


See also: IR 05000482/2013502

Text

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 Commission's 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

NRC's 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 NRC's preliminary

significance determination is described in the enclosed report. The final resolution of this finding

will be conveyed in separate correspondence. UNITED STATES

NUCLEAR REGULATORY COMMISSION REGION IV 1600 E. LAMAR BLVD. ARLINGTON, TX 76011-4511

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 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.

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 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.

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.Ma

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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

- 1 - 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

- 2 - 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, "R

eactor 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 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).

- 3 - 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 personnel's 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.

- 4 - 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 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 assess

or participating in the November 5,

2013, emergency preparedness exercise was kn

owledgeable 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

- 5 - 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 whet

her 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].

- 6 - 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).

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 licensee's 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 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.

- 7 - 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.

- 8 - 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

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.

- 1 - Attachment 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

- 2 - 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, June 26, 2012

1 CE 12 356 10 Lesson Plan: Offsite Dose Projection using EDCP, June 26, 2012 11 GE 13 356 01 Lesson Plan: E-Plan Dynamic Learning Activity for Chemistry Technicians, April 2, 2013

2 Email, Ken Thrall, to Shift Managers, Technical Support Center Site Emergency Managers, and Emergency November 7,

2013

- 3 - 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

126710 EDCP issues documented in CR 59826 and CR 59832 January 8,

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

Plan 15