IR 05000482/2014504
| ML15015A648 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 01/15/2015 |
| From: | Haire M S Plant Support Branch-1 |
| To: | Heflin A C Wolf Creek |
| G. Guerra | |
| References | |
| IR 2014504 | |
| Download: ML15015A648 (16) | |
Text
January 15, 2015
Adam C. Heflin, President and
Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
SUBJECT: WOLF CREEK GENERATING STATION
- NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000482/2014504
Dear Mr. Heflin:
On December 17, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Wolf Creek Generating Station. On December 5 and on December 17, 2014, the NRC inspector discussed the results of this inspection with Mr. S. Smith, Plant Manager and other members of your staff. The inspector documented the results of this inspection in the
enclosed inspection report. No NRC-identified or self-revealing findings were identified during this inspection.
The inspector documented a licensee-identified violation which was determined to be of very low safety significance in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy. In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, "Public Inspections, Exemptions, Requests for Withholding," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC's Public Document Room or from the Publicly Available Records (PARS) component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark S. Haire, Branch Chief
Plant Support Branch 1 Division of Reactor Safety
Docket.: 50-482 License: NPF-42
Enclosure: Inspection Report 05000482/2014504 w/Attachment: Supplemental Information
Distribution to Wolf Creek Generating Station
ML15015A648 SUNSI Review By: GGuerra ADAMS Yes No Publicly Available Non-Publicly Available Non-Sensitive Sensitive Keyword: RGN-002 OFFICE EPI:PSB1 SEPI:PSB1 C:PSB1 C:DRP/B C:PSB1 NAME GGuerra/dch PElkmann MHaire NO'Keefe MHaire SIGNATURE /RA/ /RA/ /RA/ /RA/ /RA/ DATE 1/12/15 1/12/15 1/12/15 1/15/15 1/15/15 Letter to Adam from Mark S. Haire, dated January 15, 2015
SUBJECT: WOLF CREEK GENERATING STATION
- NRC EMERGENCY PREPAREDNESS INSPECTION REPORT 05000482/2014504
DISTRIBUTION
- Regional Administrator (Marc.Dapas@nrc.gov)
Deputy Regional Administrator (Kriss.Kennedy@nrc.gov) Acting DRP Director (Troy.Pruett@nrc.gov) Acting DRP Deputy Director (Thomas.Farnholtz@nrc.gov)
DRS Director (Anton.Vegel@nrc.gov)
DRS Deputy Director (Jeff.Clark@nrc.gov)
Senior Resident Inspector (Charles.Peabody@nrc.gov)
Resident Inspector (Raja.Stroble@nrc.gov) WC Administrative Assistant (Carey.Spoon@nrc.gov)
Branch Chief, DRP/B (Neil.OKeefe@nrc.gov)
Senior Project Engineer, DRP/B (David.Proulx@nrc.gov)
Project Engineer, DRP/B (Fabian.Thomas@nrc.gov) Public Affairs Officer (Victor.Dricks@nrc.gov) Public Affairs Officer (Lara.Uselding@nrc.gov)
Project Manager (Fred.Lyon@nrc.gov)
Branch Chief, DRS/TSB (Geoffrey.Miller@nrc.gov)
RITS Coordinator (Marisa.Herrera@nrc.gov)
ACES (R4Enforcement.Resource@nrc.gov) Regional Counsel (Karla.Fuller@nrc.gov) Technical Support Assistant (Loretta.Williams@nrc.gov)
Congressional Affairs Officer (Jenny.Weil@nrc.gov)
RIV Congressional Affairs Officer (Angel.Moreno@nrc.gov)
RIV/ETA: OEDO (Cayetano.Santos@nrc.gov) Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION IV Docket: 05000482 License: NPF-42 Report: 05000482/2014504 Licensee: Wolf Creek Nuclear Operating Corporation Facility: Wolf Creek Generating Station Location: 1550 Oxen Lane NE Burlington, Kansas Dates: November 17 through December 17, 2014 Inspector: G. Guerra, CHP, Emergency Preparedness Inspector Approved By: Mark S. Haire Branch Chief, Plant Support Branch 1 Division of Reactor Safety
SUMMARY
IR 05000482/2014504; 11/17/2014 - 12/17/2014; Wolf Creek Generating Station; Inspection Report; 71114.05
The inspection activities described in this report were performed between November 17 and December 17, 2014, by an emergency preparedness inspector from the NRC's Region IV office at the plant site and in-office. The NRC inspector documented in this report one licensee-identified violation of very low safety significance. The significance of inspection findings is indicated by their color (Green, White, Yellow, or Red), which is determined using Inspection Manual Chapter 0609, "Significance Determination Process", issued June 2, 2011. Their cross-cutting aspects are determined using Inspection Manual Chapter 0310, "Components Within the Cross-Cutting Areas," issued December 4, 2014. Violations of NRC requirements are dispositioned in accordance with the NRC Enforcement Policy. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process." No NRC-identified or self-revealing findings were identified.
Cornerstone: Emergency Preparedness
- None
=
Licensee-Identified Violations===
A violation of very low safety significance (Green) that was identified by the licensee has been reviewed by the inspector. Corrective actions taken or planned by the licensee have been entered into the licensee's corrective action program. This violation and associated corrective action tracking numbers are listed in Section 4OA7 of this report.
REPORT DETAILS
REACTOR SAFETY
===Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
=
The inspector verified the adequacy of the licensee's methods for testing the primary and backup alert and notification system (ANS). The inspector also reviewed the licensee's program for identifying emergency planning zone locations requiring tone alert radios and for distributing the radios. The inspector interviewed licensee personnel responsible for the maintenance of the primary and backup ANS and reviewed a sample of corrective action system reports written for any ANS problems. The inspector compared the licensee's alert and notification system testing program with criteria in NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1; FEMA Report REP-10, "Guide for the Evaluation of Alert and Notification Systems for Nuclear Power Plants," and the licensee's current FEMA-approved alert and notification system design report, "FEMA REP-10 Design Review Report," dated May 2, 2008. These activities constituted completion of one alert and notification system evaluation sample as defined in Inspection Procedure 71114.02.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspector verified the licensee's emergency response organization on-shift and augmentation staffing levels were in accordance with the licensee's emergency plan commitments. The inspector reviewed documentation and discussed with licensee staff the operability of primary and backup systems for augmenting the on-shift emergency response staff to verify the adequacy of the licensee's methods for staffing emergency response facilities, including the licensee's ability to staff pre-planned alternate facilities.
The inspector also reviewed records of emergency response organization augmentation tests and events to determine whether the licensee had maintained a capability to staff emergency response facilities within emergency plan timeliness commitments. These activities constitute completion of one emergency response organization staffing and augmentation testing sample as defined in Inspection Procedure 71114.03.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
The inspector performed an in-office review of Wolf Creek Generating Station Emergency Plan, "Radiological Emergency Response Plan," Revision 16. This revision updated the emergency plan with the description and location of a new Emergency Operations Facility, Alternate Technical Support Center, and Alternate Operations Support Center. Several editorial and title changes were also made. The inspector also performed a visual inspection of the new facilities during the on-site inspection of the emergency preparedness program the week of November 17, 2014. This revision was compared to its previous revision, to the criteria of NUREG-0654, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, and to the standards in 10 CFR 50.47(b) to determine if the revision adequately implemented the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that the revision did not decrease the effectiveness of the emergency plan. This review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection.
These activities constitute completion of one emergency action level and emergency plan changes sample as defined in Inspection Procedure 71114.04.
b. Findings
No findings were identified.
1EP5 Maintenance of Emergency Preparedness
a. Inspection Scope
The inspector reviewed the following for the period November 2012 to November 2014:
- After-Action reports for emergency classifications and events
- After-Action evaluation reports for licensee drills and exercises
- Independent audits and surveillances of the licensee's emergency preparedness program
- Self-assessments of the emergency preparedness program conducted by the licensee
- Licensee evaluations of changes made to the emergency plan and emergency plan implementing procedures
- Drill and Exercise performance issues entered into the licensee's corrective action program
- Emergency preparedness program issues entered into the licensee's corrective action program
- Maintenance records for equipment supporting the emergency preparedness program
- Emergency response organization and emergency planner training records The inspector reviewed summaries of over 300 corrective action program reports associated with emergency preparedness and selected 55 to review against program requirements, to determine the licensee's ability to identify, evaluate, and correct problems in accordance with planning standard 10 CFR 50.47(b)(14) and 10 CFR Part 50, Appendix E, IV.F. The inspector verified that the licensee accurately and appropriately identified and corrected emergency preparedness weaknesses during critiques and assessments.
The inspector reviewed summaries of licensee evaluations of the impact of changes to the emergency plan and implementing procedures to review against program requirements to determine the licensee's ability to identify reductions in the effectiveness of the emergency plan in accordance with the requirements of 10 CFR 50.54(q)(3) and 50.54(q)(4). The inspector verified that evaluations of proposed changes to the licensee emergency plan appropriately identified the impact of the changes prior to being implemented.
The inspector reviewed records pertaining to the maintenance of equipment and facilities used to implement the emergency plan.
The inspector verified that equipment and facilities were maintained in accordance with the commitments of the licensee's
These activities constitute completion of one sample of the maintenance of the licensee's emergency preparedness program as defined in Inspection Procedure 71114.05.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Drill/Exercise Performance (EP01)
a. Inspection Scope
The inspector reviewed the licensee's evaluated exercises, emergency plan implementations, and selected drill and training evolutions that occurred between October 2013 and September 2014 to verify the accuracy of the licensee's data for classification, notification, and protective action recommendation (PAR) opportunities.
The inspector reviewed a sample of the licensee's completed classifications, notifications, and PARs to verify their timeliness and accuracy. The inspector used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the performance indicator for drill/exercise performance as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.2 Emergency Response Organization Drill Participation (EP02)
a. Inspection Scope
The inspector reviewed the licensee's records for participation in drill and training evolutions between October 2013 and September 2014 to verify the accuracy of the licensee's data for drill participation opportunities. The inspector verified that all members of the licensee's emergency response organization (ERO) in the identified key positions had been counted in the reported performance indicator data. The inspector reviewed the licensee's basis for reporting the percentage of ERO members who participated in a drill. The inspector reviewed drill attendance records and verified a sample of those reported as participating. The inspector used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this
report. These activities constituted verification of the emergency response organization drill participation performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
.3 Alert and Notification System Reliability (EP03)
a. Inspection Scope
The inspector reviewed the licensee's records of alert and notification system tests conducted between October 2013 and September 2014 to verify the accuracy of the licensee's data for siren system testing opportunities. The inspector reviewed procedural guidance on assessing alert and notification system opportunities and the results of periodic alert and notification system operability tests. The inspector used definitions and guidance contained in Nuclear Energy Institute Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 7, to determine the accuracy of the data reported. The specific documents reviewed are described in the attachment to this report.
These activities constituted verification of the alert and notification system reliability performance indicator as defined in Inspection Procedure 71151.
b. Findings
No findings were identified.
4OA6 Meetings Exit Meeting Summary
On November 20, 2014, the inspector presented the results of the onsite inspection of the emergency preparedness program to Mr. S. Smith, Plant Manager, and other members of the licensee staff. The licensee acknowledged the issues presented. The licensee confirmed that any proprietary information reviewed by the inspectors had been returned or destroyed.
On December 17, 2014, the inspector conducted a telephonic exit meeting to present the results of the in-office inspection of changes to the licensee's emergency plan to Mr. S. Koening, Manager Regulatory Affairs, and other members of the licensee staff. The licensee acknowledged the issues presented.
4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the licensee and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as a non-cited violation.
- Title 10 CFR 50.54(q) requires, in part, that licensees follow and maintain in effect an emergency plan that meets the requirements of 50.47(b). Planning Standard 50.47(b)(2) requires on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times. Procedure AP 06-002, "Radiological Emergency Response Plan," Revision 15, Attachment D, "WCGS Minimum Staffing for Emergencies," identifies two chemists for on-shift staffing. Procedure AP 21-001, "Conduct of Operations," Revision 69, Step 6.6.2, states that "the off-going SM [Shift Manager] shall ensure that the on-coming watchstanders are qualified to stand the watches assigned to them."
The failure to have the required qualified chemistry technicians on staff is a performance deficiency. The performance deficiency is more than minor because it impacts the emergency response organization readiness attribute of the Emergency Preparedness Cornerstone objective to ensure that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. Using the examples in Table 5.2-1, "Significance Examples § 50.47(b)(2),"
of Appendix B to Inspection Manual Chapter 0609, "Emergency Preparedness Significance Determination Process," issued June 2, 2011, the inspector concluded that this finding represents a degradation of the planning standard function. It meets the degraded planning standard function example, "Staffing processes would permit a shift to go below E-plan minimum staffing requirements, but there were no actual instances in which such shortages occurred." It is not Greater-than-Green because they had the required number of personnel on shift and they were capable of completing the required functions, albeit task qualified. The licensee had the required minimum staff and could perform the function; however, their processes could have failed if they had not identified this condition and could have not met functional requirements in the future by the use of unqualified personnel. It is not a loss of planning standard function because it was personnel error that caused the finding. An acting chemistry manager did not understand that two qualified chemistry technicians were required one for sampling and one for dose assessment. The licensee identified a broken process in that the watchstander bill did not require verifying qualifications for staff other than for operations personnel.
Contrary to the above, on 21 shifts, between May 24 and July 14, 2014, the licensee used two unqualified chemistry technicians for on-shift staffing. Specifically, the licensee had an on-shift unqualified chemistry technician along with a qualified chemistry technician. The emergency plan specifies two tasks for the technicians; sampling and dose assessment. For the time period in question, the licensee had placed two technicians on back shift, one fully qualified technician, who could perform sampling and dose assessment, and one not fully qualified technician for the fire brigade. The licensee missed the fact that one technician was needed for sampling and one technician for dose assessment. Although the technicians were not both fully qualified, their skills and abilities allowed for the required emergency preparedness functions to be completed. The licensee has entered this into their corrective action program as
Condition Report CR86306.
A-1 Attachment
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- L. Aiken, Health Physicist II
- A. Broyles, Manager Information Services
- J. Dagenette, Emergency Planning
- S. Dekat, Chemistry
- T. East, Supervisor, Emergency Planning
- J. Edwards, Manager, Operations
- K. Egan, Quality
- N. Good, Licensing
- S. Good, Superintendent, Security
- C. Gross, Manager, Chemistry
- J. Hawkinson, Emergency Planning
- S. Henry, Manager, Integrated Plant Scheduling
- R. Hobby, Licensing Engineer
- S. Koening, Manager Regulatory Affairs
- W. Muilenburg, Supervisor, Licensing
- E. Ray, Manager, Training
- S. Smith, Plant Manager
- R. Stumbaugh, Health Physics
- K. Thrall, Emergency Planning
- L. Upson, Manager, Strategic Initiatives
- B. Vickery, Manager, Financial Services
- J. Yunk, Manager, Corrective Actions
NRC Personnel
- C. Peabody, Senior Resident Inspector
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
None
LIST OF DOCUMENTS REVIEWED
Section 1EP2: Alert and Notification System Testing
Procedures
- Number Title Revision Date
- REP-10 Design Review Report May 2, 2008
Section 1EP3: Emergency Response Organization Staffing and Augmentation System
- Title Date Wolf Creek On-Shift Staffing Analysis Report December 12, 2012 12-Q4 Quarterly Callout Test 12/10/2012
- December 10, 2012
- 13-Q1 Quarterly Callout Test 01/17/2013
- January 17, 2013
- 13-Q2 Quarterly Callout Test 06/24/2013
- June 24, 2013
- 13-Q3 Quarterly Callout Test 09/30/2013
- September 30, 2013
- 13-Q4 Quarterly Callout Test 12/05/2013
- December 5, 2013 14-Q1 Quarterly Callout Test 02/25/2014
- February 25, 2014 14-Q1 Quarterly Callout Test 02/25/2014
- June 27, 2014
- 14-Q3 Quarterly Callout Test 09/24/2014
- September 24, 2014
Section 1EP4: Emergency Action Level and Emergency Plan Changes
Procedures
- Number Title Revision
- AP 06-002 Radiological Emergency Response Plan 16
- DRR 14-2399 Document Review Request for Radiological Emergency Response Plan, Revision 16
Section 1EP5: Maintenance of Emergency Preparedness
Procedures
- Number Title Revision
- AP 21-001 Conduct of Operations
Procedures
- Number Title Revision
- APF 21-001-01 Shift Manager Relief Checklist 16
- AP 06-002 Radiological Emergency Response Plan (RESP) - Attachment D "WCGS Minimum Staffing For Emergencies" - Figure 2 "Minimum Shift Staffing"
- AP 06-004 Equipment Important to Emergency Response 1
- EPP 06-023 Emergency Response Facility Functionality 1
- EPP 06-009 Drill and Exercise Requirements 8
- Tool Kit 42 On-Shift Staffing Analysis Review 0
Other Documents
- Number Title Date White Paper Chemistry Technician Qualifications
- RCA 86306 Root Cause Analysis: Minimum Staffing Requirements Not Met
- RA 12-0126 Evacuation Time Estimates for Wolf Creek Generating Station December 19, 2012
- ETE Update Evaluation December 19, 2013 Drill Reports
- October 23, 2012
- November 6, 2012
- November 13, 2012
- July 8, 2013
- July 10, 2013
- August 20, 2013
- August 22, 2013
- October 30, 2013
- June 18, 2014
- August 20, 2014
- August 27, 2014
- September 10, 2014 Exercise Report 13-PRE-01 October 9, 2013 Exercise Report 13-EVAL-EX November 5, 2013
- Event Report Alert Classification October 16, 2014
- Audits/Surveillances Number Title Date
- QS-2014-0695 Emergency Planning Drill - 14-SA-02 September 10, 2014
- QH-2012-0261 EP NRC Inspection Readiness August 7, 2012
- SA-2013-0056 Emergency Planning Administrative Processes and Interface with Emergency Response Organization Assessment April 18, 2013
- QS-2012-0297 Follow-up of corrective actions for
- QA-12-05-EP October 9, 2012
- QS-2014-0659 Adequacy of position training for E-Plan Operations Coordinator September 10, 2014
- QS-2014-0660 Support to QA Audit 2014-06-EP October 6, 2014 Audit 13-04-EP Emergency Preparedness June 26, 2013
- Audit 14-06-EP Emergency Preparedness August 4, 2014
Condition Reports
(CRs) in Emergency Preparedness
- 40719 53396 55977 57107 57603 57604 57605 59011 59052 59648
- 59803 59992 60783 60784 60785
- 60786 60787 60788 60789 61717 69253 63404 63405 64677 67522 68611 70899 71318 71470 72022
- 73735 74632 75927 75980 75999
- 76178 78216 78428 78532 79005
- 79670 84257 84462 84581 84812 85703 85706 86306 86347 86703 86898 87071 87303 88711
- 88786
Section 4OA1: Performance Indicator Verification
Procedures
- Number Title Revision
- AI 26A-004 Emergency Planning Performance Indicators 6