ML20055J064

Responds to NRC Re Violations Noted in Insp Rept 50-482/90-24.Corrective Action:All Dose Personnel Receiving Retraining within Normal 7-wk Training Cycle Which Began on 900723 & Emergency Procedure EPP 01-7.3 Will Be Revised

ML20055J064
Person / Time
Site:	Wolf Creek
Issue date:	07/26/1990
From:	Withers B WOLF CREEK NUCLEAR OPERATING CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-90-0137, WM-90-137, NUDOCS 9008010021
Download: ML20055J064 (4)

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I W44.F CREEK. NUCLEAR OPERATING CORPORATION Boft D. Wuhers l e,ese.m w on Ju1y 26, 1990 )

omae WM 90-0137 I U. S. Nuclear Regulatory Comunission ATTH: Document Control Desk Mail Station P1-137- '

Washington, D.C. 20555

Reference:

Letter dated June 26, 1990 from S. J. Collins, NRC, to l B. D. Withers, WCNOC '

Subject:

Docket No. 50-482: Response to Notice of Violation 482/9024-02 and Unresolved Item 482/9024-01 Gentlemen This letter provides Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violation 482/9024-02 and Unresolved Item 482/9024-01. Notice of Violation 482/9024-02 involved insufficient radiological emergency response training. Unresolved Item 482/9024-01 involved an inconsistency between the WCGb Radiological Emergency Response Plan and an Emergency Response Plan Implementing Procedure.

If you have any questions concerning this matter, please contact me or Mr. H. K. Chernoff of my staff.

Very truly yours.

.=j Bart D. Withers President and Chief Executive Officer BDW/aem Attachment cc R. D. Martin (NRC), w/a D. V. Pickett (NRC), w/a M. E. Skow (NRC), w/a D. B. Spitzberg (NRC), w/a J. S. Wiebo (NRC), w/a a 20001 On.' . ;00716 Pi irs MUL O'000482 f O P["I 7 /p RO. Ekm 411/ Burhngton, KS 66839 / Phone: (316) %4-9631 1 I

AA EgaW Opporturey EvW Mf/He/ VET

Attachm nt to WM 90-0137 4 Page 1 of 3  ;

e Violation (462/9024-02): Inadeaunte m==rnancy Reasonse Traininn Findines l 10 CFR $0.47(b)(15) states that radiological emergency response training shall be provided for those who may be called to assist in an emergency. l Section 5.1 of the Wolf Creek Radiological Emergency Response Plan states, in part, that specialized initial training and periodic retraining is provided for specified categories of emergency personnel including directors  ;

and/or coordinators of the plant emergency organization, and personnel l

responsible for accident assessment, including control room shift personnel.

l contrary to the above, at the time of the inspection, the inspector determined from interviews of key emergency personnel who might be called ,

upon to respond and assist for accident assessment in an emergency, that their radiological emergency response training was not sufficient.

Specifically, ind.viduals responsible for performing dose projections early in an emergency make errors in calculating does projections which resulted, or could result in 8aproper emergency classification and/or protective action recommendations, to offsite authorities.

Reason For Violation:

Three of four dose assessment personnel did not accurately provide offsite dose assessment in accordance with procedure EPP 01-7.3, Revision 9, ' Manual Dose Projection Determination' . Incorrect values were obtained from the

, tables contained as attachments to EPP 01-7.3. A review was performed of l the training provided to the dose assessment personnel and of EPP 01-7.3.

Based on information evaluated during this review, the root cause of this violation has been attributed to the difficulty in using the tables associated with procedure EPP 01 7.3.

Corrective Steos Which Have Been Taken And Results Achieved:

All dose assessment personnel are receiving retraining within the normal seven week training cycle which began on J~1y 23, 1990. This training is emphasizing performance of dose projectiv..e in accordance with EPP 01-7.3.

The training is also emphasizing the determination of the proper table to be used as well as stressing the correct use of the selected tables.

Corrective Steos Which Will Be Taken to Avoid Further Violations:

EPP 01-7.3, ' Manual Dose Projection Determ..natio1', and the associated tables will be revised to enhance their ease of use and to ensure that manual dose calculations can be completed quickly and efficiently. Training on the revised procedure will be completed within the normal seven week training cycles.

l

e d Attachm:nt to WM 90-0137 ,

• Page 2 of 3 ,

l Date When Full como11ance Will Be Achieved i

Retraining ou EPP 01-7.3 will be completed by September 10, 1990. EPP 01- i 7.3 will be revised by September 10, 1990. Training on the revised EPP 01 7.3 will be completed by October 31, 1990. t Unresolved Item (482/9024-01): An monarent inconsistency amists between the Emernancy Plan and an Emernency Plan fmniementina Procedure over the mini ==

orotective action recr==endations to be made at a General Emernency, t

The inspector reviewed the content of a number of EPPs to determine their consistency with the Emergency Plan. It was noted that an apparent inconsistency existed between EPP 01-10.1, Revision 6 ' Protective Action Recomendations,' and Section 3.3.2 of the plan entitled, 'Offsite Protective Actions.' According to the plan, at the General Emergency (GE) classification.

l either an evacuation, or sheltering will be reconsnended ,

for affected offsite areas of the emergency planning  !

none. This is consistent with federal guidance contained in Appendix 1 of NUREG-0654 and for Information Notice 83-23, ' Criteria for Protective Action Recommendations for General Emergencies,' May 4, 1983. The inspector found, however, that Attachment 1 of EPP 01-10.1 contained a decision making flowchart for the GE which did not recommend a minimum' of -

sheltering if projected doses were availablo and were less than protective actions guidelines. The minimum t reconsnendation to shelter the center subsone out to 2 miles, and 5 miles downwind should be made at the time a GE is detected, and should be independent of any does projections available. This will be considered an unresolved item pending the review of licensee t information requested concerning this observation.

Discussion:

EPP 01-10.1, Revision 6 ' Protective Action Reconunendations .' combined radiological and operational considerations into one chart utilising l

protective action guidelines. It was believed at the time of the change that the revision was still in compliance with the Radiological Emergency Response Pltn (RERP) and federal guidelines. It was not believed'to -be a decrease in the effectiveness of the plan.

The methodology in the attachment to the procedure indicated when projected dose assessments were less than protective action guidelines, the reconunendation of minimum sheltering was not made. It has subsequently been '

determined that this judgement was not correct. As pointed out by the inspector, this was not in compliance with the RERP or federal guidelines.

The root cause of this misjudgment was a procedural weakness in EPP 02-1.1,

' Emergency Planning Program', which did not explicitly require the review of EPP changes to ensure-compliance with the RERP.

P

• o Attachment to WH 90-0137

• Page 3 of 3 Resolution / Corrective Actions:

Procedure EPP 01-10.1. Attachment 1, will be revised to recommend shelter in a General Emergency independent of available dose projections. EPP 01-10.1 will be revised by August 17, 1990.

In addition, EPP 02-1.1, ' Emergency Planning Program', will be revised by August 29, 1990 to include a provision that the RERP shall be reviewed when ,

revising an EPP to ensure that procedure revisions comply with' the RERP. 3 This administrative control should eliminate future inconoistencies and assure the affectiveness of the plan is not decreased without prior NRC approval.

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