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Mi 91 -014 5 U. S. Nuclear Regulatory Cournission ATTN             Document Control Desk Hail Station pl-137 Washington. D. C.                                 20555
Mi 91 -014 5 U. S. Nuclear Regulatory Cournission ATTN Document Control Desk Hail Station pl-137 Washington. D. C.
20555


==Subject:==
==Subject:==
Docket No. 50 482: Kenponse to Exercise Weaknesses 482/9119-01, 482/9119-02, 482/92 "#-03 and 482/9119-04 Gentlemen This letter provides Wolf Creek Nuclear Operating Cor poration* <i                                                     (kCHOC) response to Exercise Weaknesses 482/9119-01, 482/9119-02. 482/9119-03 and 482/9119 04. Exercise Weakneen 482/9119-01 involved manual transmission and tracking of critical plant data.                                                   Weakness 482/9119-02 related to Technical Support Center Management.                                 Ve2kness 482/9119-03 addressed the failure to estahlinh and maintain habitability in the Emergency Response Fac111tien.
Docket No. 50 482:
Weaknese 482/9119-04 involved coordination and control of field monitoring teams.             As discussed between Mr. B. Jones. NRC and Mr. S. Videnan, WCNOC. en Oct ober 23, 1991, an ext ension t o Oct ober 30, 1991 was agreed upon.
Kenponse to Exercise Weaknesses 482/9119-01, 482/9119-02, 482/92 "#-03 and 482/9119-04 Gentlemen This letter provides Wolf Creek Nuclear Operating Cor poration* <i (kCHOC) response to Exercise Weaknesses 482/9119-01, 482/9119-02.
WCNOC has reviewed the available documentation and interviewed appropriate personnel.                                 based on the tesults of this review at d the interviews, WCNOC does not believe weaknesses 9119 64 and 9119-02 are valid and request these two findings be rnevaluated.                                                 The attschment containe the results of our               -
482/9119-03 and 482/9119 04.
review of the specifit weaknesses.
Exercise Weakneen 482/9119-01 involved manual transmission and tracking of critical plant data.
If you have any questions concerning this matter,                                                     please contact me or Hr. T. E. Cribbe of my staff.
Weakness 482/9119-02 related to Technical Support Center Management.
Ve2kness 482/9119-03 addressed the failure to estahlinh and maintain habitability in the Emergency Response Fac111tien.
Weaknese 482/9119-04 involved coordination and control of field monitoring teams.
As discussed between Mr. B. Jones. NRC and Mr. S. Videnan, WCNOC. en Oct ober 23, 1991, an ext ension t o Oct ober 30, 1991 was agreed upon.
WCNOC has reviewed the available documentation and interviewed appropriate personnel.
based on the tesults of this review at d the interviews, WCNOC does not believe weaknesses 9119 64 and 9119-02 are valid and request these two findings be rnevaluated.
The attschment containe the results of our review of the specifit weaknesses.
If you have any questions concerning this matter, please contact me or Hr. T. E. Cribbe of my staff.
Very truly nurs,
Very truly nurs,
                                                                                                                            'h '
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Bart D. Withern President and Chief Executive Officer Sa BDW/aem Onu
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s Attachment to Mt 91-0145 Page 1 of 9 Exercise Venkness       (487/9119-01):                                                   Hanual transmission and tracking of critical plant data was identified as a weakness.
s Attachment to Mt 91-0145 Page 1 of 9 Exercise Venkness (487/9119-01):
Kummple:     Operational status information was called into the TSC from the CR every 15 minutes.                                           There was no open or continuous phone lines between the facilities. As a result, the information flow represented a static picture of plant status during very dynamic phases of the exercise.                                                     This was also evidenced by the slowing                                                                                                   '
Hanual transmission and tracking of critical plant data was identified as a weakness.
of updates of the status boatds in the TSC of rapidly changing parameters such as hydrogen, temperature, pressure,                                                                                                                     and reactor vessel level indication.
Kummple:
Response:    Under actual accident conditions, the Nuclear Plant Information System (NPIS) is the primary method of transferring critical plant data between facilities.                                                                   This system has Operations Status Board displays which are automatically updated as data changes. During emergency drills, the plant simulator is used to simulate           the     plant                                         response                       to the accident scenario.
Operational status information was called into the TSC from the CR every 15 minutes.
Currently,             the plant simulator does not include the capability to provide plant data to the NPIS.                                                                                                                 As part of the plant                                           ,
There was no open or continuous phone lines between the facilities. As a result, the information flow represented a static picture of plant status during very dynamic phases of the exercise.
com; iter upgrade, thu simulator is being modified to allow it to                                                                                                                                                   '
This was also evidenced by the slowing of updates of the status boatds in the TSC of rapidly changing parameters such as hydrogen, temperature, pressure, and reactor vessel level indication.
driv: terminals located in the Technicel Support Center (TSC)                                                                                                                                                         j and Emergency Operations Facility (EOF) during exercises. These modificetions should be completed by February 1992,                                                                                                                           Since the NPIS could not be driven by the simulator f or the 3 991 exercise, the backup method of manually updating the Operations Status
 
                          - Boards was used.
===Response===
U9e       of         the       manual                                           method                                         involves                         sending                 the Operations Assessment Coordinator (OAC)                                                                                                             to   the     Control             Room (Simulator) per procedure to gather information and transmit it to the TSC. Gathering this information requires the OAC to move around the Control Room and record the information.                                                                                                                                 A time delay is inherent when compiling the information for the operations Status Boards using this method.                                                                                                             The information on                                           *
Under actual accident conditions, the Nuclear Plant Information System (NPIS) is the primary method of transferring critical plant data between facilities.
!                            the Operations Status Boards reflected the most recent data at l                             the time of posting.
This system has Operations Status Board displays which are automatically updated as data changes. During emergency drills, the plant simulator is used to simulate the plant response to the accident scenario.
I The Duty Emergency Director (DED) =and Operations Emergency Coordinator (OEC).                 In the TSC. were kept current on constantly changing information by communicating with the Control Room                                                                                                                                                         ,
Currently, the plant simulator does not include the capability to provide plant data to the NPIS.
l personnel.
As part of the plant com; iter upgrade, thu simulator is being modified to allow it to driv:
A 15 minute             updating                                           for       the                           backup manual posting of information does not seem unreasonable or untimely.                                                                                                                       The backup method. using 15 minute updating, has been used in the previous Wolf Creek Nuclear Operating Corporation (WCNOC) exercises.
terminals located in the Technicel Support Center (TSC) j and Emergency Operations Facility (EOF) during exercises.
Example:       The failure of the 'A' safety injection pump at 9:36                                                                                                                     a.m.           was
These modificetions should be completed by February 1992, Since the NPIS could not be driven by the simulator f or the 3 991 exercise, the backup method of manually updating the Operations Status
                          - not posted on the status boards.
- Boards was used.
Response:      The number of Safety Injection (SI) pumps and their status were indicated on the Operations Status Boards under the heading
U9e of the manual method involves sending the Operations Assessment Coordinator (OAC) to the Control Room (Simulator) per procedure to gather information and transmit it to the TSC. Gathering this information requires the OAC to move around the Control Room and record the information.
                              'ECCS'. The update of 0840 indicated the 'B' SI pump was out of service.       The update of 0940 indicated the number                                                                                                         of SI pumps as 0 (thus identifying the failure of the 'A' pump).
A time delay is inherent when compiling the information for the operations Status Boards using this method.
The information on the Operations Status Boards reflected the most recent data at l
the time of posting.
I The Duty Emergency Director (DED) =and Operations Emergency Coordinator (OEC).
In the TSC. were kept current on constantly changing information by communicating with the Control Room l
personnel.
A 15 minute updating for the backup manual posting of information does not seem unreasonable or untimely.
The backup method. using 15 minute updating, has been used in the previous Wolf Creek Nuclear Operating Corporation (WCNOC) exercises.
Example:
The failure of the
'A' safety injection pump at 9:36 a.m.
was
- not posted on the status boards.
 
===Response===
The number of Safety Injection (SI) pumps and their status were indicated on the Operations Status Boards under the heading
'ECCS'.
The update of 0840 indicated the
'B' SI pump was out of service.
The update of 0940 indicated the number of SI pumps as 0 (thus identifying the failure of the
'A' pump).
i
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Attachment to VH 91 0145                                                                                                     i Page 2 of 9                                                                                                               ,
Attachment to VH 91 0145 i
Exampics   The operatienal status board went as long as 23 minutes between updates (9:23-9:45 a.m.).             A similar problem was noted in the EOF in that the radiological status board data was not updated after 11:35 a.m. (the exercise lasted until about 2 p.m.).
Page 2 of 9 Exampics The operatienal status board went as long as 23 minutes between updates (9:23-9:45 a.m.).
Responsen   Review of the TSC and EOF Operations Status Board sheets show                                                 ,
A similar problem was noted in the EOF in that the radiological status board data was not updated after 11:35 a.m. (the exercise lasted until about 2 p.m.).
only one update which exceeded 19 minutes.                                           It is possible 23 minutes may have elapsed from the previous posting time to the time the board was actually updated.                                       This time lapse is due to the normal activities required to transmit data and change it on the status boards and is not considered excessive for isolated cases. A review of the status board sheets indicates the majority of updates were performed within 15 minutes.                                                         l l
Responsen Review of the TSC and EOF Operations Status Board sheets show only one update which exceeded 19 minutes.
Review of the EOF Radiological Status Boards sh.eet s show that these boards were updated until 1330.                                         Following EOF activation at 0957   Radiological Status Board updates were approximately every 15 minutes with two exceptions of 23 and 22 minutes.                                           EPP 01-11.2. ' Status Boards' will be evaluated to determine if any additional enhancements are necessary to improve the process for
It is possible 23 minutes may have elapsed from the previous posting time to the time the board was actually updated.
* updating the status boards. This evaluation and any necessary procedure changes will be completed by December 1$. 1991.
This time lapse is due to the normal activities required to transmit data and change it on the status boards and is not considered excessive for isolated cases.
For manual transmission of status board information, these times are not considered excessive.                   Immediate updates from Control Room personnel were available to the DED and Duty Emergency Manager (DEH).
A review of the status board sheets indicates the majority of updates were performed within 15 minutes.
Example:   Containment hydrogen was not displayed on any board, Response:  The operations Status Boards in both the TSC and EOF display a heading. ' Containment Conditions'.                       Under this heading hydrogen is listed by percent volume.                       Review of the TSC and EOF Operations Status Board sheets indicate. Containment Conditions.
l l
                                  'H2 Conc. 2 vol' was updated from 0940 until 1345.
Review of the EOF Radiological Status Boards sh.eet s show that these boards were updated until 1330.
Example:   Critical safety function status was                                       in error at times         (as an example,     10:19 a.m. when containment was yellow,                                     yet the status board showed it to be green).
Following EOF activation at 0957 Radiological Status Board updates were approximately every 15 minutes with two exceptions of 23 and 22 minutes.
Responsen Review of the TSC and EOF Operations Status Board                                           sheets does not indicate containment- to have been marked green.                                               These sheets identified containment status as yellow,                                             starting at 0950.
EPP 01-11.2. ' Status Boards' will be evaluated to determine if any additional enhancements are necessary to improve the process for updating the status boards.
Example:   The status boards in the TSC had no provisions for showing historical trends,   and the engineering group was observed to only sporadically trend two or three parameters.                                           Thero was no       '
This evaluation and any necessary procedure changes will be completed by December 1$. 1991.
plot generated, for example, of containment pressure between 11:20 a.m.     and 12:45 p.m.                     the period during which the containment equipment hatch was leaking.                                       In addition, there was no display of trended information in the EOF until very late in the exercise.
For manual transmission of status board information, these times are not considered excessive.
        . . - - - - -                            -  . _-                            -                    -.    .-              -- . u. - -
Immediate updates from Control Room personnel were available to the DED and Duty Emergency Manager (DEH).
Example:
Containment hydrogen was not displayed on any board,
 
===Response===
The operations Status Boards in both the TSC and EOF display a heading. ' Containment Conditions'.
Under this heading hydrogen is listed by percent volume.
Review of the TSC and EOF Operations Status Board sheets indicate. Containment Conditions.
'H2 Conc.
2 vol' was updated from 0940 until 1345.
Example:
Critical safety function status was in error at times (as an example, 10:19 a.m.
when containment was yellow, yet the status board showed it to be green).
Responsen Review of the TSC and EOF Operations Status Board sheets does not indicate containment-to have been marked green.
These sheets identified containment status as yellow, starting at 0950.
Example:
The status boards in the TSC had no provisions for showing historical trends, and the engineering group was observed to only sporadically trend two or three parameters.
Thero was no plot generated, for example, of containment pressure between 11:20 a.m.
and 12:45 p.m.
the period during which the containment equipment hatch was leaking.
In addition, there was no display of trended information in the EOF until very late in the exercise.
--. u. - -


i t'
i t'
Attachment to VH 91-0145 Page 3 of 9 i
Attachment to VH 91-0145 Page 3 of 9 i
Response:    The Engineering Team in the TSC trended four parameters.
Hydrogen was trended from 1000 when it first started increasing (0.02) until    1215,    after the hydrogen burn which had taken                !
hydrogen to O!.                                                                  l Reactor Vessel Level Indication System (RVLIS) was trended from 0900 to 1045 when it read 100 per cent.            At this point the Engineering Team detereined a bubble had been created and the readings on RVLIS were rot reliable.
The incore high ivtrag        ther-Teouple  (T/C) temperature was trended fro.t 0930 intil 10's ww' it dropped to below 400 F0 and                  '
it was no longer co'eideivc n essary to trend this parameter.
The conta'.nment pressure was trended from 0830 untJ' 1120.        The          ;
release started at 1103 end was verified to be occurring at 1107. At 1113 the Engineering Teams in the Tsc and EOF were working on ways to reduce or stop the release.        This included use of containment spray and sealing the hatch.      During the time period of 1120 until 1245 the Engineering Teams had shifted their efforts to these more critical activities and away from plotting the trends of the containment pressure,          which had stabilized. References in the Engineering Team's- and the Exercise Controller's logs indicated containment      pressute was being monitored during the 1120 to 1245 time period.          The EOF began trending at 1039 on the Operations Status Boards.          This was  42 minutes after EOF activation, and 24 minutos before the hydrogen burn. The TSC was keeping the EOF notified of the trends they were performing.
Based on the above, WCNOC concludes trending of plant parameters was  being performed during the exercise except during the time the Engineering Teams concentrated their 6fforts on what was r                      considered a more critical activity.
The example also dealt with lack of provisions f r displaying trends on the Operations Status Boards.      This is an area WCNOC will  review as a possible enhancement.          The displaying of trending on the TSC Operations Status Board and guidance in EPP 01-2.3  ' Accident Assessment and Mitigation' on trending will be reviewed and any appropriate enhancements completed by February 24, 1992.
Example:    The slow and incomplete updating af TSC status boards.      combined with a lack of provisions for trending data as required by EPP 01-2.3      reduced the effectiveness of analysis and support activities in the TSC.                                                          ,
Reeponse:    Time delays are inherent in use of the backup manual method of updating the status boards. Information contained on the status boards reflects only that point in time when the boards are posted. A nominal fifteen minute time lapse between updates on the status boards is not considered unreasonable.


S      .
===Response===
Attachment to WM 91-0145 page 4 of 9 Exercise   Venkness (462/9119-02):                                   The inspectors found that the TSC management applied a nonconservative and unanticipatory                                                             approach           to Important technical assessments performed by TSC staff.
The Engineering Team in the TSC trended four parameters.
Herponse   WCh0C believes that NRC's conclusions regarding this weakness results from an incorrect assumption on plant parameters.
Hydrogen was trended from 1000 when it first started increasing (0.02) until
The examples and assumptions supporting this weakness have been reviewed against the exercise logs.                                     Additionally,                       interviews have been conducted with TSC personnel.                                               The results are identified below.
: 1215, after the hydrogen burn which had taken hydrogen to O!.
Example:   During the period 10:05 to 10:15 a.m.                                   with the classification at                                                 !
l Reactor Vessel Level Indication System (RVLIS) was trended from 0900 to 1045 when it read 100 per cent.
Site Area Emergency, containment parameters transmitted to the TSC clearly indicated a containment leak or failure.                                                       While the scenario had not intended f or data to show a containment breach until about Il a.m.                                 simulator modeling problems occurred during the   period                         in question such that containment temperattre increased, pressure decreased, and radiation monitors decreased.
At this point the Engineering Team detereined a bubble had been created and the readings on RVLIS were rot reliable.
The incore high ivtrag ther-Teouple (T/C) temperature was 0
trended fro.t 0930 intil 10's ww' it dropped to below 400 F and it was no longer co'eideivc n essary to trend this parameter.
The conta'.nment pressure was trended from 0830 untJ' 1120.
The release started at 1103 end was verified to be occurring at 1107.
At 1113 the Engineering Teams in the Tsc and EOF were working on ways to reduce or stop the release.
This included use of containment spray and sealing the hatch.
During the time period of 1120 until 1245 the Engineering Teams had shifted their efforts to these more critical activities and away from plotting the trends of the containment pressure, which had stabilized.
References in the Engineering Team's-and the Exercise Controller's logs indicated containment pressute was being monitored during the 1120 to 1245 time period.
The EOF began trending at 1039 on the Operations Status Boards.
This was 42 minutes after EOF activation, and 24 minutos before the hydrogen burn.
The TSC was keeping the EOF notified of the trends they were performing.
Based on the above, WCNOC concludes trending of plant parameters was being performed during the exercise except during the time the Engineering Teams concentrated their 6fforts on what was r
considered a more critical activity.
The example also dealt with lack of provisions f r displaying trends on the Operations Status Boards.
This is an area WCNOC will review as a possible enhancement.
The displaying of trending on the TSC Operations Status Board and guidance in EPP 01-2.3
' Accident Assessment and Mitigation' on trending will be reviewed and any appropriate enhancements completed by February 24, 1992.
Example:
The slow and incomplete updating af TSC status boards.
combined with a lack of provisions for trending data as required by EPP 01-2.3 reduced the effectiveness of analysis and support activities in the TSC.
Reeponse:
Time delays are inherent in use of the backup manual method of updating the status boards.
Information contained on the status boards reflects only that point in time when the boards are posted. A nominal fifteen minute time lapse between updates on the status boards is not considered unreasonable.
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S Attachment to WM 91-0145 page 4 of 9 Exercise Venkness (462/9119-02):
The inspectors found that the TSC management applied a nonconservative and unanticipatory approach to Important technical assessments performed by TSC staff.
Herponse WCh0C believes that NRC's conclusions regarding this weakness results from an incorrect assumption on plant parameters.
The examples and assumptions supporting this weakness have been reviewed against the exercise logs.
Additionally, interviews have been conducted with TSC personnel.
The results are identified below.
Example:
During the period 10:05 to 10:15 a.m.
with the classification at Site Area Emergency, containment parameters transmitted to the TSC clearly indicated a containment leak or failure.
While the scenario had not intended f or data to show a containment breach until about Il a.m.
simulator modeling problems occurred during the period in question such that containment temperattre increased, pressure decreased, and radiation monitors decreased.
This was at a time when the loss-of-coolant accident (LOCA) had caused the source term in containment to measure up to 1E6 R/h...
This was at a time when the loss-of-coolant accident (LOCA) had caused the source term in containment to measure up to 1E6 R/h...
Response   During the period in question,                                   1005 to 1015 Operation Status Board sheets indicated containment temperature was decreasing (instead of increasing), containment pressure was decreasing, and Containment High Area Radiation Monitors (CHARMS) were increasing (not decreasing).                                 When the Loss of Coolant Accident                             (LOCA) occurred at 0930,                                   the CHARMS ware reading 0 and dxd not start incremaing until 0940.
 
Example:   ... Acting on this data,                               both the cose assessment coordinator and the engineering group tried to convince the management desk that a breach had occurred.                                     Both reports were dismissed.                                     An alternative explanation for the data was given by TSC managers as the effects of the containment cooler fans which had been started about   10 minutes earlier.                                     Monitoring teams were ordered                                                     .
===Response===
dispatched to take measurements around the containment to confirm whether a release was in prog ess                                       however, no direction was given to the technical support groups to increase the frequency and trending of key parameters...
During the period in question, 1005 to 1015 Operation Status Board sheets indicated containment temperature was decreasing (instead of increasing), containment pressure was decreasing, and Containment High Area Radiation Monitors (CHARMS) were increasing (not decreasing).
Response:  Interviews have been conducted with the Technical                                                               Support Coordinator (Engineering Team Leader), the Radiological Emergency                                                                                   ,
When the Loss of Coolant Accident (LOCA) occurred at 0930, the CHARMS ware reading 0 and dxd not start incremaing until 0940.
Coordinator (REC),                                 and the Operations Emergency coordinator (OEC).
Example:
... Acting on this data, both the cose assessment coordinator and the engineering group tried to convince the management desk that a breach had occurred.
Both reports were dismissed.
An alternative explanation for the data was given by TSC managers as the effects of the containment cooler fans which had been started about 10 minutes earlier.
Monitoring teams were ordered dispatched to take measurements around the containment to confirm whether a release was in prog ess
: however, no direction was given to the technical support groups to increase the frequency and trending of key parameters...
 
===Response===
Interviews have been conducted with the Technical Support Coordinator (Engineering Team Leader), the Radiological Emergency Coordinator (REC),
and the Operations Emergency coordinator (OEC).
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7 Attarhment to WM 91-0145 page 5 of 9                                                                                                       :
7 Attarhment to WM 91-0145 page 5 of 9 The Technical Support Cootdinator stated that the Engineering Team initially considered a cont ainment breach due to the indication that containment pressure was decreasing and reported this to the OEC and DED.
The Technical Support Cootdinator stated that the Engineering Team initially considered a cont ainment breach due to the indication that containment pressure was decreasing and reported this to the OEC and DED.                 The OEC believed that the starting of containment cooling fans was the cause of the pressure and temperature decrease.                   The   Technical             Support   Coordinator considered this to be a reasonable explanation.                         (The containment pressure and temperature trends are consistent with the expected response f ou containment coolers after a LOCA.                             This has been verified witn computer simulation by the WCNOC Nuclear Safety Analysis Group.)
The OEC believed that the starting of containment cooling fans was the cause of the pressure and temperature decrease.
The REC recorted the dose projections were increasing based on Cl! ARMS readings and decreasing containment pressure, however,                         he did not try to convey this as an indication of a release.                             The REC also suggested that monitoring teams be dispatched to the containment building.
The Technical Support Coordinator considered this to be a reasonable explanation.
Neither the REC nor the Technical Support Coordinator felt their reports had been dismissed. They both stated they considered the DED was correct in the actions he took.
(The containment pressure and temperature trends are consistent with the expected response f ou containment coolers after a LOCA.
Example     ...Hennwhile,       the Emergency Director in the EOF did declare a General Emergency at 10:27 a.m.                 based on degrading containment conditions and hydrogen levels.                 Decpite the EOF making the proper       classification and protective action recommendations (pars) based on plant conditions at 10:27 a.m.,                         the TSC managers               ,
This has been verified witn computer simulation by the WCNOC Nuclear Safety Analysis Group.)
assessed       the   indications of a containment leak neither conservatively, nor in keeping with the anticipatory nature of NUREG 06$4.
The REC recorted the dose projections were increasing based on Cl! ARMS readings and decreasing containment pressure, however, he did not try to convey this as an indication of a release.
Response: The DED in a telephone conversation at 1019 wit.h the DEH, who was in command and control,               explained the containment conditions and dose projections as reported by the OEC. Technical Support Coordinator, and REC. The DED did not dismiss any of the reports made by his staff..                   He immediately informed the DEM of the reports       since   the           decision to upgrade                 the   emergency classification was the DEH's.                     The DEM was aware of the containment conditions and had already decided to upgrade the classification.         The DEM informed the DED he would be upgrading to a General Emergency based on evaccation times,                             containment conditions, and increasing hydrogen concentration.
The REC also suggested that monitoring teams be dispatched to the containment building.
The DEH gave a briefing at 1020 to the EOF personnel on plant status and upgrading to a General Emergency.                                 The General Emergency declaration was made at 1025.                     No inappropriate delays occurred in upgrading to a General Emergency.
Neither the REC nor the Technical Support Coordinator felt their reports had been dismissed.
They both stated they considered the DED was correct in the actions he took.
Example
...Hennwhile, the Emergency Director in the EOF did declare a General Emergency at 10:27 a.m.
based on degrading containment conditions and hydrogen levels.
Decpite the EOF making the proper classification and protective action recommendations (pars) based on plant conditions at 10:27 a.m.,
the TSC managers assessed the indications of a containment leak neither conservatively, nor in keeping with the anticipatory nature of NUREG 06$4.
Response: The DED in a telephone conversation at 1019 wit.h the DEH, who was in command and control, explained the containment conditions and dose projections as reported by the OEC.
Technical Support Coordinator, and REC. The DED did not dismiss any of the reports made by his staff..
He immediately informed the DEM of the reports since the decision to upgrade the emergency classification was the DEH's.
The DEM was aware of the containment conditions and had already decided to upgrade the classification.
The DEM informed the DED he would be upgrading to a General Emergency based on evaccation times, containment conditions, and increasing hydrogen concentration.
The DEH gave a briefing at 1020 to the EOF personnel on plant status and upgrading to a General Emergency.
The General Emergency declaration was made at 1025.
No inappropriate delays occurred in upgrading to a General Emergency.
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Attachment to tal 91-0145 Page 6 of 9 Ksamplo:       The inspectors noted a similar concern in the TSC with respect to radiological assessment and protective action recommendations.
Attachment to tal 91-0145 Page 6 of 9 Ksamplo:
Prior to the exercise controllers had stipulated that they would limit to 2 hours or less, the release duration to be used in dose projections.     This was intended to avoid exceeding Environmental Protection Agency (EPA) protective action guidelines beyond the 10-mile emergency planning zone.
The inspectors noted a similar concern in the TSC with respect to radiological assessment and protective action recommendations.
Because of perturbations in the simulator code,             containment pressure parameters behaved differently than predicted in the scenario.     Between about 10:44 and 11:31 a.m..           TSC dose assessment     personnel,       using containment atmosphere sample results,   containment radiation monitor data,         and containment pressure, computed child thy.old dose rates in the range of 54 to 1317 R/h at 10 miles...
Prior to the exercise controllers had stipulated that they would limit to 2 hours or less, the release duration to be used in dose projections.
Responsen Dose projections were made based on the Contaimnent Release Design Basis Accident Model.             Dose Assessment personnel used CHARMS readings and containment pressure. The child thyroid dose rate > of $4 to 1317 R/h at 10 miles are taken from the dose projection at 1053.         The dose projection was performed using a   t leak rate based on a total drop in pressure for thirty minutes         i far a worst case condition. The dose projection was not based on the actual condit4ons at the time.
This was intended to avoid exceeding Environmental Protection Agency (EPA) protective action guidelines beyond the 10-mile emergency planning zone.
1 The pressure drop was actually due to containment coolers as noted by the OEC and not due to a actual leak.         As stated ir,the ;
Because of perturbations in the simulator code, containment pressure parameters behaved differently than predicted in the scenario.
inspection report only a two hour or less release duration was to be used.
Between about 10:44 and 11:31 a.m..
Examples       Rather than acting upon these results and making PARS for evacuation of personnel beyond 10 miles, the licensee chose to         ,
TSC dose assessment personnel, using containment atmosphere sample
;                                  rely upon field monitoring data collected after 11:40 a.m.         tor l                                   dose assessment purposes.         This became more of a concern when considered with the fact that field monitoring teams only contacted the plume on one occasion, as discussed in paragraph
: results, containment radiation monitor data, and containment pressure, computed child thy.old dose rates in the range of 54 to 1317 R/h at 10 miles...
: 7. As the scenario developed.       it was indicative of severe core damage and early containment f ailure and should hnve been trenced accordingly.
Responsen Dose projections were made based on the Contaimnent Release Design Basis Accident Model.
Response: The General Emergency was declared at 1025 by the DEM who had command   and   control     at   the   EOF. Protective Action Recommendations       (PARS) were made at that time to evacuate
Dose Assessment personnel used CHARMS readings and containment pressure.
!                                  downwind subrot.es out to 10 miles.       The County concurred with the PARS and implemented them at 1040.
The child thyroid dose rate > of $4 to 1317 R/h at 10 miles are taken from the dose t
The Emergency Planning tone (EPZ)         for Wolf Creek Generating Station (WCGS) is described in the P.adiological Emergency Response Plan and is an approximate 10 mile radius circle with its center at WCGS.           Responsibility for protective actions outside the EPZ abide with appropriate local and state agencies.
projection at 1053.
The dose projection was performed using a leak rate based on a total drop in pressure for thirty minutes i
far a worst case condition. The dose projection was not based on the actual condit4ons at the time.
1 The pressure drop was actually due to containment coolers as noted by the OEC and not due to a actual leak.
As stated ir,the inspection report only a two hour or less release duration was to be used.
Examples Rather than acting upon these results and making PARS for evacuation of personnel beyond 10 miles, the licensee chose to rely upon field monitoring data collected after 11:40 a.m.
tor l
dose assessment purposes.
This became more of a concern when considered with the fact that field monitoring teams only contacted the plume on one occasion, as discussed in paragraph 7.
As the scenario developed.
it was indicative of severe core damage and early containment f ailure and should hnve been trenced accordingly.
Response: The General Emergency was declared at 1025 by the DEM who had command and control at the EOF.
Protective Action Recommendations (PARS) were made at that time to evacuate downwind subrot.es out to 10 miles.
The County concurred with the PARS and implemented them at 1040.
The Emergency Planning tone (EPZ) for Wolf Creek Generating Station (WCGS) is described in the P.adiological Emergency Response Plan and is an approximate 10 mile radius circle with its center at WCGS.
Responsibility for protective actions outside the EPZ abide with appropriate local and state agencies.
WCNOC cooperates with these agencies and provides support and assistance as appropriate.
WCNOC cooperates with these agencies and provides support and assistance as appropriate.
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4                                     ..
4 Attachment to WH 91 014$
Attachment to WH 91 014$
Page 7 of 9 Dose projections were based on the worst case situation with no confirmation of a release in progress.
Page 7 of 9 Dose projections were based on the worst case situation with no confirmation of a release in progress.                   Honitoring teams were already in place downwind of the plant.
Honitoring teams were already in place downwind of the plant.
At 1103 the release started and at 1107 the Red Team reported 100                                   t mR/hr 3/4 mile downwinC.               The TSC performed a dose calculation at 1113 based on the monitoring team's data.                         This projection estimated a child thyroid dose rate of 0.061 R/h at 10 miles and a dose ut 0.122 R for a 2 hour exposure at 10 miles.                         The EOF perfoamed a similar dose projection at 1115 estimating a child thyroid dose rete of 0.753 R/h at 10 miles and a dose of 1.$07 R for a 2 hour exposure at 10 miles.
At 1103 the release started and at 1107 the Red Team reported 100 t
At 1118 the Blue Team reported a reading of 10 mk/h 2 miles downwind.           The projection from the TSC at 1123 estimated a child                         !
mR/hr 3/4 mile downwinC.
thyroid dose rate of 0.035 R/h at 10 miles and a dose of 0.07 R for a 2 hour exposure at 10 miles.
The TSC performed a dose calculation at 1113 based on the monitoring team's data.
At 2130 the Blue Team reported a reading of 200 mR/hr 2 miles downwind.             The TSC projected the dose at 1133.               indicating a               ,
This projection estimated a child thyroid dose rate of 0.061 R/h at 10 miles and a dose ut 0.122 R for a 2 hour exposure at 10 miles.
child thyroid dose rate of 0.701 R/h at 10 miles and-a dose of 1.403 R for a 2 hour exposure at 10 miles. The EOF projected the dose at 1135.               This projection estimated a child thyroid dose rate of 0.753 R/h at 10 miles and a dose of 1.507 R for a 2 hour exposure at 10 miles.
The EOF perfoamed a similar dose projection at 1115 estimating a child thyroid dose rete of 0.753 R/h at 10 miles and a dose of 1.$07 R for a 2 hour exposure at 10 miles.
k Honitoring team data was available at 3107 (instead of 1140 as stated in the report).               The monitoring teams contacted the plume                     '
At 1118 the Blue Team reported a reading of 10 mk/h 2 miles downwind.
twice,           approximately 3/4 of a mile downwind and at 2 miles-                             '
The projection from the TSC at 1123 estimated a child thyroid dose rate of 0.035 R/h at 10 miles and a dose of 0.07 R for a 2 hour exposure at 10 miles.
downwind.
At 2130 the Blue Team reported a reading of 200 mR/hr 2 miles downwind.
The TSC projected the dose at 1133.
indicating a child thyroid dose rate of 0.701 R/h at 10 miles and-a dose of 1.403 R for a 2 hour exposure at 10 miles.
The EOF projected the dose at 1135.
This projection estimated a child thyroid dose rate of 0.753 R/h at 10 miles and a dose of 1.507 R for a 2 hour exposure at 10 miles.
k Honitoring team data was available at 3107 (instead of 1140 as stated in the report).
The monitoring teams contacted the plume
: twice, approximately 3/4 of a mile downwind and at 2 miles-downwind.
Dose Assessment personnel in the TSC and EOF both performed dose
Dose Assessment personnel in the TSC and EOF both performed dose
                                                                                                                                      -calculations,             compared. results for concurrence, and notified management of the results. The decision for making PARS was with the DEH in the EOF during the time period of 1044 to 1131.                       PARS were conservative and timely.
-calculations, compared. results for concurrence, and notified management of the results. The decision for making PARS was with the DEH in the EOF during the time period of 1044 to 1131.
TSC Hanagement used their best' judgement in assessing the plant conditions- and           radiological consequences.             VCNOC's review indicates a conservative and anticipatory approach was used on important technical assessments based on the information that was available.           The role of the TSC when the EOF has command and control is to support the EOF.                         This role was fulfilled throughout the exercise.             -The EOF used information supplied by.
PARS were conservative and timely.
the TSC to properly assess the- situation and make timely L                                                                                                                                         classifications and PARS.               At all times during the exercise.
TSC Hanagement used their best' judgement in assessing the plant conditions-and radiological consequences.
VCNOC's review indicates a conservative and anticipatory approach was used on important technical assessments based on the information that was available.
The role of the TSC when the EOF has command and control is to support the EOF.
This role was fulfilled throughout the exercise.
-The EOF used information supplied by.
the TSC to properly assess the-situation and make timely L
classifications and PARS.
At all times during the exercise.
protection of the public health and safety was the primary
protection of the public health and safety was the primary
                                                                                                                                        -concern.
-concern.
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Attachment to WM 91-0145 Page 8 of 9 Exercise Venknees_ '4d?/9119-03):       The failure of the licensee to establish and maintain habitability       in the emergency response       facilities   was identified as an exercise weakness.
Attachment to WM 91-0145 Page 8 of 9 Exercise Venknees_ '4d?/9119-03):
l Responses Control Room                                                             1 l
The failure of the licensee to establish and maintain habitability in the emergency response facilities was identified as an exercise weakness.
back of procedural guidance is the primary reason for this             '
Responses Control Room 1
weakness.     Procedure EPP 01-1.0 ' Control Room Organization
back of procedural guidance is the primary reason for this weakness.
* will I be revised to provide guidance to appropriate personnel       in the   ;
Procedure EPP 01-1.0 ' Control Room Organization
i following areast 1.)   Establish access control for the Control Room               1 I
* will be revised to provide guidance to appropriate personnel in the i
2.)   Performance of habitability surveys in the       Control Room 3.)   Dosimetry in the Control Room 4.)   Control Room habitability operatious support Center (OSC)
following areast 1.)
A low background area was not available in the OSC to at:61yze air and swipe samples.       To provide a method for lowering background readings, lead bricks have been placed in the OSC. TSC and the EOF.     Procedures EPP 01-1.1 'WCGS Organization' and EPP 03-1.2
Establish access control for the Control Room I
2.)
Performance of habitability surveys in the Control Room 3.)
Dosimetry in the Control Room 4.)
Control Room habitability operatious support Center (OSC)
A low background area was not available in the OSC to at:61yze air and swipe samples.
To provide a method for lowering background
: readings, lead bricks have been placed in the OSC.
TSC and the EOF.
Procedures EPP 01-1.1 'WCGS Organization' and EPP 03-1.2
* Emergency Operatt.ons Pacility Emergency Organization
* Emergency Operatt.ons Pacility Emergency Organization
* will be revised     to   provide guidance to appropriate personnel for utilization of lead bricks when background is too high to accurately count samples.
* will be revised to provide guidance to appropriate personnel for utilization of lead bricks when background is too high to accurately count samples.
Technical Support Cent 9r Lack of procedural guidance is the primary reason for this weakness.       Procedure EPP   01-4.1 ' Technical Support     Center Activation
Technical Support Cent 9r Lack of procedural guidance is the primary reason for this weakness.
* will be revised to provide guidance to ensure the airlock door is closed.     The door seals will be replaced and signs will be placed on the door,       identifying that it is to be closed during activation and operation of the *SC by December 10, 1991. Procedure EPP 02-1.5 'Haintenance of Emergency Facilities and Equipment
Procedure EPP 01-4.1
' Technical Support Center Activation
* will be revised to provide guidance to ensure the airlock door is closed.
The door seals will be replaced and signs will be placed on the door, identifying that it is to be closed during activation and operation of the *SC by December 10, 1991.
Procedure EPP 02-1.5 'Haintenance of Emergency Facilities and Equipment
* will be revised to require a periodic inspection of seals on airlock doors in emergency facilities.
* will be revised to require a periodic inspection of seals on airlock doors in emergency facilities.
Procedure changes will be completed by December 16,         1991 and training for appropriate personnel will be completed by March 16, 1992.
Procedure changes will be completed by December 16, 1991 and training for appropriate personnel will be completed by March 16, 1992.
: s. , ,        ,                                                                                                                                                                                                    j i
 
i Attachineat to VM 91-014$
j s.
Page 9 of 9 Exercise                                     Weakness                             (48?/9119-04):   Poor coordination and control of monitoring teams was identified as an exercise weakness.
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Rosponse: The reason for this weakness has beon determined to be a lack of                                                                                                               I procedural guidance.                             Procedure EPP 01-1.2 ' Emergency Operations                                               !
Attachineat to VM 91-014$
Facility Emergency Organization'                                 will be revised to provide additional guidance on the deployment, control, and coordination of monitoring teams,                             Guidance will also expand instructions 1 minimiting exposure to monitoring team members.                                                 Procedures EPP                           I 01-8.2 *0ffsite Radiological Honitoring' and EPP 01-8.3 ' Joint                                                                           ;
Page 9 of 9 Exercise Weakness (48?/9119-04):
Radiological Honitoring Teams Formation and Operation' will be                                                                             ;
Poor coordination and control of monitoring teams was identified as an exercise weakness.
revised to include checklists that will require the monitoring teams to take self contained breathing apparatus with them when deployed.
Rosponse: The reason for this weakness has beon determined to be a lack of procedural guidance.
Procedure changes will be completed by December 16,                                                                 1991 and
Procedure EPP 01-1.2 ' Emergency Operations Facility Emergency Organization' will be revised to provide additional guidance on the deployment, control, and coordination of monitoring teams, Guidance will also expand instructions 1 minimiting exposure to monitoring team members.
                                                                        -training for appropriate personnel will be completed by March 16, 1992.                                                                                                                                     ;
Procedures EPP I
01-8.2 *0ffsite Radiological Honitoring' and EPP 01-8.3
' Joint Radiological Honitoring Teams Formation and Operation' will be revised to include checklists that will require the monitoring teams to take self contained breathing apparatus with them when deployed.
Procedure changes will be completed by December 16, 1991 and
-training for appropriate personnel will be completed by March 16, 1992.
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Latest revision as of 23:11, 14 December 2024

Responds to Exercise Weaknesses 482/9119-01,482/9119-02, 482/9119-03 & 482/9119-04 Re Manual Transmission & Tracking of Critical Plant Data,Technical Support Ctr Mgt & Failure to Establish & Maintain Habitability in Emergency Facility
ML20079L567
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 10/30/1991
From: Withers B
WOLF CREEK NUCLEAR OPERATING CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
WM-91-0145, WM-91-145, NUDOCS 9111060389
Download: ML20079L567 (10)
v • d • e


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NUCLEAR OPEfWING CORPOfWION i

n.vt n w'",v"i Uc t olmr 30, 1991 e, e w.mi.

O Po.it i e e s olie e PtSt v.

Mi 91 -014 5 U. S. Nuclear Regulatory Cournission ATTN Document Control Desk Hail Station pl-137 Washington. D. C.

20555

Subject:

Docket No. 50 482:

Kenponse to Exercise Weaknesses 482/9119-01, 482/9119-02, 482/92 "#-03 and 482/9119-04 Gentlemen This letter provides Wolf Creek Nuclear Operating Cor poration* of $4 to 1317 R/h at 10 miles are taken from the dose t

projection at 1053.

The dose projection was performed using a leak rate based on a total drop in pressure for thirty minutes i

far a worst case condition. The dose projection was not based on the actual condit4ons at the time.

1 The pressure drop was actually due to containment coolers as noted by the OEC and not due to a actual leak.

As stated ir,the inspection report only a two hour or less release duration was to be used.

Examples Rather than acting upon these results and making PARS for evacuation of personnel beyond 10 miles, the licensee chose to rely upon field monitoring data collected after 11:40 a.m.

tor l

dose assessment purposes.

This became more of a concern when considered with the fact that field monitoring teams only contacted the plume on one occasion, as discussed in paragraph 7.

As the scenario developed.

it was indicative of severe core damage and early containment f ailure and should hnve been trenced accordingly.

Response: The General Emergency was declared at 1025 by the DEM who had command and control at the EOF.

Protective Action Recommendations (PARS) were made at that time to evacuate downwind subrot.es out to 10 miles.

The County concurred with the PARS and implemented them at 1040.

The Emergency Planning tone (EPZ) for Wolf Creek Generating Station (WCGS) is described in the P.adiological Emergency Response Plan and is an approximate 10 mile radius circle with its center at WCGS.

Responsibility for protective actions outside the EPZ abide with appropriate local and state agencies.

WCNOC cooperates with these agencies and provides support and assistance as appropriate.

l

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4 Attachment to WH 91 014$

Page 7 of 9 Dose projections were based on the worst case situation with no confirmation of a release in progress.

Honitoring teams were already in place downwind of the plant.

At 1103 the release started and at 1107 the Red Team reported 100 t

mR/hr 3/4 mile downwinC.

The TSC performed a dose calculation at 1113 based on the monitoring team's data.

This projection estimated a child thyroid dose rate of 0.061 R/h at 10 miles and a dose ut 0.122 R for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure at 10 miles.

The EOF perfoamed a similar dose projection at 1115 estimating a child thyroid dose rete of 0.753 R/h at 10 miles and a dose of 1.$07 R for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure at 10 miles.

At 1118 the Blue Team reported a reading of 10 mk/h 2 miles downwind.

The projection from the TSC at 1123 estimated a child thyroid dose rate of 0.035 R/h at 10 miles and a dose of 0.07 R for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure at 10 miles.

At 2130 the Blue Team reported a reading of 200 mR/hr 2 miles downwind.

The TSC projected the dose at 1133.

indicating a child thyroid dose rate of 0.701 R/h at 10 miles and-a dose of 1.403 R for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure at 10 miles.

The EOF projected the dose at 1135.

This projection estimated a child thyroid dose rate of 0.753 R/h at 10 miles and a dose of 1.507 R for a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> exposure at 10 miles.

k Honitoring team data was available at 3107 (instead of 1140 as stated in the report).

The monitoring teams contacted the plume

twice, approximately 3/4 of a mile downwind and at 2 miles-downwind.

Dose Assessment personnel in the TSC and EOF both performed dose

-calculations, compared. results for concurrence, and notified management of the results. The decision for making PARS was with the DEH in the EOF during the time period of 1044 to 1131.

PARS were conservative and timely.

TSC Hanagement used their best' judgement in assessing the plant conditions-and radiological consequences.

VCNOC's review indicates a conservative and anticipatory approach was used on important technical assessments based on the information that was available.

The role of the TSC when the EOF has command and control is to support the EOF.

This role was fulfilled throughout the exercise.

-The EOF used information supplied by.

the TSC to properly assess the-situation and make timely L

classifications and PARS.

At all times during the exercise.

protection of the public health and safety was the primary

-concern.

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Attachment to WM 91-0145 Page 8 of 9 Exercise Venknees_ '4d?/9119-03):

The failure of the licensee to establish and maintain habitability in the emergency response facilities was identified as an exercise weakness.

Responses Control Room 1

back of procedural guidance is the primary reason for this weakness.

Procedure EPP 01-1.0 ' Control Room Organization

  • will be revised to provide guidance to appropriate personnel in the i

following areast 1.)

Establish access control for the Control Room I

2.)

Performance of habitability surveys in the Control Room 3.)

Dosimetry in the Control Room 4.)

Control Room habitability operatious support Center (OSC)

A low background area was not available in the OSC to at:61yze air and swipe samples.

To provide a method for lowering background

readings, lead bricks have been placed in the OSC.

TSC and the EOF.

Procedures EPP 01-1.1 'WCGS Organization' and EPP 03-1.2

  • Emergency Operatt.ons Pacility Emergency Organization
  • will be revised to provide guidance to appropriate personnel for utilization of lead bricks when background is too high to accurately count samples.

Technical Support Cent 9r Lack of procedural guidance is the primary reason for this weakness.

Procedure EPP 01-4.1

' Technical Support Center Activation

  • will be revised to provide guidance to ensure the airlock door is closed.

The door seals will be replaced and signs will be placed on the door, identifying that it is to be closed during activation and operation of the *SC by December 10, 1991.

Procedure EPP 02-1.5 'Haintenance of Emergency Facilities and Equipment

  • will be revised to require a periodic inspection of seals on airlock doors in emergency facilities.

Procedure changes will be completed by December 16, 1991 and training for appropriate personnel will be completed by March 16, 1992.

j s.

i i

Attachineat to VM 91-014$

Page 9 of 9 Exercise Weakness (48?/9119-04):

Poor coordination and control of monitoring teams was identified as an exercise weakness.

Rosponse: The reason for this weakness has beon determined to be a lack of procedural guidance.

Procedure EPP 01-1.2 ' Emergency Operations Facility Emergency Organization' will be revised to provide additional guidance on the deployment, control, and coordination of monitoring teams, Guidance will also expand instructions 1 minimiting exposure to monitoring team members.

Procedures EPP I

01-8.2 *0ffsite Radiological Honitoring' and EPP 01-8.3

' Joint Radiological Honitoring Teams Formation and Operation' will be revised to include checklists that will require the monitoring teams to take self contained breathing apparatus with them when deployed.

Procedure changes will be completed by December 16, 1991 and

-training for appropriate personnel will be completed by March 16, 1992.

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