IR 05000483/1987006
| ML20211N223 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/18/1987 |
| From: | Foster J, Patterson J, Snell W, Williamsen N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20211N187 | List: |
| References | |
| 50-483-87-06, 50-483-87-6, NUDOCS 8703020018 | |
| Download: ML20211N223 (10) | |
Text
{{#Wiki_filter:- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-483/87006(DRSS) Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Nuclear Power Plant Inspection At: Callaway Plant, Reform, Missouri Inspection Cond ct: anuary 26-30, 1987 t am leader / [[ Inspectors: - Dhte' { gz
.' Foster /f!ff9 ' D44e / W i 8M Dat6 f,0.M Approved By: W. Snell, Chief 2/ s/s7 Emergency Preparedness Date ' Section Inspection Summary: Inspection on January 26-30, 1987 (Report No. 50-483/87006(DRSS)) Areas Inspected: Routine unannounced inspection of the following areas of the emergency preparedness program; activation of the licensee's emergency plan; emergency detection and classification; protective action decisionmaking; notifications and communications; changes to the emergency preparedness program; shift staffing and augmentation; knowledge and performance of duties (training); and licensee audits. The inspection was conducted by three NRC inspectors.
Results: No violations, deficiencies, or deviations were~ identified.
8703020018 8708 g PDR ADOCK 05000403 G pga _ _ _ _
c _ .. . DETAILS 1.
Persons Contacted
- R. Shukai, General Manager, Nuclear Engineering
- G. Randolph, Manager, Callaway Plant
- J. Blosser, Assistant Manager, Operations and Maintenance
- M. Stiller, Manager, Nuclear Safety and Emergency Preparedness
- A. Neuhalfen, Manager, Quality Assurance
- J. Gearhart, Superintendent, Quality Assurance-Operations Support
- M. Evans, Acting Superintendent of Training
- T. Rook, Training Supervisor
- S. Crawford, Administrator, Nuclear Affairs-Emergency Preparedness
- M. Cleary, Supervisor, Nuclear Information
- E. Thornton, Engineering Evaluator, Quality Assurance
- G. Poteat, Nuclear Scientist, Emergency Preparedness
- A. White, Supervisor, Emergency Preparedness
- S. Harvey, Administrator, Nuclear Affairs-Emergency Preparedness P. Sudnak, Administrator, Nuclear Affairs-Emergency Preparedness M. Faulkner, Administrator, Nuclear Affairs-Emergency Preparedness G. Hughes, Supervisory Engineer, Nuclear Safety and Emergency Preparedness R. Daming, Engineer-Emergency Preparedness J. Dampf, Emergency Planner-Emergency Preparedness S. Sampson, Shift Supervisor M. Heinzen, Shift Supervisor P. Hobbs, Operations Supervisor
.B. Bredeman, Operations Supervisor P. Johnson, Shift Technical Advisor R. Pohlman, Shift Technical Advisor L. Holmes, Document Control Supervisor-M. Taylor, Operations Superintendent W. Campbell, Assistant Manager, Nuclear Engineering R. Roselius, Health Physics Superintendent C. Graham, Health Physics Supervisor J. Polchow, Health Physics Supervisor M. Trusty, Health _ Physics Technician A. Parker, Health Physics Technician R. Outz, Health Physics Technician
- Denotes those attending the exit interview on January 30, 1987.
2.
Licensee Actions on Previcusly Identified Item a.
(0 pen) Open Item No. 50-483/86009-01 (DRSS): This item related to a need for review and possible revision of the licensee's Emergency Action Levels (Eats) included in Procedure EIP-ZZ-00101, Revision 5.
As detailed elsewhere in this report, the licensee has been responsive to this item, and a revision of the EALs is in progress. This item will remain open pending submittal, review and approval of the revised EALs.
(
' . b.
(Closed) Open Item No. 50-483/86009-03: This procedure revision for Procedure EIP-ZZ-01211 was recommended because of the possibility of an unmonitored release through the blowout panels on the roof if a main steam line break occurred in the steam Tunnel. This procedure, Initial and Intermediate Oose Assessment, Revision 8, now includes methods which relate to estimation of radiological releases in the event of a main steam line break in Area 5 (Steam Tunnel).
Four separate conversion factors are now used for projected doses depending on which area of the plant is being monitored. Area 5, Steam Tunnel, - is listed as " Steam Enclosure" on the Attachment 3 form. Procedure review and approval had been completed by Health Physics, Rad Waste, Quality Assurance (QA), Emergency Preparedness (EP) and the Onsite Review Committee at the time of the inspection. This item is closed.
c.
(Closed) Open Item No. 50-483/86009-04: As a result of walk-throughs/ interviews with Control Room personnel in the previous inspection, the inspectors concluded that these personnel were unaware that the licensee should notify the NRC Operations Center immediately after notifying State and local authorities. This requirement has been emphasized through incorporation into the EP training program.
Also through interviews conducted in this inspection, the inspectors determined that those questioned were aware of this 10 CFR Part 50.72(a)3 requirement. This item is closed.
d.
(Closed) Open Item No. 50-483/86009-05: The licensee's QA audit program for EP now includes, in its audit records of areas for review, an evaluation for adequacy of the interfaces with State and local agencies. This was recommended due to the difficulty in identifying this area in the previous inspection. This addition to the audit records is satisfactory. This item is closed.
3.
Activations of the Licensee's Emergency Plan A review of Licensee Event Reports (LERs) reported in this inspection period and other documentation confirmed that were no events occurring which could be classified as emergencies.
' 4.
Emergency Detection and Classification (82201) Revisien to the licensee's Emergency Action Levels (EALs) is in progress.
A revised set of draft EALs, which considered the comments attached to the last inspection report, was available. The draft EALs were reviewed and commented upon, although this was not considered as a formal review for approval purposes.
The revised EALs correctly address the comments made during the previous review.
During the review, it was noted that one EAL, in Group 6, Radiation Release Events, Item F (on page 40), in both the draft revised EALs and the present EAls, is in error. The event or condition, that of projecting off-site radiation doses to exceed EPA Protective Action
-. . -_
.-. .- . .. . . -.- -- .- 1. , , i l Guidelines outside the exclusion area boundary, is improperly classified , i as a Site Area Emergency as opposed to a General Emergency. Licensee personnel reviewing the draft EALs had made similar comments..This EAL will be revised before final issuance of the EALs.
! Discussion with Emergency Preparedness personnel indicated that-the EAL had been patterned after the guidance contained in NUREG-0654 in
the section devoted to " Initiating Conditions, Site Area Emergency."
A review of this section of the NUREG indicated that a typographical
error existed in the section (the apparent deletion of a "not"), which had led to the improper EAL classification.
Licensee personnel indicated that the draft revised EALs were through the first phase of the review cycle (first draft circulated and comments . received), and it was projected that the revised EALs would be available
within two weeks. -The inspector indicated his concern in case the present, erroneous EAL is left in place for any length of time (as might happen - if the EAL revision were delayed for some reason).
, r The revision of this EAL and the balance of EALs, when licensee approved, will be sent to NRC Region III for their review and approval before being issued to plant operations.
Licensee management verbally committed to i sending these revised EALs to the NRC within two weeks of the inspection's exit interview of January 30, 1987.
This item will be tracked as Open Item No. 50-483/87006-01.
Interviews were held with two control room shifts, each consisting of
a Shift Supervisor, Operations Supervisor, and Shift Technical Advisor.
Each group demonstrated general knowledge of Emergency Preparedness principles, philosophy, and the plant Emergency Plan.
Each group was
also presented with various event scenarios and demonstrated the ability '
to detect and classify events properly utilizing the present plant ' Emergency Action Levels in the Emergency Plan Implementing Procedures.
Both groups were presented with a scenario representing a steam generator tube rupture (among others).
Each group properly classified the event, but' expressed doubt that certain conditions expressed in the present EAL (rate' of steam generator level increase, and timely confirmatory sample) ! could be met without difficulty. These comments were similar to those l made in the previous inspection report, and during the inspector's review of the draft revision to the pertinent EAL.
The inspector confirmed that the annual meeting to review and discuss . the EALs with the State and County emergency response agencies was held in five separate meetings, from February to May, 1986, to review the EALs as well.as proposed revisions to the Radiological Emergency Response Plan.
5.
Protective Action Decisionmaking (82202) The inspector's review of this area included the demonstrated capability of a Control Room team led by the SS to make a PAR based on plant core conditions with and without a release taking place. Both teams demonstrated knowledge of the PAR flow chart in Attachment 1 of
_ _ _. . _ _. _ .. _. _ _ ._ _ - ,. Procedure EIP-ZZ-00212. However, Procedure EIP-ZZ-00212 should be revised to clarify Section 4.1.3 regarding the use of evacuation times .in the' Sector-Subarea Matrix included as Attachment 5, page 1 of 1, and
3
the plume' arrival time information included as Attachment 6.
Presently, ! ! the procedure only implies the use of the Attachment (no direct reference) in making Protective Action Recommendations (PAR), but does not direct
the user to the Matrix or provide any guidance as to its'use. -The ' procedure does indicate that the " Health Physics Coordinator / Radiological i.
Assessment Coordinator can supply the necessary plume travel information" utilizing the procedure, but this does not appear to be sufficient.
' This procedure, particularly Section 4.1.3 and Attachment 5, should be clarified to direct the user to Attachment 5 as identified in the above ' paragraph. This should make the procedure more effective regarding the use of evacuation time studies. This will be identified as an open item. Open Item No. 50-483/87006-02.
' 6.
Notifications and Communicaticns (822031 ' Communication tests on telephones, radios, siren system, etc. were completed satisfactorily for monthly, quarterly and yearly test ! requirements. Tone alert radios are being maintained as well as being tested through the Emergency Broadcast System (EBS), as determined through interviews with EP staff and records review.
Siren system , ! maintenance program as documented was found to be satisfactory. When
malfunctions occur,~a fast corrective response time was indicated from 1, correspondence reviewed. One example of siren failure occurred when a siren alarmed but did not rotate. The supplier's maintenance staff ] evaluated this as due to a County dispatcher not following a procedure.
Corrective actions have been taken to prevent a recurrence.
' Two-way radio reception within the plant has been improved to provide i 'better reception in most plant areas. Their use in recent drills and
the annual exercise has demonstrated better reception. However, all ! three Health Physics technicians interviewed, as identified in Section 9 ' of this report, stated that they would rely on the Gaitronics public address system to communicate back to the Operational Support Center (OSC) rather than the two-way radios. As a rule, one member of a , maintenance team has a radio (on emergency missions), and this could < l be'used by the HP technician.
Communications links with the State of Missouri and the four counties within the EPZ were tested according to procedures and at the required frequency. No changes in these communications links were identified
by the inspector.
Ring-down telephones are still being used from the Control Room for offsite notifications.
, 7.
Changes to the Emergency Preparedness Program (82204) . Changes to the Callaway Radiological Emergency Response Plan were made in ! accordance with NSEP-EP-00400, Revision 1, " Preparation, Review, and Approval of Revisions to the Radiological Emergency Response Plan" (RERP), j which ensures adequate management approval so that changes made without ' i
- . . . _., _ _ _ _ _._. ___. _ _. _ _._ _ _ _.._ _ _ _. _ _ _. _. _ _,
. . the prior approval of the NRC do not decrease the effectiveness of the Plan. The inspector reviewed the draft package for Revision 10, which was currently undergoing final review by the licensee, and made a spot check to verify that changes in facilities and in administration were being addressed in Revision 10. Specifically, the inspector verified that the forthcoming revision included: a.
Changes due to the Joint Public Information Center (JPIC) being moved in Jefferson City, Missouri from the Armory to the Union Electric " Region West Offices" there.
b.
Changes due to newly created management positions, " General Manager, Nuclear Operations," and " Manager - Operations Support."
Both of the above were being incorporated into Revision 10.
Changes to emergency implementing procedures were made according to APA-ZZ-00101, Revision 15, " Preparation, Review, Approval and Control of Procedures." This procedure addressed temporary changes, which do not change the intent of the procedure; such were titled " Temporary Change Notices," or TCNs. The inspector made a spot check of recent procedure revisions and also Temporary Change Notices. All of the items checked were properly documented per APA-ZZ-00101, except for one of the Temporary Change Notices from June 1986, which had not included the signature of the " Responsible Department Head." However, the inspector was informed that subsequently APA-ZZ-00101 had been revised to clarify that every required signature line must be signed by the appropriate staff as shown on the form used for TCNs.
Distribution of changes to the Plan and Procedures has been done by the Document Control staff. Distribution was controlled by a computer printout of a summary page showing all the addressees, plus a computer generated letter of transmittal for each addressee. Actual distribution for all onsite personnel was carried out by Document Control Clerks who personally made the change in each manual and then signed off the transmittal letter.
Offsite copies were mailed through the St. Louis Corporate office, and the returned, signed letters of transmittal were monitored for compliance.
The inspector checked several transmittals and determined that distribution to the NRC was completed within 30 days after the Plant and/or procedure changes were effective as required by 10 CFR Part 50.54(q) and Appendix E to 10 CFR Part 50.
Changes to the Plan and Procedures may result from an NRC critique or a licensee critique. Open Items from NRC reports were tracked on the ' Commitment Tracking System, which is maintained by the Compliance Department. The inspector verified that Open Items 86009-01 and -04 were properly entered into the Commitment Tracking System and that action was being taken. Open Item 86009-01 was being addressed by changes to procedures and had a target date for closure of January 31, 1987; 86009-04 was already closed on the basis of training being accomplished. Critiques generated by the Emergency Preparedness staff were tracked on the Emergency Preparedness Action Item Tracking System (AITS). The inspector verified that items were being entered on AITS and action was being taken.
- _ _.. __ _. _, ,_ _ _ . _., _ _.. _ _ _ __ _. _.
... ) A newly organized " Plant Manual" was being written so that all procedures necessary for " Nuclear Function" would be in one multi-volume manual.
Previously, for example, revisions in procedures would be made by Corporate under QS-14, by Emergency Preparedness under EP-00400, and by other plant departments under APA-ZZ-00101. When the new plant manual is finished, there will be just one procedure for making revisions, and it will be used by all groups involved in Nuclear Function.
8.
Shift Staffing and Augmentation (82205) The inspector reviewed the Augmentation Drill of October 21, 1986 and compared it against the earlier drills of February and April,1986.
There has been consistent improvement. The October drill included a call of the Onsite Emergency Organization, the Interim-EOF Organization, and the Corporate Emergency Organization. The On-site organization was called by a telephone-answering service, the Interim-EOF organization was called by the Control Room, and the Corporate organization was called by a " call-tree" starting with the Recovery Manager, per Procedures EIP-ZZ-00202, -00502, and -C0020, respectively. The time of arrival of each person was estimated by adding the commute time for that person to the time at which they responded; comparing this against the time the drill started gave the elapsed time for that person.
By comparison to NUREG-0654, Revision 1, Table B-1, the results of the October drill indicated that the licensee had the capability to make a timely and adequate augmeni.ation.
For the October drill no one answered for more than one' position, as had occurred in previous drills. Also the callout procedures were being revised, so that there would be fewer position titles but just as many personnel called out.
For example, the inspector.
learned that the position titles that Rad Waste personnel might fill were being reduced from seven to four, though the total number of people called out will be the same. The telephone-answering company's two offices, one in Columbia and one in Jefferson City, share the callout list in making notifications. Also, each office has the other's phone list in case of a communications failure. ' This revised system of sharing the callout lists seemed to improve the efficiency of the drill.
The October drill was an improvement over the April drill in that 100% of the required personnel were reached. All of the drills were documented in critiques, complete with action items and recomendations. The inspector verified that corrective actions were being accomplished.
Also, the April and October drills used a newly devised standard format, as a result of an improvements item in Inspection Report No. 483/86009.
The new format makes it easier for management to review the drill results and the corrective actions.
The Emergency Telephone Directory was updated quarterly by the Emergency Preparedness staff, using a data base on a personal computer. However, this procedure will be more automated in the future, since the licensee's main-frame computer will be used with the computer interrogating personnel files and training files automatically. A list by department of qualified personnel will be submitted for final verification.
The change-over to the new system is now undemay and should be completed within the next one or two quarters.
. _ - ._ _ _ _ _
- . 9.
Knowledge and Performance of Duties (Training) (82206) A major change has been initiated by the Training Department since the - prior inspection. The training frequency, course matrix and training format has been revised for EP training.
A job analysis has been completed for each EP position. This job analysis task was in the final review process at inspection time. Actual implementation of the revised course ~ content in the new format is scheduled for June 1987. Only one training session will be held for a specific EP position, e.g. a Dose Assessment Coordinator will not have to attend two or three different sessions to meet his required training. One training date will be held whether the total time involved is two hours or six hours. This should greatly improve scheduling and attendance. As part of EP training, drills will be used to reinforce class room training and not merely used as a supplement.
Requalification training for SSs or other job categories with corresponding EP response positions will now include the annual required EP training.
Previously, EP training was not always scheduled for the same time as requalification training.
The course deficiency file, initiated last year, has now been computerized for more efficient use and easier retrieval. The licensee's EP group has been responsible for conducting offsite agencies training since September 1986. This is largely possible because the EP staff has been increased to include'those with the disciplines needed to present varied phases of the EP program to the offsite support agencies.
Walkthroughs and interviews were conducted with two three-person Control Room teams. Each team consisted of a Shift Supervisor, Operating Supervisor, and a Shift Technical Advisor. Their performances were considered satisfactory in their responses to emergency conditions and other phases of the emergency plan implementation.
Also interviewed by the inspection team were three Emergency Coordinators, three Health Physics Coordinators and three Health Physics technicians.
The first two categories demonstrated very good knowledge of the basic concepts of the licensee's EP program as well as their specific responsibilities including the coordination needed with other emergency response personnel. The Health Physics technicians' performance ranged from barely satisfactory to very good. Two of the three technicians selected were assigned to technical services jobs where they normally do not use radiation monitoring equipment or perform surveys, take smears, or do operation-type tasks.
From the interviews, it appeared that they did not seem as self-confident in an emergency mode as did the third person interviewed. A current list of 30 qualified individuals includes .18 operational types and 12 in technical services. The inspector suggested that if possible those 12 be given more hands-on experience and a re-emphasis on the emergency concepts involved with emergency responsibilities expected for both in-plant and offsite emergency response teams.
- _ _ _ _ _ _ _ _ _ - _ - _ _ - . _ _ - _. - . Training records could not be obtained for the two STAS involved in the Control Room crew walkthrough. The inspector verified that the STAS had successfully completed their required EP courses by examining documentation provided by a Supervisory Engineer of the Nuclear Safety and Emergency Preparedness Department. This individual was the instructor for the STAS, also. The course designation, T68.06.21, identified the specific course number involved. The License did provide the official training records to the inspector subsequent to the inspection on February 4,1987.
It appeared that this~ training record was mislaid by Training Department personnel in the interim period. This was identified by the inspector as an example of poor record retrieval and verification of training records for a key emergency response position.
In general, the licensee's training program for emergency preparedness is on a upward curve and has improved in several areas related to EP from the previous inspection.
10. Licensee Audits (82210) Discussion with licensee personnel and a review of records verified that an annual independent audit had been performed to meet the emergency program review requirements in 10 CFR 50.54(t).
Licensee documentation indicated that the following audits and surveillances had been conducted: a.
Audit A05A8601B, dated February 7, 1986, conducted during January 6-16, 1986. This audit covered various aspects of the on-site program, backup Emergency Operations Facility, and community hospital, and resulted in five Requests for Corrective Action (RCA), two at Level 4, and three at Level 3.
b.
Surveillance Report P8604-05, dated April 2, 1986, conducted during March 18-31, 1986. This surveillance report dealt with the county radiological training conducted by the licensee in association with the State Emergency Management Agency and the local Emergency Management Directors.
c.
Surveillance Report P8604-08, dated April 9, 1986, conducted during February 7 through April 7,1986.
This surveillance reviewed certain open items of concern identified by the plant Emergency Preparedness staff.
d.
Audit A05A8607B, dated August 8, 1986, conducted during July 24 through August 1, 1986. This Audit covered the preparation, control and conduct of the annual licensee Emergency Exercise, dress rehearsal drill records, and the annual news media briefing. This ~ audit addressed ten specific areas, with item ten being " interfaces between Union Electric and State and Local government personnel."
... .. . _ _ _ _ _ _ _ j
_ _ - _ _ _ _ _ _ _ _ - . All of the above Audits and Surveillances were adequately documented and appeared to be complete and comprehensive. The licensee system categorizes audit findings as Requests for Corrective Action (RCAs), with levels from one to four, with Level 1 being the most significant or serious level. RCAs are documented, and entered into a system which , I tracks the responses and corrective actions associated with an RCA.
Documents indicated that Audits and Surveillances were made available to State and local authorities during a yearly meeting.
Records showed I that the April 2, 1986 Surveillance report was provided to Osage County officials when requested during the May 2, 1986, annual meeting.
Due to schedule changes, the Annual meetings where Audits have been made available occur in May of each year, and the major Audit of Emergency Preparedness occurs in the following August. This has resulted in the Audit being made available approximately eight months after finalization.
A method is needed to make State and local authorities aware that the Audit has been conducted, and is available, on a more timely basis.
11. Exit Interview The NRC team leader discussed the scope and findings of the inspection.
The major item of concern was an inaccurate EAL listed in the tables, Attachment 2, Group Six - Radiation Release Events, Item F.
The licensee based the classification of this EAL condition on guidance in NUREG-0654, Revision 1, Appendix 1 Page 1-13, No. 13c. which the inspection team determined was in error. A prior licensee review also recognized that the Site Area Emergency classification was wrong.
Licensee management orally committed to revising this EAL to indicate a General Emergency classification for these conditions and to submit this revision along with other EAL revisions to the NRC within two weeks of the exit interview (Reference Section 4 of this report). The inspectors also discussed the content of the report to determine if the licensee felt that any of the information was proprietary.
The licensee responded that none of the information discussed was considered proprietary.
,
__ _ _ - _ _ }}