IR 05000483/1989007

Insp Rept 50-483/89-07 on 890403-06.No Violations Noted. Major Areas Inspected:Emergency Preparedness Program, Including Emergency Plan Activations,Licensee Actions on Previously Identified Items & Operational Status of Program

ML20244E314
Person / Time
Site:	Callaway
Issue date:	04/14/1989
From:	Patterson J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20244E302	List: IR 05000483/1989007 ML20244E300
References
50-483-89-07, 50-483-89-7, NUDOCS 8904240421
Download: ML20244E314 (7)

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V. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/89007(DRSS)

Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company P. O. Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Plant Inspection At: Callaway Site, Reform, Missouri Inspection Conducted: April 3-6,1989

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Inspector: fJ. P.00..' $)"

Patterson 4 / 4 /31 Date LdECM Approved By: William Snell, Chief 4/4/gf l

i Emergency Preparedness Date and Effluents Section Inspection Summary Inspection on April 3-6, 1989 (Report No. 50-483/89007(DRSS))

Areas Inspected: Routine, announced inspection of the emergency preparedness program including: emergency plan activations (IP 92700); licensee actions on previously identified items (IP 92701); and operational status of the program (IP 82701). The inspection was conducted by one NRC inspecto Results: No violations of NRC requirements, deficiencies, or deviations were identified as a result of the inspection. Corrective actions on three open items were reviewed and determined to be adequate. The operational status of the program remains well maintained, and the overall management of the plant emergency preparedness program is strong. Audit findings and items of NRC concern were adequately tracked and received timely resolutio {DR ADOCK 050004e3 PDC

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DETAILS Persons Contacted

• D. Schnell, Senior Vice President, Nuclear

• G. Randolph, General Manager

• J. Blosser, Manager, Callaway Plant

• M. Evans, Superintendent, Training

• T. Rook, Supervisor Training

• J. Gearhart, Superintendent, Quality Assurance-Operations Support (QAOS)

• M. Stiller, Manager, Nuclear Safety and Emergency Preparedness (NSEP)

• A. White, Supervisor, Emergency Preparedness

• F. Eggers, Supervising Engineer (QAOS)

• D. Widmer, Engineer (QAOS)

M. Daume, Shift Supervisor R. Lamb, Shift Supervisor T. Arms, Rad Chem Foreman J. Cruickshank, Rad Chem Foreman D. Young, Maintenance Coordinator S. Phol, Maintenance Engineer S. Meyer, Systems Engineer Other Personnel F. Baysinger, Director, Emergency Service, Callaway County / City of Fulton

• Denotes those personnel listed above who attended the exit interview on April 6, 198 . Licensee Actions on Previously Identified Items (Closed) Open Item No. 50-483/88003-01: This item represented a violation for inadequate emergency kit inventory control. A procedural revision to Procedure No. HTP-ZZ-06022 plus closer scrutinizing by the emergency preparedness organization (EP) over the group responsible for taking and maintaining the emergency kits constitutes adequate corrective action This is the type of

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item that must be nonitored frequently to assure efficient management i

and control by the EP group. This item is closed, (Closed) Open Item No. 50-483/88009-01: This item resulted from the Emergency Response Facility (ERF) Appraisal in June 1988. The finding was that there was no physical indication or quantitative instrumentation available to determine if a positive pressure could be maintained in the TSC. No quantitative requirements for a positive pressure in the TSC were identified in reviewing guidance of NUREG-0737, Supplement 1, and NUREG-069 In NUREG-0696 there was a statement that the "TSC ventilation system shall function in a manner comparable to the Control Room." The licensee's evaluation

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is that the TSC does meet this requirement as it does provide a

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filtered ventilation syste Upon reviewing the dose calculation,

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't vendor data sheets, and purchase specifications, it was determined that the-TSC ventilation system was designed to maintain out-leakage in the filter mode by establishing specific flows rather than-maintaining specified pressure differential Through airflow measurements in and out of the TSC,' the licensee was able to verify-that a positive airflow could be maintained in the TSC. A visual smoke test.was successfully performed to verity out-leakage at all doors. Recent smoke tests-have shown that some doors facing the wind exhibited temporary in-leakage for several seconds with wind gust Preventative maintenance, No. PM-01 on SUB-53 was written-to perform a flow verification yearly. A work order has been init4ated to repair the mechanical equipment door seals. Another work order has been completed which repaired the Damper D-3 shaft and adjusted

. Dampers D-3 and D-4 for proper stroke. Damper positions hcva now been marked as suggested in the ERF Appraisal Repor These corrective actions identified, represent a portion of the documentation and testing involved. This has satisfactorily addressed the positive airflow mode of the TSC ventilation and recirculation system. This item is close (Closed) Open item No. 50-483/88009-02: This item related to the inability to determine if there was any physical indication or instrument action available to determine if a positive pressure could be maintained in the EOF. This item, which was similar to the TSC item, was also identified in the ERF Appraisal. The design intent'of the EOF ventilation system was to maintain a positive out-leakag Documentation identified the EOF ventilation system was designed to supply a maximum of 2000 cfm filtered fresh air to reduce any radioactive containments entering the building by dilution effec To verify that a differential pressure flow could be maintained in the EOF, a work request was written to verify /rebalance the air flow in the EOF-. The purpose of recording these flows was to verify design flow of 1980 cfm filter unit irtake and area supplies greater than returns to establish out-leakags. This EOF air rebalance was done and proved that a positive air flow was being maintained.

I A visual smoke test was also performed which verified outleakage, wit? the exception that when wind gusts were resent, the smoke was l temporarily pushed into the building. Dose calculations indicated that the ventilation system in the filtration mode should operate with a positive pressur Licensee's review of NUREG-0696 and NUREG-0737, Supplement 1, did not find any quantitative requirements

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for a positive pressure in the EOF. A review of dose calculations, vendor data sheets, purchase specifications, and system drawings determined that the EOF ventilation system was designed to maintain out-leakage in the filter mode by establishing specific flows rather

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than maintaining specified pressure differentials. Original Bechtel L documents which referred to pressurization were based entirely on l flows and no value for pressurization was given. The dose calculations showed the range of flows that would be acceptable for radiation protectio The ventilation damper positions were marked at the actuator to assist the operator in determining the correct positions for adjusting the damper. Procedure OTN-ZZ-00601, used to reflect tSe visual verification of damper position when performing surveillance, has been revised by the Systems Engineer to reflect the new marked positions on the damper These corrective actions identified as reviewed represent a portion of the document action and tests conducted to prove that a positive air flow exists within the entire ECF ventilation and recirculation system. This item is close . Emergency Plan Activations (92700)

Licensee and NRC records associated with any Radiological Emergency Response Plan (RERP) activation were reviewed for the period between February 1988 through the date of this inspection. There was only one activation identified. This occurred on February 13, 1988 and included an ECCS activation due to low steam pressure resulting in discharge to the cor This Notification of Unusual Event was correctly classified and notifications were made to State and local governments and the NRC-within the required time . Operational Status of the Emergency Preparedness Program (82701) Emergency Plan and Implementing Procedures One recommended cnange to the RERP was identified in the RERP review. In Chapter 8, Section 8.1.4 the word " annually" should be added where the Public Information Program is described. The related implementing procedure, EIP-ZZ-A0020, does list this annual requirement for distribution of public information materials. The inspector confirmed that this distribution is being carried out on annual basis. At the exit interview the licensee stated that a request for this change had been initiated, and will be included in the next scheduled RERP revision later in 198 Major changes in the RERP and implementing procedures in this inspection period consisted primarily of revisions and clarifications of the EAL tables. Reviews of these and other changes were conducted and revisions approved by NRC as individually submitted since February 198 Based on the above findings, this portion of the licensee's program was acceptabl _____ - -_____

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b. Emergency Facilities, Eauipment, Instrumentation and Supplies i This area was inspected primarily in the context of the 1988 violation for inadequate emergency equipment inventory control as described in Section 2.a. of this repor Current emergency equipment inventory lists were examined for this inrpection period and found tc be current, i.e., conducted on a quarterly basis as required by Section 8.4 of the RERP. Emergency Equipment kits were opened and a spot check made for key item No discrepancies were identified. These kits were the EOF Field Team Kit and an OSC Ki Based on the above findings, this portion of the licensee's program was acceptabl c. Organizational and Management Control Through discussion with cognizant licensee management and a review of current organizational charts and information, it was confirmed that there were no organizational and/or management control changes which could adversely affect the licensee's emergency organization's ability to respond and function as designated. The Manager, Nuclear Safety and Emergency Preparedness (NSEP) still has a reporting line to the Senior Vice President-Nuclear ~as well as direct reporting responsibility to the General Manager. Thus, the Manager, NSEP, has a direct line access to two of the three highest positions in the licensee's organization chart as listed in the RERP, Revision 12, Chapter Within the last year the position of General Manager, Engineering has oeen removed from this organization chart. The Manager, NSEP, formerly reported to this positio The present reporting lines are more efficient from an EP viewpoin Continued revisions and refinements of the Emergency Action Level (EAL) tables have been implemented. The EAL Task Force Review Committee, including managerial support from the Operations Department, Training Department, and Health Physics Department were largely responsible for evaluating these changes and improving their applicabilit Presently three EP staff members are on loan to the Plant Operations Department for providing assistance in the fuel outage which started this month. This is a temporary assignment which is scheduled for approximately two months. The Plant Operations Department has agreed to compensate the EP group by assigning three individuals for three months starting about July 1,1989 to assist the EP group in scenario development ard related tasks. This would be in preparation for the October 1989 exercis l An interview was held with the Director, Emergency Operations I Center, Callaway County / City of Fulton. The Director indicated that he was satisfied with the caliber of training provided to ,

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the offsite support groups by the licensee. These training sessions also included a joint review of any EAL changes that were incorporated into the RERP since the previous meeting. The inspector stated that he would be available at any time to answer questions relating.to the licensee's EP program or NRC regulation Based on the above findings, this portion of the licensee's program was acceptabl d. Training Walkthroughs and interviews were conducted with six emergency .

response personnel: Those interviewed included: 1 2 - Shift Supervisors 2 - MERT (Medical Emergency Response Team) Team Leaders 1 - Operations and Maintenance Coordinator 1 - OSC Coordinator All individuals indicated good familiarity with their emergency response functions and utilized very well the EALs, where applicable, and the emergency plan implementing procedure In addition, 25 names of designated emergency response personnel

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were randomly selected to determine by training records if each had received all of their required EP training within the time requirements. All identified personnel were found to be current in their training requirements. The Training Department has developed  ;

a system to assure that those individuals, whose training would  !

expire immediately before or during a fuel outage, are trained prior H to this tim Training scheduling has to be adjusted, but the end result should be beneficial. It is difficult to provide required EP training in a fuel outage, but any added effort should prevent a training lapse and possible NRC violatio Based on the above findings, this portion of the licensee's program was acceptabl e. Independent Reviews / Audits The most recently completed independent review of the EP program was conducted between April 22-29, 1988. The current review is due for completion by July 31, 1989. This 10 CFR Part 50.54(t) requirement as listed in Chapter 8, Section 8.3 of the RERP allows a 25% time extension, or 15 months to correspond with the licensee's Technical Specification Part of the current annual review has been completed. This includes the evaluation of the adequacy of interface between the licensee and the State and local government This portion was thorough and adequately documented. In addition, several surveillance have been conducted which were objective and specific in nature. In summary, the quality of the QAOS audits have

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continued to improve. All'EP related requirements for this present audit must be completed by July 31, 1989, to meet RERP requirements and the commitments of license QA Procedure OQAM 1 Based on the above findings, this portion of the licensee's program was acceptabl . TMI Safety Issues Management System (SIMS) Items On October 31, 1980, the NRC issued NUREG-0737, which incorporated into one document all TMI-related items approved for implementation by the Commission at that time. On December 17, 1982, the NRC issued Supplement I to NUREG-0737 to provide additional clarification regarding Regulatory Guide 1.97 (Revision 2) - Application to Emer;er.ry Response Facilities, and Meteorological Data, as well as other areas. The status of the completion of these TMI SIMS items are internally trace.ed by the NR The July 13, 1988 Inspection Report (No. 483/88009) provided'a status listing of the SIMS items related to emergency preparedness. The following listing provides an updated status of those SIMS items that were "open" in the July 13, 1988 Report. Based on the results of the April 13-16, 1989 inspection, all emergency preparedness SIMS items are close _

II Current Status: Closed This item has been closed based on the closure of items MPA-F-63 and MPA-F-6 MPA-F-63 Current Status: Closed This item is closed based on the resolution and closure of Open Item No. 50-548/88009-01 (Section 2.b).

i MPA-F-65 Current Status: Closed

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This item is closed based on the resolution and closure of Open Item No. 50-483/88009-02 (Section 2.c). Exit Interview The inspector met with the licensee representatives denoted in Paragraph 1 on April 6, 1989. The inspectcv liscussed the scope and results of the inspection. All emergency pre; dness open items have now been closed as part of this inspection. The coordination and cooperation between the Emergency Preparedness group and plant and corporate management has j continued to be efficient and effective. The licensee indicated that none of the matters discussed during the exit interview were proprietar {

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