IR 05000483/1998006

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/98-06 on 980422

ML20248J649
Person / Time
Site:	Callaway
Issue date:	06/03/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Randolph G UNION ELECTRIC CO.
References
50-483-98-06, 50-483-98-6, NUDOCS 9806090233
Download: ML20248J649 (5)

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f Giug UNITED STATES

, f- g NUCLEAR REGULATORY COMMISSION

$ REGION IV 611 RYAN PLAZA DRIVE, SUITE 400 ARLINGTON, T EXAS 760118064 o

June 3, 1998 Garry L. Randolph, Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, Missouri 65251 SUBJECT: NRC INSPECTION REPORT 50-483/98-06 Thank you for your letter of May 22,1998, in response to our April 22,1998, letter and Notice of Violation concerning emergency plan changes that decreased the effectiveness of the Callaway Plant Radiological Emergency Response Plan and did not receive prior NRC approva We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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Blaine Murray, hief i

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Plant Support Branch Division of Reactor Safety Docket No.: 50-483 License No.: NPF-30 cc:

Professional, Nuclear Consulting, In Raines Drive Derwood, Maryland 20855 Gerald Charnoff, Es Thomas A. Baxter, Es Shaw, Pittman, Potts & Trowbridge 2300 N. Street, [

Washington, D.C. 20037 [

m so m aa m s0a PDR ADOCK 05000403 G PDR

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Union Electric Company -2-

. H. D. Bono, Supervising Engineer Qualdy Assurance Regulatory Support Union Electric Company P.O. Box 620 Fulton, Missouri 65251 Manager- Electric Department Missouri Public Service Commission 301 W. High .

- P.O. Box 360 Jefferson City, Missouri 65102 Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176

' Jefferson City, Missouri 65102 Otto L Maynard, President and

- Chief Executive Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839

- Dan 1. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 Lee Fritz, Presiding Commissioner

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Callaway County Court House L -10 East Fifth Street Fulton, Missouri 65151 L

Alan C. Passwater, Manager l Licensing and Fuels .

AmorenUE One Amoren Plaza-1901 Chouteau Avenue

~ P.O.' Box 66149

. St. Louis, Missouri 631664149 i

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Union Electric Company -3-

J V. Laux, Manager

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Quality Assurance :

Union Electric Company P.O. Box 620 Fulton, Missouri 65251

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Union Electric Company -4-DISTRIBUTION w/cooy of licensee's letter dated May 22.1998::

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Regional Administrator Callaway Resident inspector DRS Director DRS Deputy Director l, DRP Director DRS-PSB Branch Chief (DRP/B)

Project Engineer (DRP/B)

Branch Chief (DRP/TSS)

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! DRS Action item File (98-G-0067)(Goines)

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DOCUMENT NAME: R:\_CVWCW806AK.GMG'

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, To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No eq)y RIV:PSB E C:DRS\PSL ~

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Union Electric Company -4-DISTRIBUTION w/coov of licensee's letter dated May 22.1998::

DCD (IE35)

Regional Administrator Callaway Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/B)

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Project Engineer (DRP/B)

Branch Chief (DRP/TSS)

l MIS System

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RIV File DRS Action item File (98-G-0067)(Goines)

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DOCUMENT NAME: R:\_CVWCW806AK.GMG To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:PSB - E C:DRS\PSL ~

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06rJ/98 06/hq8 OFFICIAL RECORD COPY 080062

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union Doctric Po Box 620

, CallswarMant Fulton, MO 65251

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!;526 May 22,1998

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i U. S. Nuclear Regulatory Commission 1 Atta: Document ControlDesk Mail Stop P1-137

Washington, DC 20555-0001 ULNRC-3815 gI/, Oentlemen:

REPLY TO NOTICE OF VIOLATION

1. E 1xSetCr10x atrOar uO. so-483/98oo6 CALLAWAY PLANT UNION ELECTRIC C This responds to Mr. Arthur Howell's letter dated April 22,1998, which transmitted two Notices of Violation for events discussed in Inspection Report 50-483/98006. Our response to these violations is presented in the attachmen None of the material in the response is considered proprietary by Union Electri If you have any questions regarding this response, or if additional information is required, please let me kno Very truly yours, J. V. Laux Manager, Quality Assurance JVIJtmw Attachment: 1) Response to Violations

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- ULNRC-3815 May 22,1998

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Page 2-l cc: Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman,MO 65077 Ms. Kristine M. Thomas (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street Washington,DC 20037

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Manager, Plant Support Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839

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Attachment to ULNRC-3815 l

May 22,1998 Page1 Statement of Violation During an NRC inspection conducted on March 24-26,1998, two violations ofNRC requirements were identified. In accordance with the " General Statement ofPolicy and

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Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below: CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to mer.t 50.47(b) planning standards and Appendix E requirement CFR 50.47(b)(2) requires, in part, that the onsite emergency response plan

- must meet the standard of providing that adequate staffing for initial facilit accident response in key functional areas be maintained at all times, and timely augmen'tation of response capabilities is availabl Contrary to these requirements, on May 29,1997, the licensee made changes to its l emergency plan, without Commission approval, that decreased the effectiveness of the plan and did not continue to meet Planning Standard 50.47(b)(2). Specifically, augmentation capabilities were reduced as follows:

(1) The response goal for a dedicated communicator position was changed from 30-45 minutes to 60 minutes, (2) The response goal for the position that performs core thermal hydraulics assessment (technical assessment coordinator) was changed from 30-45 minutes to 60 minute (3) The response goal for the health physics coordinator, who directs assessment of onsite radiological conditions and support activities, including protective measures, was changed from 30-45 minutes to 90 minute (4). The response goal for the operations support coordinator, who forms, directs, coordinates, and briefs inplant teams, was changed from 60-75

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minutes to 90 minute q i

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Attachment to ULNRC-3815 i

May 22,1998 Page 2 (5) The response goal for the emergency team coordinator, who directs inplant i team formation and performs team briefings, dispatch, and tracking, was changed from 60-75 minutes to 90 minute (6) The response goal for six radiation / chemistry technicians was changed from 30-45 minutes to 90 minutes. The response goal for six other radiation / chemistry technicians was changed from 60-75 minutes to 90 minute (7) The response goals for the chemistry coordinator, who directs primary and secondary chemistry activities and evaluates chemical conditions, was changed from 60-75 minutes to 90 minute (8) The response goal for one mechanic was changed from 60-75 minutes to 90 minute (9) The response goal for the electrician was changed from 30-45 minutes to 90 minute (10) The response goal for one instrumentation and control technician was changed from 60-75 minutes to 90 minute (11) The response goal for the emergency operations facility communicators was changed from 60-75 minutes to 90 minute (12) The response goal for the technical support center engineering staff was changed from 60-75 minutes to 90 minute (13) The response goal for the security coordinator was changed from 60-75

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minutes to 90 minute (14) The response goals for the joint public information center coordinator, administrator, editor, and media host were changed from 2 to 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> This is a Severity Level IV violation (Supplement VIII)(50-483/98006-01).

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Attachment to ULNRC-3815 May 22,1998 Page 3 Reason for the Violation l In May of 1997, Union Electric personnel made substantial changes to the emergency

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response plan. In reviewing the plan changes under the 10 CFR 50.54(q) process, it was determined that the aggregate of the plan changes did not decrease the effectiveness of the plan. The 10 CFR 50.54(q) analysis for the RERP, Revision 21, was flawed in that the personnel involved with the analysis only considered overall RERP effectiveness and did not consider each individual part of the change as a change potentially requiring prior NRC approval. Procedures governing the evaluation process did not provide adequate guidance to insure that plan changes requiring prior NRC approval were identifie Corrective Steps Taken and Results Achieved:

Based upon the results of the NRC reactive inspection conducted March 24-26,1998, a change notice to the radiological emergency response plan was issued that revised the response goals back to the previously approved radiological emergency response pla This was implemented on March 30,199 Revision 22 to the radiological emergency response plan was generated for NRC review l and approval, and a meeting was held at NRR to discuss the plan changes on April 2,1998. Since Revision 22 is considered a potential decrease in effectiveness, Chapter 5 has been submitted for Commission revie An interim response organization was established and trained to ensure the previously approved response goals for augmentation would be me Corrective Steps to Avoid Further Violations:

An outside consultant has conducted an independent review of our administrative procedures for radiological emt.rgency response plan chrnges. This review found that existing procedures address the methodology for making changes to the emergency response plan but those procedures should be enhanced to improve the evaluation proces Procedures governing RERP changes will be revised to provide additional guidance to identify changes requiring prior NRC approva Emergency Preparedness staff and related plant management responsible for making !

changes to the radiological emergency response plan will be provided training on application of the 10 CFR 50.54(q) regulations in the plan review / revision proces I

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ULNRC-3815 May 22,1998 ~

Page 4 Date when Full Compliance was Achieved:

l Full compliance of the Callaway RERP with 10 CFR 50.54(q),10 CFR 50.47(b)(2), and 10 CFR 50, Appendix E was achieved on March 30,1998. All remaining actions listed above will be completed by June 26,199 .

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Attachment to ULNRC-3815 May 22,1998 Page 5 Statement of Violation During an NRC inspection conducted on March 24-26,1998, two violations ofNRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below: CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet 50.47(b) planning standards and Appendix E requirement Contrary to the above, on May 29,1997, the licensee made changes to its emergency plan, without Commission approval, that decreased the effectiveness of the plan. Specifically, the requirement to collect and analyze offsite sample media (solid, liquid, gas) was deleted from the description of the radiological monitoring drill. This resulted in a reduction in field monitoring team training requirement This is a Severity Level IV violation (Supplement VIII)(50-483/98006-02).

Reason for the Violation Union Electric Emergency Preparedness staff met with the Missouri State Emergency Management Agency (SEMA) and Department of Health, to discuss the responsibilities for environmental sampling. In the State of Missouri Radiological Emergency Response Plan, environmental sampling is the responsibility of the Department of Health. Based upon the State performing environmental sampling, Union Electric personnel determined that there was no reduction in effectiveness of the emergency plan for this item. The 10 CFR 50.54(q) analysis for this RERP revision was flawed in that this was a reduction in effectiveness of Union Electric's capabilit Corrective Steps Taken and Results Achieved:

Based upon the results of the NRC reactive inspection conducted March 24-26,1998, a j change notice to the radiological emergency response plan was issued that revised the environmental sampling requirement back to the previously approved radiological emergency response plan. Procedures were revised and training was verified current for field monitoring teams. This was implemented on March 30,199 l l

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Attachment to ULNRC-3815 May 22,1998 Page 6 Corrective Steos to Avoid Further Violations:

An outside consultant has conducted an independent review of our administrative procedures for radiological emergency response plan changes. This review found that existing procedures address the methodology for making changes to the emergency response plan but those procedures should be enhanced to improve the evaluation proces Procedures governing RERP changes will be revised to provide additional guidance to identify changes requiring prior NRC approva Emergency Preparedness staff and related plant management responsible for making

< changes toh t e ra o ogil dil ca emergency response plan will be provided training on application of the 10 CFR 50.54(q) regulations in the plan review / revision proces Date when Full Compliance was Achieved:

Full compliance of the Callaway RERP with 10 CFR 50.54(q),10 CFR 50.47(b)(2), and 10 CFR 50, Appendix E was achieved on March 30,1998. All remaining actions listed above will be completed by June 26,1998.

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