ML031220524
| ML031220524 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/02/2003 |
| From: | Chamberlain D Division of Reactor Safety IV |
| To: | Randolph G Union Electric Co |
| References | |
| EA-03-060 IR-03-008 | |
| Download: ML031220524 (18) | |
See also: IR 05000483/2003008
Text
May 2, 2003
Garry L. Randolph, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT: NRC SPECIAL INSPECTION: INSPECTION REPORT 50-483/03-08;
PRELIMINARY WHITE FINDING - CALLAWAY PLANT
Dear Mr. Randolph:
This report discusses a finding that appears to have low to moderate safety significance. As
described in Section 2.b of this report, the finding involved the failure to maintain your primary
emergency preparedness alert notification system, and also involved apparent cross cutting
human performance issues. This finding was assessed based on the best available
information, including influential assumptions, using the emergency preparedness Significance
Determination Process (SDP) dated December 29, 2000, and was preliminarily determined to
be a White Finding. Although the finding was determined to represent a failure to meet a risk
significant emergency preparedness planning standard, the finding has a low to moderate
safety significance because the loss of notification system function affected less than 2 percent
of the population of the emergency planning zone.
In September 1998, you identified that the database used to identify your tone alert radio
distribution contained significant errors. However, you failed to correct those errors and the
database continued to degrade until a change in electric service provider coverage in your
emergency planning zone in October 2002 prompted you to correct and update the database.
As a result of the errors, a small percentage of residences in your emergency planning zone
would not have received an emergency alerting signal in the event of an accident at the
Callaway facility. The facility staff has implemented appropriate immediate compensatory
measures, and therefore the finding does not present an immediate safety concern. The facility
staff is continuing with long-term corrective measures.
The finding is also an apparent violation of NRC requirements and is being considered for
escalated enforcement action in accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600. The current
Enforcement Policy is included on the NRCs Web Site at
http://www.nrc.gov/what-we-do/regulatory/enforcement/enforce-pol.html.
Before we make a final decision on this matter, we are providing you an opportunity (1) to
present to the NRC your perspectives on the facts and assumptions, used by the NRC to arrive
Union Electric Company
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at the finding and its significance, at a Regulatory Conference, or (2) submit your position on
the finding to the NRC in writing. If you request a Regulatory Conference, it should be held
within 30 days of the receipt of this letter and we encourage you to submit supporting
documentation at least one week prior to the conference in an effort to make the conference
more efficient and effective. If a Regulatory Conference is held, it will be open for public
observation. If you decide to submit only a written response, such submittal should be sent to
the NRC within 30 days of the receipt of this letter.
Please contact Mr. Troy Pruett at (817) 860-8215 within 10 business days of the date of receipt
of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days,
we will continue with our significance determination and enforcement decision and you will be
advised by separate correspondence of the results of our deliberations on this matter.
Since the NRC has not made a final determination in this matter, no Notice of Violation is being
issued for these inspection findings at this time. In addition, please be advised that the
characterization of the apparent violation described in the enclosed report may change as a
result of further NRC review.
In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its
enclosure, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Should you have any questions concerning this inspection, we will be pleased to discuss them
with you.
Sincerely,
//RA//
Dwight D. Chamberlain, Director
Division of Reactor Safety
Docket: 50-483
License: NPF-30
Enclosure:
NRC Inspection Report
50-483/03-08
Union Electric Company
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cc w/enclosure:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855
John ONeill, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, N.W.
Washington, D.C. 20037
Mark A. Reidmeyer, Regional
Regulatory Affairs Supervisor
Regulatory Affairs
Ameren UE
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
for Public Policy
Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102
Rick A. Muench, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
Dan I. Bolef, President
Kay Drey, Representative
Board of Directors Coalition
for the Environment
6267 Delmar Boulevard
University City, Missouri 63130
Manager
Quality Assurance
Ameren UE
P.O. Box 620
Fulton, Missouri 65251
Union Electric Company
-4-
Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, Missouri 65101
Scott Clardy, Director
Section for Environmental Public Health
P.O. Box 570
Jefferson City, Missouri 65102-0570
Manager
Regulatory Affairs
Ameren UE
P.O. Box 620
Fulton, Missouri 65251
Technical Services Branch Chief
FEMA Region VII
2323 Grand Blvd., Suite 900
Kansas City, Missouri 64108-2670
David E. Shafer
Superintendent, Licensing
Regulatory Affairs
Ameren UE
P.O. Box 66149, MC 470
St. Louis, Missouri 63166-6149
Union Electric Company
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Electronic distribution by RIV:
Regional Administrator (EWM)
DRP Director (ATH)
DRS Director (DDC)
Senior Resident Inspector (MSP)
Branch Chief, DRP/B (DNG)
Senior Project Engineer, DRP/B (RAK1)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
DMB (IE35)
W. A. Maier, RSLO
OEMail
Only inspection reports to the following:
B. McDermott (BJM)
CWY Site Secretary (DVY)
ADAMS: Yes
No Initials: ______
Publicly Available Non-Publicly Available
Sensitive
Non-Sensitive
DOCUMENT NAME: R:\\_CW\\CW2003-08RP-REL.WPD
RIV:DRS\\SEPI
RIV:DRS\\SRPI
C:DRS\\PSB
C:DRP\\B
D:ACES
RELantz*
MPShannon*
TWPruett
DNGraves*
GFSanborn
/RA/
/RA/
/RA/
/RA/
MV for
4/ 9 /03
4/ 10 /03
4/ 24 /03
4/ 11 /03
4/ 24 /03
D:DRS
DDChamberlain
/RA/
5/ 2 /03
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
- previously concurred
ENCLOSURE 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-483
License:
Report No.:
50-483/03-08
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Junction Highway CC and Highway O
Fulton, Missouri
Dates:
February 10 through March 21, 2003
Inspectors:
Ryan Lantz, Senior Emergency Preparedness Inspector
Michael Shannon, Senior Health Physicist
Approved By:
Dwight D. Chamberlain, Director
Division of Reactor Safety
Attachments:
(1) Supplemental Information
(2) Event Time Line
SUMMARY OF FINDINGS
Callaway Plant
NRC Inspection Report 50-483/03-08
IR 05000483/03-08; Union Electric Co; Callaway Plant on 02/10-03/21/2003; Special Inspection
Report; Alert Notification System Tone Alert Radios. One preliminary White finding.
The inspection was conducted by two regional senior inspectors. The inspection identified one
apparent violation of NRC requirements. The significance of most findings is indicated by their
color (Green, White, Yellow, Red) using Inspection Manual Chapter 0609 Significance
Determination Process. Findings for which the significance determination process does not
apply are indicated by No Color or by the severity level of the applicable violation. The NRCs
program for overseeing the safe operation of commercial nuclear power reactors is described at
its Reactor Oversight Process website at
http://www.nrc.gov/NRR/OVERSIGHT/ASSESS/index.html.
Cornerstone: Emergency Preparedness
TBD. Between September 1998, and November 2002, due to programmatic
inadequacies, a small percentage of residences in the licensees plume exposure
emergency planning zone would not have received an emergency alerting signal in the
event of an emergency at the Callaway facility. The failure to establish a means to
notify members of the public in the emergency planning zone was a violation of
10 CFR 50.47(b)(5), and also represented an apparent human performance cross
cutting issue involving the timely recognition and correction of degraded conditions.
The finding had greater than minor significance because the condition resulted in a loss
of alert notification capability to about 1.5 percent of the emergency planning zone
population, and if left uncorrected the condition would have continued to degrade.
Using the Emergency Preparedness Significance Determination Process the finding was
preliminarily determined to have low to moderate safety significance (White) because it
was a violation of 10 CFR 50.47(b)(5) and represented a risk-significant planning
standard degraded function failure. This finding was entered in the licensees corrective
action program as Callaway Action Request System Item CARS 200208007
(Section 2.0).
Identification and Resolution of Problems
The inspectors determined that several opportunities to promptly identify and correct a
risk significant condition involving the tone alert radio portion of the Alert Notification
System were missed. Errors in the tone alert radio distribution database were first
identified in September 1998, as a result of a review prompted, in part, by the national
change from an Emergency Broadcast System to the Emergency Alert System.
Corrective actions taken at that time failed to update the database, and failed to
implement programmatic changes to prevent further degradation. Subsequent quality
assurance audits, self-assessments, and surveillances failed to identify that the
database was not corrected in 1998, and that procedural problems and inadequate
supervisory oversight had resulted in a continuing degradation of the database through
November 2002 (Section 4OA2).
Report Details
1.0
Description of Event and Chronology
1.1
Event Summary
Tone Alert Radios (TARs) were used by the licensee as the primary emergency alert
notification system for those residences located within the licensees 10-mile Emergency
Planning Zone (EPZ) that were outside alert notification siren coverage. A database of
those residences requiring TARs was maintained by facility nuclear senior clerks (NSCs)
and updated monthly by reviewing information provided by Callaway Electric
Cooperative, Three Rivers Electric Cooperative, and Ameren Union Electric (UE); the
three utilities supplying residential electric service in the licensees 10-mile EPZ. While
performing surveillance ST-12055, Monthly Distribution of Tone Alert Radios, on
November 7, 2002, the assigned NSC noted an abnormally high number of new
electrical hookups of residences in the Callaway Electric Cooperative service area.
Unknown to the licensee, Callaway Electric Cooperative had acquired additional service
area from Ameren UE in October 2002. After comparing the new electrical hookup list
to the current TAR database, the licensee concluded that approximately 65 residences
in the prior Ameren UE service area had not been issued TARs as required. On
November 26, 2002, the licensee documented the partial loss of TAR coverage in the
stations corrective action program as Callaway Action Request (CAR) 200208007.
On November 27, 2002, CAR 200208007 was screened by the Callaway Onsite Review
Committee as a Significance Level One CAR, requiring a root cause analysis, and
notification to NRC Region IV, Federal Emergency Management Agency Region VII,
and the Missouri State Emergency Management Agency of the occurrence. TAR
mailings to the initially identified 65 affected residences were completed on
November 27, 2002. The licensees full analysis of the partial loss of TAR coverage,
completed in early March 2003, resulted in identification of an additional 33 affected
residences. TARs were mailed to each of these additional residences immediately after
identification.
1.2
Sequence of Events
The inspectors developed a detailed sequence of events and organizational response
time line. The time line included applicable events and actions before, during, and
following the November 2002 identification of a partial loss of TAR coverage. The time
line was generated from the licensees root cause analysis report, written records, and
interviews with members of the licensees staff. The detailed sequence of events is
provided in Attachment 2.
2.0
Human Factors and Procedural Aspects of the Event
a.
Inspection Scope
The inspectors evaluated the quality of procedures for maintenance of the TAR
database, and the effectiveness of supervisory oversight and administrative staff actions
in utilizing those procedures. The inspectors interviewed facility and electric service
provider personnel, and reviewed the facility root cause report. The inspectors also
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reviewed documents to determine the design requirements for the Callaway Alert
Notification System (ANS).
b.
Observations and Findings
Introduction. The inspectors identified an apparent violation of 10 CFR 50.47(b)5, which
requires, in part, that a . . . means to provide early notification and clear instruction to
the populace within the plume exposure pathway Emergency Planning Zone have been
established. The finding was preliminarily determined to be of low to moderate safety
significance (White).
Description. The inspectors identified several instances of poor procedural guidance,
inadequate supervisory oversight, and ineffective administrative practices which affected
the ability to maintain an accurate TAR database. The inspectors also identified several
missed opportunities to identify errors in the TAR database and programmatic
inadequacies that allowed continued degradation of the TAR database.
The Callaway NSCs were responsible for performing the monthly and annual
surveillances used to maintain the TAR database. These surveillances were used to
satisfy, in part, Section 8.5, Maintenance and Inventory of Emergency Equipment and
Supplies, of the Callaway Emergency Response Plan (ERP). The inspectors observed
the following inadequacies in the performance and content of both of these maintenance
surveillances:
The monthly surveillance, ST-12055, Monthly Distribution of Tone Alert Radios,
required the NSC to review new electric service hookup and disconnect
information and determine if any of the addresses were outside of siren
coverage. The NSC utilized a TAR desktop guide, Emergency Preparedness
Tone Alert Radio Distribution/Database Maintenance, as a reference to make
the determination. The NSC independently evaluated the information supplied
by the electric utilities, updated the TAR database, and prepared a mailing for
the new TAR users. During an interview, an NSC explained to the inspectors
that she had been told verbally that when a Mokane address was observed, it
should be considered to be within siren coverage, and therefore would not
require issuance of a TAR. The desktop guide reinforced this expectation in
Section 2.1.3, Ameren UE Cards, which stated, in part, that if the address was
. . . a street, . . . its probably located in the town of Mokane, which is covered by
siren. However, after the November 2002 event, it was identified that some
street addresses in Mokane were outside siren coverage.
The annual surveillance, ST-12056, Annual Mailing of Tone Alert Instructions,
was used by the NSCs to send each residence in the TAR database new
batteries and use instructions. In 2000, the annual surveillance was modified to
require the NSC to select one of the three local electric service utilities, request
an updated customer list to compare to the TAR database, and revise as
needed. This change was made as a cost saving measure to ensure new TAR
batteries and instructions were not mailed to inactive residences. The
surveillance did not specify which utility should be chosen, nor did it require
selection of a different utility each year. The inspectors noted that each year
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since modification of the surveillance, the Three Rivers Electric Cooperative was
chosen for database comparison. The inspectors determined that use of the
same utility each year did not result in adequate coverage of all utilities by the
annual surveillance.
The NSCs had inadequate guidance concerning when to expect electrical
hookup information from the Ameren UE utility. The TAR desktop guide stated,
in part, that a monthly report would be received from the Callaway and Three
Rivers Cooperatives, but only stated that . . . you will also receive cards for
Union Electric customers. The majority of the Ameren UE customers are in siren
coverage. From May 2002 through November 2002, Ameren UE failed to send
the hookup/disconnect cards due to a change in the Ameren UE customer
tracking system. This failure to send the cards was not questioned by the NSCs
nor the emergency preparedness staff.
The completion of each monthly and annual surveillance was required by
procedure to be reviewed by a member of the emergency preparedness staff,
but neither that review nor any independent or quality control verifications were
required to validate the accuracy of the NSCs conduct of the surveillance. Prior
to the licensees evaluation of corrective actions for the November 2002 event,
neither the emergency preparedness reviewer, nor any other quality control or
audit review, identified that the practice of selecting the same utility for review
each year did not result in an adequate coverage by the surveillance and would
be ineffective in correcting database errors.
The inspectors determined that the poor procedural guidance provided to the NSCs and
inadequate supervisory oversight of the conduct of the TAR maintenance surveillances,
directly contributed to the emergency preparedness programmatic weakness that
resulted in the inability to provide timely notification to all members of the populace
located in the EPZ.
The inspectors reviewed the specific design requirements of the Callaway ANS system
to determine program compliance with the required design. The Callaway ERP,
Section 3.1, stated that the ERP . . . satisfies the intent of the guidance stated in
NUREG-0654/FEMA-REP-1, Revision 1. NUREG-0654/FEMA-REP-1, Criteria for
Preparation and Evaluation of Radiological Emergency Response Plans and
Preparedness in Support of Nuclear Power Plants, gives specific design criteria for the
ANS in Appendix 3. Section 6.7.2.1 of the ERP, Alerting the General Public,
describes, in general terms, the use of fixed sirens and tone alert receivers as the
system used to alert the population in the 10-mile EPZ. More specific uses of the ANS
are contained in Appendix H of the ERP. Both of these areas of the ERP stated that the
ANS provides alerting to approximately 100 percent of the population within the 10-mile
EPZ. The detailed design of the ANS is described in the FEMA approved ANS Design
Report. The ANS Design Report confirms the use of the TARs as the primary means of
physical notification for those residents outside siren coverage. The ANS Design Report
discusses both the administrative and physical means of notification in Section E.6, and
stated that additional information on the administrative means of notification is found, in
part, in Annex D of the affected countys Radiological ERP.
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The inspectors reviewed Annex D of the Callaway County ERP. Section III.A,
Emergency Instructions to the Public, Public Alert System, described the ANS as
having two specific capabilities: 1) within 15 minutes, provide area-wide coverage of the
entire 10-mile EPZ and direct coverage of essentially 100 percent of the population
within five miles of the plant, and 2) within 45 minutes, coverage of the entire population
within the 10-mile EPZ. These criteria are essentially a reprint of the criteria in
Appendix 3 to NUREG-0654/FEMA-REP-1.
The inspectors determined that the Callaway ANS design required the licensee to be
able to identify where failures in the primary ANS had occurred, and take compensatory
measures within 45 minutes to notify those residents who were potentially affected by
that failure. The inspectors determined that the 45 minute design criterion could not be
met due to, (1) the inaccurate TAR distribution, and (2) the inability to identify those
residences without TARs and take appropriate compensatory actions within
approximately 45 minutes. The licensees final evaluation of the partial loss of TAR
coverage required extensive effort and approximately 4 months of time to identify all of
the affected residences and issue the appropriate TARs.
The inspectors reviewed the extent of the TAR system loss. The licensees evaluation
identified approximately 98 residences that had not received TARs. Based on a total
TAR distribution of approximately 2500, this represented a loss of approximately
3.9 percent of the TAR portion of the ANS system. Based on an average of
three occupants per residence, and a total population of 19,000, this loss affected
approximately 1.5 percent of the population of the EPZ. Sixty-five of the missing TARs
were located in the prior to October 2002 Ameren UE service area, which had a total of
232 residences outside of siren coverage. This represented a loss of approximately
28 percent of the TAR system for the prior Ameren UE service area. The inspectors
concluded that the likelihood for residents to be alerted to an emergency condition by
other means, such as increased traffic, noise in the streets, etc. . . . was reduced in the
prior Ameren UE service area due to the relatively large percentage of the TAR system
affected.
The inspectors determined that the failure of the licensees self-assessments, audits,
and supervisory oversight to identify this finding was a significant weakness in the
problem identification and resolution cross cutting area. Since this failure is related to
the finding, the inspectors did not characterize the failure as a separate problem
identification and resolution concern. Additional details are in section 4OA2.
Analysis. The finding was assessed through the Failure to Meet Regulatory
Requirement branch of the Emergency Preparedness Significance Determination
Process (SDP). This finding is a performance deficiency in that inadequate procedures,
quality reviews, and supervisory oversight resulted in TARs not being distributed to
approximately 98 residences. The finding had greater than minor significance because
the condition resulted in a loss of alert notification capability to about 1.5 percent of the
EPZ population and if left uncorrected, the condition would have continued to degrade.
The issue is associated with attributes of the Emergency Preparedness Cornerstone,
and did affect the cornerstone objective, in that 98 residences would not have been
notified of an emergency through their primary notification system. The finding was
determined to represent an apparent failure to meet a risk significant emergency
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preparedness planning standard as defined by Inspection Manual Chapter 0609,
Appendix BProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix B" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 2.a, with a preliminary significance determination of WHITE.
Enforcement. 10 CFR 50.47(b) requires that the onsite emergency response plans for
nuclear power reactors meet each of fourteen planning standards. Standard (5) states,
in part, that a . . . means to provide early notification and clear instruction to the
populace within the plume exposure pathway Emergency Planning Zone have been
established. The failure to maintain an accurate TAR database, and the inability to
recognize that failure and take compensatory measures in a sufficiently short time
period, resulted in the failure to establish a means to notify members of the populace in
the EPZ between September 1998 and November 2002, in the event of an accident at
the Callaway facility, and is an apparent violation of 10 CFR 50.47(b). The licensee took
immediate corrective actions to issue TARs to the residences initially identified during
this event. The licensee also took extensive actions to identify all of the residences in
the EPZ that are outside siren coverage to correct any additional errors in the TAR
database and issued TARs, as appropriate. The inspectors determined that the interim
corrective actions taken were adequate and that based on these actions, the finding and
apparent violation is not an immediate safety concern. The licensee has entered this
issue into its corrective action program as CAR 200208007 (AV 50/483-0308-01).
4OA2 Identification and Resolution of Problems
a.
Inspection Scope
The inspectors reviewed periodic audits and surveillances, as well as corrective action
documents, to identify prior opportunities to identify and correct the TAR database errors
and programmatic inadequacies.
b.
Observations and Findings
The inspectors determined the first missed opportunity to identify the degraded TAR
database was due to incomplete corrective actions in response to Suggestion
Occurrence Solution (SOS) Report SOS-98-3339 dated September 1, 1998. This SOS
identified that TAR database errors existed, but failed to complete corrective actions to
update the database, and failed to identify process control and procedural inadequacies
that contributed to the errors. Quality Assurance Surveillance Report SP98-100, dated
December 28, 1998, incorrectly identified that all actions from SOS-98-3339, with the
exception of issuing new radios, were completed. In fact, the TAR database had not
been corrected for the Ameren UE utility, since an updated customer list had not been
received. On May 11, 1999, SOS-98-3339 was closed based on the completion of the
TAR database revisions which, in fact, had not been performed.
Annual reviews of the emergency preparedness program conducted by the facility
quality assurance organization, as required by 10 CFR 50.54(t), failed to identify the
incomplete corrective actions from SOS-98-3339, and also failed to identify the process
and procedural inadequacies which led to the continuing degradation of the TAR
database. The inspectors determined the weaknesses displayed in the audit program
directly contributed to the emergency preparedness programmatic weakness that
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resulted in the inability to provide timely notification to all members of the populace
located in the EPZ.
Supervisory review of the second and third instances of the revised annual TAR
maintenance surveillance, ST-12056, completed April 10, 2001 and 2002, respectively,
failed to identify that the surveillance was not providing adequate coverage of all utilities.
Although the surveillance was being conducted as written, the TAR database was not
being reviewed and updated for two of the three residential electric service providers.
The inspectors determined that these programmatic and implementation weaknesses
represented a human performance cross cutting issue involving the timely recognition
and correction of degraded conditions. Because this cross cutting issue directly
contributed to the apparent violation discussed in Section 2.0, it was not identified as a
separate finding.
4OA6 Management Meetings
Exit Meeting Summary
On March 21, 2003, the inspectors presented the inspection results to Mr. G. Randolph,
Senior Vice-President, Generation and Chief Nuclear Officer, and other members of his
staff at a telephonic exit meeting. The licensees staff acknowledged the findings
presented.
The inspector asked the licensees staff whether any materials examined during the
inspection should be considered proprietary. No proprietary information was identified.
ATTACHMENT 1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee
R. Affolter, Vice President, Nuclear
L. Akers, Accountant, Callaway Electric Cooperative
J. Beck, Customer Service, Ameren UE Jefferson City
B. Berger, Office Supervisor, Three Rivers Electric Cooperative
W. Bevard, Emergency Response Coordinator
J. Blosser, Manager, Regulatory Affairs
S. Crawford, Emergency Response Coordinator
L. Graessle, Superintendent, Protective Services
J. Hiller, Engineer, Regional Regulatory Affairs
G. Houghs, Supervising Engineer, Quality Assurance
D. Kuhlman, Customer Accounts, Ameren UE Saint Louis
J. Laux, Manager, Operations Support
A. Lee, Supervisor, Access Control
V. McGaffic, Superintendent, Performance Improvement
G. Pendergraff, Evaluator, Protective Services
G. Randolph, Senior Vice President, Generation; Chief Nuclear Officer
M. Reidmeyer, Supervisor, Regional Regulatory Affairs
A. Ruga, Nuclear Clerk
C. Struttmann, Senior Nuclear Clerk
J. Winkler, Corrective Action Specialist
W. Witt, Plant Manager
NRC
J. Hanna, Resident Inspector
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
05000483/0308-01
Failure to meet the Alert Notification System design
criteria due to programmatic deficiencies resulting
in an inaccurate Tone Alert Radio database in
apparent violation of 10 CFR 50.47(b)(5).
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DOCUMENTS REVIEWED
The following documents were selected and reviewed by the inspectors to accomplish the
objectives and scope of the inspection and to support any findings:
Corrective Action Program Documents
SOS-98-3339, CAR 199901955, CAR 200208007, CAR 200300778
Root Cause Evaluation, CAR 200208007, February 5, 2003
Miscellaneous Documents
Callaway Radiological Emergency Response Plan, Revision 25
Annex D to Callaway County/Fulton Radiological Emergency Response Plan, June 1999
Callaway County/Fulton Emergency Procedures #6 and #15
Alert and Notification System Design Report, January 7, 2002
Surveillance Report SP98-100, of December 28, 1998
Procedures
Procedure APA-ZZ-00500, Corrective Action Program, Revision 31
Procedure KSP-ZZ-0001, Alert and Notification Availability, Revisions 0 and 1
Tone Alert Radio Desktop Guide, Emergency Preparedness Tone Alert Radio
Distribution/Database Maintenance, November 10, 1998
LIST OF ACRONYMS USED
Alert and Notification System
Callaway Action Request
CFR
Code of Federal Regulations
10-mile Plume Exposure Emergency Planning Zone
ERP
Emergency Response Plan
Federal Emergency Management Agency
Nuclear Senior Clerk
Significance Determination Process
SOS
Suggestion Occurrence Solution
To Be Determined
Union Electric
ATTACHMENT 2
Event Time line:
Partial Loss of Tone Alert Radio Coverage at Callaway.
January 1998
Per normal practice, letters were sent to verify type of residence to new
residents in the Emergency Planning Zone (EPZ) identified as located
outside siren coverage. Tone Alert Radios (TARs) were sent after
responses to the letters verified permanent occupied residences. Very
few letters were returned. Implementation of the National Emergency
Alert System from the Emergency Broadcast System changed the
broadcasting radio frequencies and made the current TARs ineffective.
September 1, 1998
Callaway RMS Supervisor initiates an investigation on the delay in
issuance of TARs. No TARs had been issued to new residents in the
EPZ since January 1998, resulting in errors in the current database.
Corrective Action Report (Suggestion Occurrence Solution Report)
SOS-98-3339 was written on September 1, 1998, to document the issue.
Corrective actions included requesting a list from each of the three local
residential electric service companies of all customers located in the EPZ.
September 29, 1998 SOS-98-3339 stated, All action to close this SOS projected to be
completed by the end of January 1999. We are waiting for receipt of
customer printouts from local utilities. TARs were then issued to new
residents as customer lists were received.
December 23, 1998
Quality Assurance Surveillance Report SP98-100 was issued. This
surveillance report reviewed the corrective actions associated with
SOS-98-3339. Surveillance Report SP98-100 stated that, There is a
current status for completion of 1/31/1999, to allow shipment of new
radios upon receipt. All other actions have been completed.
May 11, 1999
SOS-98-3339 was closed based on receipt of utility printouts and
completion of the TAR distributions and database revisions. (During the
investigation of the problem identified in November 2002, the licensee
determined that a customer list was not received from Ameren UE and
that SOS-98-3339 was incorrectly closed.)
March 17, 2000
Annual surveillance ST-12056 was performed using Three Rivers Electric
Cooperative customer information. No problems were identified.
October 24, 2000
Annual surveillance ST-12056, Annual Mailing of Tone Alert
Instructions, was modified to require, in part, that the licensee obtain one
of the three local service utilitys customer data base, and compare it to
the current TAR database.
April 10, 2001
Annual surveillance ST-12056 was performed using Three Rivers Electric
Cooperative customer information. No problems were identified.
April 10, 2002
Annual surveillance ST-12056 was signed off as being performed and
was approved by a reviewing authority, with no problems identified;
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however, the documentation did not show that the TAR distribution list
was compared to a current local utility customer list as required by the
surveillance. The inspectors interviewed the individual who performed
the surveillance and determined that the TAR database was compared to
the monthly update list provided by the Three Rivers Electric Cooperative,
which would have met the surveillance requirement.
November 7, 2002
Monthly surveillance ST-12055 was performed to identify new residences
that required TARs. Clerical personnel noted an abnormally large
number of new customers for the Callaway Electric Cooperative.
November 26, 2002
Corrective Action Report (CAR) 200208007 was written to document the
large number of customers needing TARs issued. Immediate corrective
actions included: (1) Calling residences identified as possibly not having
TARs; (2) Requesting route alerting from the Callaway County
Emergency Management Director of the areas affected if an emergency
were to be declared; and (3) Identifying the number of TARs available on
site and taking actions to have additional radios delivered to the site
overnight.
November 27, 2002
CAR 200208007 screened as a Significant Level 1 CAR requiring a
formal root cause analysis. Additional immediate corrective actions taken
were to: (1) Mail TARs to all identified residences that required but did not
have radios; and (2) Provide a list of affected residents to the Callaway
County Emergency Management Director.
December 11, 2002
The event was evaluated for reportability using the guidance in
NUREG 1022, Section 3.2.13, Loss of Emergency Preparedness
Capabilities. The event was determined not to be reportable because a
major loss of offsite response capabilities had not occurred. Based on
the initial assessment of 65 affected residences, approximately
1.0 percent of the households in the EPZ were affected, which did not
meet the threshold for a major system loss. Using the final assessment
of 98 affected households, approximately 1.5 percent of the households
were affected, and similarly did not meet the reportability threshold.
January 29, 2003
CAR 200300778 was written to evaluate the extent of condition.
CAR 200300778 requested that each department head identify all cases
where their departments rely on outside organizations to ensure that they
meet regulatory responsibilities.
February 5, 2003
The root cause analysis for CAR 200208007 was completed.
February 10, 2003
NRC Special Inspection commenced on site at the Callaway facility.
March 3, 2003
The licensee completed their analysis of the extent of the loss of TAR
coverage. Thirty-three more residences that required TARs were
identified in addition to the initial sixty-five. All affected residences were
mailed TARs and usage instructions.
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March 21, 2003
The final NRC exit meeting was conducted by telephone with Callaway
facility management.