ML20057F969
| ML20057F969 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/08/1993 |
| From: | Mccormickbarge, Reidinger T, Simons H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057F962 | List: |
| References | |
| 50-483-93-14, NUDOCS 9310200030 | |
| Download: ML20057F969 (7) | |
See also: IR 05000483/1993014
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-483/93014(DRSS)
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Docket No. 50-483
License No. NDF-30
Licensee: Union Electric Company
Post Office Box 149 - Mail Code 400
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St. Louis, M0 63166
Facility Name:
Callaway Nuclear Power Plant
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Inspection At:
Callaway site, Steedman, M0
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Inspection Conducted:
September 13-17, 1993
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Inspectors:
M <-
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H. Sinfons
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Date
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T. Rei8inger
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Approved By:
~J. W. McCormickfifrger,/ Chief
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Radiological Corrtrols Section 1
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Inspection Summary
Inspection on September 13-17. 1993 (Report No. 50-483/93014(DRSS))
Areas Inspected:
Routine, announced inspection of the operational status of
the emergency preparedness (EP) program (IP 82701) and follow-up on licensee
actions on previously identified items (IP 82301). The inspection involved
two NRC inspectors.
Results: Three violations were identified involving the failure of the
Radiological Release Information System (RRIS) to provide accurate offsite
dose projections (Section 3.b); the failure to provide adequate training to
dose assessment personnel in the use of the RRIS (Section 3.d); and the
failure to correct identified deficiencies in the training course provided to
dose assessment personnel (Section 3.d).
In addition, an issue was identified
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regarding the availability of emergency implementing procedures at the
auxiliary shutdown panel (Section 3.a).
This concern will tracked as an
inspection followup item.
Emergency response facilities continued to be well maintained.
The EP
organization and management control remained unchanged.
However, significant
weaknesses were identified in the EP training program.
9310200030 931008
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DETAILS
1.
Persons Contacted
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G. Randolph, Vice President, Nuclear Operations
J. Laux, Manager, Quality Assurance
M. Stiller, Manager, Nuclear Services and Emergency Preparedness
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M. Evans, Superintendent, Health Physics
G. Czeschin, Superintendent, Training
G. Hamilton, Supervising Engineer, Quality Assurance
A. White, Supervisor, Emergency Planning
J. Barbour, Quality Assurance Engineer
K. Mills, Quality Assurance Engineer
J. Kovar, Quality Assurance Engineer
P. Sudnak, Administrator Nuclear Affairs
R. Miller, Supervisor Radwaste\\ Environment
C. Graham, Supervisor, Health Physics Technical Staff
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M. Henry, Quality Assurance Engineer
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S. Petzel, Quality Assurance Engineer
The above licensee staff attended the exit interview on
September 17, 1993. The inspectors also contacted other licensee
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personnel during the inspection.
2.
Licensee Action on Previously Identified Items (IP 82301)
(0 pen) Inspection Followup Item No. 483/93007-01: The need for the
licensee to reevaluate the split Operational Support Center (OSC)
concept.
The licensee was evaluating the current locations of the OSC and was
considering relocating the OSC to the building where the Technical
Support Center (TSC) is located.
This item will remain open pending the
licensee's final evaluation and relocation, if necessary, of the OSC.
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3.
Doerational Status of the Emeraency Preparedness (EP) Proaram (IP 82701)
a.
Emeraency Plan and Implementina Procedures
Procedure OT0-ZZ-00001, " Control Room Inaccessibility", was
reviewed.
The procedure has automatic provisions to declare an
Alert in the event of a Control Room fire, prior to evacuating the
Control Room and proceeding to the auxiliary shutdown panel (ASP).
Upon declaring an Alert, one of the Shift Supervisor's
responsibilities as Acting Emergency Coordinator is to maintain
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the appropriate emergency classification based on plant
conditions.
If plant conditions degrade while the Emergency
Coordinator is at the ASP and a reclassification is necessary, no
emergency implementing procedures are available to reevaluate the
emergency classification. This concern will be tracked as an
Inspection Followup Item (No. 483/93014-01).
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The inspectors also reviewed procedure EIP-ZZ-01210, " Radiological
Release Information System Monitoring," which is used to perform
offsite dose assessments using the Radiological Release
Information System (RRIS).
This procedure described the
capabilities of RRIS. However, through interviews with dose
assessment personnel with the responsibility for using the
procedure, it was determined that additional enhancements could be
made to clearly define the methodology for obtaining dose
projections using the RRIS.
The procedure did not provide useful
step by step instructions, nor did it provide sample dose
assessment problem projections. Numerous operator aids for the
RRIS were available to assist the dose assessors in steps where
the procedure was deficient.
The inspectors reviewed Letters of Agreement with support agencies
and determined that they were current and had been reviewed and
updated as required.
Current copies of the Emergency Plan and
emergency implementing procedures were found to be maintained and
readily available in the emergency response facilities and the
Control Room.
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No violations or deviations were identified; however, one
inspection followup item was identified.
b.
Emeroency Response Facilities. Eouipment and Sucolies
An inspection tour was conducted through the Control Room,
Technical Support Center, Operational Support Center, and the
Emergency Operations Facility.
These emergency response
facilities were found in an excellent state of operational
readiness.
An inspection of supplies located in emergency
cabinets did not reveal any problem areas. Radiological
monitoring instruments were properly calibrated.
As part of the inspection tour, a demonstration of the licensee's
primary dose assessment model, Radiological Release Information
System (RRIS) was given. This demonstration included the method
for obtaining meteorological data and release rate information;
and for calculating an offsite dose projection based on these
parameters. When an offsite dose projection was performed based
on the normal unit vent stack effluent monitors, the RRIS produced
an erroneous result. The projected dose given by the RRIS at the
site boundary was approximately 1.2 mSv/hr (120 mrem /hr).
The
actual offsite dose at the site boundary was approximately 5.0 E+8
times lower than the projected value by RRIS, or 2.4 E-9 mSv/hr
(2.4 E-7 mrem /hr).
Based on these erroneous results, the licensee initiated a review
of the RRIS dose projection model to locate the source of the
error.
At the conclusion of the inspection, the licensee declared
the RRIS inoperable for dose assessment purposes since the root
cause of the erroneous results had yet to be determined.
The
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licensee could not identify the length of time during which the
RRIS system had been producing erroneous results.
Based on this
evaluation, the inspectors concluded that the RRIS did not
accurately provide near real-time predictions of atmospheric
transport and diffusion estimates of radioactive releases as
required by the licensee's emergency plan and 10 CFR 50.47. This
is a Severity Level IV violation (Violation No. 483/93014-02).
The licensee did not conduct routine surveillances on the RRIS
after software modifications.
In addition, no quality control
records were maintained for any software reconfigurations to RRIS.
The inspectors reviewed communications test documentation and
inventories of emergency equipment and determined that these were
being conducted in accordance with the applicable procedure and
were adequate in ensuring that all equipment was kept in an
operational state of readiness. A review of records indicated
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that the licensee had performed quarterly tests of the Emergency
Response Data System (ERDS).
One violation was identified.
c.
Oraanization and Manaaement Control
The organization and management control of the emergency
preparedness (EP) program was unchanged from the last routine EP
inspection. The EP Supervisor reported through the Manager of
Nuclear Safety and Emergency Preparedness and the Vice President-
Nuclear to the Senior Vice President-Nuclear.
In addition, the EP
staff had been very stable. The training department continued to
be responsible for providing periodic training to the licensee's
emergency response organization (ER0).
The emergency telephone directory was well maintained with an
excellent staffing level for all but one key and support
positions. The Emergency Coordinator position was adequately
staffed with only two available individuals listed on the
emergency telephone list. Another individual listed for that
position had left the utility during that quarter.
No violations or deviations were identified.
d.
Trainina
The inspection of the training program included a review of lesson
plans, interviews with members of the ERO assigned to the position
of Dose Assessment Coordinator, and discussions with the
Supervisor, Curriculum Development.
A comparison of training records and the ERO members listed in the
emergency telephone directory revealed that all ERO members were
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currently qualified and had received the training as outlined in
TDP-ZZ-00066, "RERP Training Program."
The EP training program consisted of initial and requalification
training with specific lesson plans designated for each type of
training.
The method for developing lesson plans outlined in TDP-
ZZ-00005, " Instructional System Design," was reviewed. This
procedure allowed modifications to the EP lesson plan without
review by EP staff or management if the objectives of the lesson
plan were not changed. However, TDP-ZZ-00066, "RERP Training
Program", stated that "the Supervisor, Emergency Preparedness is
responsible for the review and approval of RERP training program
materials to ensure that they are adequate and accurate." Since
the training department staff can make major modifications to the
text of a lesson plan without EP management review, the potential
for inaccurate or inadequate training exists.
The inspectors reviewed several EP lesson plans. The lesson plans
were not routinely updated to reflect changes to the EP program.
Rather, the lesson plans were updated prior to being taught.
Discussions with the training department staff indicated it is the
responsibility of the instructor to update the material prior to
teaching a course.
Although no discrepancies were noted between
the material in the lesson plan and the Emergency Plan, several
discrepancies were noted in various reference pages of the lesson
plans itemizing revisions of procedures used in the lesson plans.
Seven separate interviews were conducted with ERO members assigned
to the position of Dose Assessment Coordinator. Their overall
performance was marginal with respect to the following tasks:
acquiring metecrological and release rate information from RRIS,
performing dose assessment using RRIS methodology and using the
guidance in the RRIS procedure and operator aids.
The licensee's
Emergency Plan states that periodic retraining is conducted to
update the knowledge and skills of onsite personnel.
However, it
was determined through these interviews, where personnel were
asked to perform dose assessments, that periodic retraining of
personnel assigned to the ERO position of Dose Assessment
Coordinator was not effective in updating their knowledge and
skills. Since the licensee is required to maintain and follow
their Emergency Plan per 10 CFR 50.54(q), this is a Severity Level
IV violation (Violation No. 483/93014-03).
After the radiological assessment course, T68.1090.8, was taught
on July 28, 1992, participants filled out course critiques.
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synopsis of numerous negative comments were summarized on the
instructor's critique form and included:
the need for improved
RRIS labs, the need to spend more training time on RRIS, the need
for more procedure review time, and the need to work dose
assessment problems on a quarterly basis.
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An action item, CA-#185A, Document #92-61, was generated to track
the resolution of these deficiencies; however, the action item was
closed out with no corrective actions. Closecut comments,
reviewed from the licensee's training action tracking system,
stated that there was nothing they could do to incorporate the
item and "not to expect to see any corrective actions."
In
addition, the Senior Training Supervisor, Radiological Emergency
Response Plan (RERP), notified of the closure of the action item,
did not implement any corrective actions.
Participants in the May 7,1993 Radiological Assessment Course
also completed course critiques.
The same deficiencies were
identified and no corrective actions had been taken.
10 CFR Part 50, Appendix E, Section F.5, states that "all training, including
exercises, shall provide for formal critiques in order to identify
weak or deficient areas that need correction.
Any weaknesses or
deficiencies that are identified shall be corrected." Since the
training deficiencies were not corrected, this is a Severity Level
IV violation (Violation No. 483/93014-04).
One error noted by the inspectors in procedure TDP-ZZ-00007,
" Training Records Program", was immediately corrected by the
licensee. The procedure which indicates that critiques were not
necessary for courses which were less than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in length was
revised to ensure that all RERP courses were critiqued regardless
of length. A review of training records indicated that past RERP
courses had been critiqued, including those less than eight hours
in length.
Two violations were identified.
e.
Audits
Aspects of the audit and surveillance programs were discussed with
the lead auditor for the EP functional area.
Records of audits
and surveillances conducted during 1993 were also reviewed. The
depth and coverance of EP activities and training had
significantly increased since the annual exercise on June 9,1993.
Audit AP93-005, " Quality Assurance Audit of Emergency
Preparedness," met the requirements of 10 CFR 50.54(t), which
included an assessment of the effectiveness of the licensee's
interfaces with State and local emergency response agencies.
With
the exception of reviews of several revised procedures, the audit
only addressed the ER0's performance during the May 1993 pre-
exercise drill, rather than most aspects of the EP program. This
audit was supplemented by numerous surveillances during the year.
Since the annual exercise, fo r surveillances had been completed
with the primary focus on the following areas:
radiological
assessment training and retraining; emergency communication
systems; emergency medical equipment kit maintenance; and
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maintenance of the public information program.
Significant
concerns were identified in the surveillance completed
September 10, 1993 of the radiological assessment retraining for
Dose Assessment Coordinators. As this surveillance had just been
completed, no corrective actions had been initiated.
Another audit, AP93-017 TQ, " Quality Assurance Audit of Licensed
and Non-licensed Training," was performed on July 26 - August 11,
1993, and included an evaluation of RERP training. A significant
finding was also identified during this audit.
The required
reading program was not being properly implemented in regards to
EP.
Procedure changes had not been issued in accordance with the
licensee's required reading program. Corrective actions will be
reviewed at a later date.
No violations or deviations were identified.
4.
Exit Interview
The inspectors held an exit interview on September 17, 1993, with those
licensee representatives identified in Section 1 to present and discuss
the preliminary inspection findings. The licensee indicated that none
of the matters discussed were proprietary in nature.
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