IR 05000483/1988003

Insp Rept 50-483/88-03 on 880125-0202.Violations Noted. Major Areas Inspected:Emergency Preparedness Program Including,Emergency Plan Activations,Licensee Actions on Previously Identified Items & Required Drills

ML20149M836
Person / Time
Site:	Callaway
Issue date:	02/19/1988
From:	Christoffer G, Patterson J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149M830	List: IR 05000483/1988003 ML20149M829 ML20149M835
References
50-483-88-03, 50-483-88-3, NUDOCS 8802290131
Download: ML20149M836 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/88003(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: January 23 through February 2,1988

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. Patterson bhW

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Inspectors: '[11[?T

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Date h I/l W a G. M. Christoffer - '

f Date Approved By:

Ld.b. b William Snell, Chief  ?/s//':A Emergency Preparedness Section Fate Inspection Summary Inspection on January 25-February 2, 1988 (Report No. 50-483/88003(URSS))

Areas Inspected: Routine, unannounced inspection of the emergency preparedness program including: emergency plan activations; licensee actions on previously identified items; changes to the emergency plan and implementing procedures; training; management and organization control; independent audits; staf f augmentation; communications; facilities and equipment; and required drill The inspection was conducted by two NRC inspector Results: One violation was identified as a result of this inspection.

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DETAILS 1. Persons Contacted

• J. Blosser, Manager, Callaway Plant

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

"J. Gearhart, Superintendent, Quality Assurance - Operations Support (QA05)

• M. Evans, Superintendent, Training

• A. White, Supervisor, Emergency Preparedness

• T. Stotlar, Supervisor, Engineering, QA05

• E. Thornton, Engineering Evaluator, QA05

• G. Nevels, Supervisor, Nuclear Information

• M. Faulkner, Administrator, Nuclear Affairs - Emergency Preparedness

• P. Sudnak, Administrator, Nuclear Affairs - Emergency Preparedness

• S. Harvey, Administrator, Nuclear Affairs - Emergency Preparedness

• D. Lewis, Administrator, Nuclear Affairs - Emergency Preparedness

• J. Dampf, Emergency Response Coordinator, NSEP

• S. Crawford, Administrator, Nuclear Affairs - Emergency Preparedness

• R. Rehmeier, Senior Training Supervisor, Training Department

• W. Hinchie, Assistant Engineer, Emergency Preparedness D. Heinlein, Assistant Superintendent, Operations N. Barnett, Shift Supervisor C. Rowe, Training Supervisor - Chemistry R. Barton, Training Supervisor - Licensing P. Bell, Chemist 14. Daume, Shift Supervisor T. Moser, Supervisory Engineer G. Pendergraff, Security Director L. Walling, Security Supervisor, BISSI (Burns International Security Services, Inc.)

• Denotes those who attended the exit interview on January 29, 198 . Licensee Actions on Previously Identified Items (Closed) Open Item No. 50-483/85003-04: The licensee has developed and implemented a means of informing State and local governmental organizations of the relevant Quality Assurance and other independent audit and surveillance findings that concern the interface between these agencies and the licensee. These findings have been transmitted to and discussed with these offsite agencies at joint meetings held at least yearl This item is closed, (Closed) Open Item No. 50-483/86009-01: A revision of the Emergency Action Levels (EAls), included in Procedure EIP-ZZ-00101 Revision 5, and the Radiological Emergency Response Plan (RERP) Revision 10 has been completed and approved by licensee managemen These Emergency Action Level (EAL) revisions were also approved by the NRC as part of Revision 10 to the RERP. The key changes included an upgrade of 4 emergency classification from a Site Area Emergency to a General Emergency for Item F, Group 6 of the EALs titled, "Radiation Release Events." Also included in the EAL revision were 15 improvements recommendo.d during a March 1986 inspectio This item is close _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _ _ _ _ __ _ _______ __ _ _ ______ ___ ____ _

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.. (Closed) Open Item No. 50-483/86002-02: A review and analysis of the capability of the Radiological Release Information Systems 7 (RRIS), for performing dose projections including computer display functions, was made in the March 1986 inspection. Training for those

, using this computer system has been implemented. Refinements and adaptations to RRIS were made subsequent to that inspection, as well as training provided to those with dose assessment responsibilitie There were nine items of concern resulting from the 1986 inspection. -

These items included some human factor elements, which have been adequately addressed. Other items included the addition of an IBM-F0 computer to the TSC in the event of a plant electrical outage; RRIS capability to provide either historical or real time data; direction on Form CA-1014 of EIP-ZZ-01211 as to which of three possible wind

! speeds available on RRIS are to be used for manual dose calculations;

and, in lieu of an isotope library in the index for the type of accident associated with the release case, an isotopic spectrum is displayed which can be used as a predictive tool. This item is close . Activations of Licensee's Emergency plan There were two events which resulted in emergency classifications during the inspection period, each of which resulted in a Notification of

] Unusual Event (NUE). Each met the EAL guidance for an earthquak The

, first event on June 8,1987 was initiated by a mine explosion near

! St. Genevieve, Missour The second event was confirmed as seismic activity by the U.S. Geological Service office in Denver, Colorado in response to the licensee's inquiry. Documentation received confirmed that notifications to the Counties of Gasconade, Montgomery, Osage, and Callaway and the State of Missouri were made in the time span required

. for each event. The NRC was adequately notified within one hour after each event was declared. Initial notification forms were properly

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i completed for each even . Operational Status of the Emergency Preparedness Program (82701)

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Changes to the Emergency Plan and Implementing Procedures

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(Also 82204)

l The licensee has just completed Revision 11 to the RERP. The Onsite i Review Committee approved this revision as part of their review

! agenda on January 29, 1988. Revision 11 to the RERP will be

submitted to NRC for review and approval within 30 days of this i inspection. Four of the main changes included are as follows

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(1) The format of the EAL tables has been changed as well as i significantly reduced in volume, from 53 pages to 27 pages.

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< (2) The concept of the interim EOF and Corporate Organization will

be replaced by a single EOF Organizatio ; (3) Letters of Agreement will no longer be maintained in the l Emergency Plan. The plan will only list which letters are in

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effect and the last update of each.

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• i (4) The RERP will be revised to reflect FEMA's new guidance of requiring only one off-hours exercise every six years, between 6:00 p.m. and 4:00 i

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Actual distribution of plan and procedure changes was conducted by e Distribution Clerks who were responsible for maintaining specific manuals and by individuals who were responsible for maintaining their own manuals. Offsite copies were mailed through the St. Louis Corporate offic They returned the signed letters of transmittal to Callaway, where records clerks monitored the letters for complianc Changes to the RERP and implementing procedures were submitted to the NRC within 30 days of such changes, as required by 10 CFR Part 50, Appendix E, Paragraph Based on the above findings, this portion of the licensee's program was acceptable, b. Emergency Facilities, Equipment and Suppliet i Documentation was reviewed which confirmed that communications tests I were completed satisfactorily per monthly, quarterly, and annual requirements. Telephone operability between the EOF and the TSC, and between the EOF and Control Room were checked at both terminals of each connection and were determined to be working satisfactoril).

Emergency kits located in the OSC, 50, and EOF were inspected and their contents verifie Inventory records for these kits were also reviewed for 1987. Inventories of the three emergency kits were conducted four to five times during 1987, but not j on a quarterly basis as required by RERP, Section 8.5 and Procedure HTP-ZZ-06022. Listed below is a tabulation of physical inventories of the emergency kits perforr.ud during 1987:

OSC TSC EOF

'anuary 1987 January 1987 January 1987 April 1987 April 1987 April 1987

i May 1987 May 1987 May 1987

! August 1987 June 1987 June 1987 January 1988 January 1988 August 1987

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January 1988 i

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The January 1988 inventories were being conducted during the week of this inspectio Tha time span from the latest 1987 inventories until the ones being conducted during the last week in January 1988 exceed the quarterly frequency (plus the 25% grace period allowed by Technical Specifications.)

Other aspects of Procedure HTP-ZZ-06022 which were not being followed satisfactorily were: Section 8.3.10, Section 8.3.13 and Section 8.3.14. These three sections relate, respectively, to replacing the old inventory checklist with a copy of the new checklist; notifying the Rad / Chem Foreman of any deficiencies which cannot be corrected immediately; and replacing, repairing, or correcting all deficiencies as soon as possibl The OSC kit was not stocked with the required amount of GRMI respirator cartridge Seventy cartridges were required as indicated on the inventory list, but only 36 were in the ki All four of the 1987 OSC inventories and the January 1988 inventory identified this deficiency. No notation was made on the inventory checklist to indicate that corrective action was in progress. None of the inventory checklists for the emergency kits in the OSC, TSC or EOF contained any notation that batteries present had been replaced semiannually as required by Procedure HTP-ZZ-06022, Section 8. CFR 50.54(q) requires that licensee's shall follow and maintain in effect emergency plans which meet the standards in 50.47(b)

and Appendix E to Part 50. The licensee has not complied with Section 8.5 of the RERP regarding inventory frequency or implemented prompt corrective action to correct identified deficiencie This is a violation of NRC requirements, and will be tracked as Item No. 50-483/88003-0 Current inventory practices by the Health Physics Group did not include sending a copy of the inventory results and corrective actions to the Emergency Preparedness (EP) Sectio It is recommended that EP be put on a distribution list for these inventory reports, and take an active role in ensuring proper inventory completio Based on the above findings, one violation was identifie c. Organization and Management Control As listed in Section 4.a., the concept of eliminating the interim E0F organization will be demonstrated in the next annual emergency exercise scheduled for June 1988. Prior drills to this exercise will utilize Corporate level personnel as EOF staff, who will be permanently assigned to the Callaway sit Previously, most E0F staff came from the corporate offic The overall emergency response effort should function more efficiently with the elimination of the interim E0F organizatio , - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ . - - - - - - - - - _ _ _ _ _ _ - . _ _ - _ _ _ _ _ _ _ _

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One new staff position has been added to_the EP group since the prior _ inspection. 'This person will concentrate on training of

'offsite~ support agencies. Otherwise, management organization and control systems have not changed since the prior inspectio Based on the above findings, this portion of the licensee's program was acceptabl Shift Staffing'and Augmentation (82205)

No changes were identified in the emergency response positions which relate to shift augmentation requirements. To verify that minimum shift staffing can be accomplished, the licensee conducted three call-in drills in May, August, and December 1987. The August drill critique determined that one individual accepted a response acknowledgement call for two separate emergency response position One Instrument and Control (I&C) Technician was required to be called by the answering service, when actually two I&C Technicians should have been contacted. This problem was resolved satisfactorily. The communicator's unfamiliarity with the paging system was the main reason for five individuals from the onsite emergency organization exceeding their response time goal by 6 to 24 minutes in the December dril The answering service instructions have been changed to ask the responder whether or not the person has already accepted a call to another emergency position. All the drills were adequately documented and critiqued. Recommended changes were acted upon with dispatc The Emergency Telephone Directory nas been updated quarterly using a data base on a personal compute Based on the above findings, this portion of the licensee's program was acceptabl Training (Also 02206)

Walkthroughs and interviews with a sampling of personnel having emergency response duties were conducted. Those interviewed included:

2 - Shift Supervisors 1 - Control Room /TSC Liaison 2 - TSC/ EOF Communicators 1 - Chemistry Coordinator 1 - Technical Assessment Coordinator 2 - Security Coordinators All were knowledgeable of their emergency response functions and utilized relevant emergency implementing procedures satisfactoril Their responses indicated a range of good to very good knowledge of their emergency responsibilitie .

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Training records were reviewed for 12 personnel who were part of the emergency response organization. All 12 had received the required EP courses and several had also participated in drills or the 1987 exercise. None of the persons selected were overdue on their required annual trainin Semiannual Health Physics Drills and the annual Radiological Monitoring Drill have been satisfactorily conducted, documented, and critique Revised and increased-training has been implemented by the Training Department for those having medical response emergency positions, including those who could be called as part of the Medical Emergency Response Team (MERT). This training resulted largely from a 1987 exercise weakness which related to the licensee's response to a simulated injured, radioactively contaminated individual located outside the protected area. Also, a site-represented task force was appointed to study and make recommendations on how Callaway would handle several injured individuals, rather than just one as most licensee exercise scenarios addres A tentative agreement has been initiated with the University of Missouri in Columbia, Missouri for use of a helicopter to transport contaminated injured licensee employees directly to the University of Missouri Hospita This hospital has a Trauma #1 Rating, which is the highest category for trauma victims. Provisions are being made for some facets of medical response training to be given by the University of Missouri. Helicopter use and such specialized training should be contractually agreed upon by March 198 Based on the above findings, this portion ;f the licensee's program was acceptabl f. Independent Reviews / Audits (Also 82210)

A review of records and discussion with licensee peisonnel verified that an annual independent audit had been performed by the licensee as required by 10 CFR Part 50.54(t). This audit was conducted from May 15 through July 8, 1987. Surveillances were also conducte Other input to the audit included the NkC inspection reports, the NRC SALP 7 report, and current EAL tables as they related to emergency plan activations at Callaway. An independent assessment of the Security Force's capability to respond to a simulated sabotage event in a drill scenario was also observe The portion cf the audit which applied to State and local governmental agency interface was made available to them by Quality Assurance (QA) staf The finding of the 1986 audit relating to offsite agencies, as well as surveillances, were discussed with S+3te and County representatives at a series of meetings held from March through May 1987. These meetings also included discussions of the RERP, changes and of two

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o emergency. implementing procedures, EIP-ZZ-C0016, Activation of the Backup Emergency Operations Facility, and EIP-ZZ-PR020, Activation and Operation of Emergency Public Information Facilitie In addition, an Emergency Management Director's meeting 'was held on September 23,

'1987, in Jefferson City, Missouri with representatives from the State-Emergency Management' Agency (SEMA), the1 State Bureau of Radiation Health, and the four Counties of Callaway, Osage, Montgomery, and ,

Gasconade. This meeting covered a wide range of emergency preparedness topics. Evacuation possibilities was one-topic addressed by the Manager, Nuclear Safety and Emergency Preparedness, including a "lessons learned" approach from a recent evacuation of a small town in Pennsylvani Overall, the licensee's independent audit program has a firm base and is well documented. Followup on items of concern is good. Interactions through meetings and discussions with offsite agencies has demonstrated a good effort which should lead to better understanding and cooperation between all entities in real emergency situations as well as the annual exercise Based on the above findings, this portion of the licensee's program was acceptable, Licensee Action on NRC Information Notice 87-58 - Continuous Communications Following Emergency Notifications In the event of an emergency the licensee has sufficient personnel to adequately provide continuous communications with NRC by on-shift personnel knowledgeable of plant operations. Interviews with two TSC/E0F communicators helped confirm this capability. Present emergency plan implementing procedures provide instructions and guidance specifying that the telephone line with NRC should be continually maintained upon NRC reques . Exit Interview The inspectors met with the licensee representatives denoted in Paragraph 1 on January 29, 1988. The inspectors summarized the scope and results of the inspection and discussed the likely content of the inspection report, including further in-office evaluation of emergency kit inventory discrepancies. The licensee did not indicate that any of the information disclosed during the inspection could be considered proprietary in natur l 8