ML20151X156
| ML20151X156 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/10/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| 50-483-98-14, NUDOCS 9809160293 | |
| Download: ML20151X156 (4) | |
See also: IR 05000483/1998014
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
REGION IV
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611 RYAN PLAZA DRIVE, sulTE 400
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ARUNGTON, TEXAS 76011-8064
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September 10, 1998
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Garry L. Randolph, Vice President and
Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT:
NRC INSPECTION REPORT 50-483/98-14
Dear Mr. Randolph:
Thank you for your letter of August 27,1998, in response to the exercise weakness
identified in NRC Inspection Report 50-483/98-14, dated July 17,1998. We have reviewed
your reply and find it responsive to the concerns raised in our inspection report. We will review
the implementation of your corrective actions during a future inspection.
Sincerely,
Blaine Murray, Chief
Plant Support Branch
Division of Reactor Safety
Docket No.:
50-483
License No.: NPF-30
cc:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855
John O'Neill, Esq.
Shaw, Pittman, Potts & Trowbridge
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2300 N. Street, N.W.
Washington, D.C. 20037
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H. D. Bono, Supervising Engineer
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Quality Assurance Regulatory Support
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Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
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9809160293 980910
ADOCK 05000483
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Union Electric Company
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Manager - Electric Department
Missouri Public Service Commission
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301 W. High
P.O. Box 360
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Jefferson City, Missouri 65102
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Ronald A. Kucera, Deputy Director
Department of Natural Resources
P.O. Box 176
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Jefferson City, Missouri 65102
Otto L. Maynard, President and
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Chief Executive Officer
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Wolf Creek Nuclear Operating Corporation
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P.O. Box 411
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Burlington, Kansas 66839
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Dan 1. Bolef, President
Kay Drey, Representative
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Board of Directors Coalition
for the Environment
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6267 Delmar Boulevard
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University City, Missouri 63130
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Lee Fritz, Presiding Commissioner
Callaway County Court House
10 East Fifth Street
Fulton, Missouri 65151
A'an C. Passwater, Manager
L. censing and Fuels
AmerenUE
One Ameren Plaza
1901 Chouteau Avenue
P.O. Box 66149
St. Louis, Missouri 63166-6149
J. V. Laux, Manager
Quality Assurance
Union Electric Company
P.O. Box 620
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Fulton, Missouri 65251
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Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, Missouri 65101
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Union Electric Company
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DISTRIBUTION w/coov of licensee's letter dated Auaust 27.1998:
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DCD (IE35)
Regional Administrator
Callaway Resident inspector
DRS Director
DRS Deputy Director
DRP Director
DRP Deputy Director
,
DRS PSB
Branch Chief (DRP/B)
Project Engineer (DRP/B)
Branch Chief (DRP/TSS)
MIS System
RIV File
DRS Action item File (98-G-0109)(Goines)
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DOCUMENT NAME: R:\\_CW\\CW814AK.GMG
To receive copy of document, indicate in box: 'C" = Copy without enclosures *E" = Copy with enclosures "N" - No copy
RIV:SEPA\\PSB
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09/8/98
09/f)'98
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OFFICIAL RECORD COPY
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Unixn utetric
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Cd3w3Y Plant
Fulton, MO 65251
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August 27,1998
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U. S. Nuclear Regulatory Commission
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Wggggg Attn: Document Control Desk
Mail Stop PI-137
UE Washington,DC 20555-0001
UWRC-3869
Gentlemen:
REPLY TO PERFORMANCE WEAKNESS
INSPECTION REPORT NO. 50-483/98014
CALLAWAY PLANT
UNION ELECTRIC CO.
This responds to Mr. Blaine Murray's letter dated July 17, 1998, which transmitted a
Performance Weakness for concerns discussed in Inspection Report 50-483/98014. A
response due date of August 31,1998 was authorized by Mr. William D. Johnson on
August 11, 1998.
Our response to the performance weakness is presented in the
attachment.
None of the material in the response is considered proprietary by Union Electric.
If you have any questions regarding this response, or if additional information is required,
please let me know.
Very truly yours,
k* U 'f
J. V. Laux
Manager, Quality Assurar.ce
JVL/ MAR /tr. w
Attachment: 1) Response to Performance Weakness
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ULNRC-3869
August 27,1998
Page 2
cc: Mr. Ellis W. Merschoff
Regional Administrator
U.S. Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011-80.64
Senior Resident Inspector
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Callaway Resident Office
U.S. Nuclear Regulatory Commission
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8201 NRC Road
Steedman,MO 65077
Ms. Kristine M. Thomas (2 copies)
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Licensing Project Manager, Callaway Plant
Office of Nuclear Reactor Regulation
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U. S. Nuclear Regulatory' Commission
Mail Stop 13E16
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Washington, DC 20555-2738
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Manager, Electric Department
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. Missouri Public Service Commission
PO Box 360
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Jefferson City, MO 65102
- Mr. Thomas A. Baxter
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Shaw, Pittman, Potts, & Trowbridge
2300 N. Street N.W.
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Washington,DC 20037
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Mr. Jerry B. Uhlmann
Director
Missouri State Emergency Management Agency
PO Box 116
Jefferson City, MO 65102
Manager, Plant Support
Wolf Creek Nuclear Operating Corporation
PO Box 411
Burlington, KS 66839
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Attachment to
ULNRC-3869
August 27,1998
Page1
Statement of Performance Weakness
Crew performance during the walkthroughs was generally good. The first crew promptly
recognized and classified all emergency events. The failure of the primary notification
system and the transition to the backup system caused some minor delays in offsite agency
notifications during the first walkthrough. The second crew did not classify one of three
events in a timely manner because an emergency operating procedure conflicted with an
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emergency implementing procedure. The procedure for emergency operating procedure
usage stated that emergency action level determination commences after exiting the
reactor trip procedure. The classification procedure required classification when abnormal
readings indicate an emergency situation has occurred. The first crew did not have the
same problem because it entered the reactor trip procedure later in the scenario. The
delayed classification was identified as a performance weakness. Both crews effectively
performed communications, protective action recommendations, and dose assessments
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(Section P4).
Reason for the Performance Weakness
Procedure ODP-ZZ-00025, Rev.1, " Emergency Operating Procedure Usage",
Section 4.10 " Emergency . Action Level Implementation", Step 4.10.1.2 states:
"For events requiring entry into the EOP' network, determination
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of EAL applicability per EIP-ZZ-00101 is commenced when either
of the following has occurred:
E-0' has been exited
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or
ECA-0.0* step 4 has been completed."
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This procedural philosophy was developed to ensure that the Control Room staff was
properly focused on the critical initial stages of the plant casualty, and not encumbered by
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distractions. Industry events in recent history have reinforced the need for the Shift
' EOP - Emergency Operating Procedures
2 Emergency Plan Implementing Procedure EIP-ZZ-00101 - Classification of Emergencies
' Emergency Operating Procedure E-0 - Reactor Trip or Safety Injection
- Emergency Operating Procedure ECA-0.0 - Loss of All AC Power
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Salem, Unit 1, April 7,1994 - Transient resulting in reactor trip and multiple safety injection system
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actuations.
- Calvert Cliffs, Unit 2, January 15,1995 -Infrequent evolution resulting in reactor trip.
- Wolf Creek, September 17,1994 - Reactor Coolant System draindown event.
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Attachment to
ULNRC-3869
August 27,1998
Page 2
Supervisor to maintain command and control during a plant event to ensure that
appropriate focus is maintained by the Control Room staff. Without this focus, industry
data has demonstrated that relatively minor events can deteriorate significantly.
Generally, this approach has worked well since procedure EIP-ZZ-00101, " Classification
of Emergencies" relies on procedure E-0 for the necessary diagnosis of the casualty
required to complete the emergency classification. For more severe casualties, the
diagnostic logic of procedure E-0 results in prompt exit from the procedure and
subsequent commencement of EAL applicability determination per EIP-ZZ-00101.
The Callaway Plant Radiological Emergency Response Plan (RERP), Chapter 4,
Emergency Conditions, states in part,
"The initial assessment of plant conditions and classification of an
emergency using the guidance of the Emergency Implementing
Procedures is performed by operating shift personnel under the
direction of the Shift Supervisor. This assessment i: performed as
quickly as possible. The goal is to have the emerge y classified,
and initial notifications complete, within 15 minute
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recognition of the initiating condition. On-shift pe.
.nel then
activate the emergency response organizations ensu..ng additional
manpower as the emergency progresses."
However, for casualties that progress more slowly, procedure E-0 may not be exited in
sufficient time to achieve the above goal.
While the approach specified by ODP-ZZ-00025 did ensure proper focus by the Control
Room staff on the casualty, it did not ensure the RERP goal for prompt classification and
notification would be met for all scenarios.
Corrective Ste,ns Taken to Avoid Further Performance Weaknesses:
The Callaway Plant staff recognizes the need to ensure that implementation of the
emergency operating procedures is appropriately balanced with implementation of the
emergency implementing procedures. Early declaration of emergencies is important to
ensure the successful execution of the Callaway Plant RERP.
Therefore, procedural controls will be enhanced to ensure that determination of EAL
applicability is commenced promptly in order to achieve the RERP goals for emergency
classification and notification, while maintaining the appropriate focus on emergency
operating procedures.
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Attachment to
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ULNRC-3869
August 27,1998
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Page 3
Specifically, ODP-ZZ-00025, will be revised to commence determination of EAL
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applicability per EIP-ZZ-00101 as follows:
Reactor Trip - When E-0 has been exited.
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Safety Injection - When E-0 step 4 has been completed the SS should ensure that
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EAL's are being monitored.
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Loss of All AC Power - ECA-0.0 step 4 has been completed.
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In addition, guidance will be included to complete declaration of an emergency within
15 minutes of recognition of exceeding an EAL indication.
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Date when Full Compliance will be Achieved:
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The revision to procedure ODP-ZZ-00025 will be completed and issued by September 4,
1998. Associated training will be completed during the next operator qualification cycle
scheduled to be completed by October 30,1998.
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Union Electric Company
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DISTRIBUTION w/ copy of licensee's letter dated Auaust 27.1998:
DCD (IE35)
Regional Administrator
Callaway Resident inspector
' DRS Director
DRS Deputy Director
DRP Director
DRP Deputy Director
DRS-PSB
Branch Chief (DRP/B)
Project Engineer (DRP/B)
,
Branch Chief (DRP/TSS)
MIS System
'
RIV File
DRS Action item File (98-G-0109)(Goines)
)
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DOCUMENT NAME: R:\\_CW\\CW814AK.GMG
l
To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
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RIV:SEPA\\PSB
E
C:DRS\\PSh
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GMGood:nh
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09/S/98
09/b'98
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OFFICIAL RECORD COPY
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