ML20211H501
| ML20211H501 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/02/1997 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-97-13, ULNRC-3648, NUDOCS 9710060437 | |
| Download: ML20211H501 (6) | |
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i UNION Eu.cnue octose,2,i997 E
U. S. Nuclear Regulatory Commission Attn: Document Control Desk 1
Mail Stop Ps 137 l
Washington, DC 20555-0001 ULNRC 3648 l
l Gentlemen:
l REPLY TO EXERCISE WEAKNESSES INSPECTION REPORT NO. 50-483/97013 CAILAWAY PLANT This responds to Mr. Ilowell's letter dated September 4,1997, which transmitted two Exercise Weaknesses for events discussed in Inspection Report 50-483/97013. Our response to these weaknesses are presented in the attachment.
None of the materialin 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, V. Laux Manager, Quality Assurance JVUMAR/tmw ll1
Attachment:
- 1) Response to Exercise Weaknesses p0' k
9-e ll!E,E kIflllllll 9710060437 971002 PDR ADOCK 05000483 0
ULNRC-3648
' October 1,1997 Page 2 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 Omce U.S. Nuclear Regulatory Con mission 8201 NRC Road Steedman,MO 65077 Mr. Bariy C. Westreich (2 copies)
Acting Licensing Project Manager, Callaway Plant Omce ofNuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13816 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 N.W.
Washington, DC 20037 Manager, Plant Support Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839
At*Waat to
'ULNRC-3648 October 1,1997 Page1 During an NRC inspection ttnducted on August Il 15,1997, two exercise weaknesses were identified.
A.
Statement of Weakness The inspectors observed several programmatic complications associated with offsite agency notifications following the alert declaration. The combined efect inappropriately and unnecessarily delayed offsite agency notif' cations, inspectors made the following observations:
The alert declaration time was logged when the control room announcement was made (7:43 a.m.) rather than when the shlA supervisor made the decialon to declare the alert (7:41 a.m.). The shiA supervisor was distracted by other activities for 2 minutes.
Pertinent to this observation, Appendix 1 to NUREG-0654/ FEMA REP-1,
" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, states that, "The time (prompt notification) is measured from the time at which operators recognize that events have occurred which make declaration of an emergency class appropriate." Accordingly, the inspectors determined that the alert was declared at 7:41 a.m. when the shiA supervisor recognized that the conditions for an alert were met.
. Control room personnel did not begin offsite notification form preparation until a communicator errived (about 10 minutes aAer the announcement). The licensee stated that the communicator was " pre-positioned" within the training center, near the control room simulator. The communicator's arrival was delayed to account for the noS travel time to the control room from the individual's normal work location.
The communicator was not familiar with the SENTRY soAware (a new electronic system for making _offsite notifications) and did not know where to obtain information needed to complete the form (meteorological conditions and emergency action level text), As a result, several more minutes elapsed before the notifications were transmitted electronically at 7:58 a.m.
The inspectors determined that the above programmatic factors caused a delay in making timely offsite agency notifications (i.e., within the 15 minute regulatory limit), in response, the licensee considered the notification timely based on the alert
l Attachment to
'ULNRC-3648 l
October 1,1997 Page 2 declaration log entry (15 minutes versus 17 minutes). The inspectors concluded that there were programmatic reasons for the delays: (1) a lack of clear underwanding about when the notification period starts, (2) the use of communicators who were not stationed in the control room, and (3) a lsek of familiarity with the new electronic notification system. Due to the progranunatic factors, the inspectors identified the failure to make timely offsite agency notifications as an exercise weakness (50-483/9713 0l).
Reason for the Weakness Union Electric concurs with the reasons for the notification delays as stated in the inspection report.
Corrective Steos Taken and Results Achieved:
A corrective action document was initiated to track comjletion of corrective actions.
Corrective Steos to Avoid Further Weaknesses:
Each reason is listed below followed by the action to be taken to address the concern.
"(1) a lack of clear understanding about when the notification period starts" Training regarding declaration and notification time requirements will be included in Operations requalification cycle 97-5.
"(2) the use of communicators who were not stationed in the control room" Shift Supervisors arepeing trained on use of the Sentry Notification system during the current training cycle. This will allow the Control Room to complete the initial notification, if necessary, prior to personnel designated as Conununicators arriving at the Control Room.
"(3) a lack of familiarity with the new electronic notification s3 stem" An operator aid will be developed for use of the Sentry Notification system to assist Communicators in collecting the necessary information and completing the on-lisw form.
l.
Attachment to
'ULNRC-3648 October 1,1997 Page 3 Date when Full Comallance will be Achieved:
The operator aid will be available for use by Communicators by October 15,1997. Full compliance will be achieved upon completion of training by December 22,1997.-
B.
Statement of Weakness Technical support center access controls were established but were periodically inefr tive in maintaining positive control of those who exited. A security.ofHeer ec was assigned to control center access and ensure that all personnel who entered the center walked through the portal monitor. Personnel who exited the center were logged out by the security officer.
Although the process worked most of the time, when the security officer interfaced with the administrative group or the security coordinator, opportunities occurred for personnel to exit the center without being noticed by the security ofBcer. During the exercise, at least three individuals lea the technical support center without logging -
out with the security officer. As a result, continuous accountability was not maintained.
In addition, there was no process to establish and communicate radiological
- precautions to those who exited the center once the radiological release started -
(except inplant response team members). As a result, the three individuals who lea the center were not informed of areas to avoid, routes to take, or personal protective measures. In a related matter, the inspectors observed limited coordination with security personnel ccnceming radiological precautions; however, the licensee informed the inspect);rs that radiological precautions were taken for security personnel. Due to the impact on personnel safety, the failure to establish effective technical support center access controls was identified as an exercise weakness (50-483/9713-02).
Reason for the Weakness Controls for dispatch and tracking of emergency teams from the Technical Support Center
- are adequate to ensure continuous accountability and proper radiological controls for emergency team members. However, existing programmatic controls are inadequate to ensure others leaving the facility will be adequately briefed and accounted for.
J
a Attachment to
'ULNRC-3648 October 1,1997 Page 4 Corrective Stcos Taken and Results Achieved:
A corrective action document was initiated to address the weakness identified in the l
exercise. Exits from the Technical Support Center have been clearly posted with appropriate signs to remind personnel to establish radiological precautions with IIcalth Physics personnel and maintain accountability with Security prior to departing from the Technical Support Center. Expectations for radiological controls and continuous accountability in the Technical Support Center have been communicated to all emergency response personnel.
1 Corrective Steos to Avoid Further Weaknesses:
Specific progra.nmatic requirements for all personnel leaving the Technical Support Center will be established to strengthen continuous accountability and radiological controls for personnel who are not assigned to emergency teams.
Date when Full Compilance will be Achieved:
Changes to affected emergency response procedures to implement programmatic changes will be completed by November 10,1997.
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