ML20216B579
| ML20216B579 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/06/1998 |
| From: | Randolph G UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20216B584 | List: |
| References | |
| ULNRC-3799, NUDOCS 9805180216 | |
| Download: ML20216B579 (12) | |
Text
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l Union Ehctnc PO Box 620 l
Callaway Plant Fulton, MO 6r>251 573.676.8245 Gerry L Randolph 573676 4056 fat Vice President and r
Chief Nuclear Officer U. S. Nuclear Regulatory Commission Attn: Document Control Desk MailStop PI-137 Washington, DC 20555-0001 ULNRC-3799 Gentlemen:
EMERGENCY PREPAREDNESS RADIOLOGICAL EMERGENCY RESPONSE PLAN, Revision 22 CALLAWAY PLANT, DOCKET NUMBER 50-483 h,,,
UNION ELECTRIC CO.
V pg Ref: NRC Inspection 50-483/98-06 H
ULNRC-3787, dated March 30,1998
{
NRC Inspection 50-483/95003 Enclosed is Revision 22 to Chapter 5 of the Callaway Plant Radiological Emergency Response Plan (RERP). As a result of discussions held with NRR and Region IV staff on April 2,1998, the changes submitted for review are limited to those necessary to address concerns with staff augmentation identified during NRC Inspection 98-06.
Union Electric has evaluated the croposed change and determined certain items may constitute a reduction in effectiveness of the plan. Pursuant to 10 CFR 50.54(q), this part of the revision is hereby submitted for Commission aoproval. identifies the specific changes, based on our evaluation, that require NRC approval prior to implementation. Enclosure 2 provides an evaluation of the proposed changes in accordance with 10 CFR 50.54(q) and a summary of those changes. Enclosure 3 provides the change summary for Revision 22 compared to Revision 20, which is the latest revision reviewed by the Staff. Enclosure 4 provides full text of the proposed revision to RERP Chapter 5," Organizational Control of Emergencies" We believe this proposed resision is necessary to establish achievable response goals for our Emergency Response Organization. Our current refueling shift manning assures that current response goals will be met, but does not obviate the need to establish response goals that reflect the residential demographics of the Callaway Plant staff. This proposed change will also ensure that RERP staff augmentation responsibilities will allow our duty sections to function as teams as they have been trained and drilled, while assuring timely augmentation of response capabilities is maintained as required by 10 CFR 50.47(b)(2). Approval of this proposed change is requested by April 30,1998.
If you have any questions regarding this proposed changed please contact me at 573-676-8245 or Jim Peevy at 573-676-8246.
Sincerely, tt )
Garry. Randolph GLR /glb Enclosures 9805180216 980406
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PDR ADOCK 05000483
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PDR i
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a sukoJtary at Ameren Corporation
ULNRC-3799 Page 2 cc:
Mr. Ellis W Merschoff(2 copies)
Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Mr. Dwight D. Chamberlain Deputy Director Division ofReactor Safety U.S. Nuclear Regulatory Commission y
Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76066-8064 Mr. Edwin F. Fox, Jr.
Senior Emergency Preparedness Specialist U.S. Nuclear Regulatory Commission I
NRR/DRPM/PERB Mail Stop 9H15 Washington, DC 20555 Ms. Gail M. Good Senior Emergency Preparedness Analyst U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76066-8064 Senior Resident Inspector Callaway Resident Office i
U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Barry C. Westreich (2 copies)
Acting Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738 L
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ULNRC-3799 April 6,1998 Page 3 l
STATE OF MISSOURI
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sS COUNTY OF CALLAWAY )
Garry L. Randolph, oflawful age, being first duly swom upon oath says that he is Vice President and Chief Nuclear Officer for Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to d^ so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.
A By
/
Garry C. Randolph Vice President and Chief Nuclear Officer SUBSCRIBED and sworn to before me this b 'Lh day of hV
,1998.
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ADDREY A.TERNES NCNY PUBUC f
3DGE OFM6800RkCAUAWAYCOUNW NO N YSEAL MYCOMM6810N EMMS OC100ER22,2000 NOTE: Per discussion with the NRR Project Manager for Callaway Plant, the original copy of this letter, ULNRC-3799 dated April 6,1998, was not received by the U.S. Nuclear Regulatory Commission Document Control Desk. This best available copy is being provided as a replacement for the original.
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I ULNRC 3799 Page1of1 ENCLOSUREI CHANGES FOR NRC REVIEW Union Electric proposes the following changes to Chapter 5 of the Callaway Plant Radiological Emergency Response Plan for NRC review and approval. The entire chapter has been submitted to facilitate your review.
1)
Section 5.2 Onsite Emergency Response Organization 2)
Section 5.3 EOF Emergency Response Organization 3)
Table 5-2 Emergency Staffing Requirements On-site Emergency Response Organization 4)
Table 5-3 Emergency Staffing Requirements Emergency Operations Facility Organization 1
These proposed changes reflect changes in response goals from 30-45 minutes to 30-60 minutes for designated Emergency Response Duty Personnel and from 60-75 minutes to 60-90 minutes for designated Emergency Response Augmentation Personnel.
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I ULNRC 3799 Page1of3 1
ENCLOSURE 2 EVALUATION OF PROPOSED CHANGES l
The response goals for emergency responders have been extended by 15 minutes. These times have been changed to give personnel responding to an emergency a more realistic I
time to respond after normal working hours.
The Callaway Plant is located approximately ten miles southeast of Fulton, Missouri, in Callaway County, at the junction of County Road Route O and County Road Route CC.
All roads within five miles of the plant site are county roads and have numerous hills and curves. The only major highway running close to the plant is State Highway 94 approximately five miles to the south.
l Residential areas within 50 miles of the plant site are sparse. Fulton, Missouri, population 10,033, is just outside the 10 mile EPZ. Hermann, Missouri, to the southeast of the plant, population 2,754, and Holts Summit to the southwest, population 2,292, are within 20 miles of the plant site. This area is marked as ORANGE on the attached map and would be considered a 30-45 minute response time to the plant site. Approximately 36% of the responders reside in this area.
Montgomery City, Missouri, isjust outside the 20 mile circle and has a population of 2,281. Mexico, Missouri, population 11,290, and Jefferson City, Missouri, population 35,517, are toward the outer part of the 20 mile circle, marked GREEN on the attached map. These areas are considered 50-55 minute response times to the plant.
Approximately 41% of the responders reside in this area.
3 Warrenton, Missouri, population 3,962, and Columbia, Missouri, populaticn 69,133, are just outside the 30 mile perimeter in the YELLOW area. This area is considered to take 60 minutes to respond to the plant. Approximately 21% of the responders reside in this area.
In the upper right hand corner of the attached map is a breakdown, by percent, of the emergency responder's residences. Also attached is an enlarged copy of the road atlas, with these residential areas marked in RED.
Prior to this revision, an automatic dialing system was used to contact all emergency response personnel for staff augmentation. As noted by inspection follow-up item 50/483/95003-03, the effectiveness of this method was not consistently demonstrated during call out drills. The system is capable of making multiple simultaneous calls and is a tremendous improvement over the previous manual call out methods. Still, with longer commute times from some of the surrounding communities, there is little time to establish contact and still meet the response goals. This revision establishes sixty minute response goals for the positions necessary to relieve the on-shift organization of 1i
ULNRC 3799 Page 2 of 3 emergency responsibilities not directly related to plant operation. Duty sections were established for personnel filling these positions and cellular pagers were issued to duty personnel. When designated, duty personnel are required to remain fit for duty and stay within approximately sixty minutes of the plant to ensure they are able to meet the response goal. (Sixty minutes was chosen because this is a reasonable response time for employees living in the Columbia area. Columbia is the most distant community of residence for any significant number of plant employees). Since duty personnel are equipped with pagers, they were removed from the automatic dialing system. With the reduced number of positions, the automatic dialing system can call all remaining members of the organization within approximately fifteen minutes. However, because of busy signals, answering machines and small children answering, it may be necessary for the machine to make several iterations before all positions are filled. Given commute times from Columbia and time necessanf to complete the calling process, ninety minutes was chosen as a reasonable response goal that could be consistently met by the great majority of remaining augmentation personnel.
Changes in the response goals in RERP Revision 21 were noted as a potential reduction in effectiveness by NRC Region IV. Change Notice 98-04 reestablished the previous goals. This revision seeks to extend response goals by fifteen minutes based on the reasoning noted in the previous paragraph. The process and procedures established by this revision for augmenting the emergency organization are clearly more effective than previous methods. Personnel on pagers with duty restrictions are defined as Emergency Response Duty Personnel and response goals are set at 30 to 60 minutes. Those with longer response goals who are contacted by the automatic dialing system are defined as Emergency Response Augmentation Personnel. Explanations have been added to clearly state the objectives for each contingent. The Cellular Paging System and the Emergency Callout System are defined. The Plan now defines the mobilization process and clearly identifies who is contacted by each system.
Except for the changes in response goals, all changes in this revision either maintain or increase the effectiveness of the Radiological Emergency Response Plan. The previous goals are difficult to consistently meet due to the remote location of the plant relative to the surrounding communities in which the plant staff members reside. Even with improved methods of mobilizing staff members (i.e. duty section assignments and cellular pagers), commute times preclude consistently achieving 30-45 minute goals for employees from the Columbia area. Jefferson City residents may also experience difficulty with this goal depending on the specific location of their residences within the city. Our automatic dialing system for calling Emergency Response Augmentation Personnel is programmed to call responders in order according to commute time. This results in preference for filling emergency response positions being given to those living closest to the plant. Emergency Response Duty Personnel are contacted simultaneously using a group page program provided by the cellular paging service. Since these individuals are designated on a duty roster, they are expected to be the earliest responders.
ULNRC 3799 Page 3 of 3 1
l Positions to be filled by the earliest responders are selected on the basis of minimum l
staffing necessary to relieve on-shin personnel of responsibilities not directly related to plant operations. These are the 30-45 minute responder positions from Revision 20 with the exception of the Rad / Chem Technicians. Rad / Chem Technicians are designated as augmentation personnel (30-90 minutes) rather than duty personnel (30-60 minutes) because they are not necessary to meet the objective of relieving members of the on-shin organization. Since dose assessment no longer transfers to the TSC, the Health Physics Coordinator is available to relieve the on-shin HP Operations technician ofin-plant radiological support for emergency repairs.
The positions filled by Emergency Response Duty Personnel are sufficient to provide for at least one to one relief of on-shiR personnel so they can return their focus to operation and, if necessary, safe shutdown of the plant. Emergency Response Augmentation Persennel complete the process of fully staffing the emergency response organizations.
To ensure response time goals are met, we are relying on stafTmg levels in place to support the current refueling outage and certain personnel who reside such that 30-45 minute response goals can be met. However, this is not a viable means for maintaining long term staff augmentation capability due to the residential demographics of the Callaway Plant staff, and the undue burden placed on personnel that reside in closer proximity to the plant. We believe a better alternative is available and are therefore submitting this revision to the RERP.
These changes can be considered a reduction in effectiveness if taken alone. However, when considered with the assignment of duty sections, improved notification capabilities, one step transfer of responsibilities and strengthened plant assessment function established by Revision 21, we believe the overall result is an improvement in response capability. Other changes to improve the augmentation process include early I
mobilization of the EOF organization (at the ALERT rather than Site Emergency).
Additionally, it was our past goal to achieve a 30-45 minute response for a percentage of responders in that response category. With implementation of duty sections, it is our expectation to fP.1 all duty personnel positions within the 30 to 60 minute response goal.
l This change will also ensure that RERP staff augmentation responsibilities will allow our duty sections to function as teams as they have been trained and drilled, while assuring timely augmentation of response capabilities is maintained as required by 10 CFR 50.47(b)(2).
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Attachment:
Map i
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ULNRC 3799 Page 1 of 3 l
Callaway Plant RERP/NuRee 0654 Comparison Table l
Maior Functional Area NuRea 0654 Rev.20 Rev.22 Plant Operations and Shift Supv. (1)
Shift Supv. (1)
Shift Supv. (1) l Assessment of Shift Frmn (1)
Op.Supv. (2)
Op. Supv. (2) l Operational Aspects CR Opr. (2)
Rx Opr. (2)
Rx Opr. (2)
(On Shift)
Aux. Opr. (2)
Equip. Opr (2)
Equip. Opr. (4)
Emergency Direction and STA or SS SS until EDO arrives SS until EDO arrives Control (Emergency l
Coordinator) * *
- *EDO arrives in 30-60 minutes (pager) and becomes Emergency Coordinator.
l Notifications /
Communication (1) On Shift I&C Tech or Equip Opr.
I&C Tech or Equip Opr (1 of 3 Onshift)
(1 of 5 Onshift) l (1) 30 min Commun. Coord. (1)
(ENS) Commun.(1)
(30-45 min)
(30-60 min pager)
(Notif.) Offsite Liaison (1)
(30-60 min pager) l (2) 60 min Communicator (2)
Communicator (1)*
(60-75 min)
(60-90 min)
- Reduced (1) 60-90 minute communicator, due to notification duties being assumed by Offsite Liaison at 30-60 minutes.
EOF Director (1) 60 min Recovery Manager Recovery Manager (60-75 min)
(30-60 min pager)
Offsite Dose (1) 30 min HP Coordinator Dose Assess Coord.
Assessment (30-45 min)
(30 60 min pager)
Radiological Surveys (2) On shift (2) R/C Tech On shift (3) R/C Tech On shift Chemistry / Radio-Chemistry (4)R/C Tech (1) HP Coord.
(1) HP Coord.
(30 min)
(30-45 min)
(30-60 min pager)
(4)R/C Tech (4) R/C Tech (8) R/C Tech (60 min)
(30-45 min)
(30-90 min)
(4) R/C Tech (60-75 min)
(1) R/C Tech (chem)
(1) Chem Coord.
(1) Chem Coord.
(60 min)
(60-75 min)
(30-60 min pager)
(1) R/C Tech (chem)
(1)R/C Tech (chem)
(60-75mia)
(30-90 min)
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I ULNRC 3799 Page 2 of 3 Maior Functional Area NuRee 0654 Rev. 20 Rev.22 Plant Syste i Engineerir.g, Repair And Corrective Actions Technical Support.
Operating Supv.
Onshift lof 2 Onshift lof 2 Onshift Core / Therm Hyd. Eng.
Tech Assess. Coord.
Tech Assess Coord.
(1) 30niin.
(1) 30-45 min (1) 30-60 min pager Electrical Eng.
Eng. Staff Lead Engineeer (1) 60 min.
(.7) 60-75 min (1) 60-90 min Mech. Eng.
Electrical Eng.
(1) 60 min.
(1) 60-90 min Mech. Eng.
(1) 60-90 min Reactor Eng.
(1) 60-90 min I&C Eng.
(1) 60-90 min Eng. Support Staff (3) 60-90 min Repair Support Mechanic Equip. Opr.
Equip. Opr.
(1) Onshift 1 of 2 Onshift 1 of 4 Onshift Electrician I&C Tech or Equip Opr I&C Tech or Equip Opr (1) Onshift 1 of 3 Onshift 1 of 5 Onshift Electrician Electrician Emer Team Coord.(Elec.)
(1) 30 min (1) 30-45 min (1) 30-60 min pager I&C Tech I&C Tech I&C Tech (1) 30 min (1) 30-45 min (1) 30-90 min Electrician I&C Tech Electrician (1) 60 min (1) 60-75 min (2) 60-90 min Mechanic /Radwaste Mechanic Emer Team Coord. (Mech)
(2) 60 min (1) 60-75 min (1) 30-60 min pager Mechanic (2) 60-90 min
ULNRC 3799 Page 3 of 3 Maior Functional Area NuRee 0654 Rev.20 Rev.22 i
Radiation Protection (2*) R/C Tech (2) R/C Tech 2 of 3 R/C Tech Onshift Onshift Onshift
- May be provided by shift personnel assigned other functions.
j (2) R/C Tech (2) R/C Tech (1) Rad Con Coord.
l 30 min 30-45 min 60-90 min l
(2) R/C Tech (2) R/C Tech (2) R/C Tech 60 min 60-75 min 30-90 min Fire Fighting / Rescue /
First Aid are onshift personnel Security by Security Plan TOTAL Responders 37 38 47 To Meet 0654 Requirements l
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ULNRC 3799 Page1of2 ADEQUACY COMPARISON BETWEEN CHAPTER 5 REVISION 22 CALLAWAY PLANT RADIOLOGICAL EMERGENCY RESPONSE PLAN AND
' NUREG 0737 SUPPLEMENT 1, IEQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY-AND NUREG 0696, FUNCTIONAL CRITERIA FOR EMERGENCY RESPONSE FACILITIES The Callaway Plant control room is initially staffed with on shift personnel using NuReg 0654 Table B-1 as a guide. Therefore the operating crew would be able to meet the requirements of plant operation during abnormal conditions as specified in NuReg 0737 and 0696. These responsibilities are as follows:
1 To diagnose the abnorma: conditions.
To perform corrective Ac. ions.
To mitigate the abnormal conditions.
To manage plant operations.
To manage emergency response.
To inform Federal, State and local officials.
To recommend public protective measures to state and local officials.
To restore the plant to a safe condition.
To recover from abnormal conditions.
Some of the above responsibilities will be assumed by the emergency response facilities 1
as they are staffed. This will occur as follows.
Plant Management -will be assumed, in the Technical Support Center, by the Emergency Coordinator, wearing a pager with a 30-60 minute response goal.
Technical Support -will be assumed in the Technical Support Center, by the Technical Assessment Coordinator, wearing a pager with a 30-60 minute response goal.
The Technical Assessment Coordinator will be responsible for accepting the following from the Control Room.
Assisting in diagnosing the conditions.
Assisting in performance of corrective actions.
Assisting in condition mitigation.
A Health Physics Coordinator and two Emergency Team Coordinators (TSC/OSA),
wearing pagers and having 30-60 minute response times will assist in relieving the control room of congestion by dispatching repair teams and operational support functions.
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ULNRC 3799 j
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Page 2 0f 2 The Recovery Manager will wear a pager and have a response goal of 30-60 minutes.
Response will be to the Emergency Operations Facility (EOF). The responsibilities accepted from the control room include, management of overall emergency response, informing Federal, State, and local officials, protective action recommendations, and planning recovery.
Peripheral Duties will be assumed as follows:
- Communications / Notifications
- 1. Emergency Notification System (ENS) communications will be assumed in the Technical Support Center (TSC), by the TSC Communicator (ENS), wearing a pager with a 30-60 minute response goal.
- 2. Offsite Notifications responsibilities will be assumed in the Emergency Operations Facility (EOF), by the Off Site Liaison Coordinator, wearing a pager with a 30-60 minute response goal.
A Dose Assessment Coordinator, in the EOF, wearing a pager with a 30-60 minute response goal will assume dose assessment.
The Protective Measures Coordinator, wearing a pager with a 30-60 minute response goal will assume protective action recommendations, in the EOF.
This comparison indicates the responsibilities and functions identified in these NuRegs will be adequately assumed in a timely manner in Chapter 5 of the Callaway Plant Radiological Emergency Response Plan Revision 22.