ML20237E931
| ML20237E931 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/27/1998 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-98-14, ULNRC-3869, NUDOCS 9809010297 | |
| Download: ML20237E931 (5) | |
Text
,
Uni.m Electric PO BoxG20 Callaway Plant Fulton, MO 61251 August 27,1998 MI, U. S. Nuclear Regulatory Commission 4
Wggg Attn: Document Control Desk fg Mail Stop Pl-137 UC Washington, DC 20555-0001 ULNRC-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, j
please let me know.
Very truly yours, A
'n J. V. Laux
, c.i -
Manager, Quality Assurance JVL/ MAR /tmw
Attachment:
- 1) Response to Performance Weakness 9809010297 980827 PDR ADOCK 05000483 G
PDR n subsidiary of Amoren Comoration
ULNRC-3869 August 27,1998 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 Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Ms. Kristine M. Thomas (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 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 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
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 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 l
delayed classification was identified as a performance weakness. Both crews effectively performed communications, protective action recommendations, and dose assessments (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:
i "For events requiring entry into the EOP' network, determination ji of EAL applicability per EIP-ZZ-00101 is commenced when either 2
f of the following has occurred:
3 E-0 has been exited p
or ECA-0.0' step 4 has been completed."
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 5
distractions. Industry events in recent history have reinforced the need for the Shift i EOP Emergency Operating Procedures 2 Emergency Plan Implementing Procedure EIP-ZZ-00101 - Classification of Emergencies 8 Emergency Operating Procedure E Reactor Trip or Safety Injection j
d Emergency Operating Procedure ECA-0.0 - Loss of All AC Power 5-Salem, Unit 1 April 7,1994 - Transient resulting in reactor trip and multiple safety injection system actuations.
- Calvert Cli1Ts, Unit 2,.fanuaryl5,1995 -Infrequent evolution resulting in reactor trip.
- Wolf Creek, September 17.1994 - Reactor Coolant System draindown event.
L____-_________-___-____________-_-_-_---_-__-_
Attachment to ULNRC-3869 j
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.
j 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 Cooditions, 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 is performed as quickly as possible. The goal is to have the emergency classified, and initial notifications complete, within 15 minutes after i
recognition of the initiating condition. On-shift personnel then j
activate the emergency response organizations ensuring additional manpower as the emergency progresses."
i i
However, for casualties that progress more slowly, procedure E-0 may not be exited in -
o sufficient time to achieve the above goal.
While the approach specified by ODP-ZZ-00025 did ensure proper focus by the Control i
Room staff on the casualty, it did not ensure the RERP goal for prompt classification and notification would be met for all scenarios.
L Corrective Steos 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 I
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.
l w____-__-_-_--
Attachment to GLNRC-3869 August 27,1998 Page 3 Specifically, ODP-ZZ-00025, will be revised to commence determination of EAL applicability per EIP-ZZ-00101 as follows:
Reactor Trip - When E-0 has been exited.
Safety Injection - When E-0 step 4 has been completed the SS should ensure that EAL's are being monitored.
Loss of All AC Power - ECA-0.0 step 4 has been completed.
In addition, guidance will be included to complete declaration of an emergency within 15 minutes of recognition of exceeding an EAL indication.
Date when Full ComDliance will be Achieved:
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.
i
-