ML20247M224
| ML20247M224 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/19/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20247M210 | List: |
| References | |
| 50-483-98-10, NUDOCS 9805260206 | |
| Download: ML20247M224 (7) | |
See also: IR 05000483/1998010
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ENCLOSURE
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U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-483
License No.:
Report No.:
50-483/98-10
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Junction Hwy. CC and Hwy. O
Fulton, Missouri
Dates:
April 28-30,1998
Inspector (s):
Thomas H. Andrews, Emergency Preparedness Analyst
Approved By:
Blaine Murray, Chief, Plant Support Branch
Attachment:
Supplemental Information
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9805260206 990519
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ADOCK 05000483
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EXECUTIVE SUMMARY
Callaway Plant
NRC Inspection Repnrt 50-483/98-10
This was a reactive, announced inspection that reviewed the contingency plan developed in
response to inspection findings in NRC Inspection Report 50-483/98-06 with special emphasis
on the training process used to qualify people added to the emergency response organization.
Plant Suncort
Emergency response organization personnel were trained as described in the
emergency plan and training procedure.
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Reoort Details
IV. Plant Sucoort
P5
Staff (raining and Qualification in Emergency Preparedness
a.
Insoection Scoce (82701-02.04)
The inspector reviewed the licensee's radiological emergency response plan, emergency
plan implementing procedures, training department procedures, and lesson plans to
identify and assess the existing process for training emergency response organization
personnel. The inspector reviewed the process used to qualify the additional personnel
needed to fill rapid response positioes. The inspector reviewed the staffing roster for
each position to determine if the staffing level was appropriate. This inspection focused
upon the process used to qualify these people as emergency response organization
members.
b.
Observations and Findinas
On March 30,1998, the licensee issued Change Notice 98-004 to Revision 21 of the
Callaway Radiological Emergency Response Plan. The change notice restored the
response goals specified in Revision 20, including the operational support area positions.
As part of its contingency plan, the licensee added approximately 145 additional people
to the emergency response organization to fill rapid response positions (30-45 minute
responders).
According to 10 CFR 50.47(b)(15), radiological emergency response training is to be
provided to those who may be called on to assist in an emergency.Section IV.F of
10 CFR Part 50, Appendix E, further states that emergency plans must describe the
program used to train these people. Chapter 8 of the licensee's radiological emergency
response plan briefly described the training process and referred to training procedures
to provide the details for training requirements.
According to the radiological emergency response plan, personnel must meet the
minimum criteria for the required training as specified in the training procedures. The
plan also stated that periodic retraining is conducted to update the knowledge and skills
personnel, typically on an annual basis. Emergeng Plan Implementing Procedure
EIP-ZZ-A0020, " Maintaining Emergency Preparedness," Revision 13, stated that on-site
emergency response training is conducted in accordance with TDP-ZZ-00066.
Training Department Procedure TDP-ZZ-00066, "RERP Training Program," Revision 10,
specified the requirements for initial training, identified the retraining frequency, and
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specified the method to evalutte student performance. The inspector determined that
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these elements of Procedure TDP-ZZ-00066, Revision 10, were consistent with the
licensee's radiological emergency response plan.
Initial training requirements for emergency response personnel were identified in
Attachment 1 of Procedure TDP ZZ-00066. The inspector reviewed selected lesson
plans and determined that they sufficiently covered the topics presented. The licensee
was in the process of revising or developing these lesson plans as needed to incorporate
current information prior to teaching the courses.
The specific requirements for retraining courses were not clearly stated in the training
procedure. While the procedure implied that the retraining would involve an actual
training class, the licensee permitted the use of drill / exercise participation to be
substituted in lieu of actual training. As a result, the computerized course catalog
identified drill / exercise participation as an equivalent course for some of the retraining
courses.
In addition to the actual drill / exercise participants, the licensee also allowed drill / exercise
participation credit for training for the controllers and evaluators. According to the
licensee, these people received training on the areas they were controlling / evaluating to
ensure that the assessment would be valid. While the procedure did not appear to
permit this practice, there was nothing in the procedure that specifically prohibited this
practice.
The inspector reviewed the process of establishing initial training requirements and the
process for determining retraining requirements. For retraining courses, there was no
established criteria or predefined basis for what constituted an acceptable retraining
course. In many cases, the initial training was the same as the requalification training.
However, in other cases, the retraining course was significantly different and more
abbreviated.
The inspector pointed out that initial training required assessment of individual
performance. The process of substituting a drill or exercise for this was not considered
to be equivalent because the drill / exercise evaluation criteria were based upon team
performance. There were no individual performance criteria identified, and they were not
directly linked to the initial training criteria. Therefore, it appeared that the basis for
qualifying personnel based upon drill / exercise performance was less equivalent than that
used to initially qualify personnel.
The inspector discussed concerns associated with the use of drill / exercise participation
as training and the control of course content with the licensee. The licensee stated that
they would revleu their training program and make the necessary enhancements to
properly ensure these concems are properly addressed.
The inspector reviewed documents in the licensee's corrective action program, the
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Suggestion Occurrence Solution System, and identified examples in which problems had
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been identified with training records. Because people may be called upon to evaluate or
control positions other than those they are assigned, the inspector asked if the licensee's
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program ensured that proper credit was being given for personnel assigned as
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evaluators or controllers during an exercise. The inspector expressed concem regarding
the personnel that were to assume emergency response duty if there were potential
questions regarding the accuracy of the training records. The licensee stated that they
would review the qualifications of each duty section (team) prior to the duty section
(team) assuming interim response duties.
During the exit meeting on April 30,1998, Mr. Garry L. Randolph, Vice President and
Chief Nuclear Officer, stated that Callaway would verify that no credit was given for
requalification for personnel evaluating / controlling drills and exercises unless they
performed this function for their assigned emergency response position or a functionally
equivalent position. This will be completed for each duty section (team) prior to the
30-45 minute response personnel assuming interim duty responsibilities. Mr. Randolph
stated that Callaway would incorporate the following enhancements to the training
program:
(1)
The training program will be modified to clearly identify how drills and exercise
are used to meet training requirements. To utilize drills and exercises, the
following requirements will be met:
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Objectives and evaluation methodology must be identified and approved
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by the Emergency Preparedness Department. A lesson plan, instructor
guide, or other appropriate course material must be developed and
reviewed by the Emergency Preparedness Department prior to
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conducting the training session.
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Evaluation objectives must be established for each position or functional
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group.
To receive credit for annual requalification during a drill or exercise, an
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evaluator / controller must be evaluating their position or a closely related
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position (requiring the same or similar training requirements).
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(2)
Radiological Emergency Response Plan training material (initial and
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requalification) must be reviewed by the Emergency Preparedness Department
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prior to conducting the training session.
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(3)
If equivalent courses are developed for exi-ting radiological emergency response
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plan training, they will be reviewed by the Emergency Preparedness Department
prior to conduc'ing the training session. This review will ensure that the training
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activity addresses the requirements of the specific position (s).
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Mr. Randolph stated that these enhancements are expected to be made by May 15,
1998.
The review of the implementation of the enhancements of the training program and the
review of qualifications for duty sections is identified as an inspection followup item (50-
483/98010-01).
c.
Conclusions
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Emergency response organization personnel were trained as described in the licensee
emergency plan and training procedure. The qualifications of each duty section will be
reviewed prior to it assuming interim duty responsibilities. The training program will be
enhanced by clarifying the process for use of drills / exercises for qualification purposes
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and by establishing controls over course content.
V. Management Meetings
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Exit Meeting Summary
The inspector presented the inspection results to members of licensee management at
the conclusion of the inspection on April 30.1998. The licensee acknowledged the facts
presenied. No proprietary information was identified. During the exit meeting,
Garry L. Randolph, Vice President and Chief Nuclear Officer, committed to implement
the program enhancements and the qualification verification discussed in Section P5
above.
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ATTACHMENT
SUPPLEMENTAL INFORMATION
PARTlAL LIST OF PERSONS CONTACTED
LLCCDitt
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S. Crawford, Supervisor Emergency Preparedness
M. Evans, Manager, Health Physics
J. Laux, Manager, Quality Assurance
D. Lewis, Emergency Preparedness
G. Nevels, Radiation / Chemistry Supervisor
J. Peevy, Manager Emergency Preparedness Operations Support
G. Pendergraff, Engineering Evaluator
G. Randolph, Vice President and Chief Nuclear Officer
M. Reidmeyer, Engineer
NRC
F. Brush, Resident inspector
D. Passehl, Senior Resident inspector
INSPECTION PROCEDURES USED
82701 Emergency Preparedness Operational Status
ITEMS OPENED. CLOSED. AND DISCUSSED
Ooened
50-483/98010-01
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Review c, personnel qualifications prior to each duty section
assuming interim duty responsibilities and review of the
implementation of training program enhancements (Section PS).
Documents Reviewed
Callaway Radiological Emergency Response Plan, Revision 2
Training Guide, Systematic Approach to Training, March 4,1998
Procedures:
EIP-ZZ-A0020
Maintaining Emergency Preparedness
Revision 13
TDP-ZZ-00066
RERP Training Program
Revision 10