ML20247R004
| ML20247R004 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/22/1998 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-98-06, 50-483-98-6, ULNRC-3815, NUDOCS 9805290054 | |
| Download: ML20247R004 (8) | |
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Union Electric Vo Box G20 CallawayMant Fulton, M0 65251 May 22,1998 U. S. Nuclear Regulatory Ccmmission Attn: Document Control Desk Mail Stop Pl-137 Washington, DC 20555-0001 ULNRC-3815 gI/,
Gentlemen:
REPLY TO NOT1CE OF VIOLATION
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UE iNSeECT10N acPORT NO so-483/98oo6 CALLAWAY PLANT UNION ELECTRIC CO.
This responds to Mr. Arthur Howell's letter dated April 22,1998, which transmitted two l
Notices of Violation for events discussed in inspection Report 50-483/98006. Our response to these violations is presented in the attachment.
Nane of the material in the response is considered proprietary by Union Electric.
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If you have any questions regarding this response, or if additional information is required, please let me know.
Very truly yours, 7'
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J. V. Laux JA)
Manager, Quality Assurance JVL/tmw
Attachment:
- 1) Response to Violations l
l 9905290054 980522 PDR ALOCK 05000483 O
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l ULNRC-3815 May 22,1998 j
Page 2 l
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i cc: Mr. Ellis W. Merschoff i
Regional Administrator
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U.S. Nuclear Regulatory Commission j
I Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064
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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 j
OfEce of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 l
Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 i
JefTerson City, MO 65102 l
l Mr. Thomas A. Baxter l
Shaw, Pittman, Potts, & Trowbridge l
2300 N. Street N.W.
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Washington, DC 20037
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l Manager, Plant Suppoit 1
Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839 4
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Attachment to ULNRC-1815
. May 22,1998 Pagei Satement of Violation During an NRC inspection conducted on March 24-26,1998, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet 50.47(b) planning standards and Appendix E requirements.
10 CFR 50.47(b)(2) requires, in part, that the onsite emergency response plan must meet the standard of providing that adequate stafling for initial facility accident response in key functional areas be maintained at all times, and timely augmentation of response capabilities is available.
Contrary to these requirements. on May 29,1997, the licensre made changes to its emergency plan, without Commission approval, that decreased the effectiveness of the plan and did not continue to meet Planning Standard 50.47(b)(2). Specifically, augmentation capabilities were reduced as follows:
(1)
The response goal for a dedicated commimicator position was changed from 30-45 minutes to 60 minutes.
(2)
The response goal for the position that performs core thermal hydraulics assessment (technical assessment coordinator) was changed from 30-45 minutes to 60 minutes.
(3)
The response goal for the health physics coordinator, who directs assessment of onsite radiological conditions and support activities, including protective measures, was changed from 30-45 minutes to 90 minutes.
(4)
Th response goal for the operations support coordinator, who forms, directs, coordinates, and briefs inplant teams, was changed from 450-75 minutes to 90 minutes.
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Attachment to I
ULNRC-3815
. May 22,1998 Page 2 I
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The response goal for the emergency team coordinator, who directs inplant l
team formation and performs tearn briefings, dispatch, and trackmg. was changed from 60-75 minutes to 90 minutes.
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The response goal for six radiatien/ chemistry technicians was changed from I
30-45 minutes to 90 minutes. The response goal for six other radhtion/ chemistry technicians was changed from 60-75 minutes to 90 minutes.
l (7)
The response goals for the chemistry coordinator, who directs primary and J
secondary chemistry activities and evaluates chemical conditions, was changed from 60-75 minutes to 90 minutes.
1 (8)
The response goal for one mechanic was changed from 60-75 minutes to l
90 nnnutes.
1 (9)
The resonse' goal for the electrician was changed from 30-45 minutes to j
90 minutes.
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l (10)
The response goa; for one instrumer,tation and control technician was I
changed from 60-75 minutes to 90 minu;es.
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(11)
The response goal for the emergency operations facility communicators 1
was changed from 60-75 minutes to 90 minutes.
(12)
The response goal for the technical support center engineering staff was changed from 60-75 minutes to 90 minutes.
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(13)
The response goal for the security coordinator was changed from 60-75
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minutes to 90 minutes.
(14)
The response goals for thejoint public information center coordinator, admininrator, editor, and media host were changed from 2 to 3 hcurs.
This is a Severity Level IV violation (Supplement Vill)($0-483/98006-01).
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' Attachment to j
ULNRC-3815
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. May,22,1998 Page 3 Rason for the Violation -
in May of 1997, Union Electric personnel made substantial changes to the emergency response plan. In reviewing the plan changes under the 10 CFR 50.54(q) process, it was determined that the aggregate of the plan changes did not decrease the effectiveness of the l
plan. The.10 CFR 50.54(q) analysis for the RERP, Revision 21, was flawed in that the 1
personnel involved with the analysis only considered overall RERP effectiveness and did ~
not consider each individual part of the change as a change potentially requiring prior l
NRC approval. Procedures governing the evaluation process did not provide adequate l
guidance to insure that plan changes requiring prior NRC approval were identified.
1 Cprrective Steps Taken and Results Achieved:
13ased upon the resuhs of the NRC reactive inspection conducted March 24-26,1998, a j
change notice to the radiological emergency response plan was issued that revised the response goals back to the previously approved radiological emergency response plan.
This was implemented on March 30,1998.
Revision 22 to the radiological emergency response plan was generated for NRC review and approval, and a meeting was held at NRR to discuss the plan changes on l
April 2,1998. Since Revision 22 is considered a potential decrease in effectiveness, l
Chapter 5 has been submitted for Commission review.
l An interim response organization was established and trained to ensure the previously l
approved response goals for augmentation would be met.
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l Corrective Steps to Avoid Further Violations:
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An outside consultant has conducted an independent review of our administrative procedures for radiological emergency response plan changes. This review found that existing procedures address the methodology for making changes to the emergency l
re>ponse plan but those procedures should be enhanced to improve the evaluation process.
Procedures governing RERP changes will be revised to provide additional guidance to l
identify changes requiring prior NRC approval.
' Emergency Preparedness statTand related plant management responsible fbr making changes to the radiological emergency response plan will be provided training on application of the 10 CFR 50.54(q) regulations in the plan review / revision process.
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Attachment to l
ULNRC-3815 May 22,1998 Page 4 Date when Full Compliance was Achieved:
Full compliance of the Callaway RERP with 10 CFR 50.54(q),10 CFR 50.47(b)(2), and 10 CFR 50, Appendix E was achieved on March 30,1998. All remaining actions listed i
above will be completed by June 26,1998.
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Attachment to l
ULNRC-3815
. May 22,1998 Page 5 Statement of Violation During an NRC inspection conducted on March 24-26,1998, two violations of NRC requirements were ider,tified. In accordance with the " General Statement of Policy and Procedure for NiiC Enforcement Actions," NUREG-1600, the violations are listed below:
B.
10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet 50.47(b) planning standards and Appendix E requirements.
Contrary to the above, on May 29,1997, the licensee made changes to its emergency plan, without Commission approval, that decreased the effectiveness of the plan. Specifically, the requirement to collect and analyze offsite sample media (solid, liquid, gas) was deleted from the description of the radiological monitoring drill. This resulted in a reduction in field monitoring team training requirements.
This is a Severity Level IV violation (Supplement VIII)(50-483/98006-02).
Reason for the Violation Union Electric Emergency Preparedness staff met with the Missouri State Emergency Management Agency (SEMA) and Department of Health, to discuss the responsibilities for ewironmental sampling. In the State of Missouri Radiological Emergency Response Plan, environmental sampling is the responsibility of the Department of Health. Based I
upon the State performing environmental sampling, Union Electric personnel determined tat there was no reduction in effectiveness of the emergency plan for this item. The 10 CFR 50.54(q) analysis for this RERP revision was flawed in that this was a reduction in effectiveness of Union Electric's capability.
Corrective Steps Taken and Results Achieved:
Based upon the results of the NRC reactive inspection conducted March 24-26,1998, a change notice to the radiological emergency response plan was issued that revised the environmental sampling requirement back to the previously approved radiological emergency response plan. Procedures were revised and training was verified current for field monitoring teams. This wasimplemented on. March 30,1998.
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Attachment to ULNRC-3815
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. May 22,1998 Page 6 Corrective Steps to Avoid Further Violations:
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.An outside consultant has conducted an independent review of our administrative I
procedures for radiological emergency response plan changes. This review tsund that f
I existing procedures address the methodology for making changes to the emergency response plan but those procedures should be enhanced to improve the evaluation process.
j Procedures governing RERP changes will be revised to provide additional guidance to
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identify changes requiring prior NRC approval.
Emergency Preparedness staff and related plant management responsible for making changes to the radiological emergency response plan will be provided training on application of the 10 CFR 50.54(q) regulations in the plan review / revision process.
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Date when Full Congliance was Achieved; Full compliance of the Callaway RERP with 10 CFR 50.54(q),10 CFR 50.47t,b,(2), and 10 CFR 50, Appendix E was achieved on March 30,1998. All remaining actions listed above will be completed by June 26,1998.
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