ULNRC-04848, Reply to Preliminary White Finding Regarding Inspection Report No. 50-483/2003-008

Reply to Preliminary White Finding Regarding Inspection Report No. 50-483/2003-008

ML031681388
Person / Time
Site:	Callaway
Issue date:	06/10/2003
From:	Randolph G AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-03-008, ULNRC-04848
Download: ML031681388 (4)

Text

AmerenUE PO Box 620 Callaway Plant Fulton, MO 65251 573.676.245 Grry L Randolph 573.676.4056 fax Senior Vice President and Chief Nuclear Officer June 10, 2003 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 WAmercn Washington, DC 20555-0001 ULNRC-04848 IIELadies and Gentlemen:

REPLY TO PRELIMINARY WHITE FINDING INSPECTION REPORT NO. 50483/2003-008 CALLAWAY PLANT UNION ELECTRIC CO.

This responds to Mr. Dwight D. Charnberlain's letter dated May 2, 2003, which transmitted a Preliminary White Finding for events discussed in Inspection Report 50-483/2003-008. Our response to the Preliminary White Finding is presented in the attachment. On June 2, 2003, Mr. Ronald A. Kopriva, Senior Project Engineer, Division of Reactor Projects Branch B, authorized a response date of June 10, 2003.

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, please contact Mr. Mark A. Reidmeyer, Regional Regulatory Affairs Supervisor at 573/676-4306.

Very truly yours, G. L. Randolph GLRIMARIslk

Attachment:

1) Reply to Preliminary White Finding

-J,E o a subsidiary of Ameren Coporation

ULNRC-04848 June 10, 2003 Page 2 cc: Mr. Thomas P. Gwynn Acting Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Jerry B. Uhlmann Director Missouri State Emergency Management Agency PO Box 116 Jefferson City, MO 65102 Superintendent, Licensing Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839

Attachment to ULNRC-04848 June 10, 2003 Page 1 AmerenUE takes its obligation to protect the health and safety of the public very seriously and sincerely regrets the fact that it missed sending Tone Alert Radios to some residents who should have received them. AmerenUE does not wish to challenge the finding as preliminarily characterized. However, the Callaway organizational response to this issue merits clarification.

The inspection report notes prior opportunities to identify and correct the weakness in the maintenance of the tone alert radio population in the Callaway Plant Emergency Planning Zone (EPZ). AmerenUE does not disagree that prior corrective actions failed to adequately address the problem, nor did routine monthly monitoring of changes to the Tone Alert Radio database surface the weakness. While the identified weakness is indicative of past performance, AmerenUE believes Callaway's current standards for problem identification and resolutions are substantially different. Specifically:

• The concern was brought to management's attention due to the questioning attitude of the Senior Nuclear Clerk and entered into the corrective action system. Had this not occurred, normal monthly updating of the database and distribution of Tone Alert Radios to affected households would have completed the monthly surveillance. The inaccuracies in the Tone Alert Radio database and the process for detecting errors in the database would have remained unchanged. Moreover, due to the importance associated with the public prompt notification system, the corrective action was assigned the highest significance level, to ensure a formal root cause process was utilized. This significance level assured dedication of resources to resolve the matter in a manner consistent with its significance.

• The concern was evaluated for reportability using the criteria of 10 CFR 50.72(b)(3)(xiii), Loss of Emergency Preparedness Capabilities. This evaluation was completed on November 27, 2002, the day following identification of the concern. The issue was determined not to be reportable, since the missing radios did not constitute a major loss of the public prompt notification system; i.e. the Tone Alert Radios, per the Event Reporting Guidelines of NUREG-1022, Revision

2. However, as a prudence measure, the NRC Chief, Division of Reactor Safety, Plant Support Branch was notified of this concern by telephone on November 27, 2002. During this conversation, the results of the reportability determination were explicitly discussed.

• Tone Alert Radios were sent to all initially identified affected residences on November 27, 2002. As reviews of the Tone Alert radio database were completed, radios were supplied to residences as additional discrepancies were identified. As noted, this comprehensive review did take approximately four months to complete.

Attachment to ULNRC-04848 June 10, 2003 Page 2 While we are not satisfied with the circumstances that permitted this concern to remain undetected, AmerenUE does believe the response to this concern was prompt and comprehensive and is indicative of substantially improved capabilities to resolve problems.

The inspection report also discusses the failure to promptly identify and correct a degraded condition as a direct contributor to the preliminary finding. As we understand the process, cross cutting issues can be identified in the areas of problem identification and resolution, human performance and safety conscious work environment.

Inspection Report Section 40A2, Identification and Resolution of Problems, captures this issue as a cross cutting issue involving problem identification and resolution.

However, the last paragraph of this section states, "The inspectors determined that these programmatic and implementation weaknesses represented a human performance cross cutting issue involving the timely recognition and correction of degraded conditions."

As a result, the characterization of the issue lacks clarity. AmerenUE has resolved this matter based on our understanding of the issue. We believe a clear characterization of the issue's cross cutting aspects is necessary to ensure the potential finding is properly addressed.