ML20217F488

Insp Rept 50-483/98-06 on 980324-26.Violations Noted.Major Areas Inspected:Plant Support

ML20217F488
Person / Time
Site:	Callaway
Issue date:	04/22/1998
From:	Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217F440	List: ML20217F436 ML20217F449 ML20217F488
References
50-483-98-06, 50-483-98-6, NUDOCS 9804280173
Download: ML20217F488 (10)

See also: IR 05000483/1998006

Text

w

s.

ENCLOSURE 2

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l Docket No.: 50-483

l

i License No.: NPF-30

Repet No.: 50-483/98-06

l Licensee: Union Electric Company

Facility: Caliaway Plant

Location: Junction Hwy. CC and Hwy. O

Fulton, Missouri

Dates: March 24-26,1998

Inspector (s): Gail M. Good, Senior Emergency Preparedness Analyst

Approved By: Blaine Murray, Chief, Plant Support Branch

l Division of Reactor Safety

Attachment: Supplemental Information

l

!

!

.

l

1

'~

9804280173 980422

PDR ADOCK 05000483

G pm

s

lr q

-2-

EXECUTIVE SUMMARY

Callaway Plant

NRC Inspection Report 50-483/98-06

A reactive, announced inspection involving changes to the Callaway Plant Radiological

Emergency Response Plan and implementing procedures was conducted.

Plant Support

Two violations of 10 CFR 50.54(q) requirements were identified involving changes that

_

were made to the emergency plan, without prior NRC approval, that: (1) reduced

augmentation capabilities by extending response goals for nearly all emergency

organization personnel, and (2) reduced training commitments for field monitoring team -

personnel. The response goal changes had the most significant effect on the areas of

. operations support and health physics. There was a lack of attention to detail during the

j emergency plan review and revision process (Section P3).

1

,

i

l

l

l

\

l

H

l

4

L

." ,

-

L'

, ,

\l-'

,

L

!@-

L

y,

-3-

L iP3 Emergency preparedness Procedures' and Documentation '

I a. Insoection' Scone (82701-02.01)

!

L L An in-office review of Revision 21 to the Callaway Radiological Emergency' Response :

p Plan, dated May 29,1997, was initiated on March 12,1998. The licensee did not ,

K request prior approval because it determined that the changes did not decrease the

L , - effectiveness of the emergency plan and continued to meet '10 CFR 50.47(b) planning

standards and 10 CFR Part 50, Appendix E, requirements.i The preliminary results

<

indicated that some of the changes potentially decreased the effectiveness of the

L emergency plan. This reactive inspection was conducted to further review the

.

l  : emergency plan changes. In addition to Revision 21, the following Radiological

L  : Emergency Response Plan and procedure changes were reviewed'during the :

i: ,

' inspection:

.

Radiological Emergency Response Plan, Revision 21, Change Notice 97-01, ,

l; dated August 5,1997. The licensee did not request prior approval because it j

L determined that the changes did not decrease the effectiveness of the

K

" emergency plan and continued to meet 10 CFR 50.47(b) planning standards and

' 10 CFR Part 50, Appendix E, requirements.

l

.

Radiological Emergency Response Plan, Revision 21, Change Notice 97-02,

dated February 25,1998.- The licensee did not request prior approval because it -

'

determined that the changes did not decrease the effectiveness of the

emergency plan and continued to meet 10 CFR 50.47(b) planning standards and

10 CFR Part 50, Appendix E, requirements.

. Emergency implementing Procedure, EIP-ZZ-00101, " Classification of

Emergencies," Revision 20. . The licensee did not request prior approval because

it determined that the changes did not decrease the effectiveness of the

emergency plan and continued to meet 10 CFR 50.47(b) planning standards and

.

- 10 CFR Part 50, Appendix E, requirements.

b. Observations and Findinas

Radioloaical Emeroency Resoonse Plan. Revision 21

{

The inspector identified isse es in two categories: those that appeared inconsistent with

'10 CFR 50.54(q) requirements, and those that needed additional clarification, detail, or

correction. The two categories and corresponding issues are discussed below:

.

Cateaorv 1

'The first category consisted of changes in two are'as (staff augmentation and

training) that were inconsistent with 10 CFR 50.54(q) requirements.10 CFR

50.54(q) requires licensees to follow and maintain in effect an emergency plan,

,

.

-4-

which meets the standards in 10 CFR 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 the 50.47(b) planning

standards and the Appendix E requirements. As previously mentioned, the -

licensee did not request prior approval because it determined that the changes l

did not decrease the effectiveness of the emergency plan and continued to meet '

10 CFR 50.47(b) planning standards and 10 CFR Part 50, Appendix E,

requirements.

A. The following changes to staff augmentation times were made:

(1) The response goal for a dedicated communicator position was

changed from 30-45 minutes to 60 minutes. This change.

increased the burden on the shift communicator to perform offsite

agency and NRC notifications.

(2) The response goal for the position that performs r ore thermal

hydraulics assessment (technical assessment coordinator) was

changed from 30-45 minutes to 60 minutes. ' This change affected -

operations / technical support and increased the burden on

available shift personnel.'

(3) The response goal for the health physics coordinator, who directs

l

assessment of onsite radiological conditions and support activities,

!.

including protective measures, was changed from 30-45 minutes

to 90 minutes. This change affected operations support

capabilities.

(4) The response goal for the operations support coordinator, who

forms, directs, coordinates, and briefs inplant teams, was changed

from 60-75 minutes to 90 minutes. This change affected

operations support capabilities.

(5) The response goal for the emergency team coordinator, who

directs inplant team formation and performs team briefings,

dispatch, and tracking, was changed from 60-75 minutes to 90

'

minutes. This change affected operations support capabilities.

(6) The response goal for six radiation / chemistry technicians was

changed from 30-45 minutes to 90 minutes. The response goal for

six other radiation / chemistry technicians was changed from 60-75

minutes to 90 minutes. This change affected operations support

and offsite monitoring caprSlities. ,

!

1

l

l

h

%

l -5-

(7) The response goals for the chemistry coordinator, who directs

j primary and secondary chemistry activities and evaluates

!- chemical conditions, was changed from 60-75 minutes to 90

!. ' minutes. This change affected operations support capabilities.

l -(8) The response goal for one mechanic was changed from 60-75

minutes to 90 minutes. This change affected operations support

L capabilities.

(9) The response goal for the electrician was changed from 3045

l minutes to 90 minutes. This change affected operations support

capabilities.

l- (10) The response goal for one instrumentation and control technician

was changed from 60-75 minutes to 90 minutes. This change

i affected operations support capabilities.

l

l (11) The response goal for the emergency operations facility

l communicators was changed from 60-75 minutes to 90 minutes.

l This change placed a greater burden on the 60-minute responders

l who perform offsite agency notifications.

!

l (12) The response goal for the technical support center engineering

!-

staff was changed from 60-75 minutes to 90 minutes. This change

affected technical support capabilities.

(13) The response goal for the security coordinator was changed from ,

g 60-75 minutes to 90 minutes. This change placed a greater l

! burden on available security personnel. .I

L

(14) The response goals for the joint public information center 1

coordinator, administrator, editor, and media host were changed i

from 2 to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. This change affected the availability of I

personnel to interact with the media,

in making the above changes, the licensee attempted to establish a

L minimum staffing level for emergency response facilities (to perform basic

l functional capabilities). Facility minimum staffing positions were given 60-

l. minute response goals, placed on pagers, instructed to remain within 60-

minutes of the site, and were expected to remain fit-for-duty. No changes

to the call-out system were initiated that would add to existing response

times (based on residential demographics of the plant staff). However, by

making the above changes, the licensee: (1) overlooked the functions of

the operations suppo;t area (operations support centers at other sites)

which is collocated with its technical support center; (2) failed to recognize

that it dropped below NUREG-0654, Table B-1, minimum staffing levels  ;

I

.

g .

-6-

i

that were met in the previously approved emergency plan (Revision 20);

(3) extended response goals beyond those specified in NUREG-0654,

Table B-1, that were met in the previously approved emergency plan ]

(Revision 20); and (4) failed to request approval prior to implementation.

As a result, the inspector determined that the above response goal

changes constituted a violation of 10 CFR 50.54(q) because they

decreased the effectiveness of the emergency plan and did not continue

to meet Planning Standard 50.47(b)(2) which requires that udequate

staffing for initial response and timely augmentation of response l

capabilities are maintained (50-483/98006-01). l

!

B. The requirement to collect and analyze offsite sample media (solid, liquid,

gas) was deleted from the description of the radiological monitoring drill.

The inspector determined that the reduction in field monitoring team

training requirements constituted a violation of 10 CFR 50.54(q)

requirements because it reduced the effectiveness of the emergency plan 3

(50-483/98006-02).

Cateoorv 2

The second category consisted of the following issues that needed additional

clarification, detail, or correction:

r

!

(1) Facility minimum staffing (60-minute responders) was not clearly

described.

(2) Terms used to describe facility activation, staffing, and manning were not

used consistently. Changes to Section 4.1 did not fully implement the

change to activate the emergency operations facility at the alert

emergency classification level.

(3) Based on discussions with the licensee, the referenco to the corporate

organization was incorrectly deleted from Section 3.1.1.5 of the

emergency plan. There was still some support provided by the corporate

office. .

(4) Table 6-1 did not accurately describe environmental monitoring

capabilities.

(5) Offsite sampling point maps were incorrectly deleted.

(6) There were numerous editorial errors (e.g., biannualinstead of biennial).

(7) The change summary was incomplete (some changes were not

mentioned). ,

l

!

.

,

s

6

l

7

(8) There were numerous errors involving revision bars (e.g., changes without

revision bars and revision bars without changes).

Based on the number and types of issues listed in Category 2 above, the

inspector concluded that there was an apparent lack of attention to detail during

the emergency plan review and revision process. The licensee agreed to correct

the changes in the next change notice / revision. This response was acceptable.

Radioloaical Emeraency Resoonse Plan. Revision 21. Chanae Notice 97-0j

No issues were identified. The changes did not appear to decrease the effectiveness of

the emergency plan.

Radiofoaical Emeroency resoonse Plan Revision 21. Chance Notice 97-02

i

The changes included a new reference to the severe accident management guides. The

licensee had identified that the emergency plan change was issued before the guides

were placed in the control room and technical support center. This inconsistency existed

until March 25,1998 (about one month), when the guides were placed in the two

locations. The changes did not appear to decrease the effectiveness of the emergency

plan; however, implementation was improperly coordinated.

Emeraency lmolementina Procedure. EIP-ZZ-00101. " Classification of Emeraencies."

!

Bayision 20

No issues were identified. The changes did not appear to decrease the effectiveness of

the emergency plan.

c. Conclusions

Two violations of 10 CFR 50.54(q) requirements were identified involving changes that

l

were made to the emergency plan, without prior NRC approval, that: (1) reduced

l augmentation capabilities by extending response goals for nearly all emergency

organization personnel, and (2) reduced training commitments for field monitoring team J

l

personnel. The response goal changes had the most significant effect on the areas of

operations support and health physics. There was a lack of attention to detail during the

emergency plan review and revision process.

V. Manaaement Meetings

X1 Exit Meeting Summary i

The inspector presented the inspection results to members of licensee management at

the conclusion of the inspection on March 26,1998. The licensee acknowledged the

facts presented. No proprietary information was identified.

r

t J

. . .. . . . ,

s

4

%

-8-

Regional management, who participated in the above exit meeting by telephone,

requested the licensee to promptly arrange a meeting to discuss actions planned to

address the concerns identified in the inspection. 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, and reinstated the requirement to

collect and analyze specific environmental samples.

The licensee met with members of the Office of Nuclear Reactor Regulation and Region

IV on April 2,1998, to discuss the emergency plan. A meeting summary will be issued

by the Office of Nuclear Reactor Regulation.

l

. ...

.. .

.

. _ .

b

'

b I

ATTACHMENT

l

l

'

SUPPLEMENTAL INFORMATION

PARTIAL LIST OF PERSONS CONTACTED

Licensee

R. Affolter, Plant Manager

J. Blosser, Manager, Operations Support

S. Crawford, Acting Supervisor, Emergency Preparedness

J. Laux, Manager, Quality Assurance

J. Neudecker, Superintendent, Personnel

J. Peevy, Manager, Emergency Preparedness and Organizational Support

M. Reidmeyer, Engineer

NBG

D. Chamberlain, Deputy Director, Division of Reactor Safety (by telephone)

B. Murray, Chief, Plant Support Branch (by telephone)

D. Passehl, Senior Resident inspector

l

LIST OF INSPECTION PROCEDURES USED

IP 82701 Operational Status of the Emergency Preparedness Program

LIST OF ITEMS OPENED

Ooened

50-483/98006-01 VIO Failure to meet 10 CFR 50.54(q) requirements when personnel

response goals were extended in the emergency plan (Section P3)

50-483/98006-02 VIO Failure to meet 10 CFR 50.54(q) requirements when field

monitoring team training requirements were deleted from the

emergency plan (Section P3)

i

LIST OF DOCUMENTS REVIEWED

Radiological Emergency Response Plan, Revision 21, dated May 29,1997

Radiological Emergency Response Plan, Revision 21, Change Notice 97-01,

dated August 5,1997

b

3'

,%

-2-

Radiological Emergency Response Plan, Revision 21, Change Notice 97-02,

dated February 25,1998

l Emergency implementing Procedure, EIP-ZZ-00101, " Classification of Emergencies," Revision

20-

l

l

l

0

l

i

i

l

p

i

!

l_.