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Insp Rept 50-483/98-10 on 980428-30.No Violations Noted. Major Areas Inspected:Contingency Plan Developed in Response to Insp Findings in NRC Insp Rept 50-483/98-06 W/Special Emphasis on Training Process Used to Qualify People for Er
	ML20247M224
Person / Time
Site:	Callaway
Issue date:	05/19/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20247M210	List: ML20247M204; ML20247M224;
References
	50-483-98-10, NUDOCS 9805260206
	Download: ML20247M224 (7)
	v • d • e

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ENCLOSURE

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l U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-483

License No.: NPF-30

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 '

PDR ADOCK 05000483

O PDR

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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 i

specified the method to evalutte student performance. The inspector determined that j

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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 !

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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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

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 !

conducting the training session. !

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. Evaluation objectives must be established for each position or functional

group.

. To receive credit for annual requalification during a drill or exercise, an

evaluator / controller must be evaluating their position or a closely related 1

position (requiring the same or similar training requirements).

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(2) Radiological Emergency Response Plan training material (initial and j

requalification) must be reviewed by the Emergency Preparedness Department j

prior to conducting the training session. 1

(3) If equivalent courses are developed for exi-ting radiological emergency response i

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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

i 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 -

and by establishing controls over course content. I

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V. Management Meetings l

X1 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 IFl 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

ML20247M224

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