IR 05000483/1998006

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)

Text

w 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

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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 conducte Plant Support

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

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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).

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-3-L iP3 Emergency preparedness Procedures' and Documentation '

I Insoection' Scone (82701-02.01)

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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

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indicated that some of the changes potentially decreased the effectiveness of the L emergency plan. This reactive inspection was conducted to further review the

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l : emergency plan changes. In addition to Revision 21, the following Radiological L  : Emergency Response Plan and procedure changes were reviewed'during the :

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' inspection:

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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.

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Radiological Emergency Response Plan, Revision 21, Change Notice 97-02, dated February 25,1998.- The licensee did not request prior approval because it -

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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, requirement . 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

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- 10 CFR Part 50, Appendix E, requirement Observations and Findinas Radioloaical Emeroency Resoonse Plan. Revision 21

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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:

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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,

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-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

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- 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, requirement 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 chang increased the burden on the shift communicator to perform offsite agency and NRC notification (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,

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including protective measures, was changed from 30-45 minutes to 90 minutes. This change affected operations support capabilitie (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 capabilitie (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

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minutes. This change affected operations support capabilitie (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 caprSlitie ,

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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.

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

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staff was changed from 60-75 minutes to 90 minutes. This change affected technical support capabilitie (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 personne .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- 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 ;

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-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 implementatio 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

! The requirement to collect and analyze offsite sample media (solid, liquid, gas) was deleted from the description of the radiological monitoring dril 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:

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(1) Facility minimum staffing (60-minute responders) was not clearly describe (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 leve (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 offic .

(4) Table 6-1 did not accurately describe environmental monitoring capabilitie (5) Offsite sampling point maps were incorrectly delete (6) There were numerous editorial errors (e.g., biannualinstead of biennial).

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

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(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 acceptabl 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 pla 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 coordinate Emeraency lmolementina Procedure. EIP-ZZ-00101. " Classification of Emeraencies."

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Bayision 20 No issues were identified. The changes did not appear to decrease the effectiveness of the emergency pla 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 proces 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.

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-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 sample 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.

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b I ATTACHMENT l

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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

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-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

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