ML20059G887
| ML20059G887 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/02/1993 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2901, NUDOCS 9311090168 | |
| Download: ML20059G887 (7) | |
Text
.
~
1901 Douteau Amnue Ihst C" ice B3149 St iDJI5, h05%H E3Ilf; 314 554-2550 j
q l
i
{ INION N "b 2' 1993
- "'h"
Etecraic CC""*""
i 53 U. S. Nuclear Regulatory Commission l
Document Control Desk Washington, DC 20555 ULNRC-2901 l
Gentlemen:
l REPL,Y TO NOTICE OF VIOLATION l
INSPECTION REPORT NO. 50-483/93014 CALLAWAY PLANT l
This responds to Mr. William Snell's letter dated October 8,1993, which transmitted a i
Nodce of Violations for events discussed in Inspection Report 50-483/93014. Our I
response to the violations are presented in the attachment.
i None of the material in the response is considered proprietary by Union Electnc Company.
i If you have any questions regarding this response, or if additional information is required, please let me know.
l l
Very truly yours, Donald F. Schnell i
DFS/tmw i
Attachment:
- 1) Response to Violation ec:
J. B. Martin - Regional Administrator, USNRC Region III.
T. M. Tongue - Acting Chief, Reactor Projects Section 3C, USNRC Region III l
L. R. Wharton - USNRC Licensing Project Manager (2 copies)
USNRC Document Control Desk (Original)
Manager - Electric Department, Missouri Public Service Commission B. L. Bartlett - USNRC Senior Resident Inspector 0Sn009 Shaw, Pittman, Potts, and Trowbridge W. G. Snell, Acting Chief, Reactor Support Programs Branch
/
9311090168 931102 C
PDR ADOCK 05000483 F
/
3 u G
-PDR i
l
l Attachment to ULNRC-2901 Page 1 of 6 Statement of Violations During an NRC inspection conducted on Se.ptember 13 through 17,1993, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
1 1.
10 CFR 50.47 states, in part, that " adequate methods, systems, and equipment.
for assessing and monitoring actual or potential offsite consequences of a e
radiological emergency condition are in use."
The Callaway Plant Radiological Emergency Response Plan states that "the f
Radiological Release Information System (RRIS) provides near real-time j
predictions of atmospheric transport and diffusion estimates of radioactive releases."
Contrary to the above, on September 14,1993, the RRIS did not provide an accurate near real-time prediction of atmospheric transport and diffusion estimate of a radioactive release when its capabilities were demcnstrated.
j This is a Severity level IV violation (Supplement VIII).
2.
10 CFR 50.54(q) requires that a licensee authorized to possess and operate a j
nuclear power reactor shall follow and maintain in effect emerge.cy plans I
which meet the standards in 10 CFR 50.47(b) and the requirements of Appendix E to 10CFR Part 50.
i The Callaway Radiological Emergency Response Plan, Section 8.1.1, states, in part, that periodic retraining is conducted to update the knowledge and skills of onsite personnel.
Contrary to the above, periodic retraining of personnel provided on May 7, 1993, for the Emergency Response Organization position of Dose Assessment Coordinator (DAC) was not effective in updating their knowledge and skills in the functional use of the RRIS.
This is a Se'.erity Level IV violation (Supplement VIII).
l Attachment to l
ULNRC-2901 Page 2 of 6 3.
10 CFR Part 50, Appendix E, Section F.5, states that "all training, including exercises, shall provide for formal critiques in order to identify weak or deficient areas that need correction. Any weaknesses or deficiencies that are identified shall be corrected."
l Contrary to the above, no corrective actions were taken on deficiencies l
identified for the Radiological Assessment Course, T68.1090.8, held on July 28,1992.
This is a Severity Level IV violation (Supplement VIII).
{
General Reasons for the Violations In order to fully comprehend the events that culminated in the Notice of Violations, it is necessary to understand development of dose assessment capability at Callaway j
Plant.
l Beginning at the time of receipt of the Operating License in 1984, a computer software l
l package known as the " Radiological Release Information System" (RRIS) was implemented in the dose assessment area. The RRIS provided several functions, including a Cla.ss A atmospheric transport and diffusion model, effluent radiation j
monitor data, and calculation of dose and dose rates from gaseous releases.
Unfortunately, the RRIS was difficult to use and had several shortcomings which required manual calculations in order to perform dose projections, determine centerline dose values, and, perhaps most importantly, the RRIS was not designed to use field monitoring data or any other data except that provided from a select group of radiation monitors.
In order to overcome these shortcomings and to eliminate the need for manual calculations, the Health Physics and Emergency Preparedness organizations wrote and t
implemented a user friendly personal computer-based code. An advantage of the PC based program is its ability to perform dose projections using several different types of data, including field measurements, which are considered vital to performing an effective dose assessment. This program incorporates a straight-line Gaussian meteorological model. Input parameters are supplied by the various RRIS display screens, field data and portable instrument readings and are manually entered into the PC based program.
v ww
-tw, e-ww y
~vv-y 7
l l
\\
Attachment to l
ULNRC-2901 Page 3 of 6 Because the PC based program provides additional functions required for an effective and timely dose assessment and was easy to use, it was allowed to supplant the RRIS as the primary dose assessment tool. While this fulfilled immediate needs, it created a long term situation wherein resolution of the technical and human factor shortcomings of the RRIS remained uncorrected, while the PC based program was continuously enhanced and has evolved over a period of approximately 10 years into its current form. Training and manpower resources were dedicated to performing dose assessment with the PC based program. Unfortunately, dose assessment still has a dependence on f
the RRIS, since it provides input data to the PC based program and provides the Class A meteorological model as required by NUREG-0654.
i Our failure to correct the technical and human factor shortcomings of the RRIS was the root cause of these violations.
s Reason for Violation 1 l
l In addition to the above, the particular circumstances of this event were caused by l'
inadequate control of parameters which can be manually edited by the RRIS user, and inadequate knowledge of the dose assessment coordinators relative to the effect of changing these parameters.
I The RRIS is designed to be a very open system in order to facilitate expeditious editing l
of various parameters by the RRIS user as dictated by accident conditions. This feature is not protected by passwords or other security measures, but relies instead on the l
operator to know and understand the effect of his actions on the system. In this specific case, inappropriate nuclides were inserted into the release spectrum, which resulted in erroneous dose calculations. Since the RRIS software maintains its parameters for only seven days, and the erroneous data was present during all of this period, the exact date of the occurrence cannot be determined.
Corrective Steos that have been taken and results achieved:
On September 17,1993, the RRIS was administratively declared inoperable for calculating dose projections. Also on September 17, correct information was inserted into the data file of the RRIS and subsequent trials produced accurate dose projections.
However, the RRIS will remain inoperable for dose calculations until corrective actions are complete. RRIS will be used only as a source of data for input into the personal computer program which is used for dose assessment calculations.
l
o
'I Attachment to ULNRC-2901 Page 4 of 6 Cerrective steps that will be taken to avoid further violations:
A team has been assembled to define a course of action which will correct problems identified with the RRIS. Changes wiU be made to the Callaway Plant Radiological Emergency Response Plan, computer programs, implementing procedures, operator aids, and/or training based upon the results of the study.
i Date when full compliance will be achieved:
i The results of the team study will be available in January,1994. Full comphance is predicated on results of this study. However, we would expect implementation of the-results of the study to be accomplished by July 1,1994. In the interim, dose projections will be made using the personal computer program.
{
I i
I i
i l
l l
i
~.
Attachment to ULNRC-2901 Page 5 of 6 Reason for Violation 2 i
In addition to the general reasons cited earlier, this violation is attributed to the complexity of the RRIS, the inability of DACs to retain knowledge of RRIS operation between training sessions and reliance on the personal computer program by Dose Assessment Coordinators in the Emergency Preparedness drills and exercises.
Corrective Steos that have been taken and results achieved:
i All DACs have received remedial training using the RRIS as a source of data to the PC j
program for performing dose calculations. Each person trained has demonstrated j
proficiency using this methodology. This retraining was completed October 1,1993.
t l
Corrective stens that will be taken to avoid further violations:
A team has been assembled to define a course of action which will correct problems identified with the RRIS. Changes will be made to the Callaway Plant Radiological Emergency Response Plan, computer programs, implementing procedures, operator aids, and/or training based upon the results of the study.
1 1
Initial training and retraining courses will be developed as necessary ar.d provided to dose assessment personnel to insure their capability to perform dose projections.
i Date when full compliance will be achieved:
Initial training will be developed and provided prior to implementing any changes in dose projection methodology. Retraining will be provided as necessary to maintain the capability of dose assessment personnel.
All DACs can perform dose assessments / projections now using data from the RRIS in a personal computer program. Other actions to prevent recurrence as defined by the study team should be completed by July 1,1994.
l l
f i
l l
L_.__.___._,
_ _, _. _ _ _ - ~. - - -. -
- '