IR 05000483/1986002
| ML20209J131 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/31/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20209J101 | List: |
| References | |
| 50-483-86-02, 50-483-86-2, NUDOCS 8609160164 | |
| Download: ML20209J131 (33) | |
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SALP 6 SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-483/86002
Inspection Report
Union Electric Company
Name of Licensee
Callaway Plant
Name of Facility
June 1, 1985 - May 31, 1986
Assessment Period
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information.
SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations.
SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
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resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on
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August 8, 1986, to review the collection of performance observations
and data to assess the licensee's performance in accordance with the
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guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
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provided in Section II. of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Callaway for the period June 1, 1985 through May 31, 1986.
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SALP Board for Callaway:
NAME
TITLE
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J. A. Hind
Director, Division of Reactor Safety and Safeguards
C. E. Norelius
Director, Division of Reactor Projects
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R. M. Lerch
Project Inspector, Reactor Projects 1A
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B. H. Little
Senior Resident Inspector
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W. L. Forney
Chief, Reactor Projects Section 1A
N. J. Chrissotimos Deputy Director, Division of Reactor Safety
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L. R. Greger
Chief, Facilities Radiation Protection Section
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M. C. Schumacher
Chief, Independent Measurements and Environmental
Protection Section
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P. W. O'Connor
Project Manager, Division of Licensing, Office
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of Nuclear Reactor Regulation
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J. R. Kniceley
Safeguards Inspector
E. R. Schweibinz
Chief, Technical Support Section
M. P. Phillips
Chief, Operational Programs Section
C. F. Gill
Reactor Inspector, Facilities Radiation Protection
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Section
J. P. Patterson
Emergency Preparedness Analyst
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II.
CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or operating
phase.
Functional areas normally represent areas significant to nuclear
safety and the environment.
Some functional areas may not be assessed
because of little or no licensee activities, or lack of meaningful
observations.
Special areas may be added to highlight significant
observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1.
Management involvement and control in assuring quality
2.
Approach to the resolution of technical issues from a safety standpoint
3.
Responsiveness to NRC initiatives
4.
Enforcement history
5.
Operational and Construction events (including response to, analyses
of, and corrective actions for)
6.
Staffing (including management)
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is
classified into one of three performance categories.
The definitions of
these performance categories are:
,
Category 1.
Reduced NRC attention may be appropriate.
Licensee
management attention and involvement are aggressive and
oriented toward nuclear safety; licensee resources are
ample and effectively used so that a high level of
performance with respect to operational safety and
construction quality is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident
and are concerned with nuclear safety; licensee resources
are adequate and are reasonably effective so that
satisfactory performance with respect to operational safety
and construction quality is being achieved.
Category 3.
Both NRC and licensee attention should bc increased.
Licensee management attention or involvement is acceptable
and considers nuclear safety, but weaknesses are evident;
licensee resources appear to be strained or not effectively
used so that minimally satisfactory performance with
respect to operational safety and construction quality is
being achieved.
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III. SUMMARY OF RESULTS
The regulatory performance of the Callaway Plant is very good.
Although
the ratings in Surveillance and Security improved and the rating for
Licensing Activities declined, performance improved to some extent in
most areas.
Rating Last
Rating This
Functional Area
Period
Period
A.
Plant Operations
2
B.
Radiological Controls
2
C.
Maintenance
2
D.
Surveillance
1
E.
Fire Protection
1
F.
2
G.
Security
1
H.
Outages
1 (Fuel Loading)
1 (Refueling)
I,
Quality Programs and
Administrative Controls
Affecting Quality
2
J.
Licensing Activities
2
K.
Training and Qualification
Effectiveness
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
Portions of seven inspections were performed in this area
by the resident inspectors and region based inspectors which
included direct observation of operating activities.
Extensive
inspections were performed during the seven week Cycle 1
refueling outage which included assist inspections by NRC
resident inspectors from the Byron and Wolf Creek Plants.
The
operations portions of these inspections focused on overall
control room discipline and specifically on shift crew
performance during normal and off-normal conditions and shift
relief and turnover activities.
The inspections included a
review of logs and records, interviews with plant personnel
and followup of significant operating events to ascertain
facility operations in conformance with the Technical
Specifications and administrative procedures.
One violation
was identified as follows:
Severity Level IV - Failure to operate within the Axial Flux
Difference target band as required by Technical Specifications.
(Inspection Report No. 50-483/85016).
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The violation involved operating the reactor beyond the
allowable Axial Flux Difference (AFD) limits allowed by
Technical Specification (TS).
Technical Specifications
require that with the indicated AFD outside of the above
required target band and with thermal power greater than
or equal to 90% of rated thermal power, within 15 minutes,
either restore the indicated AFD to within the required
target band limits, or reduce thermal power to less than
90% of rated thermal power.
Although there are four channels of power range flux difference
indication, an NIS Recorder, and a CRT display provided on the
control room " front panel" to indicate AFD conditions, the
allowable AFD band was exceeded by approximately 1% for
135 minutes before an operator noted and corrected the condition.
This event indicates a lack of operator attention which resulted
in exceeding the allowable Axial Flux Difference.
NRC
inspection determined that the event posed no technical safety
problem; however, the event was considered significant as it
resulted from a lack of operator attention to plant parameters
and conditions.
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Escalated enforcemert is being considered involving two examples
of the licensee's failure to maintain plant / instrumentation
systems operable as required by Technical Specifications and
one example of failure to meet NRC reporting requirements.
(1) The Intermediate Head Safety Injection System was
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inoperable for approximately six hours.
The event resulted
from a combination of procedural and personnel performance
errors.
(2) The Auxiliary Feedwater Pumps (AFPs) Engineered
Safety Features Actuation System (ESFAS) blocking switches
were in " block" position for approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, which
defeated the automatic start feature of the AFPs upon loss
of the main feedwater pumps.
(3) The licensee failed to
notify NRC within four hours of a condition which rendered
the Intermediate Head Safety Injection System inoperable.
NRC inspections determined that the two events posed no
significant threat to public/ plant safety; however, escalated
enforcement action is being considered to emphasize the
importance of conducting activities in full compliance with
the facility license, and to underscore the importance of
procedural discipline and operator attentiveness.
The licensee's initial evaluation of reportability by the
operating crew classified the event as a 30 day Licensee Event
Report (LER).
Licensee's followup review process failed to
identify the appropriate reportability of the event.
Although the above violations directly involved plant operations,
other violations which indicate direct or indirect involvement
by plant operations are discussed in Sections IV.B., Radiological
Controls, and IV.I., Quality Programs.
In addition, NRC
inspections determined that plant operations personnel were
involved in procedural and Technical Specification violations
for which Notices-of Violations were not cited because the
violations were of lesser safety significance, and the licensee
identified, thoroughly evaluated, factually reported, and
provided prompt corrective measures.
Overall, the number of LERs issued during the assessment period
indicate a downward trend.
However, the number attributed to
personnel error is greater than expected.
For example, during
the last three months of this assessment period, 12 of the
20 LER events which occurred are attributed to personnel
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performance problems.
Of those attributed to " personnel",
seven events relate to containment / control room ventilation
isolations involving inoperable radiation monitors.
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Licensee events receive a high level of management attention.
In addition to disciplinary action / supervisory consultations,
management holds bi-monthly " fire-side" chats with the
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operating crews. These meetings focus on increasing operator
awareness of LERs and reactor trips and have stressed personal
accountability.
LER/ reactor trip performance trends are posted
on plant status boards.
To reduce performance errors the
licensee has added sign-off action steps to I&C and maintenance
procedures, placed warning signs at radiation monitors and
electrical controls, and conducted special training sessions
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on radiation monitors. Written LERs, received during this
assessment period, are summarized further in the " Supporting
Data and Summaries,"Section V.G.I. of this report.
There were no events during this assessment period which were
classified as an " Unusual Event." There were four unusual
events during the previous assessment period.
A total of 83 events were reported to the NRC Operations Center
via telephone. Of these, 42 were non-security events reported
under the requirements of 10 CFR 50.72 and 41 were LER notifications
made per 10 CFR 50.73. Review of the LERs indicates that about
half of them involved minor technical specification violations
and were not significant enough to be reported to the Operations
Center.
There were fourteen (14) reactor trips which occurred during the
period from June 1, 1985 through May 31, 1986. Twelve were
from power levels greater than 15% power and 2 were from less
than 15% power or during shutdown conditions. Of these, nine
were related to equipment deficiencies and five resulted from
personnel errors. The NRC and the Licensee consider this
number of reactor trips to be excessive. The Licensee has
established a set of goals for seven reactor trips between the
period January 1 through December 31, 1986.
If the plant has
seven trips their performance goal will be met; if there are
five trips their performance will be considered excellent by
the licensee, and if there are three or fewer trips their
performance will be considered outstanding by the licensee.
Of the 42 non-security events reported per 50.72, 22 events
involved actuations of engineered safety features. A large
number of these events involved spurious Containment Purge
Isolation (CPI), Control Room Ventilation Isolation (CRVI),
and Fuel Building Ventilation Isolation (FBVI). Two events
were caused by personnel error. A number of events were due
to spurious signals generated during gas sampling evolutions.
In 1985 (note the SALP period is 6/1/85 through 5/31/86), the
reactor critical hours of operation were 8,161, the forced
outage rate was 6.4% or 536.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the unit had 20 scrams
which is equivalent to 2.45 scrams per 1000 critical hours of
operation, which is much higher than the industry average of
1.47 scrams /1000 critical hours in 1985. However, the plant
availability factor for 1985 was 90% which is much higher than
the 61% national average availability factor for 1985. This
high availability factor in spite of the high number of scrams
is because the plant was not refueled during 1985, the outages
that occurred were of fairly short duration, and plant staff
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performance was good.
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NRC inspection of licensee events has found that " event
reduction" has been given a high level of management attention
and support.
This includes the implementation of a Plant Trip /
Incident Reduction Program which is discussed in more detail
in Section I., Quality Programs. The licensee has provided
prompt and thorough evaluation of causal factors and prompt
implementation of corrective measures.
Corrective measures
specified by the licensee usually include performance goals
such as the attainment of main control panel " black boards"
for example. Operational improvements attributable to
management atteni. ion include reductions in the number of
reactor trips and reportable events, and reduction in the
backlog of work items including the reduction of alarming
control room annunciators. Management attention to operating
events is evident in the quality of LER reports.
An evaluation
of LER reports by the Office for Analysis and Evaluation of
Operational Data found the content and quality of a sample of
LERs to be higher than the industry average.
See the summary
in Section V.G.1 of this report.
Inspection of licensee performance relating to control room
behavior was performed routinely by the resident inspectors and
Region III inspectors.
The extended coverage during the
refueling outage provided observation of the licensee's shift
crew performance during days, off-shift, and weekends, including
shift turnovers.
The control room operators and supervisors were attentive to
plant conditions'and displayed a professional attitude toward
the control and operations of the plant.
Plant alarms, and
both planned and unplanned events were promptly responded to,
appropriately communicated, and logged.
The operating logs,
status boards, and equipment out of service logs were being
maintained and reflected current plant and system conditions.
Administrative and operating procedures were adhered to.
Crew shift relief and turnovers were performed in a thorough
manner and included discussions of past, current, and planned
activities, the review of logs, and panel walkdowns.
Control
room access is limited and enforced. The inspectors noted
that licensee management and quality assurance personnel
provided frequent in plant observations of the shift crews'
performance.
During site visits on June 24, 1985, August 28, 1985 and
April 29, 1986, headquarters staff toured several plant areas
including the reactor building, turbine building, auxiliary
building, radwaste building, and the control room.
The
staff found that the plant was in good order with respect to
cleanliness and housekeeping.
Activities in the control room
were observed to be conducted in a professional manner with
assigned personnel appearing to be alert and attentive to duty.
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2.
Conclusion
The licensee is rated Category 2 in this area.
This is the
same rating as the previous assessment period.
3.
Board Recommendations
None.
B.
Radiological Controls
1.
Analysis
Four inspections were conducted during this assessment period
by region based inspectors.
These inspections included
radiation protection, radioactive waste management, TMI
Action Plan Items, chemistry / radiochemistry, confirmatory
measurements, and environmental monitoring. The resident
inspectors also reviewed this area during routine inspections.
Four violations were identified as follows:
a.
Severity Level IV - Failure to follow procedures for
sampling the unit vent radioactive gaseous effluent,
resulting in failure to identify inoperability of the
unit vent gaseous monitor.
(Inspection Report
No. 50-483/85017)
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b.
Severity Level IV - Failure to implement specified
actions (alternate sampling and report to NRC) required
due to inoperability of unit vent gaseous monitor.
(Inspection Report No. 50-483/85017)
c.
Severity Level IV - Failure to leak test two sealed
sources at required frequency.
(Inspection Report
No. 50-483/85017)
d.
Severity Level IV - Failure to implement specified actions
(auxiliary sampling or termination of releases) required
due to isolation of the radwaste building vent iodine and
particulate sampler.
(Inspection Report No. 50-483/86014)
Violations a. and b. resulted when, due to personnel error, a
sample line was not reconnected following maintenance on the
unit vent sample pump.
Due in part to another personnel error,
the disconnected sample line was not detected for thirteen days,
during which time required gaseous monitoring or alternate
sampling was not performed. Violations c. and d., although
identified by the licensee, were cited because licensee
corrective actions were inadequate.
The violations appear to
reflect minor programmatic failures of licensee personnel and
administrative systems to effectively recognize and implement
oporational requirements.
At the end of this SALP assessment
period, the plant had been operational for approximately
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17 months. The number of personnel and administrative system
failures in this functional area during this initial operational
period has been typical for new plants.
Staffing continues to be a licensee strength.
The number
of technician and supervisory personnel is ample, with
essentially all positions filled and has been very stable
with losses generally limited to internal promotions.
This
stability should enhance the staff's performance as experience
is gained. Additionally, an adequate number of well qualified
contract radiation protection technicians were utilized during
the extended maintenance outage.
Positive management involvement in this functional area
continued to be demonstrated.
There is consistent evidence
that supervision is directly involved in day-to-day activities.
A radiation protection representative attends all outage
planning meetings.
Plant work group managers are utilized to
support correction of radiation protection infractions by their
workers.
The radiation work violation reporting system for
documenting and correcting problems appears to be working well.
Quality assurance auditors are well qualified and have
performed timely and thorough audits of this functional area.
Responsiveness to the audit specific findings has been good.
However, an improved system is needed to obtain timely
responses to programmatic weaknesses identified by audits
and evaluations.
Management shortcomings in this functional
area were evidenced in continued delays in resolution of
ventilation system filter housing drain problems and certain
TMI Action Item analysis issues. The filter housing drain
issue was resolved near the end of this assessment period;
however, the TMI Action Item issue remains open from the
previous SALP assessment period.
An additional recurrent
problem area requiring licensee attention was radioactive
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effluent leakage from piping systems, which was straining
the decontamination work force; many of these leaks were
repaired during the refueling outage near the end of this
assessment period.
Responsiveness to NRC issues was acceptable.
The licensee has
resolved or initiated actions for several NRC concerns, including
fuel manipulator crane area monitors, ventilation system deluge
and drain provisions, painting of concrete surfaces in potentially
contaminated areas, control room ventilation charcoal desorption
potential, fluid calibrations of liquid and gaseous effluent
monitors, radon levels, and sample line iodine plateout.
Additional licensee actions are needed concerning TMI Action
Items and contaminated leakage from piping systems.
Generally, a conservative approach to resolution of technical
issues continues to be exhibited.
Personal radiation exposures
for the first eighteen months of operation were about
240 person-rems which is consistent with early PWR operations.
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The licensee's ALARA program is well organized and amply staffed.
Plant and work group goals have been established in numerous
areas and have been updated, as necessary, to reflect existing
conditions.
Additional work requests for repair of contaminated
system leakage necessitated upward revision of the ALARA goal
for the total contaminated plant area.
The ALARA program places
emphasis on contaminated area controls.
The decontamination
work force appears well organized under the Radwaste
Superintendent but suffers somewhat from understaffing and
inexperience.
Several noteworthy ALARA improvements were
implemented during this assessment period including expanded
use of temporary, job-specific air filtration equipment and
use of temporary shielding during reactor head gasket
replacement.
Liquid, airborne, and solid radioactive releases during this
assessment period were consistent with early PWR operation.
No transportation problems were identified.
The licensee has performed and implemented a satisfactory
water chemistry control program for the primary and secondary
system chemistry which addresses the major elements of the PWR
Owners Guidelines designed to minimize localized corrosion in
the steam generators and turbines.
The Radiological Controls Technicians demonstrated satisfactory
capability for collecting samples and analyzing them for key
chemical parameters.
The licensee also has adequate capability
to monitor conductivity, pH, sodium and dissolved oxygen
through on-line monitors on different plant systems to ensure
the appropriate water quality is maintained.
The licensee
maintains awareness of the water quality through trend plotting
of analytical data over time and will impose action levels if
necessary when monitored chemical parameters are confirmed to
be outside normal operating values.
The licensee has demonstrated a satisfactory QA/QC program
through control charts on chemical parameters and on counting
data using performance check sources.
Licensee participation
in an interlaboratory cross check program involving radiological
and nonradiological sampics has been satisfactory.
The
licensee's results in the confirmatory measurements program
are excellent with all agreements for the comparisons made.
Conduct of the Radiological Environmental Monitoring program
during this period is satisfactory with no significant
discrepancies noted during the review of the Annual Operating
Report.
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2.
Conclusion
The licensee is rated Category 2 in this area.
Although
the rating for the last SALP was Category 2 also, overall
performance this assessment period was better than the
majority of SALP Category 2 plants.
3.
Board Recommendations
None.
C.
Maintenance
1.
Analysis
Inspections in this functional area were routinely included
in seven inspections performed by resident inspectors, region
based inspectors, and a resident inspector from another site.
The inspections included a review and observation of the
maintenance programs, staffing, staff training, and records.
In addition to selected preventive and corrective maintenance
and system modifications surveyed to verify that these
activities were completed in accordance with Technical
Specifications and the licensee's quality assurance program
requirements, followup inspections were performed on
significant equipment problems.
Discussions were held with
craftsmen, maintenance supervision, and plant management.
The following items were also considered during these
inspections:
the limiting conditions for operation were
met while components or systems were removed from service;
approvals were obtained prior to initiating the work;
activities were accomplished using approved procedures and were
inspected as applicable; functional testing and/or calibrating
were performed prior to returning the components or systems to
service; parts and materials that were properly certified;
radiological controls were implemented as necessary; and, fire
prevention controls were in place.
No violations or deviations were identified.
One LER was issued relating to instrumentation & control
maintenance during the assessment period.
This event involved
troubleshooting that resulted in a signal being injected
into the incorrect Reactor Protection System trains which
caused an inadvertent reactor trip.
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An inspection assessed the licensee's programs for equipment
classification, vendor interface, and post maintenance testing
and found them to be adequate.
An inspection was conducted to perform an in-depth evaluation
of maintenance related events.
The maintenance program was
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determined to be basically sound with the licensee addressing
some minor weaknesses. The licensee management has shown an
aggressive posture in dealing with the maintenance program and
the implementation problems including a thorough evaluation
of root causes.
Maintenance scheduling and performance consistently shows
improvement and evidence of good planning and assignment of
priorities.
This was evident during the outage when a large
effort was incorporated in the maintenance program to reduce
the number of backlogged items as well as during routine
operations.
The corrective actions performed appear to be
effective as indicated by the lack of repetitive work orders.
Management involvement is also evident in the concern placed
on the reduction of work order items backlog.
The maintenance
records were found to be clear and retrievable.
The staffing appears to be sufficient for routine work demands.
During the evaluation period, contractors were onsite working
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to reduce the number of backlogged work orders.
During this
period, the number of work orders were reduced from over
5000 to approximately 2000.
The events and occurrences in this functional area have
received a high level of management involvement.
" Crew
chats" have been used and procedures have been revised (with
additional action step signoffs) to reduce performance errors.
Specialized training in specific areas has also been
incorporated to reduce the number of events.
The maintenance
area is also included in the " Plant Trip / Incident Reduction
Program."
2.
Conclusion
The licensee is rated Category 2 in this area.
The rating for
the last SALP was Category 2.
3.
Board Recommendations
None.
D.
Surveillance
1.
Analysis
Inspections were routinely performed in this functional area
during five inspections by the resident inspectors and two
inspections by regional based inspectors.
No violations were
identified in this area.
The resident inspectors reviewed or observed selected portions
of Technical Specifications required surveillance testing
during power operations and mode changes during startup from
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the refueling outage.
Items which were considered during the
inspections included whether adequate procedures were used to
perform the testing, test instrumentation was calibrated, test
results conformed with Technical Specifications and procedural
requirements, and the test was performed within the required
time limits.
The inspectors determined that the test'results
were reviewed by someone other than the personnel involved with
the performance of the test, and that any deficiencies
identified during the testing were reviewed and resolved by
appropriate management personnel.
Two inspections were performed by regional based inspectors to
review the calibration and surveillance testing programs.
The
programs were found to be sound and well implemented.
A
regional based inspector performed a review and evaluation of
the in-service inspection of the piping system components.
The
activities were controlled through the use of well stated
procedures. The review showed that the activities had received
good planning and priorities had been assigned. Observation
of the in-service inspection activities indicated that
personnel have a good understanding of work practices and that
procedures were followed.
Records were found to be essentially complete, well maintained,
and available.
The records also indicated that equipment and
material certifications were current and complete and that the
personnel performing nondestructive examinations were trained
and certified.
Discussions held with personnel performing the
examinations indicated they were knowledgeable of their job.
Three reportable licensee events, which included two reactor
trips were classified in this area.
This number of events
is considered acceptable in relationship to the number of
surveillances that were performed during this period.
Technical Specification requirements have been converted
to verification test requirements and the schedule
placed on the computer.
Only two tests were tardy this
period.
These occurred during unusual conditions that had
not been factored in from the Technical Specifications and,
therefore, are not a programmatic problem.
These deficiencies,
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and others that have been identified, have been promptly
documented, evaluated, and corrected.
The program was
considered to be fully implemented on June 1, 1985, and it
appears that the planning and scheduling portion of the
program has been very effective.
The computerizing of the surveillance schedule and designating
a group to followup performance of the surveillance tests has
essentially eliminated missed or late performance of the tests.
Review of individual procedures has shown these to be quality
procedures, which include the appropriate acceptance criteria.
The test results were reviewed and evaluated in a timely manner.
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The planning and scheduling group also schedules maintenance
on equipment at the same time as the surveillance is to be
performed. This feature helps keep safety-related equipment
out-of-service to a minimum.
In response to comments provided in the previous SALP report,
improvements were implemented in the field performance
activities.
The NRC inspections determined that the licensee
has implemented a comprehensive surveillance program in which
identified deficiencies are evaluated and corrected promptly.
The licensee has been very receptive to comments and suggestions
by the NRC and demonstrated a conservative and conscientious
attitude toward maintaining a quality surveillance testing
program.
The licensee's staffing levels have been adequate to perform
and followup in the area of surveillance tests.
The management
involvement in this area has been consistently evident in
planning and the assignment of priorities.
The LERs classified
in the area of the surveillance program are included in the
" event reduction" study which has received a high level of
management attention.
2.
Conclusion
The licensee is rated Category 1 in this area.
The rating for
.
the last SALP was Category 2.
3.
Board Recommendations
None.
E.
Fire Protection
1.
Analysis
The inspections in this functional area were conducted during
the six routine inspections performed by the resident inspectors.
The inspections did not include the verification of conformance
to Appendix R requirements.
The inspections did include
observation of the on shift fire brigade training drills,
housekeeping, storage, and control of flammable liquids and
combustibles, status and condition of manual fire fighting
equipment, and the condition of the emergency breathing
equipment and " turn out" gear.
No violations or deviations were issued.
Nine LERs were issued in this functional area.
Seven involved
improperly stationed fire watch patrols.
One LER reported
missing conduit smoke and fire seals due to a construction
installation inadequacy.
The remaining LER identified a number
of fire dampers that may not have had the necessary clearances
.
.
had a fire occurred.
Licensee reviews of the reportable events
were timely, thorough, and technically sound, and the corrective
actions appear to have been timely and effective.
The improperly stationed fire watch patrols were of minor
significance to safety-related equipment.
The patrols were
tardy due to misunderstanding or misinterpreting the
requirements or the patrols were simply late at a checkpoint.
The five dampers that were reported were of minor safety
significance due to associated fire sensing and/or suppression
systems.
The licensee implemented appropriate temporary
controls until the fire dampers are corrected.
The fire protection / prevention equipment and procedures have
been found to be maintained at an excellent level.
Two drills
and portions of other exercises were observed.
The fire
brigade performance during the drills was noted to be
business-like and the functional performances were very
professional. The inspections showed that housekeeping in
the plant had been maintained at a high level.
During the
outage, the licensee utilized additional personnel to maintain
the cleanness of the plant. The inspectors' walkdowns
performed during the outage indicated that housekeeping was
maintained at a very good level throughout the outage.
2.
Conclusion
The licensee is rated Category 1 in this area.
This is based
on operational inspections and not an inspection of 10 CFR
Appendix R implementation. The rating for the last SALP was
Category 1.
3. ' Board Recommendations
None.
F.
1.
Analysis
Two inspections were performed during the assessment period.
One of these was an evaluation of the annual emergency
preparedness (EP) exercise conducted on June 5, 1985.
The
other was a routine inspection which included a review of
emergency detection and classification, protective action
decisionmaking, notifications and communication, changes to
the emergency program, shift staffing and augmentation,
training, and licensee audits.
No violations were identified.
Two weaknesses were identified during the exercise.
One was
lack of a health physics (HP) control point for radiological
.
.
.
self-monitoring at the Technical Support Center (TSC),
Maintenance Operational Support Center (OSC), and the HP
Access Control Point.
The other weakness was inadequate
communications in the OSC, e.g., telephone reception
interference, poor audibility of Gaitronics, and ineffective
use of radios for contacting in plant teams.
Correction of
these two weak areas was successfully demonstrated and
reviewed during the July 30, 1986 annual emergency exercise.
The routine inspection included a thorough review of the
" Classification of Emergencies" procedure including the
Emergency Action Level (EAL) classification criteria.
The
inspectors recommended that certain EALs be modified, revised
or restated to more accurately identify emergency plant
operating conditions.
Proper management attitude and
involvement was demonstrated by the licensee's commitment to
review the EALs and consider changes to the EAL format.
A new computerized dose assessment program has been initiated
by the licensee.
This program, Radiological Release
Information System (RRIS), while functional, appeared to have
been designed to run with current meteorological data only,
and was unable to use forecast meteorological data.
As
evaluated by the inspection team, the program needed several
software changes to make it function as a predictive device for
calculating projected releases of radioactivity.
Management's
response to the EAL and dose assessment issues has indicated an
understanding of the issues, and a willingness to address NRC
Concerns.
To correct a shift augmentation drill which failed to obtain
minimum required responses, an additional drill was successfully
performed in April 1986, and monitored by the NRC Senior
Resident Inspector.
Additional drills will be monitored for
assurance that reliability has been developed in the shift
augmentation area.
Independent audits of the program have been timely and thorough,
with the findings needing corrective actions being identified
by Quality Assurance (QA) auditors.
Follow-up corrective
actions were taken and upper management was made aware of
the findings.
Responsiveness to NRC initiatives and other
issues has been viable, generally sound, and thorough in most
instances.
Enforcement history has been very good,
Corrective
actions have been timely and effective in most cases.
The
training program has steadily improved.
EP training has now
been incorporated into simulator training for control room
personnel with emergency response functions.
A Job Task
Analysis has been developed by the Training Department to
better define the objectives and responsibilities of each
emergency response position.
As a result, three lesson plans
have been established for each of the 55 emergency response
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I.
- positions.
The Emergency Preparedness Required Reading
i
Procedure has been revised to make the supervisor accountable
for assuring that the procedure is adhered to by those with
emergency preparedness responsibilities.
The training program
is well defined and implemented with dedicated resources and
a means for feedback experience.
.
Two activations of the Callaway Radiological Emergency Response
Plan (RERP) were identified during this SALP-6 period. Both
events were categorized correctly and proper notifications were
made in a timely manner to State, local agencies, and the NRC.
With the addition of the ring down phone in the control room
and emphasis on correctly completing the notification form,
l
this aspect of communications has improved from the previous
j
SALP period.
2.
Conclusion
<
The licensee is rated Category 2 in this area.
Licensee
I
performance was determined to be improving near the close
of the assessment period.
The rating for the last SALP
was Category 2.
3.
Board Recommendations
None.
G.
Security
1.
Analysis
One routine inspection and one reactive inspection were
conducted by regional based inspectors during this assessment
i
period.
The resident inspectors also made periodic inspections
!
of security activities assessing routine program implementation
and providing initial response to security events. One
j
violation was identified as follows:
Severity Level IV - The licensee failed to have a fully
adequate barrier from the owner controlled area to the
I
protected area.
(Inspection Report No. 50-483/86005)
During the assessment period, the region received allegations
of security improprieties and communicated telephone threats
,
to the plant.
The allegations were not substantiated. The
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licensee's investigative actions and increased security
-
!
measures pertaining to the security related telephone threats
!
were comprehensive, timely, and adequately reported, although
initial evaluation of the significance and reaction to the very
l
first event required regional management discussions with the
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security organization.
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_ _ _ _ _ _ _ _ _ _ _
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_ _ _ _ _ _ _ _ _ _ _ _
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'
The licensee's senior management demonstrated an awareness of
security issues and has been effective and responsive to
identifying, resolving, and recommending solutions for security
issues.
Concerns and observations receive the same exceptionally high
level of management attention normally associated with violations.
The security management is responsive to all NRC initiatives and
suggestions that can strengthen their program, rather than
concentrating on just minimum compliance required by the security
plan.
Full management support has been demonstrated by site
management, and the security organization operates in a highly
supportive environment. The weaknesses identified during the
previous SALP period were adequately corrected.
The lack of
significant violations is attributable to the security force's
high caliber of performance. Weaknesses identified by the
licensee were not repetitive and not indicative of a programmatic
breakdown.
Corrective actions were prompt and effective.
Management has established policies and procedures that are
well written and effectively enforced.
The licensee's staffing levels are adequate to fulfill security
plan commitments.
Positions within the security organization
are identified and authority and responsibilities are well
defined.
Training policies and procedures have ensured that
all security personnel are trained and qualified to perform
assigned security related tasks or duties.
There were no technical security issues with respect to plant
safety that required resolution during this assessment period.
Additionally, no regulitory issues which required a licensee
response were identified during the assessment period.
Security events were properly and accurately reported to the
NRC under 10 CFR 73.71(c).
There have been eight such events
during the assessment period.
These events pertained mainly
to computer hardware problems which were adequately resolved.
The licensee properly analyzed the events and initiated
appropriate corrective action.
The licensee's Quality Assurance Department, which conducts
independent security program audits, has been effective in
identifying security program weaknesses and has been
instrumental in strengthening the security program.
In summary, the licensee's security staff has been highly
effective in the operation and implementation of the security
program.
The security staffing is adequate and departmental
support for the security program has been effective.
Supervision of the security force is aggressive which results
in a stable, well trained security force.
.
.
'
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2.
Conclusion
l'
Because of the excellent enforcement history and management
involvement in problem resolution, the licensee is rated
Category 1 in this area.
The rating for the last SALP was
Category 2.
,
,
3.
Board Recommendation
None.
/
H.
Outages
,
,
1.
Analysis
Three inspections were performed in this functional area by
regional based and resident inspectors. Only one major outage
occurred during this period, the first refueling and maintenance
outage.
The inspections included the receiving inspection of
new fuel assemblies, defueling and refueling, various maintenance
and surveillance activities, radiological protection, and planning.
No violations were identified.
Extensive management involvement was evident several months
prior to and during the initial refueling outage.
The personal
involvement of management was observed at advanced planning and
y
daily planning meetings and frequent in plant tours.
The
outage was well planned and administered.
The licensee has
a permanent outage group that schedules the outages.
The
outage group held twice daily meetings with all concerned
i
groups for problems and information dissemination.
The detail
i
of jobs to be performed during the next three days was issued
at this time.
Outage coordinators were onsite around the clock
to make any schedule changes that were found to be necessary.
The licensee provided additional staffing and supervision,
special equipment checkout, and training.
Advanced planning
also provided detailed / integrated subnets for major work and
activities and assignment of task performance responsibilities.
Personal accountability was evident during the outage meeting
and was effective in resolving technical problems.
The need
for increased plant security was recognized in the planning
and was subsequently provided.
The refueling operations were performed by licensee personnel
with contracted fuel loading supervision.
Refueling
operations were performed smoothly with only minor equipment
problems occurring.
The radiological controls were enhanced with the advanced
planning and the hiring of the contract rad technicians that
>
provided sufficient personnel to cover the jobs in progress.
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The advanced planning / scheduling set the outage at 42 days and
I,A.;
.
the actual outage was completed in 49 days. The licensee
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b
stated that this was the shortest initial refueling outage for
,
a Westinghouse four-loop plant to date.
The outage schedule
i
'
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was developed with no contingency time built in.
The seven day-
j
outage extension was the accumulation of delays in the critical
'
t
.
path items due to equipment failures, jobs taking longer to
complete than historical information indicated, and other
'
miscellaneous reasons.
The major projects completed during
-
the outage were inspection of main turbine and generators,
,
i
local leak rate tests of containment valves, steam generators
tube inspection, secondary side inspection of steam generators,
and maintenance on reactor coolant pumps and feedwater pumps.
No major spills or contamination occurred during the outage
,0
and housekeeping was maintained at a high level of cleanliness.
, 1:
The commitments for the Safety Parameter Display System (SPDS)
'
to be operable were completed during the outage and the Reactor
'
'. >
Vessel Level Indicating System was made functional. The
/l
modifications to reduce the number of alarms lit continued
and reduced the number to less than ten.
(This program remains
,
',. -
ahead of schedule.) There were 103 modifications performed
during the outage with the majority being considered in the
operational upgrade category.
NRC inspections during the Cycle 1 refueling outage determined
that the licensee had provided adequate staffing, supervision,
,
and training for the outage activities.
Procedures were
detailed and adhered to by the performing groups.
Exceptional
performance was noted by the operating crews' conduct and control
of the outage activities, health physics, controls and practices,
and overall maintenance.
Subsequent startup testing was also
conducted with no significant problems.
Plant-wide maintenance
and housekeeping control / practices and conditions were
exceptionally well maintained.
2.
Conclusion
The licensee is rated Category 1 in this functional area.
This is the first SALP rating of this area.
3.
Board Recommendations
None.
I.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
The licensee's Quality Assurance (QA) Program, including
quality verification and oversight activities, was routinely
assessed in six inspections by the resident inspectors during
t
.
.
observations of plant activities in the areas of testing,
operations, maintenance, and surveillance.
The licensee's
implementation of its Quality Assurance / Quality Control (QA/QC)
Administration and Audit Programs was also the subject of two
inspections by region based inspectors.
No violations or
deviations were identified.
Escalated enforcement is being considered for failure to
environmentally qualify electrical equipment. The violation
involved two examples of the use of non-environmentally
qualified (EQ) electrical connectors on the Reactor Vessel
Head Vent Valves, and the Containment Isolation Valve for
the Chemical Volume and Control System.
NRC inspection determined that the licensee's use of the
non-EQ connectors resulted from deficient oversight of a
modification and a design change.
Upon discovery, this matter
received a high level of management attention.
Licensee
corrective actions included a re-review of EQ documents and
a 100% in plant inspection of all valves and limit switches
requiring EQ (Conax) connectors.
No additional deficiencies
were identified.
In the areas of QA/QC administration, the licensee developed
new procedures to address the preparation and control of
quality assurance planning guides and the parts Q-list data
base.
Another procedure was revised to accommodate the SNUPPS
computer program requirements.
The licensee made good progress
in addressing these.
In the area of audit implementation, the licensee proceeded
with their audit programs in four separate areas:
Operations,
Operations Support, Technical Support, and Quality Systems.
These audits were conducted in accordance with their program
schedules, by certified auditors, using approved plans and
checklists, and with proper attention to corrective action
requirements.
The NRC expressed minor concerns regarding the
flexibility granted to the auditors to vary from the planned
checklists, the lack of auditor identity on all the
certification papers, and the similarity between the 1985
and 1986 overall audit schedules.
The licensee promptly
responded to these items and committed to a thorough review
of their practices.
There was adequate evidence of management
involvement in planning and assignment of priorities for the
control of these activities.
Management's high degree of attention, frequent site visits,
and personal involvement in quality programs has been
continually evident at Callaway.
Both corporate and site
management frequently met with the resident inspectors.
During
these meetings, the licensee has been open and forthright in
!
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discussing events, problems, corrective actions, and enhancement
programs.
Management's influence in this area is evident
throughout the licensee's staff.
The effectiveness of the licensee's quality programs during
this assessment period, has been demonstrated by the favorable
reduction in the number of reactor trips and reportable events,
and the reduction in the backlog of work items including
alarming control room annunciators. Other favorable indicators
include the licensee's achievement of a fully accredited
training program and operator's performance on licensing exams.
The operating crews demonstrated a high degree of professional
conduct during routine operation and the ability to effectively
control unplanned events.
Inspection results and the licensee's good performance during
the refueling outage demonstrated that administrative controls
were well applied to outage activities including training,
staffing, supervision, and planning.
A major strength relates to the licensee's selection and staffing
of operations and support organizations including key advisory
personnel.
Oversight functions have been adequately staffed
and effectively utilized in the evaluation process of
operational activities and plant events.
These activities
include:
Onsite Review Committee (ORC), Independent Safety
Engineering Group (ISEG), Senior Operations Advisory Panel
(SOAP), Operating Advisors (0A), Compliance, and Quality
l
Assurance (QA).
Observation of group performance and
individual discussions with group members show them to be
dedicated and capable people who are responsive to industry
and NRC activities.
!
During the previous assessment period (SALP 5) NRC expressed
concerns regarding the excessive number of reactor trips and
other reportable events.
The licensee has been responsive in
this matter.
Inspections have found that the licensee has
continually provided a high degree of attention and resources
to the area of unplanned events, not only in evaluating them
but also in instituting corrective and preventive measures to
preclude their recurrence.
In September 1985, the licensee
implemented a Plant Trip / Incident Reduction Program.
This
program included a seven member team to assess plant events,
determine root and contributing causes, and recommend corrective
measures.
An overall reduction in both the number of events
and reactor trips indicates that the licensee has been effective
in this effort, most notably during the last half of this
assessment period.
Notwithstanding the favorable trend, the
number of recent events attributed to personnel errors is
considered high resulting in LERs and in the Technical
Specification violations discussed in Section A., Plant
Operations.
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The licensee's Site QA Organization is professionally organized
and staffed.
The QA audit and surveillance programs are well
defined and effectively implemented.
QA engineers provided
extensive surveillance coverage (including off-shifts and
weekends) during the refueling outage, startup, and power
ascension periods.
NRC inspection has determined that the
site QA is functionally independent and assertive and has
been effective in the identification and resolution of quality
concerns. Management's support of QA activities has been
evident.
2.
Conclusion
The licensee is rated Category 2 in this area.
This area was
rated Category 2 in the previous assessment period.
3.
Board Recommendations
None.
J.
Licensing Activities
1.
Analysis
During the current rating period, the primary licensing
activity involved the resolution of license conditions which
remained from the full power license issuance and the completion
of licensing actions relating to first cycle operations and the
approval of Reload 2 for cycle 2 operation.
The licensee's management has participated in licensing
activities and has assured timely response to the staff's
requirements.
In particular, the UE management has been
actively involved in major licensing activities such as the
Cycle 2 reload that they considered to be a critical path item
for the UE operational schedule.
UE is generally aware of NRC requirements and usually provides
the staff with adequate technical information to resolve staff
concerns.
However, on two occasions during the first half of
this rating period licensing actions were delayed by deficient
"no significant hazards considerations" analyses provided by UE
in support of amendment requests.
The basis for this appraisal was the licensee's performance in
..
support of amendment requests and responses to generic letters
which have been reviewed and evaluated by the staff during the
rating period.
The subjects involved include the following:
!
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Generic Reviews:
Plant Specific Reviews:
Reactor Trip System
Enrichment Increase in Spent
Reliability (B-80)
Fuel Pool (Amendment 12)
Detailed Control Room
Fire pump Diesel Inspection
Design (F-71)
(Amendment 11)
Post-Trip Review (B-85)
Surveillance Interval
Safety Parameter Display
Extension (Amendment 8)
System (F-09)
Deletion of Fuse Testing
(Amendment 9)
Low Temperature Overpressure
Protection
Organization Change
(Amendment 10)
Revised Value of Pa
(Amendment 13)
Quality Systems Department
Change (Amendment 14)
Reload for Cycle 2
(Amendment 15)
Fuel Drop Accident Inside
Containment
Low Temperature Over Pressure
Circuitry
Use of Code Case N416
Extension of Performance on
Type C tests
During the present rating period the licensee's management
demonstrated active participation in licensing activities
and kept abreast of current and anticipated licensing actions.
In addition, the management's involvement in licensing
activities assured timely response to the requirements of the
Commission's rules related to Environmental Qualification of
Electrical Equipment and license conditions related to Detailed
Control Room Design Review, Emergency Response Capabilities,
The implementation schedules
have been met by the licensee and their submittals have
generally been of high quality and have not required
significant rework to satisfy staff requirements.
UE management was particularly effective in assuring that high
quality submittals were provided to the staff during the
preparation and review of the UE's reload submittal for Cycle 2
operation. The submittal was timely and more than usually
complete. UE requested a pre-review meeting with the staff in
order to facilitate their submittal and our review.
.
The licensee's management and its staff have demonstrated sound
technical understanding of issues involving licensing actions.
Their approach to resolution of technical issues has demonstrated
extensive technical expertise in all technical areas involving
.
_ _ _
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f
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licensing actions. The decisions related to licensing issues
have routinely exhibited conservatism in relation to significant
safety matters. The licensee's clear understanding of the staff's
concerns assured sound technical discussions regarding
resolution of safety issues.
UE is generally aware of NRC requirements and their licensing
submittals usually provide the staff with the information needed
to complete its review without extensive requests for additional
information.
On two occasions the staff was unable to prepare a "no significant
hazards consideration" (NSHC) finding related to a UE amendment
request because the NSHC analysis provided by UE was deficient.
In both cases the required notice to the public was delayed
while UE was requested to provide by A NSHC analysis that
satisfied the requirements of 10 CFR 50.91(a)(1).
The licensee has been generally responsive to NRC initiatives.
During the rating period, they have made efforts to meet the
established commitments as illustrated by their response to
TMI action items I.D.1.2, and to the rules related to
environmental qualification of safety-related electrical
equipment.
In several subject areas the licensee responded
in a timely and thorough manner.
In response to NRC requests
and suggestions related to the staff's review of generic issues
and license amendment requests, the requested information
was usually provided quickly and was adequate to allow
the staff to resolve the issue promptly.
All scrams were promptly corrected and reported to the NRC
Operations Center.
2.
Conclusion
,
l
The licensee is rated Category 2 in this functional area.
!
The licensee has been responsive and technically competent in
pursuing its licensing activity during this SALP rating period.
Concerns relative to the "no significant hazards consideration"
l
findings during the first half of this period appear to have
i
been resolved.
The rating for the last SALP was Category 1.
3.
Board Recommendations
!
[
None.
i
K.
Training and Qualification Effectiveness
1.
Analysis
Resident and regional inspectors have evaluated training and
qualification effectiveness during inspection of specific
program areas.
In addition, an inspection was conducted to
'
.
.
.
evaluate the effectiveness of the licensee's licensed and
'
non-licensed personnel training programs.
No violations
were identified.
During inspections of licensee activities personnel were
knowledgeable and effective in implementing their duties.
l
Training appeared to be well planned and adequately presented.
In cases where abnormal incidents had occurred at the plant,
the licensee prepared an Incident Report (IR).
The licensee's
review of the event in the IR not only evaluated whether
personnel error contributed to the event, but in the cases
where it did, the licensee also evaluated the cause of the
personnel error.
This evaluation included an assessment of
whether the training program had been effective or could have
contributed to the cause of the event.
In all cases, completed
irs were forwarded to the Training Department for independent
evaluation to determine if the formal training program could
be improved to prevent a recurrence of the incident.
In
addition, the Training Department was conducting evaluations of
licensee LERs, INP0 SOERs, and NRC inspection report findings
to determine if improvements could be made to the training
program.
The licensee had developed a program whereby personnel can
suggest modifications to the training program based on their
first hand field knowledge.
In addition, training department
instructors conducting licensed operator training were required
,
to stand one watch per month as part of their regular duties.
Overall, the licensee appeared to have a good method for
operational feedback into the training program.
For the maintenance groups, the training program appears to
have been well defined and implemented with dedicated resources
and a means provided for feedback of experiences.
Inadequate
training could only rarely be traced as part of the cause of
events occurring during this rating period.
The licensee's training program provided several means of
disseminating information related to incidents and recent
events; however, the training program was not as effective in
providing training on plant modifications prior to the
modification being declared operational.
In addition, the
licensee's recordkeeping of training related records was
fragmented, with required readings and OJT completions being
documented in one department, formal classroom training was
l
documented in the Training Department, and old test results
were microfiched and kept by the Document Control Department.
i
l
During the assessment period, examinations were administered to
six Senior Reactor Operator and one Reactor Operator applicants.
The overall pass rate was 86%.
This passing rate exceeds the
overall nc.tional average passing rate.
During the last
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e
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assessment period, the pass rate was also above the national
average.
Based on these results, the operator license training
program at Callaway was very effective.
In addition to adequate technician and general employee
training programs, radiological controls special radiation
protection training programs were implemented for maintenance
workers, contract radiation protection technicians,
decontamination workers, and outage work groups.
A 36-month
apprentice training program was developed to allow plant
helpers to qualify as Assistant Radiation-Chemical
Technicians specializing in radiation protection, chemistry,
or radwaste. The licensee's radiological training and
qualification program is well defined and implemented and is
comprehensive in terms of the workers encompassed.
The licensee has completed INP0 accreditation of all training
programs subject to accreditation.
These programs are
non-licensed operator, control room operator, senior control
room operator, shift technical advisor, instrument and control
technician, mechanical maintenance personnel, electrical
maintenance personnel, radiological protection technician,
chemistry technician, and onsite technical staff and managers.
The licensee was the third utility in the nation to complete
INP0 accreditation of all subject areas.
In cases where the NRC recommended improvements to a training
course, the licensee was very responsive in modifying the
content of lesson plans to address NRC concerns.
2.
Conclusions
The licensee is rated Category 1 in this functional area.
This is based on the licensee's timely completion of INP0
accreditation in all training categories and the excellent
feedback program setup to improve the training program based
on operational events.
This functional area was not rated
separately in previous SALPs.
l
3.
Board Recommendations
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None.
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V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
During SALP 6, assessment period June 1, 1985 through May 31,
1986, the following significant licensee activities occurred.
The plant was in its first refueling starting on February 28, 1986.
The plant resumed operation on April 15, 1986.
The Linion Electric Company training program became the third utility
to become fully accredited by INPO.
On May 19, 1986 the plant was shutdown to repair a S/G feedwater
check valve and was restarted on May 25, 1986.
B.
Inspection Activities
The inspection program at Callaway consisted of routine resident
and region based inspections including inspections of the outage
activities of the first refueling.
Inspection Reports Nos. 85015-85019
Inspection Reports Nos. 85021-85024
Inspection Reports Nos. 86001-86010
Inspection Reports Nos. 86012-86014
Table 1
Enforcement Activity
Number of Violations in Each Severity Level
Functional Areas
I
II
III
IV
V
l
--
--
--
A.
Plant Operations
--
B.
Radiological Controls
--
--
--
--
C.
Maintenance
--
--
--
--
--
i
D.
Surveillance
--
--
--
--
--
E.
Fire Protection
--
--
--
--
--
F.
--
--
--
--
--
'
G.
Security
--
--
--
--
,
H.
Outages
--
--
--
--
--
l
-.
_
-____.
!
.
Functional Areas
I
II
III
IV
V
I.
Quality Programs and
Administrative Controls
--
--
--
--
--
J.
Licensee Activities
--
--
--
--
--
K.
Training and Qualification
Effectiveness
--
--
--
--
--
TOTALS
0
6
C.
Investigations & Allegations Review
There were four allegation files opened.
Subsequent inspections of
the allegations did not identify any violations or deviations.
1.
An anonymous allegation was received that several improper
security practices were being allowed.
Inspection did not
substantiate any of the allegations.
2.
A former contractor employee alleged that some magnetic
particle tests were improperly performed.
Inspection could
not substantiate the allegation.
3.
An anonymous allegation was received by the Office of
Inspection and Enforcement regarding drug use by specific
names of prior employees of a licensee contractor.
This
information was forwarded to the licensee to investigate.
Followup inspection determined that the licensee received
the information and reviewed it in the context of their
drug policies and construction programs, and concluded there
was no evidence to substantiate the allegations against
individuals or to question the integrity of safety-related
construction.
4.
An anonymous letter was received by the Office of Inspection
and Enforcement with concerns over new security restrictions.
The licensee was notified of a concern received from an employee,
and review by safeguards inspectors found that the security
actions referred to were appropriate.
D.
Escalated Enforcement
1.
Civil Penalties
..
,
No civil penalties were issued.
2.
Orders
No orders were issued.
i
, -.
-
-
_ - - - - - -,. _
_,. _ - - - - - _ - - -,
-. _.
-_
. -.
. --
.
.
E.
Management Conferences Held During the Appraisal Periods
August 28, 1985, Management meeting with representatives of the
Union Electric Company to present the Systematic Assessment of
Licensee Performance Report (SALP 5) for the Callaway Plant.
February 5,1986, Licensee presentation on trip reduction program
and Quality Systems Department.
April 9-10, 1986, Management plant tour and meeting with licensee
management regarding actions which were taken as a result of the
recent threat against the plant.
Region III management toured the
plant and met with licensee personnel before the conclusion of the
first refueling outage.
In addition, potential violations regarding
equipment not environmentally qualified were discussed.
June 3, 1986, Management meeting and enforcement conference to
discuss the inadvertent isolation of the intermediate head injection
system.
June 10, 1986, regional managemer.t toured the site. The
licensee presented their findings and actions regarding an error
which blocked auxiliary feedwater initiation signals on main
feedwater pump trip.
F.
Confirmation of Action Letters (CAls)
There were no Confirmatory Action Letters issued during this
assessment period.
G.
Review of Licensee Event Reports, and 10 CFR 21 Reports Submitted
by the Licensee
1.
Licensee Event Reports
During SALP six assessment period, June 1, 1985 thru May 31,
1986, there were 45 Licensee Event Reports submitted.
These
events constituted LERs 85-25 thru 85-54; 86-01 thru 86-15.
An evaluation of the content and quality of a representative
sample of the Licensee Event Reports (LERs) submitted by
Callaway 1 during the June 30, 1985 to May 31, 1986 Systematic
Assessment of Licensee Performance (SALP) period was performed
using a refinement of the basic methodology presented in
The results of this evaluation indicate that
Callaway 1 has an overall average LER score of 9.0 out of a
possible 10 points, compared to a current industry average
score of 7.8 for those units / stations that have been evaluated
.
to date using this methodology.
NRC rated Callaway LERs as
the best in the nation.
l
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--
,
_
, _ - -, - -, - -,. -,, - -
,.., - - -. -,,,. - -,,
.
f
.
A
A strong point for Callaway 1 LERs is that the root cause
information for most events is discussed very well as is the
mode, mechanism, and effect of failed components.
Callaway's LER scores are indicative of an apparent commitment
to provide LERs that meet the requirements of 10 CFR 50.73(b).
LERs BY CAUSE
Total June 1, 1985
Cause*
to May 31, 1986
Personnel Error
Equipment Failure
Design
Procedure
_2
TOTAL
- Cause assigned by the licensee
The total of 45 LERs is an improvement over the 74 LERs issued
in the previous SALP period; however, the proportion of LERs
attributed to personnel errors went from 33.7% to 57.7%.
This
resulted mostly from a corresponding reduction in equipment
failure LERs from a proportion of 54% to 33%. Overall,
continued reduction in the number of LERs appears feasible
with most improvement to be made in reducing personnel errors.
2.
Part 21 Reports
There were no 10 CFR Part 21 reports submitted by the licensee
in this assessment period.
H.
Licensing Activities
1.
NRR/ Licensee Meetings
To Discuss Reload 2
12/05/85
To Discuss low-temperature over pressure
protection system
11/07/85
2.
NRR Site Visits / Meetings
Training to obtain unescorted access and
06/24/85 &
meeting with resident inspector
08/28/85
Site Tour with regional personnel to discuss SALP
report and meeting with resident inspector
04/29/86
3.
Commission Meetings
NONE
!
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.
'
4.
Schedular Exemptions Granted
NONE
5.
Reliefs Granted
NONE
6.
Exemptions Granted
NONE
7.
License Amendments Issued
Amendment 8
Extension of initial 18 month
10/03/85
surveillance interval
Amendment 9
Deletion of resistance testing of
11/19/85
certain fuses
Amendment 10
Revision to unit organizational
11/19/85
chart
Amendment 11
Revision to fire pump diesel engine
01/22/86
surveillance requirement
Amendment 12
Spent fuel pool enrichment limit
01/24/86
. Amendment 13
Revised value of Pa
03/04/86
Amendment 14
Quality Systems Department
03/04/86
organization
Amendment 15
Reload 2
04/04/86
8.
Emergency Technical Specification Changes
NONE
9.
Orders Issued
NONE
10.
NRR/ Licensee Management Conferences
NONE
.
.
.
..
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