IR 05000483/1986016

Insp Rept 50-483/86-16 on 860601-0731.No Violation or Deviation Noted.Major Areas Inspected:Regional Requests, Allegation,Previous Insp Findings,License Conditions & Radiological Emergency Response Drill

ML20203K330
Person / Time
Site:	Callaway
Issue date:	08/15/1986
From:	Forney W, Lerch R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203K328	List: IR 05000483/1986016 ML20203K325
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.E.4.2, TASK-2.K.3.01, TASK-2.K.3.05, TASK-2.K.3.10, TASK-2.K.3.12, TASK-TM 50-483-86-16, GL-85-05, GL-85-06, GL-85-07, GL-85-13, GL-85-14, GL-85-22, GL-85-5, GL-85-6, GL-85-7, NUDOCS 8608200205
Download: ML20203K330 (9)

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U. S. NUCLEAR REGULATORY COWilSSION

REGION III

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Report N /86016(DRP)

Docket N License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Plant, Unit 1 Inspection at: Callaway Site, Steedman, M0 Inspection Conducted; June 1 through Jony 31, 1986 Inspectors: B. H. Little C. H. Brown y M

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Approved By: W L y, ief P[.dP 6 Reactor Projects Section 1A Date'

Inspection Summary Inspection on June 1 through July 31, 1986 (Report No. 50-483/86016(DRP))

Areas Inspected: A routine, unannounced safety inspection by the resident inspectors and one region based inspector of generic letters, regional requests, allegation, previous inspection findings, license conditions, radiological emergency response drill, TMI action plan requirements, maintenance, monthly surveillance, ESF system walkdown, and operational safet Results: No violations of NRC requirements were identified during the course of this inspectio I

8608200205 860815 PDR ADOCK 05000483 G PDR

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DETAILS

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1. Persons Contacted D. F. Schnell, Vice President, Nuclear ~

S. E. Miltenberger, General Manager, Nuclear Operationc

• G. L. Randolph, Manager, Callaway Plant

C. D. Naslund, Manager, Operations Support A. P. Neuhalfen, Manager, Quality Assurance J. D. Blosser, Assistant Manager, Operations & Maintenance

• J. R. Peevy, Assistant Manager, Technical Services P. T. Abbleby, Assistant Manager, Support Services W. F. Powell, Assistant Manager, Materials M. E.. Taylor, Superintendent, Operations D. E. Young, Superintendent, Maintenance W. R. Robinson, Superintendent, I&C R. R. Roselius, Superintendent, Health Physics

V. J. Shanks, Superintendent, Chemistry J. A. Ridgel, Superintendent, Radwaste G. J. Czeschin, Superintendent, Planning & Scheduling W. H. Sheppard, Superintendent, Outages t

J. M. Price, Superintendent, Training G. R. Pendergraff, Superintendent, Security

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• J. V. Laux, Superintendent, Technical Support

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J. E. Davis, Superintendent, Compliance

D. W. Capone, Manager, Nuclear Engineering W. R. Campbell, Assistant Manager, Nuclear Engineering A. C. Passwater, Superintendent, Licensing T. H. McFarland, Superintendent, Design Control R. D. Affolter, Superintendent, Systems Engineering

> *B. K. Stanfield, Engineer

• W. R. Bledsoe, Engineer

• W. C. Jessop, Senior Training Supervisor i * Denotes those present at one or more exit interviews.

I In addition, a number of equipment operators, reactor operators, senior

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reactor operators, and other members of the quality control, operations, j maintenance, health physics and engineering staffs were contacte . Generic Letters (92703)

j The following generic letters were reviewed for the appropriateness of

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the licensee's review and response.

. (Closed) Generic Letter 483/85005-HH

Inadvertent' Boron Dilution

Events. This generic letter.was-issued to provide the. staff position

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regarding the need for upgrading the instrumentation for detection of

boron dilution events in operating reactors. This was issued for i information only. The licensee reviewed the letter and determined

! that the plant has a boron dilution system which is described in FSAR,

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, Section 7.6.12 and has appropriate technical specifications. The staff noted that many plants do not have a positive alarm to alert the operators to boron dilution events. The inspector determined that the installed system provides an alarm for the operator (Closed) Generic Letter 483/85006-HH: Quality Assurance Guidance for-ATWS Equipment That is Not Safety-Related. This letter, dated April 15, 1985, issued quality assurance (QA) guidance for non-safety-related

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equipment encompassed by 10 CFR 50.62, the ATWS rule,.and required that the licensee develop and submit a proposed schedule for meeting the rule within 180 days. The licensee submitted a letter (NRC-1189) within 180 days dated October 14, 1985 from Donald F. Schnell to Harold R. Denton which identified a Westinghouse Owners Group Topical Report, WCAP-10858,

"AMSAC Generic Design Package". This topical report presents designs for ATWS Mitigating System Actuation Circuitry (AMSAC) and was submitted to the NRC for review. The licensee committed to implementing AMSAC at the third refueling outage pending staff review of the AMSAC generic design packag (Closed) Generic Letter 483/85007-HH: Implementation of Integrated Schedules for Plant Modifications. This letter transmitted a survey form regarding the creation of an. Integrated Living Schedule for NRC required plant modification The letter was distributed to licensee management for review and respons Based on the low number of NRC required modifications to be implemented and reservations about the schedule implementation, the licensee determined there was little applicability for Callaway and decided not to respond to the generic lette No formal response was made; however, this decision was transmitted to the NRC staff by telephone. The staff finds this response to be acceptabl (Closed) Generic Letter 483/85013-HH: Transmittal of NUREG-1154 Regarding the Davis-Besse Loss of Main and Auxiliary Feedwater Event, issued for information only. The licensee reviewed this letter for plant operability and identified seven areas for review by the appropriate departments. Five of the seven reviews are reported complete.' The inspector reviewed training records which indicated that NUREG-1154 was circulated to operators and Davis-Besse lessons were included in rite training as specified in the generic lette (Closed) Generic Letter 483/85014-HH: Commercial Storage at Power Reactor Sites of Low Level Radioactive Waste Not Generated by the Utilit This letter was reviewed by the licensee and determined to be not applicable to the site. No response was require (Closed) Generic Letter 483/85022-HH: Potential for Loss of Post-LOCA Recirculation Capability Due to Insulation Debris Blockage. No response or specific action is required by this letter; however, the licensee has distributed it for review. Due to the complexity of the issue, the licensee has initiated an engineering evaluation of insulation for use as guidance in the conduct of 10 CFR 50.59 review The licensee review meets the suggested action of the generic letter.

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In addition, the inspector reviewed licensee handling of generic letters

. on-site. Generic letters are received and distributed at corporate headquarters in St. Louis. The licensee has files on-site of generi letters forwarded for on-site review. The generic letters are reviewed, circulated for information or comments as appropriate, comments forwarded to headquarters and the on-site action closed based on headquarters revie Site control of generic letters is maintained by a lo Per telecon wi+.h licensee headquarters personnel, generic letters and responses aie controlled via a lo No violations or deviations were identifie . Followup on Regional Requests (92701) Licensee Plans for a low Level Radioactive Waste Storage Facility Region III requested by memorandum that the licensee be asked about their intentions to build a low level waste storage facility; the licensee was asked about plans for such a facilit Based on conversation with licensee management, the 1.icensee does not have an on-site low level waste storage facility and does not plan to build on Use of Licensed Reactor Operators in Supervisory Positions Callaway Plant Administrative Procedure APA-ZZ-00010, " Conduct of Operations," and Operations Department Procedure ODP-ZZ-00001, " Code of Conduct," designates individuals authorized to assume the control room command function. This command function is assigned to the shift supervisor (SS). During the absence of the SS from the control room (while in Mode 1 through 4) the operating supervisor (0S) is designated to assume the command function. Both the SS and .

OS are required to have valid senior operator (SRO) license l The inspector determined that the licensee's procedures clearly establish that command functions are restricted to individuals having a SRO license while in Modes 1 through 4, and that the procedures are in agreement with Technical Specifications, Section 6.2.2 (unit staff).

No violations or deviations were identifie . Followup on Allegation (99014)

(Closed) Allegation 483/86052: Allegations were received by the NRC which were made under oath naming individuals employed by a contractor ;

at the site. The allegations were forwarded to the licensee and the l contractor for review. The contractor's review determined that none of the individuals has worked at Callaway since mid 1983. The licensee concludes that no evidence to substantiate the allegations against individuals or to question the integrity of safety-related construction exists based on the following factors:

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, Use, sale or possession of illegal drugs on the job site has been strictly prohibited throughout the life of the projec Termination has been used against personnel-identified of suspected drug use on or off the sit l Unannounced searches, using drug-sniffing dogs, have been used which found only small amounts of marijuana not traceable to individual The plant received a multi-layed inspection by craftsmen, craft foremen, and quality control with additional oversight by engineering, quality assurance, and_ special audits and inspections, Extensive preop testing and 1 1/2 years of operation have '

demonstrated sound construction, and systems operabilit The contractors continuing policy and action taken t'o ensure that their employees remain aware of this polic Based on the NRC review of the licensee's review and conclusions regarding the allegation and the absence of any evidence of faulty work performance, this allegation was not substantiated and is considered ,

close No violations or deviations were identifie . Licensee Actions on Previous Inspection Findings (92701)

(Closed) Open Item (483/85003-03(DRSS)): The licensee's initial drill to demonstrate the augmentation of the Interim-Emergency Operations Facility (EOF) failed to meet response time goals. On April 29, 1986, the licensee performed a callout drill which included the onsite,-Interim-EOF, corporate, and public information emergency organizations.- The inspector participated in the callout drill, reviewed the drill critique and discussed results with licensee emergency preparedness personne The inspector determined that the licensee has successfully demonstrated j Interim-EOF augmentation. Corrective action has been taken for the minor deficiencies noted during the onsite and corporate callout.-

No violations or deviations were identifie . Inspection of Licensee Condition (94300)

(Closed) License Condition C.(12): Callaway Plant Operating License-NPF-30, Condition C.(12) relates to equipment modifications to the residual heat removal system (RHRS) which concern low temperature overpressure protection (LTOP); e.g., specifically the addition o an alarm circuit to the RHRS suction valves 8702A and 8701B. The modification'was made to provide assurance that' the RHRS ~ is properly-isolated from the reactor coolant system pressure when the plant is returned to operating pressure. The inspector,'through inplan inspection and quality records review, determined that the specified i i

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equipment modification was completed and functionally tested during the Cycle 1 refueling outage. The work was accomplished under Callaway Modification Package (CMP) No. 85-0383 and associated Work Requests (WRs).

The alarm circuit was functionally tested to procedure ETP-ZZ-ST01 The inspector reviewed the Annunciator Response Procedure (OTA-RL-RK049) and determined that the procedure had been appropriately revised. Through questioning of crew members, the inspector determined that the modification had not been included as a " required reading" training item. This matter was brought to the licensee's attentio The licensee determined that failure to include the modification as required reading resulted during the changeover from manual to computer tracking of required readin The licensee has included this item as required readin No violations or deviations were identifie . Radiological Emergency Response (RER)

The inspectors observed the licensee's preparations for and performance during the annual RER field exercise. The inspection included inspector's participation in two accountability drills and observations during pre-field exercise training and shift crew performance at the simulator (control room) during the field exercis During a pre-exercise training drill, the inspector questioned crew members regarding core cooling instrumentation. The crew members were knowledgeable of the appropriate reactor vessel level instruments to use during no coolant flow condition The inspector noted that the control board labels identified the level instruments by number, while the emergency operating procedure referred to the instruments as " wide range" and " narrow range". The adequacy of the existing instrument labels was discussed with the licer.:ss. The licensee acknowledged the potential for use of the non-valid level instrument during off normal plant conditions and have issued a " Request for Resolution" to add " pump on" and " pump off" label The inspector's observations of crew performance during the field exercise are included in NRC Inspection Report No. 8601 No violations or deviations were identifie . Inspection of TMI Action Plan Requirements (92705)

This inspection concerned licensee actions relative to TMI Action Plan Requirements developed by the NRC as a result of the Three Mile Island (TMI) Unit 2 accident. These requirements were contained in NUREG-0737,

" Clarification of TMI Action Plan Requirements," and were assigned item numbers for identificatio Completion of certain licensee actions required by the TM1 Action Plan line items reviewed during this inspection was previously verified by NRC inspection personnel. This inspection waL conducted to establish a correlation between individual items (by number and title assigned in

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NUREG-0737) and the NRC Inspection Reports which document these verification This inspection was also conducted to supplement previous inspections conducted to verify completion of required action The staff findings, as documented in the Callaway Safety Evaluation Report (SER)

NUREG-0830 and four supplements, are included in some of the item The following TMI Actions are considered clo.ed:

II.E 4.2, Containment Isolation Dependabilit The licensee was to perform verification of the containment isolation dependability and evaluate the setpoints that provide isolatio The ganged reopening of containment valves, if any, was to be modified to valve-by-valve open basi In Section 22.2 of the Callaway SER (NUREG-0830) the staff determined that the diversity of the signals that isolate the containment meet the requirements of this ite The containment pressure setpoints justification as minimum for operation was subc'itted with the Technical Specifications and determined to be acceptable to the staf The staff concluded that the containment isolation system complies with the requirement for containment purge and vent valve isolation on a high radiation signal. The reopening of the isolation valves is being performed by a valve-by-valve or line-by-line basi II.K.3.1, Installation and Testing of Automatic Power-Operated Relief Valve Isolation System: The requirement was for the licensee to evaluate and install a system that would automatically close the block valve if the PORV stuck ope The Callaway design included the capability to automatically isolate the power-operated relief valve (PORV), on low reactor pressure; but the evaluation indicated that the use of the auto feature should not be necessar II.K.3.5, Automatic Trip of Reactor Coolant Pumps During Loss-of-Coolant Accident (LOCA): The licensee was to provide an evaluation of a reactor coolant pump trip with a loss-of-coolant accident while evaluating other solutions to a small-break LOC The Owners Group evaluation has shown that an automatic trip of the reactor coolant pumps is not necessary at the present time, as sufficient time is available to trip the pumps manuall Design modifications are therefore not being considered at the present tim II.K.3.10, II.K.3.12, Proposed Anticipatory Trip Modification: The licensee was to perform a probability study of small-break loss-of-coolant ~

accident resulting from a stuck-open PORV and whether or not it would be affected by an anticipatory trip; II.K.3.12, Confirm Existence of Anticipatory Reactor Trip Upon Turbine Trip: The licensee was to confirm the anticipatory reactor trip when the turbine was tripped. (The following response relates to II.K.3.10 and II.K.3.12.)

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The plant has a anticipatory reactor trip from a turbine trip when

, operating above 50% power (this trip setpoint is adjustable). The 50%

setpoint.is the capacity of the steam dump valves to the condenser. The actuation of the steam dumps up to 50% power will maintain the reactor

. pressure below the PORV setpoint; therefore, the loss-of-coolant accident from the valve stuck open should not occu The analysis performed by the licensee of the steam dumps not functioning on a turbine trip with reactor power less than 50% indicated that in the band of 0 to 35 or 40% power, the pressurizer sprays would maintain pressure below the PORV setpoint as well as the higher setpoints of the pressurizer atmospheric relief valve The capacity of the atmospheric steam relief valves is about one-half of the steam dump system. Above the 35% to 40% and up to the turbine trip-reactor trip setpoint (approximately 50%) the pressurizer PORVs would open to maintain reactor pressure with associated loss-of-coolant and also the possibility of a stuck open valve. The results of the evaluation showed the probability for the plant to be operating between 35% to 50% power and have a loss of condenser vacuum (turbine trip - no reactor trip and steam dump valves inoperable) is less than one time during the life time of the plan No violations or deviations were identifie . Monthly Maintenance (62703)

Selected portions of the plant maintenance activities on safety related systems and components were observed or reviewed to ascertain that the activities were performed in accordance with approved procedures, regulatory guides, industry codes and standards, and that the performance of the activities conformed to the Technical Specifications. The following items were 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 used were properly certified; radiological controls were implemented as necessary; and, fire prevention controls were implemente No violations or deviations were identifie . Monthly Surveillance (61726)

The. inspectors reviewed or observed selected portions of the Technical Specifications required surveillance testing during power operation Items which were considered during the inspection 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 inspector determined that the test results were reviewed by someone other than the personnel involved with'

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the performance of the test, and that any deficiencies identified during the testing were reviewed and resolved by appropriate management personne No violations or deviations were identifie . ESF System Walkdown (71710)

The operability of selected engineered safety features (ESF) was confirmed by the inspectors during a walkdown of the accessible portions of the system. The following items were included: procedures match the plant drawings, equipment conditions, housekeeping, instrumentation and valve and electrical breaker lineup status (per procedure checklist);

locks, tags, jumpers, etc. are properly attached and identifiable. The following systems were walked down during this inspection perio * The Emergency Diesel Generator System

• Station Battery No violations or deviations were identifie . Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs, and conducted discussions with control room operators throughout the inspection perio The inspector verified the operability of selected safety related systems, reviewed tagout records, and verified proper return to service of affected components. Tours of the reactor, auxiliary, and turbine buildings were conducte During these tours, observations were made relative to plant equipment conditions, fire hazards, fire protection, adherence to procedures, radiological control and conditions, housekeeping, security, tagging of equipment, ongoing maintenance and surveillance, containment integrity, and availability of safety related equipmen No violations or deviations were identifie . Exit Interview (30703)

The inspector met with licensee representatives (denoted under Persons Contacted) at intervals during the inspection perio The inspector summarized the scope and findings of the inspection. The licensee representative acknowledged the findings as reported herein. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspectio The licensee did not identify any such documents / processes as proprietar