IR 05000483/1987001

SALP Rept 50-483/87-01 for June 1986 - May 1987

ML20236V545
Person / Time
Site:	Callaway
Issue date:	08/06/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236V527	List: IR 05000483/1987001 ML20236V524 ML20236V539
References
50-483-87-01, 50-483-87-1, NUDOCS 8712040366
Download: ML20236V545 (27)

Text

.

)

.

'

,I

.-

,

h

SALP 7

!

i

.I

.)

SALP BOARD REPORT

a

]

'

NUCLEAR REGULATORY COMMISSION

.

i l

REGION III

l

-

I J

.

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

.

50-483/87001 Inspection Report No.

Union Electric Company

.

..

Name of Licensee

~l

,

..

'1 Callaway Plant Name of Facility i

June 1. 1986 through May 31, 1987 i

Assessment Period

.

.

I B712040366 871118"i PDR ADOCK 0500

'

_ _ _ - - - _ _ _ _.

.

-.

SUMMARY OF RESULTS

. The regulatory performance of the Callaway Plant is very' good. Although

~

the rating in the surveillance area declined, performance improved from Category 2 to Category I ratings in four functional areas.

In addition to these, plant operations showed an improving trend toward the end of; this assessment period.

'

Rating Last Rating This-H Functional Area Period Period A.

Plant Operations.

2 B.

Radiological Controls

2 C.

Maintenance

1 l

D.

Surveillance

2 E.

Fire Protection

N/R*

l F.

Emergency Preparedness

1

';

l G.

Security

1

'

'

H.

Outages

1

1.

Quality Programs and

1

-

Administrative Controls Affecting Quality J.

Licensing Activities

1

,

K.

Training and Qualifica' tion

1

-

Effectiveness l

l

• Not rated this assessment period due to limited inspection in this area

'

during the period.

.

-

I i

I l

t

l

.

>

=

x

-\\

)

y

. IV. HRFDEE ANALYSIS A.

let Operations

'

.L Analysis j

Evaluation of this functional area was based on the results of"

routine' inspections by res,ident'and region-based inspectors.

j

.

.

Enforcement history in this area indicated improvement.in.

l performance. During this ar,sessment period one Severity Level IV

.

violation was identified. This violation did not indicate any major weakness in performance and did not'have major safety.

significance. During the previous assessment period, one _

Severity Level IV violation was identified, as well as a Severity Level III violation, which resulted in a cumulative a

civil' penalty of $25,000 assessed during this period.

j

.

Operational events experienced during this assessment, period

indicate improved performance. The plant had seven reactor

'

trips over the 12-month assessment period, a number which is '

'

slightly above the industry average trip rate; however, only.

.

two reactor trips occurred during the last eight months of-

'

this assessment p'eriod. This' number is a.significant decrease-

.from the 14 reactor trips which occurred duringlthe previous assessment period.- Of the seven reactor trips, five occurred

..

between 50 and 100% power. One of these resulted_ from personnel

.

error; the others involved equipment. failures and included a

'

annually initiated trip. Of the remaining trips, one occurred-4 ring a plant shutdown (Mode 3).and involved both. equipment'

failure and personnel error, the other was an inadvertent RPS

';

actuation in Mode 5 due' to personnel. error.. The causes of the-trips were not of a repetitive nature.

Fifteen LERs were

.;

'

associated with plant operations during this assessment period

-

i and included 10 operations-related actuations of Engineered

-

Safety Features Actuation Systems (ESFAS), representing a decrease from the 20 LERs of the previous period. Of the 15 LERs, nine involved personnel error, compared to 12 during the' previous period.

A' high level of management attention and support was directed toward the overall reduction of operational events.

The licensee's improvement programs have provided comprehensive evaluations and corrective measures. These programs are discussed -

in more detail in Section I'(Quality Programs).

,

Staffing in this area was excellent. The-licensee's operating.

and support groups have been staffed with trained and qualified -

-

personnel.

Fositions and responsibilities have been clearly.

defined.

The licensee experienced various equipment and -

lwrsonnel-related problems-following the. refueling outage

SALP 6 assessment period) and during'the initial months of

,

j'

this as'sessment period; however, both: personnel and. equipment '

showed excellent performance during the last nine months. This-performance was evident in the 80% unit capacity factor, which o

. 5

.

-

_ - _ _ _ _ _ _

-_ m

,

i

-

.

-

_

'

exceeds the in' ustry average. and the.142-day' continuous 'run -

d record. This run more than doubled the' plant's previous record.-

The licensee's operating crews demonstrated'their ability to

i effectively control plant activities during operational modes _

z and one major maintenance outage. ' The control room operators

and supervisors were attentive to plarit conditions 'and displayed-a professional attitude'toward the control and operation 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 satisfactorily maintained and _ reflected current' plant and system conditions.

~

l Management involvement was very good. The' licensee' maintains j

a professional,-businesslike. atmosphere in the control room.

!

Work package processing was performed external to'the "at the controls" area.

Personal radios and reading material were prohibited _ at the plant. Control room access was limited and

-enforced. Licensee management, operation. supervision, and quality assurance personnel provided frequent in-plarrt i

observations of the shift crews' performance.

2.

Conclusions

,

Licensee performance is rated Category 2 in' this : area, with -

an improving trend. There has been an overall improvement.

H

'

in operating performance and a reduction in operational events, including reactor-trips. The licensee was rated Category 2

'

in the previous assessment.

3.

Board Recommendations

}

None

.

-.

B.

Radiological Controls

1.

Analysis Evaluation of this functional area was based on the results of four inspections performed 'during this assessment period, and the completion of an inspection from the previous period, by

<

region-based specialists and on observations by the resident i

inspectors.

.

.

i Enforcement history in this area improved since the last

'

assessment period in that' two Severity Level..IV violations l

-

were identified, compared to four Severity Level IV violations identified during the last assessment' period. These violations did not indicate any programmatic weeknesses in performance.-

The licensee's corrective actions were timely and appropriate.

g Four LERs, including one ESFAS actuation, were issued in.this.

functional area.

t

'6 y

'

- _ _ _ _ _ _ _ - _ -. _ _ _

.

. _.

i

\\

il

,

l.

' i y

,

'l i

-

Staffing generally was good. The numbers of technicians and supervisory personnel have been ample, with essentially all positions filled. The staffing has been very stable, with'

losses generally limited to internal promotions. Additionally, an adequate number of well qualified contract radiation protection technicians were utilized during the extender-maintenance outage. However, recurring minor weaknessey in

'

housekeeping, laundry, and decontamination activities appear to have resulted' from staffing, experience, and/or supe,rvision

{

weaknesses associated with the Rad / Chem helper staff; Also, a i

recent licensee budgetary decision to reduce the radiation protection staff by five positions may have a negative effect on performance, especially the reduction from two health physicist positions to one, since coverage during outages by the i

,

professional health physics staff is already strained.

'

Manag'ement involvement in chemistry, radiation protection,.

and radwaste matters was evident and adequate. New improvement, programs were instituted by management during this asessment,

period, including challenging goals for reduction of radiattor.

exposures and solid radwaste generation, a radiation protection task field-observation program, radiologically controlled crea access facility improvements, chemistry QA/QC improvements, a

,

floor area decontamination effort, and a personal cor.tamination

,

incident reduction plan.

By contrast, more effective management attention is desirable in some areas, including radiological work practice deviation reporting, the ALARA program, technician performance incentives, RWP compliance, and documentation to

)

demonstrate compliance with certain TMI Action Items.- Licensee j

'

audits and responses have been generally satisfactory.

Licensee responsiveness to NRC issues was generally acceptable during this assessment period;. exceptions include the time

_

required for compliance documentation regarding certain TMI

,

Action Items, Rad / Chem helper staff size-and relative inexperience,

and the recurrence of failures to leak test sealed sources and to maintain purge valves in the failed position when required by Technical Specifications.

Examples of good performance included radiation monitor design deficiency corrections, improvement in seal table area access control, licensee aid in resolving certain generic issues regarding radiation monitors, and compliance with comitments made to the NRC regarding the GMR-1 canister respiratory protection program.

The licensee's approach to resolution of technical issues was generally satisfactory. Personal radiation exposure' for 1986

-

was 224 person-rem, which was significantly less than the average for U.S. pressurized water reactors..However, the plant has been through only one refueling cycle; therefore, low exposure is to be expected.

It appears desirable to. improve the ALARA program in several areas, including the ALARA suggestion program, job history files, pre-job briefings, generation of ALARA computer-data, and staffing.

- _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _

p

-

--

J

\\

l t

n (s

'

y

.

y i,

'

s.

t

\\

l

k'

.

i t

,

q

.

t

.g j

.

.The number of per:;onal contaminations was somewhat high for the i

age of,thelpl Ant; however, the licenstn is making good efforts gy cs

~

s s

.,5 i

s, (<,

'to reduce.yersonal contaminations in 1987. An internal exposure

j

,

i

incident resulted in a violation for.1nadequate evaluation of i x o

<

//

airborne radioactivity for a containment entry.. The incident

,

(

alskrevealed a significant error in the licensee's whole body s

,

r i

' csnt assessment computer software.

i a

'

,

'b' '.e Liquid 2nd aseous radiological effMnts in 1986 were

'

'

J significant y greater than those for 1985, due mostly to an

'

increase M h el defects; the licensee plans to ree ve defective 3

,

.T fuel from tRe core during the scheduled September 1987 refueling *

,

'f

' t outage. The licensee corrected a situation whirh b:d resulted I

/

t

(

't in waste gas being inadvertently vented into the radwaste Aoi) din,5

'

'

'

g, y'

The solid radioactive waste volume generated in 1986 is're.ts than

<

e half of the average for U.S. pressurized water reactors, due, it.

s part/tothelicensee'sconscientioussolidradwastereduction i

progrtm. No transportation problems were identified.

?

\\

N ei The lidensee has utablished a basically sound chemistry QA/QC

i program which includes control charts, technician performance

.)

tht.) j interlaboratory comparisons of analytf[al re'sults and procefare revisions.

Chemistry supervision assessment of the' technicians' proficiency th<aproved the

.s since'the last

!j rerartit.g period. Some weaknesses were no*.edfin the program:

,

the boron analysis procedure had no control eart; many of the l

control limits on the charts were not regularly updated to j

l

/

. <

,

,

'

represent the parameters plotted on the charts, resulting in J

..

/

excessively wide control limits; the procedures do not require

,'

/

, the use of dual standard solutions to check the accuracies of

,.

y I

I the celebrations., and some instruments standardized at a

'

>

$

,

'

single point were used without verification'of straight-line

,,'I I

calibrations. The licensee addressed some of these concerns

!

,

..

and was considering additional modifications. - In the first l

. I j,

comparison tests pfNnradiological confirmatory measurements

w\\

using unknown ( tupplied by the NRC, the licensee had 11 disagreements

'

-

J(

in 36 cxparigens. ' These were reduced to five disagreements

'after repeat analyses. The disagreements were not significant

,

'

'

from e safe:y perspective.

In radiologicalgonfirmatory

%

>

meas;re'nents, the licensee's contractor laboratory had difficulties w

in obtaieng agreements with the NRC for Sr;#9 Jnd Sr-90. The t

i cth.ensee%twn laboratory has attained agreements with blind

'

iP

-

sscheck samples from a vendor and is planning further comparisons With contractor laboratories to assure the adequacy of analyticel capabilities.

f n

"-

t

-

2.

Conclusion J

d

,

\\

'

?

\\

.

,,

i Licensee perfomance was rated Category 2 in this area. Tne

..

\\

^

>

,i g licensee was rated Category 2 in the previous assessment period.

1i

<

..F

\\'

3., i g d Rerpenendations

'

>

3p I,

s None e N c

'

\\

<

r j

i

'

^

u

0

,3 u_i__n_______

. _ _ $ __ *i s

^

\\ '\\

b db a'

!

-

'

(

<

i

'

t

')

.

.

C.,

Maintenance 1.

Analysis

-

>

.

Evaluation of this functional area was based on the results of routine inspections conducted by resident and region-based i

i inspectors.

The enforcement history th this area showed a good understanding of the NRC requirements; no violations were identified in the maintenance area. This cc:npares to no violations during the last SALP period.in this area.

flanagement continued to demonstrate a high level of involvement in this functional area. This has been demonstrated through the overall effectiveness of applied resources and implemented maintenance programs.

Planning and scheduling is based on a 13-week cycle which integrates work preparation and performance

activities associated with corrective and preventive maintenance j

and testing activities. This program has been highly effective in preventing " wrong train" events, in reducing equipment down time, and in reducing equipment operation to satisfy post-maintenance / testing requirements. The program is applied to bith primary and" secondary plant systems. Management provides

,

f

• ^

frequent oversight of ongoing maintenance activities.

Curently, the licensee's preventive maintenance effort amounts

'

to approximately 25 percent of the total maintenance effort.

While the ratio of preventive to total maintenance is below the industry average, it is a result of the extended maintenance outage and the effort expended to reduce the work backlog. The work backlog of plant equipment items greater than 90 days old accounts for'Vess than 35 percent of the total work backlog,

_

which is considerably less than the industry average and indicates an aggressive maintenance program.

Approximately 1500 work items, including 43 plant modifications, were completed during the maintenance outage discussed in Paragraph H (Outages). The notable lack of required rework, low operating plant leakage rates, and satisfact ry equipment perfc. nrm e as evidenced by post-mainter.ance tes.s and post-oatage gerating history are indicators of the high quality of the Ticensee4 maintenance programs.

The license? has been responsive to NRC initiatives, as evidenced by tr.: achnvement of a control room annunciator

" black board" aheao ci schedule, by the reduction of the work request backlog from 2000 to 1400 work requests, by the reduction of radioactive contaminated areas, and by its aggressive response to IE Bulletin 85-03 (Motor Operated Valve Actuator Test (MOVAT) Program).

I

i

_ _ _ - _ _ _ _ _ _ __

l

~

!

,

l

'

.

i Four LERs, including three ESFAS actuations, were attributable.

to maintenance during this assessment period, compared to one during the previous period. One plant trip resulted from.

maintenance activities; there were no other significant operational events related to this functional area. Minor infractions and deficiencies identified by the NRC-and the l

a licensee's quality assurance, compliance, and engineering groups have been promptly reported and analyzed and have received timely resolutiori and correctiv? action.

Maintenance and supporting groups are well staffed, with authorities.and responsibilities clearly defined. The licensee has filled key positions in maintenance, planning, and I

scheduling with personnel licensed as Senior Reactor Operators.

l In addition, the licensee's training and qualification program

for i,ts maintenance staff has been effective.

I 2.

Conclusion Licensee performance is rated Category 1 in this area. The licensee was rated Category 2 during the previous assessment period. The improved rating reflects the licensee's favorable enforcement history, the involvement of licensee management, l

and the effectiveness of the licensee's maintenance programs.

l 3.

Board Recommendations None D.

Surveillance 1.

Analysis The evaluation of this area was based on the routine inspections

_

conducted by the resident inspectors and on inspections conducted by region-based inspectors.

Enforcement histor'y and operational events in this area have indicated no significant regulatory concerns. One Severity Level IV and two Severity Level V_ violations were identified in this area, compared to no violations during the previous assessment period. The licensee responded aggressively to correct and limit recurrence of these items. The violations and reportable events relating t'o missed surveillance resulted from the licensee's failure to include the components in the'

initial surveillance of the surveillance. program and the subsequent late performance The licensee review identified and reported these items and placed them in the program. When the surveillance were performed, the equipment was found operable.

The licensee's corrective action included a comprehensive review of related surveillance programs to verify that all required surveillance had been identified.

_ _ _ - - _ -

l

1 l

,1

-

Eleven LERs, including two ESFAS actuations (one reactor trip),

were attributable to this functional area during this assessment'

period. An additional trip attributable to surveillance occurred late in the assessment' period and had not' yet been reported via LER. There were three reportable events,. including two trips, identified.during.the previous assessment period.

Management involvement to assure quality in this functional'

area.was extensive. The a'ctivities were well planned, with authorities and responsibilities well defined. The management

'

involv_ement throughout a containment ~ integrated leak rate. test was above aurage. The surveillance'and maintenance programs have been integrated and provide for a smooth flow of. work.

Quality assurance audits have indicated that surveillance are-

.

'

very well managed.

Staffing is appropriate and effective. The reviews.and audits of the records have indicated that they are complete, up-to-date, and well maintained. The. personnel involved were well trained

'

and knowledgeable in' their jobs.

i The computerization of the surveillance schedule and the i

designation of a group to follow surveillance tests has essentially elimihated missed or late surveillance tests.

.

'

2.

Conclusion The licensee performance is rated Category 2 in this area.

The licensee was rated a Category 1 during the previous

assessment period. The lower rating is attributable to the increased number of reportable events and deficiencies in the initial surveillance program.

3.

Board Recommendations

.

--

None E.

Fire Protection 1.

Analysis The evaluation of the fire protection functional area was based on the results of the routine inspections and observations by the resident inspectors.

The enforcement history in this area indicated licensee performance that conformed to NRC requirements. As in the last assessment period, no violations were identified.

The management involvement to assure quality in this functional

<

area was considered to be very effective.

The fire protection j

staff is well qualified and sufficiently staffed to maintain l

a very effective program. The QA organization has been actively-

]

!J

{

u

.

,

,

.

l

.

involved in oversight of the _ fire protection program.. QA audits, and surveillance indicate very good performance in this area.

The observation of the fire brigade performance has indicated,

a high level of training and effective fire fighting procedures.

.!

)

L As observed by region-based _and_ resident; inspectors and byl

]'

L headquarters personnel, housekeeping at the plant was maintained.

<

.at a high level throughout the assessment period.

2.

Conclusion

'

The licensee was' not. rated in'this area due to limited inspection effort during the assessment' period. The licensee l

was rated Category 1 during the previous assessment period..

I 3.

-Board Recommendations None F.

Emergency preparedness

.

.

1.

Analysis One routine inspection and one_ irspection of-an_ emergency-exercise were. perfonned during the assessment period.- As in the last assessment period,-no violations were identified in either inspection. No weaknesses were identified in.the 1986

exercise, compared to two weaknesses identified during the-1985 exercise. The two areas identified as weaknesses in the 1985 exercise were successfully demonstrated in the'1986 exercise. Corrective actions on open items and other areas of concern have been timely and effective.

_

Emergency preparedness (EP) staffing was very. good and was

]

further improved when a licensed SR0 was added to the EP staff

'

during the SALP period. This addition has increased the reactor j

technology capability of the group. particularly-for scenario developmentandEmergencyActionLevel.(EAL) review.

!

Improvements have been made in the licensee's shift augmentation-I capabilities, which previously were a problem. The shift

augmentation complement is now notified in three different.

a components: the onsite emergency ~ organization, the interim EOF

!

organization, and the corporate emergency organization. This

new method, as well as callout procedure revisions and use.of a.

.

telephone answering service, have contributed to making recent

!

shift augmentation drills successful.

-

Responsiveness to NRC initiatives has been very good. Action

has been taken to clarify and/or revise over 15 EALs.as.

,

recomended by the NRC in a' previous inspection. Management j

involvement included various technical review levels for i

these proposed changes, prior to submittal to Region III as anl

-

emergency plan change. Also, as-the result of an NRC j!

'l

- _ _ _ - _ _ _ _ -

,

.

recommendation Quality Assurance now includes in its annual F review an evaluation for' adequacy of the licensee's interface with state and local governmental agencies.

mangement involvement is very good end especially evident-in a training.

Implementation of a joo ' task analysis developed ny the Training Department for EP training is scheduled for

.kne 1987. Training has been revised to include a single training session, either for two or six hours, for each EP gesition.. Formerly two or three sessions were needed to meet seautred EP training. This change should greatly improve scheduling and attendance, while still including the entire amurse lesson plan. The course deficiency file, initiated in 26. Inas now been computerized for more efficient use and'

ester. retrieval. Since September 1986 the EP group has been'.

amponsible for conducting training of offsite support agencies..

Dis 'is now possible because of the increase in EP staff to ihclude the disciplines needed to adequately present the EP pogram to these agencies.

k events occurred in the last inspection period which would twe activated the Callaway Radiological Emergency Response-Man (RERP).

,

g Dnclusion Utensee performance is rated Category 1 in this area. The Mcensee was rated Category 2 in the last SALP period. The tproved rating is attributable to increased management involvement, increased staffing for the EP training program, revised callout w ipment and procedures to meet shift augmentation requirements, ed major revisions of over 15 EALs to improve the respue i.irnes useded for an emergency.

-

.

g geord Recommendations h

'

G. WW L

halysis tweluation of this functional area was based on results of two vestine inspections conducted by region-based physical security taspectors and the inspections conducted by the resident-laspectors to routinely observe security activities.

.

The enforcement history in this area showed an improvement in licensee performance. There were no. violations or concerns identified during this assessment period, compared to one Severity Level IV violation identified during the previous SALP

>

_ __

.

j

.

assessment period. The lack of violations is attributable to the security force's high quality performance and to management's

!

involvement in security issues.

'

Management and the security force have effectively identified and resolved security issues. The licensee's security management continually reviewed the security program to identify and resolve I

potential problems before they became significant.

The licensee's review of IE Information Notice 86-91'(Limiting Access l

Authorization) was found to be acceptable. The licensee's l

Quality Assurance (0A) audits and surveillance were excellent l

and were instrumental in strengthening the security program.

There were n,o technical security issues with respect to plant safety that required resolution during the assessment period.

Security events were promptly and completely reportea to the NRC a' required. There were three events reported during this s

period which were hardware related, compared to eight during the 1:st assessment period.

The licensee properly analyzed the

,

i events and initiated. appropriate corrective actions. The licensee's approach to reporting incidents was conservative.

l The licensee's responsiveness to NRC initiatives was excellent.

l When concerns were identified, corrective actions were taken in

!

l a prompt and effective manner.

l The licensee's staffing levels amply fulfilled sccurity plan commitments. Positions and responsibilities were well defined. Training policies and procedures ensured that all personnel were well trained and qualified to perform assigned i

security-related tasks or duties and represented a significant program strength. The licensee's security staff has been

'

extremely effective in the management and implementation l _

of the security program.

I

.

2.

Conclusion Licensee performance is rated Category 1 in this area. The licensee was rated Category 1 during the previous assessment period.

3.

Board Recommendations A reduction in inspection frequency should be considered.

H.

Outages 1.

Analysis The evaluation of this functional area was based on inspections performed by the resident and region-based inspectors during the 47-day maintenance / modification outage occurring in March and

,

April,1987.

- - - - - _ - - - - - - - - - - -

- - - - - - -

-

- - _ _ -

.

.

Enforcement history indicated performance in accordance with NRC regulations. As in the last assessment period no violations-or deviations were identified in this area.

,

Management involvement to assure quality appeared to be very effective. This included extensive involvement in the pre-outage planning and scheduling and the day-to-day outage meetings. The licensee is ace nulating a data base of historical work and is now able to schedula the necessary manpower for the scheduled work more effectively. A permanent outage group was maintained to pre-schedule outages and verify availability of equipment an,d manpower. This management system resulted in a smooth outage with completion on schedule even though large unplanned items were added into the outage schedule.

Staffing was excellent, especially in radiological techniciam Advan'ce planning and sufficient coverage by contract radiological technicians. enhanced the maintenance of radiological controls.

Sufficient personnel provided supervision and training during j

the outage, and coordinators were onsite around the clock.

q Housekeeping was maintained at a high level during the outage and contributed to the high quality of maintenance performed

'

during the outage:

2.

Conclusion Licensee perfonnance is rated a Category 1 in this area. The l

l licensee was rated Category 1 during the previous assessment

'

period.

3.

Board Reconnendations None

.,

,

I.

Quality Programs and Administrative Controls Affecting Quality

-

1.

Analysis

.

!

Evaluation of this functional area was based on results of routine inspections performed by resident and region-based

!

inspectors.

'

Enforcement history in this area indicates improvement in licensee performance.

During the previous assessment period, l

one violation (use of non-environmentally qualified electrical

'

equipment) was identified; no escalated enforcement action will i

be taken for this issue.

In addition, escalated enforcement i

was taken during this assessment period for three other violations

which occurred during the previous period.

These violations j

resulted in a Severity III violation, as discussed in Section A l

(Operations). There has been no recurrence of similar violations,-

and no violation or deviation was identified in this area during

(

1

_ _ - - _ _ _ -

_

_.

.

'

,

this period. The violations discussed in Section B (Radiological

.

Controls) and D (Surveillance) are considered to be neither major, i

repetitive, nor indicative of programmatic breakdown, but do l

indicate weaknesses in the licensee's initial review and or

overview process. The violations received the licensee's prompt l

attention, thorough evaluation, and corrective action, j

l Management's high degree of attention, frequent site visits, i

and personal involvement in quality, programs have been continually j

evident at Callaway.

Both corporate and site management frequently i

met with the resident inspectors. During these meetings, the licensee has been open and forthright in discussing events,

!

problems, corrective actions, and enhancement programs.

Management's influence in this area is evident throughout the

licensee's staff. Management: continued to demonstrate a high level,of involvement in quality improvement programs.

The effectiveness of the quality improvement programs was evidenced l

by the decrease in plant trips and operating events. Management's continued involvement in training includes the assignment of

licensed senior reactor operators to supervisory positions within the training, planning, scheduling, operations, Independent Safety Engineering Group (ISEG), emergency preparedness, and maintenance departments.

Licensed reactor operators have also been placed in the Instrumentation and Control section. The maintenance training facility provides hands-on training under simulated radiological conditions. The ISEG performs comprehensive causal evaluations,

'

employing accident investigation techniques, of both plant and industry events; conclusions and reconsnendations are factored into the licensee's experience feedback program.

'

The licensee has been responsive to NRC initiatives, in most cases providing technically sound, thorough responses and acceptable resolutions.

This has been demonstrated in the

-

utility's thermal hydraulic anomaly investigation, its lead plant role for Motor Operated Valve Actuator Testing (MOVAT) and Fire Protection Technical Specification revision, and its

reduction of Engineered Safety Features actuations such as reactor trips and radiation monitoring initiated events. The licensee also achieved the control room annunciator black board objective.

Management's support of Quality Assurance (QA) activities has been evident. 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 maintenance outage, startup, and plant operating periods.

NRC inspections have determined that the site QA is functionally independent and assertive and has been effective in the identification and resolution of quality concerns. Specifically noted is QA's involvement in the emergency preparedness,

_ _ _

l i

.

)

..

security, and fire protection areas. Approximately half of the

]

QA staff has completed operator licensing-training courses or

the Shif t Technical Advisor certification training.

2.

Conclusion Licensee performance is rated Category 1 in this area. The licensee was rated Category 2 in this. area during the previous

!

assessment period. The improved licensee perfonnance in this

area-is due to the high degree of management attention to and -

personal involvement in quality programs.

3.

BoardRecom$endations None J.

Licensing Activities

=

1.

Analysis

[

,

The basis for this assessment was the staff's evaluation of the l

licensee's performance in support of licensing actions (amendment I

requests, responses to generic letters and other actions) during

!

the rating period'. These actions have resulted in eight license

!

amendments resulting in changes to the Technical Specifications I

(one amendment was issued on an emergency basis) and one exemption j

to 10 CFR Part 20, Appendix A.

Management demonstrated active participation in licensing activities and kept abreast of all current and anticipated licensing actions.

In addition, the management's involvement in licensing activities assured timely response to the Conunission's requirements related to Generic Letter 83-28.

The submittals have generally been of.high quaiity and have

_

not required significant rectork to satisfy NRC requirements.

Management involvement related to the iodine filter exemption request was extensive and showed careful planning and preparation for the complex technical issues and administrative matters involved. Concern over quality assurance related to GRM-I'

canister use was evident for both onsite and vendor. programs.

Corporate management has been an active participant in the Westinghouse Owners Group activities intended to delete unnecessary issues from the technical specifications.

In particular, Callaway volunteered to serve as a lead plant in the area of fire protection improvements to the Standard.

-

Technical Specifications.

Management and staff have demonstrated extensive technical expertise in all technical areas-involving. licensing actions.

In the review of Generic Letter 83-28, the staff noted that the licensee's direct approach enabled ready verification of the acceptability of its program.

Its submittals. indicated-

E__ _

J

_ _ _ _ _ _ _ _ _.

.

an understanding of the pertinent safety issues and permitted the staff to resolve issues without requiring significant additional information.

!

In the review of flow-induced anomalous flux variations detected

!

at Callaway, the licensee provided prompt and technically sound responses to NRC concerns related to identifying the cause of the anomalous behavior.

The licensee made a presentation to NRC management and staff regarding the flux anomalies and kept the NRC aware of the results of their investigations.

This cooperation with the staff was very helpful in allowing the staff to ass,ess the safety significance of this phenomenon.

A unique aspect of the licensee's approach to resolution of technical issues has been its interaction with Wolf Creek, the other SNUPPS plant.

Continued observation of problems and participation in the development of solutions for both plants have permitted the licensee to plan its approach to problems

,

'

that are common to both plants.

The licensee has been responsive to NRC requirements and requests.

It has provided generally complete information in response to staff requests in a timely manner. The licensee was particularly respensive in providing additional information to assist the staff's review of the iodine filter exemption request.

2.

Conclusion Licensee performance is rated Category 1 in this area. The licensee was rated Category 2 during the previous assessment period. The improved performance is due to improvements in the quality of licensee amendment applications. The problem

-

of deficient "no significant hazards considerations" analysis identified in the previous assessment period was corrected this assessment period.

3.

Board Recommendations None K.

Training and Qualification Effectiveness 1.

Analysis Evaluation of this functional area was routinely perfonned by the resident inspectors and is also based on the results of licensed operator replacement examinations and related

'

observations, as well as the post-accreditation evaluation conducted by the NRC after INPO accreditation of all of the ten training programs subject to accreditation.

The licensed operator examinations were administered to three Senior Reactor Operators (SR0s) and seven Reactor Operators (R0s). Of these, all passed except one of the Reactor Operators.

,

- _ -

_

-

,

.

.

.

Enforcement history-in this area-indicated perfonnance that q

conformed to NRC regulations.

No violations or deviations were i

identified during this assessment. period.

Management involvement to assure quality in this functionalLarea

'

has ~ proven to be high. An excellent feedback' mechanism existed to factor facility deficiency reports,' LERs (from any facility in the nation.. including Callaway), INp0 event reports, and Westinghouse notices.into the training program.

In additi.on,-

the licensee has developed and implemented a program to factor. -

,

in'" requests for' training," which could be initiated'by'anyone-

'

at the facility.

The licensee's responsiveness to NRC initiatives has also been a

L excellent.

Improvements suggested during the June 1986~

.

L inspection regarding record keeping and centralized trainingc

.

statu's. had been implemented by _0ctober of the same ' year.

During this assessment period, the NRC also implemented a

-

pilot prequalification program ~ evaluation at Callaway.. This evaluation consisted,of limited NRC participation in the o

licensee's requalification examinations. Of,the eight d

candidates (5 SR0s, 3 R0s)Lwho took the pilot requalification

examinations, all passed except one R0, based on the NRC's exam

'

grading. The NRC-examiners determined that the licensee' had met I

its commitments as stated in its approved program.

The operating crew's performance reflects favorably on training effectiveness. The operators' ability to effectively supervise and control the plant has been demonstrated during normal and off-normal, operating and shutdown conditions. The control room was maintained in a businesslike manner.. Control room supervisors and operators were attentive, knowledgeable of ~

plant status and ongoing activities, and responsive to-cff-normal events. Equipment operators have demonstrated.

,

-

attentiveness _ during plant tours. Adverse trends or conditions have been promptly connunicated to the control room operators-

.

and corrected. There has been a significant reduction in the

number of reactor trips, with only two reactor trips occurring

during the last eight_ months of this' assessment period..Seven'

l plant startups from hot standby to power operation were performed

!

during this_ period without experiencing steam generator. water level events.

Maintenance staff training was also effective. Staff members'

undergo special training in pump and valve repair at the

.

j

,

dedicated maintenance training facility.. The training includes

.

'

completion of practical factors and hands-on experience under,

,

sirwlated radiological conditions. Minor events and problems _

>

occurring during this period did not indicate inadequate-training.

19-U

_

i;.1

...

.

.

The licensee maintained a qualified staff and associated training materials for the conduct of all training activities.

The licensee has developed a " system mockup" which includes valves, piping, and pumps. :The' mockup has been'used to conduct i

hands-on. training-for maintenance personnel. Training staff members also participated.in plant activities to he'np maintain'

an accurate awareness of facility. operations.

l 2.

Conclusion

.

.

i Licensee performance;is rated Category 1 in this area. ;The-licensee.was rated Category 1 in this area during the' previous

'l assessment period.

'

l 3.

Board Recommendations None'

-

_

d

-

-

20

_ _ _ - _ - _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

V.

SUPPORTING DATA AND SUMMARIES A '.

Licensee Activities Callaway Nuclear Station engaged in routine-power operation for-extended periods during this SALP assessment. The following

,

significant licensee activities occurred:

1.

On June 21, 1966, the pla'nt tripped on lo-lo steam generator..

water level due.to a circuit card failure ' The plant remained shutdown until June.25 for repairs.

2.

On August-25, 1986, the plant was manually. tripped after a.

turbine runback and subsequent rod. control problems -during ' i a

controlled shutdown to repair a Reactor: Coolant System (RCS)

resistance temperature' detector.(RTO) loop bypass valve leak..The plant remained shutdown until August 27,.1986.

3.

The plant was in a forced' shutdown for 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> beginning on'-

January 30, 1987, t6 investigate and repair RCS leakage (less than Technical Specification limits).

4.

From April 2-May,14,'1987, the plant was shutdown for-a scheduled maintenance outage.

The average unit availability during the assessment period was i

approximately 86%. Seven reactor trips'were reported during this assessment; five occurred at greater than or equal to 15% power, and two occurred with no rod movement. Three of the trips were due to personnel errors, and four trips were due to mechanical / component problems. ~ The plant experienced 16 Engineered Safety Feature (ESF)-

actuations during the assessment period.

B.

Insoection Activities

-

-

1.

Routine Resident and Region-Based Inspections

-

.

>

Inspection Report Nos.: 86002. 86011, 86014 thru 86020, 87002 thru 87008, 87010 thru 87012, 87014, and 87016

i i

,

'

21'

- _ _ _ _ -

.__

.

i i

.

Table 1 Enforcement Activity Number of Violations in Each Severity level i

Functional Areas I

II III IV V

Plant Operations 1*

Radiological Controls

Maintenance

'

Surveillance

-2 j

Fire Protection

!

Emergency Preparedness Security l

Outages i

I Quality Programs and

'

Adminis trative' Efforts Affecting Quality i

Licensing Activities Training & Qualification Effectiveness

,

I II III IV V

!

TOTALS

4

-

-

,

• Violation issued this SALP period; identified last 3 ALP period.

!

2.

Special Inspection Sumary June 10, 1986; The Regional Administrator and a representative from the Division of Reactor Projects toured the Callaway site.

C.

Investigations or Allegations Review

I

-

One allegation relating to Callaway was identified during this assessment period. This allegation was dismissed when the alleger

.

l

.

failed to provide any information regarding Callaway. This allegation,.

as well as two previous allegations, were closed during this assessinent period.

D.

Escalated Enforcement Actions 1.

One escalated enforcement case involving the use of non-environmentally qualified electrical connectors was I

initiated during the last assessment period. No escalated enforcement action will be taken for this issue.

2.

A civil penalty of $25,000 was issued September 9,1986. This action was based on three violations of NRC requirements that were identified during the previous assessment period. These violations were related to the inoperability of the safety injection system, a failure to male the required four-hour NRC notification, and a partial loss of the auxiliary feedwater pump auto-start feature.

_ _ - - _ _ _ _

,

i

.

.

l

!

E.

Licensee Conferences Held During Assessment Period 1.

September 10, 1986 - Regional Offices: Management meeting with.

i licensee representatives to discuss the Systematic Assessment i

of Licensee Performance (SALP) findings.

l 2.

October 14-16, 1986 - Callaway Site: Region III~ representatives along with a team from the NRR Division of Human Factors Technology

were at Callaway Facility'for an INP0 post team visit and management

'

meeting with licensee representatives to discuss matters of general interest.

i

.

3.

June 3,1986 - Enforcement Conference with licensee.

representatives to discuss the failure to maintain safety

,

'

injection operability and to notify the NRC within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the event.

F.

Confirmatory Action Letters (CALs)

No Confirmatory Action Letters (CALs) were issued during this assessment period.

G.

A Review of Licensee Events Reports and 10 CFR Part 21 Reports Submitted by the Licensee i

1.

Licensee Event Reports (LERs)

i LER Numbers: 86016 thru 86042 87001 thru 87007

.

Thirty-four LERs were issued during this assessment period;

,

17 LERs were the result of personnel errors; 3 LERs were the,

result of procedural inadequacies; and 14 LERs were the result

_

of component / equipment failures.

-

During the SALP 6 assessment period, 42 LERs were identified

!

for an average of 3.5 per month, compared to an average of 2.8 per month during the SALP 7 assessment period. The number of LERs resulting from personnel errors decreased by 10 LERs.

NOTE: The above information was derived from a review of LERs performed by the NRC Staff and may not completely coincide with the licensee's.cause assignments.

,

2.

10 CFR Part' 21 Reports No 10 CFR Part 21 Reports were submitted by the licensee during this assessment period.

'

!

l

w__-___-_-.

.

3, Analysis and Evaluation of Operational Data (AE00)

The results of the Office of Analysis and Evaluation of Operational Data (AEOD) assessment of a sample of the LERs for this assessment period for the three areas that are evaluated (i.e., the text, abstract, and coded fields)

indicated an increase in the quality of the licensee's issued LERs. AE0D gave an overall average score of 9.2 out of a possible 10 points, compared to a current industry average of 8.4 for those units / stations that have been evaluated to date. A particularly strong area identified during AEOD!s review was the licensee's LER abstracts.

AE00 stated that improvements were needed in discussing corrective actions and safety consequences, and in listing safety systems which actuate automatically during events.

H.

Liensing Activities

1.

NRR/ Licensee Meetings

-

Inservice Testing of Pumps and Valves 09/10/86 Flux and Flow Anomaly 01/16/87 Response to IE Btrlietin 85-03 02/19/87 Cycle 3 Reload and Uprating 04/29/87 2.

WRR Site Visits / Meetings Site visit to join Region III management 05/28/87 during its quarterly visit

!

3.

Comission Meetings None i

4.

Schedular Exemptions Granted None

-

5.

Reliefs Granted None 6.

Exemptions Granted Exemption authorizing use of iodine filter 12/29/86 protection factors 7.

a.

License Amendments issued l

Organizational Changes (Amendment 16)

09/08/86

-

Surveillance Intervals for Analog Tests (Amendment 17)09/08/86 MSIV and MFIV Tech Spec Changes (Amendment 18)

03/10/87 GenericLetter83-28 Item 4.3TS(Amendment 19)

04/03/87

Containment Radiation Monitors (Amendment 20)

04/10/87 Diesel Generator Tech Specs (Amendment 21)

05/01/87 ESF Respense Times (Amendment 22)

05/04/87 l

Spent Fuel Pool (Amendment 23)

05/22/87

_

.?

i

l

.

b.

Generic Reviews j

i Generic Letter 83-28 (Item 1.2)

I Generic Letter 83-28 (Item.2.1)-

j Generic Letter'83-28 (Item 2.2)

)

,.

Generic letter 83-28 (Item 3.1.3/3.2.3)

i Generic Letter 83-28 (Item 4.3 TS)

Pressurized Thermal Shock i

,

'

DCRDR Function.and:Tatk Analysis j

l-8.

EmergencyLTechnical Specifications Changes

-

~

'ESF Response TimesL(Amendment 22)

)

I 9.

Orders Issued None

'

10.

NRR/L'icensee Management Conferences None

..

-

)

a

~

..

,

i

)

!

l l

!

_ - _ _ - _ _ - - - _ _ _ __ _ _ _ _ _ _ _ - _ _ - _ - _ - _ _.-

. _ _ _ - _ _ _ _ _ - _ _,

.