IR 05000483/1987012

Insp Rept 50-483/87-12 on 870406-16.No Violations or Deviations Noted.Major Areas Inspected:Previously Identified Concerns,Licensee Verification & Assessment Activities of Design Changes & Maint Program Activities

ML20214J327
Person / Time
Site:	Callaway
Issue date:	05/18/1987
From:	Jablowski F, Vandel T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20214J315	List: IR 05000483/1987012 ML20214J312
References
50-483-87-12, NUDOCS 8705280011
Download: ML20214J327 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/87012(DRS)

Docket No. 50-483 License No. NPF-25 Licensee: The Union Electric Company Post Offic.e Box 149 St. Louis, M0 63166 Facility Name: Callaway, Unit 1 Inspection At: Callaway Site, Callaway County, Missouri Inspection Conducted: April 6-16., 1987

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G$bMb G g./g c'o 7 Inspector: T. ndel Date

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GbkM C Approved By: . J b onski, Cnief 5-/P 8 7 Quality Assurance Programs Date Section Inspection Summary Inspection on April 6-16, 1987 (Report No. 50-483/87012(DRS))

Areas Inspected: An unannounced safety inspection by a regional inspector of:

previously identified concerns; licensee verification and assessment activities of design changes; maintenance program activities; corrective action program; and program change control. The inspection was conducted in accordance with Inspection Procedures 35701, 37702, 62700, 62702, 92701, and 9272 Results: No violations or deviations were identified, however, one unresolved item was identifie PDH ADOCK 05000483 G PDR

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DETAILS Persons Contacted

• J. D. Blosser, Manager, Callaway Plant D. W. Capone, Manager, Nuclear Engineering

• J. J. Cassmeyer, Assistant Engineer, Program Support QA

• J. C. Gearhart, Superintendent, 0perations Support QA

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'*L. H. Kanuckel, Supervising Engineer, Program Support QA

• J. V. Laux, Superintendent, Technical Support QA-

, *T. H. McFarland, Superintendent, Design Control:

• J. E. McLaughlin III, Superintendent, Administration Records A. P. Neuhalfen, Manager, Quality Assurance G. L. Randolph, General Manager, Nuclear Operations

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• M. A. Reidmeyer, Engineer, Operations QA

• C. E. Slizewski, Supervising Engineer, Technical Support QA

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. *J. A. Tunink, Senior Planning, Supervisor

• B. L. Walton, Assistant Superintendent, Administration Records

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• Denotes those attending the exit meeting on April 16, 1987. Other personnel were contacted during the course of the inspection.

, Licensee Action on Previous Inspection Findings (Closed) Open Item (483/85013-01): Three procedures concerning planning guides, Q-Lists, and computer program requirements were incomplete

including the following:

I Procedure QAP-ZZ-01830, " Quality Assurance Planning Guide", was-issued with the administrative system number.GDP-ZZ-1083 This procedure is a series of functionally arranged planning guides to be used as a planning source documer.t for acceptance criteria, requirements and commitments.

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, Procedure WEP-ZZ-00011, " Classification of Parts", was issued

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as APA-ZZ-0043 This procedure, together with Procedure APA-ZZ-00018, " Upgrade of Parts, Materials, and Supplies",~provides the controls that assure replacement parts, components and subsystems related parentused in safetyare components related, special quali appropriately scope,fied and/oror non-safety upgrade ' Procedure QE-343, " Classification of Systems and Components", has been replaced by a new Procedure APA-ZZ-00303, " Classification of Systems and Equipment". This procedure was scheduled for onsite review committee review and approval recommendation on Friday, April 17, 1987. This procedure established the re methods for determining equipment classificatio quirements providedand

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the Callaway Equipment Q-List, as a sublist of the master equipment l list in the ADABASE computer program being develope ,

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Items a - c satisfied the original concerns of the Open Item; therefore, the item is close The inspector reviewed the current Q-List system relied on for the Callaway sit The following information was. verifie A four volume set of the SNUPPS Q-List, current to the last revision issued by SNUPPS in 1986, continued to be the basis for evaluation of Callaway partc and component This Q-List was the one developed by the architect engineer for classifying systems and components

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during the design and construction. Continued maintenance and

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reporting of this list was uncertain.

. In a letter to the NRC dated November 8, 1983, UNLNRC-687, the licensee

, committed to developing a Callaway,Q-List, embodying the SNUPPS Q-List,

-for use in assigning quality classifications to spare and replacement parts, along with components, In the same letter, the licensee also committed to an onsite

Computerized History and Maintenance Planning Systems (CHAMPS)

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that incorporated design information pertaining to the safety classification of systems and components, and included results i of the Q-List developemen The Superintendent of Design Control informed the inspector that

Callaway has substituted the ADABASE computer system for CHAMP The ADABASE master equipment list system, commenced during the testing phase of the plant, was under development. The Callaway 3 site Q-List information will be incorporated into the ADABASE master list system.

4 The inspector was also informed that the system was expected to be in place and in use by the end of 198 The items described in d - h are open for further review (483/37012-01).

No violations were identifie . Quality Assurance Program (35701)

This inspection was conducted to ascertain whether the licensee was  !

implementing a QA, program in conformance with regulatory requirements, commitments, and industry guides and standards. -Management involvement l

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and information flow for management assessment were reviewe ' Reference Documents (1) Operating Quality Assurance Manual (0QAM), Revision !

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(2) Callaway Administrative Procedure * GDP-ZZ-00106, " Reference Tracking System, Its uses

and Controls," Revision 1.

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• GDP-ZZ-00230, " Training, Qualification and Certification of Quality' Assurance Personnel," Revision 0.

i * GDP-ZZ-00600, " Preparation, Review, and Approval,of Revisions and Change Notices to the 0QAM,"

Revision 0.

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• GDP-ZZ-01810, " Quality Assurance Audits and Surveillances," Revision * GDP-ZZ-01830, " Quality Assurance Planning Guides (QAPGs),"

Revision (3) Quality Assurance Audit Schedule 1987, 0QM-87-005, January 14, 198 (4) Audit Report * 70T03, Audit'of Training, Qualification, and Performanc * AD5A8605A, Audit of Non-Licensed Training and Performanc * G170.07-8609P, Audit of the I&C Departmen * 70C03, Qualifications and Trainin (CorporateOffice)

• AD5A86028, Cesign Contro * AD5A8603B, Design Change Implementatio * AP-87-001, Design Change Developmen * AP-87-003, Corrective Action and Nonconforming Item Contro * G170.10-8610P, Planning and Scheduling of Corrective

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and Preventative Maintenanc * A05A8607C, Maintenanc * AD5A8512A, The I&C Departmen ,

• ADSA8508C, Callaway Preventive Maintenance Progra * AD5A85070, Callaway Maintenance and Instrument and Control Program ,

l ( . Results of Inspection-

-Qualification and certification of site auditing personnel were reviewed by the inspector. Six. lead auditors from three different onsite QA support groups were sampled. Certification records met the requirements of ANSI N45.2.2 Thirteen " Request for Corrective Action" items issued as a result ofauditingactivityinauditreports,werefollowedthrough to resolution and close out. All items appeared to be adequately-handled and closed out in a timely fashion.

L The Reference Tracking System was reviewed'by the inspector to assess the system for tracking 0QAM changes to all applicable sub-tier documents and to gain assurance that all applicable e seb-tier documents were also revised. Although several instances

! of change notifications were observed, no example was found where actual changes to sub-tier procedures had been made. The inspector learned that the Emergency Response Program System for reference documents was complete and in place. This computerized system was reviewed by the inspector. In. response to questions, the inspector learnedthatasimilarreferencesystemwasplannedforthe0QAM; however, programming had not been done. This. item remains open for review at a later date. (483/87012-02).

Thirteen audit-reports, listed above, were reviewed by the inspecto Attributes were assessed and found adequate as follows:

l (1) The planned schedule adequately assured timely coverage of the applicable progra (2) Corrective action was taken for identified deficiencies in a timely fashio (3) Audits were distributed to management personnel.

l (4) Checklists were utilized in the performance of audits.

l l (5) Basic requirements and acceptance criteria were available and l

usedinconjunctionwiththeaudit.

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l (6) Followup items were completed in a timely fashio ,

No violations or deviations were identified.

l Corrective Action (92720)

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l ThisinspectionwasperformedtoassesslicenseeQAauditingofcorrective

action, and applicable information reported to management personnel.

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$ ' Reference Documents-(1) Operations Quality Assurance Manual (0QAM), Revision * Section 16, Corrective Action

-* Section 18, Auditing

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(2) Quality Assurance Audit Schedule, 1987, 0QM-87-005, January 14, 1987

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(3) Callaway Administrative Procedures

• GDP-ZZ-00100, " Quality Assurance Stop Work Actions,"

l Revision * GDP-ZZ-01810, " Quality Assurance Audits and Surveillances,"

Revision 2.

• APA-ZZ-00007, " Quality Assurance Organization, Responsibility, and Conduct of Operations,"

Revision (4) Audit Report Number AP87-003, QA Audit of Corrective Action and Nonconforming Item Control, Results The inspector reviewed the above listed audit report.for the following attribute (1) Utilization of checklist (2) Issuance of. Requests for Corrective " ^ ions (RCAs).

(3) Followup activity where applicabl (4) Distribution to Managemen The ins! ector concluded that the corrective action program was being

adequately' audite The inspector also reviewed the Quality Assurance Division's, semi-annual report for the period July 1 through December 11, 198 Included was Trend Analysis Report ~No. 6! Potential areas of concern were highlighted and' charted. The report, addressed to the

, Vice-President Nuclear, appeared to be an effective management

reporting too l

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, No violations or deviation were identifie l

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, Maintenance Assessment (62700 and 62702)

This. inspection was conducted to measure the effectiveness of the licensee auditing program to measure the ability of the maintenance staff to conduct a maintenance program respcnsive to regulatory requirements, technical specifications, application commitments, and-industry ~ guides or standard Reference Documents (1) Callaway Administrative Procedure * APA-ZZ-00549, " Reliability Program," Revision * APA-ZZ-00340, " Surveillance Program Administration,"

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Revision 8.

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• APA-ZZ-00142, " Post Trip Review Program," Revision (2) Callaway Licensee Event Reports.

j * 86-022-00, Feedwater Isolation Valve Card Failure.

! * 86-037-00, Spurious Turbine Driven - Auxiliary Feedwater-.

Actuation.

! * 86-038-00, Valve Leakage Results in Hi Containment RAD Levels and ESF Actuations.

j * 86-022-01, (Followup of abcve listed items).

t (3) Callaway Audit Report * AD5A8507D, Callaway Maintenance and Instrument and Control Program * AD5A8508C, Callaway Preventative Maintenance Progra * AD5A8512A, I&C Departmen * AD5A8605A, Audit of Non-Licensed Training and Performanc * A05A8607C, UEN0 Maintenance Progra * G170.07-8609P, Audit of the I&C Department.

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• G170.10-8610P, Planning and Scheduling of CA&PA Activitie j

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(4) Selected Callaway Request for Corrective Actions (RCAs).

• P8508-129, Inadequate Corrective Actio * P8508-131, Inadequate MTT Procedure * P8512-205, Failure to Maintain Documents as QA Record * P8512-206, Inade_quate Trending Procedur Results

The inspector reviewed the audit report about non-licensed training and performance. The audit objectives were to verify the following: Personnel requalified as require . Adequate qualification documentation exit . Compliance with established criteria for education and experience used for qualificatio . Qualificationcardstandardsandtrainingrelatedtoappropriatejob and task analysi . Mechanisms exist for feedback of operating experienc The inspector concluded that a thorough, in-depth audit was performed and the conclusion, traihing and qualification had been adequately implemente The inspector determined that the audits performed of the implemented program activities for both corrective and preventive maintenance programs supported the licensee's conclusion that the maintenance program was adequately implemented.

, Four Requests for Corrective Action (RCA) were reviewed by the inspector.

The identified concerns, responses to the RCAs, followup, and close out actions all appeared to be extensive, timely, and adequate. The inspector identified no concern No violations or deviations were identifie . Design Changes (377028)

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This inspection was conducted to measure the effectiveness of the licensee s auditing program to: measure the adequacy of program controls for design and modification ~ changes; assess the qualification and training of design personnel; and determine adherence to regulatory requirements, technical specifications, application commitments, and industry guides and standards.

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a. Reference Documents (1) Callaway Nuclear Function Directive Number NFD-5,

" Qualification and Training," Revision ,

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(2) Callaway FSAR Site Addenda, Section 13.1.1.3, " Qualifications of Technical Support Personnel".

(3) Callaway Technical Specification Interpretation Number 24, " Audits".

(4) Callaway Administrative Procedure APA-ZZ-00126, "Callaway Plant l Training Manual," Revision (5) Callaway Audit Report * ADSA86028, Design Control.

l * AD5A86038, Design Change Implementation.

l * AP87-001, Design Change Development.

l * 70C03, Training,. Qualification and Performance General l Office.

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• 70T03(G170.20-8609G), Training, Qualification ~and

Performance General Offic ,

(6) Selected RCAs and Checklist Item * P8603-029, Design Reviews Not Performe * P8603-028, NMRs Not Processed as Design Change * P8604-061, Improper Deviation from CMP (Callaway Modification Package) Desig *

RP87-005, Design Change Documentation Does Not Meet Commitment * Checklist Item No. 23 (from Report No. AD5A8603B) Review of Callaway Systems and_ Components Q-List (CSCQL).

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b. Results Review by the inspector of the audit reports and the related RCAs established that:

(1) Adequate verification of design change program implementation was conducte (2) ' Corrective action was adequately performe *

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(3) One RCA, Number P8507-108, reviewedinconjunctionwithRCA Number P8603-028 remained unresolved for an extended period of time. In-depth review by the inspector established that corrective action resolution evolved over a longer period of time. Although the followup had not been completed, the inspector considered the resolution adequat (4) Training and qualification of the engineering staff was reviewed. The licensee had committed to an effective training program in Nuclear Function Directive Number NFD-5, Revision Moreover, as stated in Section 13.1.1.3 of the Callaway FSAR Site Addendum, the technical staff of the Manager, Nuclear Engineering, was to include personnel trained and experienced as set forth on Page 13, 1-13 of the FSAR. The inspector reviewed the licensee's audits of these commitments with the following results:

• Corporate Audit Number 70C03, September 11, 1985, indicated no discernable informatio * Audit Report Number AD5A8602B, March 27, 1986, indicated no auditable informatio * Corporate Audit Number 70T03, October 17, 1986, provided to the inspector just prior to the exit meeting established that seven nuclear function personnel located at the corporate office had the necessary training degree to comply with FSAR-SA, Section 13.1.1. The inspector was unable to determine if training or qualifications had been adequately verified by the licensee. This matter is unresolved and will be reviewed further during a future inspectio M3/87012-03).

No violations or deviations were identified; however, there was one unresolved ite . Open Items Open items are matters that have been discussed with the licensee, which will be reviewed further by the inspector, and involve some action on the part of the NRC or licensee or both. Open items disclosed during this inspection are discussed in Paragraphs 2 and 3 . Unresolved Items An unresolved item is a matter about which more information is required in order to ascertain whether it is an acceptable item, and open item, a deviation, or a violation. An unresolved item disclosed during this inspection is discussed in Paragraph 6b(4).

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.. Exit Interview-The Region III inspector met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on April 16, 198 The inspector summarized the purpose-and findings of the inspection. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed during the inspection. The-licensee representatives did not identify _any such documents / processes as proprietar ,

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