IR 05000483/1987019
| ML20235L698 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/08/1987 |
| From: | Hasse R, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20235L701 | List: |
| References | |
| 50-483-87-19, GL-82-33, NUDOCS 8707160789 | |
| Download: ML20235L698 (6) | |
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i U. S. NUCLEAR REGULATORY COMMISSION l
REGION III
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Report No. 50-483/87019(DRS)
Docket No.-50-483 License No. NPF-30
Licensee:
The Union Electric Company Post Office Box 149 St. Louis, MO 63166 l
Facility Name:
Callaway, Unit 1 Inspection At:
Callaway Site, Callaway County, Missouri Inspection Conducted:
June 15-19, 1987 Inspectors:
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Date
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Date Approved By:
ips, Chief f 87 Operational. Programs Section Date
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-Inspection Summary l
Inspection on June 15-19, 1987 (Report No. 50-483/87019(DRS))
i-Areas Inspected:
Special announced safety inspection to determine if Emergency.0perating Procedures were prepared and validated in accordance.with
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the approved Procedures Generation Package.
The. inspection was conducted in accordance with IE Temporary Instruction TI 2515/79.
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Re s ul ts., No violations were identified.
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0707160709 070710ADOCK 05000403 PDR PDR O
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e DETAILS 1.
Persons Contacted
- Union Electric Company D. F. Schnell, Vice-President, Nuclear M. E. Taylor, Superintendent, Operations G. L. Randolph, General Manager, Nuclear Operations G. Hughes, Supervisor, ISEG/STA S. Petzel, Engineer, QA N. Lombardi, Engineer, QA D. Heinlein, Assistant Superintendent, Operations W. Jessop, Senior Training Supervisor J..R. Peevy, Assistant Manager, Technical Services M. S. Evans, Superintendent, Training USNRC B. H. Little, Senior Resident Inspector, Callaway.
Other personnel were contacted as a matter of routine during this inspection.
- All licensee personnel listed attanded the exit interview held on June 19, 1987.
2.
Emergency Operating Procedures Emergency Operating Procedures (EOPs) have undergone significant changes as a result of the 1979 accident at the Three Mile Island facility.
The new EOPs are required to be symptom-oriented rather than event-oriented.
Generic Letter 82-33, " Requirements for Emergency Response Capability"
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(Supplement 1 to NUREG-0737) required all licensees and applicants to submit to the NRC for approval a Procedure Generation Package (PGP)
describing their plan for developing the upgraded E0Ps.
The PGP consists
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of four parts:
Plant-Specific Technical Guideline (P-STG) - the technical basis for
the new E0Ps.
For Callaway, the Generic Technical Guidelines (GTG)
previously approved by the NRC serve as the P-STG since it closely matched the reference Plant for the GTG.
Plant-Specific Writers Guide (P-SWG) - the details of the specific
methods to be used by the licensee in preparing the E0Ps.
A description of the program for verification and validation (V&V)
of the E0Ps.
A description of the program for training operators on the E0Ps.
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The purpose of this inspection was to determine if the licensee's E0Ps
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had been prepared and validated in accordance with their NRC approved PGP.
This was accomplished by a detailed comparfson of a sample of E0Ps against the approved PGP (effectiveness of operator training will be covered at a later date).
a.
Documents Reviewed The following documents were reviewed during this inspection:
(1)
FR-C.1, " Response to Inadequate Core Cooling," Revision 4.
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(2)
ES-3.1, " Post - SGTR Cooldown Using Backfill," Revision 3.
(3)
E-3, " Steam Generator Tube Rupture," Revision 3.
(4)
E-0, " Reactor Trip or Safety Injection," Revision 3.
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ES-0.0, "Rediagnosis," Revision 1.
(6) CSF-1, " Critical Safety Function Status Trees," Revision 1.
(7) APA-ZZ-00101, " Preparation, Review, Approval, and Centrol of Procedures," Revision 16.
(6) APA-ZZ-00102, " Emergency Operating Procedure Writers Guide,"
Revision GR1.
(9) Emergency Response Guidelines, Revision 1.
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b.
Inspection Results The inspectors determined that the licensee's E0Ps were generally prepared, verified, and validated in accordance with the PGP.
However, weaknesses in controlling the technical basis for revisions to the E0Ps were identified.
Additional management attention is needed in these areas to assure that traceability of E0P parameters and actions to basis documents will not be lost in future revisions.
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(1) Plant-Specific Technical Guidelines The Callaway Plant closely matched the reference plant for the generation of the Westinghouse Owners Group (WOG) Emergency Response Guidelines (ERGS).
As a result, there is very little difference between the ERGS and the Callaway E0Ps.
This obviated the generation of normal Plant-Specific Technical Guidelines for the Callaway Plant.
Those differences that had been identified were resolved with NRR and the final Safety Evaluation was transmitted to the licensee by the Project Manager on March 4, 1987.
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During their review of the E0Ps, the inspectors developed a concern relative to the generation and control of basis documents for the E0Ps.
Examples were as follows:
(a) ERG FR-C.1, " Response to Inadequate Core Cooling," bases the exit from this procedure, in part, on a core exit thermocouple reading of less than 700 F.
Revision 2 of E0P FR-C.1 changed this value to less than 900 F.
While the licensee was able to provide the basis documentation for this difference, no reference to this basis was included in the procedure change documentation.
(b) ERG E-0 included a step to ensure feedwater isolation.
In part, this step verified that, the steam generator (SG)
blowdown isolation and SG sample isolation valves were closed.
E0P E-0 deleted this step with no documented basis.
Discussions with the licensee and a review of the system description in the Callaway FSAR, determined that while the Callaway Plant does have both types of valves, these valves receive an isolation signal upon an auxiliary feedwater actuation, rather than a feedwater isolation.
The licensee drafted a change to Revision 3 of E0P E-0 to include the verification of the closure of the SG blowdown and sample isolation valves, subsequent to an auxiliary feedwater actuation.
The basis for this difference between the E0P and ERG was included in the draft change documentation.
(c) The licensee was generally able to provide the documentation supporting plant specific parameters used in the E0Ps.
However, retrieval of this documentation relied almost exclusively on the personal knowledge of the licensee representative working with the inspectors as to its location.
There was no controlled system for tracing these parameters to their basis documentation.
The basis for one parameter, the temperature defining adverse containment, could not be located.
The licensee was responsive to these concerns and agreed that it was prudent to provide better control over the E0P basis documentation.
Completion of this effort, including the identification of the basis for the temperature defining adverse containment will be tracked as an open item (483/87019-01).
(d)
In general, the completed Procedure Request Forms used to initiate procedure changes were not sufficiently detailed to provide a specific basis for each change incorporated.
Without this detail, the basis for specific changes is never documented or, if documented elsewhere, traceability is lost (e.g., see items (a) and (b) above).
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l (2) Plant-Specific Writers Guide The inspectors reviewed a sample of E0Ps against the requirements of the P-SWG.
No significant discrepancies were identified.
The few minor discrepancies that were identified were corrected by the licensee by incorporation into the draft i
revision to the P-SWG currently in progress.
l (3) E0P Verification and Validation (V&V)
The purpose of the V&V effort is to ensure the technical adequacy and useability of the E0Ps.
The V&V of the original revision (Revision 0) of the WOG ERGS was performed using the Callaway Plant-Specific version of the ERGS (i.e., Revision 0 of the Callaway E0Ps).
This effort was documented in WCAP-10204, dated September 1982, and was consistent with the commitments made in the PGP.
The technical validation demonstrated that the tasks specified in
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the E0Ps (Revision 0-T) were sufficient to accomplish the objective; namely, to place the plant in a safe and stable condition, and to remove the Critical Safety Function (CSF)
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challenges.
The verification ensured the technical content,
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format and structure, and the accuracy of the E0Ps.
Human factors was acceptable in that the E0Ps could be accomplished in an orderly and efficient manner.
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li The inspectors reviewed the WCAP in general, and the E-0 V&V, specifically.
Two of the major changes / improvements resulting from problems identified in the WCAP are discussed below:
(a) The ES-0.0, "Rediagnosis," procedure was written.
This procedure was needed after the initial E-0 transition, to allow the operator to react to new and/or conflicting
symptoms.
It was used in a manner similar to continuous status tree monitoring.
(b) The E0Ps were quite bulky due to the inclusion of tables of specific control board tag numbers for referenced instruments and controls.
The bulk was reduced by deleting information familiar to the trained operator.
The V&V effort for Revision 1 (the current revision) of the ERGS was performed at the Seabrook Plant.
Although the Callaway E0Ps have been revised to reflect Revision 1 of the ERGS, the Callaway plant-specific differences from the reference plant had been addressed during the Revision 0 V&V effort and no additional major V&V effort beyond that conducted at Seabrook was required for Revision 1.
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One portion of the V&V effort involves the review of E0Ps to assure that they are technically consistent with the EPGS and reflect good human factors engineering.
The
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inspectors identified two items of concerns in this area:
(a) Revision 1 of E0P E-0 included a step to determine RCS subcooling prior to terminating the SI (Safety Injection).
Two methods were available in the form of attachments for the procedure; a manual method and a RCS subcooling meter error correction.
In Revision 2, the step allowing the use of the subcooling meter was deleted in favor of the manual method.
However, the associated attachment for using the subcooling meter was overlooked and was not deleted.
The licensee drafted a change Revision 3 of E-0 to delete the unnecessary
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attachment.
l (b) Revision 1 of E0P CSF-1 added Attachment 7, " Critical Safety Function Status Trees Review Summary," to the procedure.
However, no reference to this attachment j
appears in the procedure.
Further, the inspector
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identified an error on the attachment.
The " orange" condition in the core cooling critical safety function prompted the activation of the functional restoration Procedure FR-C.3.
This procedure would only be performed in the " yellow" condition.
The licensee drafted a change
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to Revision 1 of CSF-1 to give direction for performing i
Attachment 7, and to correct the identified error, i
The inspectors were satisfied with the corrective actions to the identified concerns and recommended that the licensee perform a complete review of the E0Ps to determine if other similar problems existed.
The licensee responded that an individual had been assigned to perform this function.
3.
Open Items Open items are matters which have been discussed with the licensee which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both.
An open item disclosed i
during the inspection is discussed in Paragraph 2.b.(1).
4.
Exit Interview The inspectors held an exit interview with licensee representatives (denoted in Paragraph 1) on June 19, 1987.
The inspectors summarized the purpose, scope, and findings of the inspection.
The licensee stated that the likely informational content of the report would contain no
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proprietary information.
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