IR 05000483/1987036

Insp Rept 50-483/87-36 on 871205-880206.No Violations Noted. Major Areas inspected:LER,inspector-identified Problems, Plant Operations,Esf Sys Walkdown,Radiological Controls, Maint,Surveillance,Fire Protection & Security

ML20149M812
Person / Time
Site:	Callaway
Issue date:	02/23/1988
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149M798	List: IR 05000483/1987036 ML20149M796
References
50-483-87-36, NUDOCS 8802290099
Download: ML20149M812 (13)

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'U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/87036(DRP)

Docket No. 50-483 License No. NPF-30

' Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St.- Louis, M0 63166 Facility Name: Callaway-Plant, Unit 1 Inspection at: Callaway Site, Steedman, Missouri Inspection Conducted: December 5,1987 through February 6,1988 Inspectors: B. H. Little C. H. Brown k.N ibfAW ft4 Approved By: J. M. Hinds, Chief z /.23 /gr Reactor Projects Section 1A Date Inspection Summary

__ Inspection from December 5,1987 through February 6,1988 (Recort No. 50-483/87036(DRP))

Areas Ins)ected: -A routine unannounced safety inspection of Licensee Event Reports (.ERs), inspector-identified problems, plant operations, engineered safety features (ESF) system walkdown, radiological controls, maintenance,-

surveillance, fire protection, emergency preparedness, security, quality programs and administrative controls affecting quality, training and qualification effectiveness and regional request R_esul ts : Of the 13 areas inspected, no violations were identified in 12 areas. One violation was identified in the remaining area (failure-to place the auxiliary feedwater pressure switch in a tripped condition within one hour - paragraph 2.d). However, in accordance with 10 CFR 2, Appendix C, Section V.A, a Notice of Violation was not issued. The violation was of minor safety significanc PDR ADOCK 05000483 :

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

• G. L. Randolph, General Manager, Nuclear Operations

• J. D. Blosser, Manager, Callaway Plant C. D. Naslund, Manager, Operations Support A. P. Neuhalfen, Manager, Quality Assurance

• J. R. Peevy, Assistant Manager, Technical Services W. R. Campbell, Assistant Manager, Nuclear Engineering M. E. Taylor, Superintendent, Operations D. E. Young, Superintendent, Maintenance W. R. Robinson, Assistant Manager, Operations and Maintenance R. R. Roselius, Superintendent, Health Physics T. P. Sharkey, Supervisor, Compliance G. J. Czeschin, Superintendent, Planning and Scheduling W. H. Sheppard, Superintendent, Outages G. R. Pendegraff, Superintendent, Security

• L. H. Kanuckel, Supervisor, Quality Assurance Supervising Engineer R. D. Affolter, Superintendent, Systems Engineering J. V. Laux, Superintendent, Technical Support, Quality Assurance G. A. Hughes, Supervisor, Independent Safety Engineer Group J. C. Gearhart, Superintendent, Operations Support, Quality Assurance

• J. J. Cassmeyer, Quality Assurance Engineer

• Denotes those present at one or more exit interview In addition, a nwrber of equipment operators, reactor operators, senior reactor operators, and other members of the quality control, operations, naintenance, health physics, and engineering staffs were contacte . Inspection of Licensee Event Reports (92700)

Through direct observations, discussions with licensee personnel, and a review of records, the following licensee event reports were reviewed to detennine that reportability requirements were fulfilled, that immediate corrective action was accomplished, and that corrective action to prevent i recurrence was accomplished in accordance with Tcchnical Specifications (T/Ss). The LERs listed below are considered closed, LER 87-003-00: Reactor protection system actuation due to inappropriate human performance and valve failur On April 2, 1987, a reactor protection system actuation occurred due to the water level in the "D" steam generator reaching the lo-lo level trip setpoint. The plant was in the process of shutting down for other reasons and was subcritical at the time of the trip. In dccordance with a plant procedure, the operator shut all the auxiliary feedwater (AFW) flow control valves before starting the motor-driven auxiliary feedwater (MDAFW) pump The operator noted the closure demand for the valves, but failed to verify a closed indication for the "A" steam generator AFW flow control valve. When he started the

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MDAFW pumps, he found that he could not throttle the "A" steam generator AFW flow control valve. He shut off the "B" MDAFW pump (securing AFW flow to the "A" and "D" steam generators) to provide time for manually shutting the valve, but AFW flow was not reestablished in time to prevent the "D" steam generator from reaching its 10-10 trip setpoint. All systems responded as designed, and the plant was placed in a stable shucdown condition. The breaker for the AFW valve for the "A" steam generator was found in the open position. The breaker was replaced and tested; no problems were discovered. The valve was tested satisfactorily. The length of time that the breaker had been open could not be detennine LER 87-003-00 is considered close LER 87-029-00: Containment purge and control room ventilation isolation On October 8, 1987, an ESF automatic actuation signal was received from the containment purge radiation monitor, which resulted in a containment purge isolation (CPI) and a control room ventilation isolation (CRVI). The vessel had been defueled, and no abnormal airborne radioactivity levels were detected. The actuation was considered spurious, and all systems were returned to norma LER 87-029-00 is considered close LER 87-014-00: ESF actuation due to a failed power suppl On July 18, 1987, a CRVI, a fuel building isolation (FBI), and a CPI occurred. These actuctions resulted from a power supply failure in an engineered safety features actuation signal (ESFAS) cabinet. The proper actuations of the components were verified. The defective power supply unit was replaced, but the cause of the failure could not be determine LER 87-014-00 is considered close LER 87-022-01: Two occurrences of T/S 3.0.3 unknowingly entered when action statement for inoperable AFW pressure channel not met due to procedural inadequacie On August 28, 1987, an AFW suction pressure (AFSP) channel was placed out of service to perform a T/S-required surveillance. Per T/S 3.3.2.c.6-h, this channel should have been placed in the tripped condition within one hour of being declared inoperable. Operators discovered that the channel had not been placed in the tripped condition about three and one-half hours late, during which time the plant had unknowingly entered T/S 3.0.3. This channel is not readily testable in the tripped condition, and the one-hour time limit is usually sufficient to perform the surveillanc The surveillance was not immediately completed on this date due to troubleshooting. The procedure was revised to call out the one-hour T/S time limit. Other procedures were reviewed for similar

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inadequacies. A review of previous surveillances revealed one similar situation in which the plant had unknowingly entered T/S 3. The licensee's failure to place the AFSP channel in the tripped condition within one hour is a violation of T/S 3.3.2. The violation meets the tests of 10 CFR 2, Appendix C, Section V.A; consequently, no Notice of Violation will be issued, and this matter is considered closed. The corrective action was timely and appropriate, and the safety significance was minor. The switchover to the alternate water system is a long-term item and would allow time for operator actio LER 87-022-01 is considered close LER 86-002-01: Environmental qualification (EQ) of the reactor vessel head vent valves had not been implemented. Installation of qualified CONAX seals on the conduit connectors for these valves had been deferred to the first refueling outage. Also, the connectors for the solenoid and limit switch for containment isolation valve BG-HV-8160 lacked qualified seal The licensee has installed qualified conduit seals on the components in question. In the case of the solenoid and limit switch for BG-HV-8160, this corrective action was conservative, in that a licensee analysis shows that an environmentally initiated failure would result in the closure of the containment isolation valve. A complete discussion of the safety significance of this issue and of the corrective actions taken to ensure proper sealing of electrical connections is contained in Inspection Report No. 483/87015(DRS),

which closed two related unresolved item LER 86-002-01 is considered close . Follow-up on Inspector-Identified Problems (92701)

0)en Item 87018-01: Fire brigade drill deficiencies were identified by

, tie NRC during the licensee's emergency exercise on June 3, 1987. The deficiencies included timeliness of gathering and donning fire fighting equipment, team directions and coordination, and a performance erro The inspector witnessed both announced and unannounced fire drills to evaluate the performance of fire brigade members in response to simulated

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plant fire The fire brigades were adequately staffed, and team members

, appeared well trained in the use of equipment and fire-fighting techniques.

l The team members responded in a timely manner and displayed professionalism during the drills. The brigade leaders provided effective direction and coordination of the fire-fighting activitie Open item 87018-01 is considered closed.

t I Urresolved Item 87020-01: Adverse trend in performance errors associated iith T/S surveillance activities. This matter addressed the increased I frequency of missed T/S surveillances associated with infrequent j r.ctivities and with requirements which are conditional in nature.

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The licensee's response in this matter included the assignment of a Conditional Surveillance Task Force and a Fuel Handling Task Force as subcommittees of the On-Site Review Committee (ORC). The teams were responsible for event evaluation, identification of generic weaknesses and ioot causes, and recommendations for corrective action. This effort revehled that conditional surveillances lacked an adequate triggering mechanism, and found human factor weaknesses in fuel handling procedure The licensee has completed corrective actions to prevent recurrenc The long-term improvement recommendations of.the task forces have been entered in the Plant Manager's action tracking syste The inspector determined that this matter received appropriate licensee attention and response. There has been no recurrence of similar events in the past four months. Unresolved item 87020-01 is considered close No violations or deviations were identifie . Plant Operations (71707) Operational Safety Verification Inspections were routinely performed to ensure that the licensee conducts activities at the facility safely and in conformance with regulatory requirements. The inspections focused on the implementation and overall effectiveness of the licensee's control of operating activities, and on the performance of licensed and non-licensed operators and shift technical advisors. The following items were considered during these inspections:

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Adequacy of plant staffing and supervisio Control room professionalism, including procedure adherence, operator attentiveness, and response to alarms, events, and off-normal condition Operability of selected safety-related systems, including attendant alarms, instrumentation, and control Maintenance of quality records and report The inspections included direct observation of activities, tours of the facility, interviews and discussions with licensee personnel, independent verification of safety system status and LCOs, and reviews of facility procedures, records, and reports, Off-shift Inspections of Control Rooms The inspectors performed routine inspections of the control room durino off-shift and weekend periods; these included inspections between the hours of 10:00 p.m. and 5:00 a.m. The inspections were conducted to assess overall crew performance and, specifically, control room operator attentiveness during night shifts. The 5 .

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inspectors also reviewed the licensee's administrative controls regarding "Conduct of Operations" and interviewed the licensee's security personnel, shift supervisors and operators to determine if shift personnel were notified of the inspectors' arrivals on site during off-shift The inspectors determined that both licensed and non-licensed operators were attentive to their duties, and that the inspectors'

arrivals on site were unannounced. The licensee has implemented appropriate administrative controls related to the conduct of operation These include procedures which specify fitness for duty and operator attentiveness. Personal radios and reading materials are prohibite No violations or deviations were identifie . ESF System Walkdown (71710)

The operab'lity of selected engineered safety features was confirmed by the inspectors during walkdowns of the accessible portions of several systems. The following items were included: verification that procedures match the plant drawings, equipment conditions, housekeeping, instrumentation, valve and electrical breaker lineup status (per procedure checklist), and verification that locks, tags, jumpers, etc. are properly attached and identifiable. The following systems were walked down during this inspection period:

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"A" Emergency Diesel Generator

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Component Cooling Water System

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Auxiliary Feed Water System

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Reactor Trip System

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125-Volt D.C. Power Source

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AC Electrical Vital Power Source No violations or deviations were identifie . Radioloaical Controls (71709)

The licensee's radiological controls and practices were routinely observed by the inspectors during plant tours and during the inspection of selected work activities. The inspection included direct observations of health physics (HP) activities relating to radiological surveys and monitoring, maintenance of radiological control signs and barriers, contamination, and radioactive waste controls. The inspection also included a routine review of the licensee's radiological and water chemistry control records and reports. Good HP housekeeping practices were observe The inspectors observed that personnel entering, working in, and exiting radiological control areas generally displayed good radiological work practice .

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No violations or deviations were identifie . 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 the Technical !

Specifications. The inspections included activities associated with preventative and corrective maintenance of electrical, instrumentation and control, and mechanical equipment and systems. 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 calibration was performed prior to returning the components or systems to service; parts and materials that were used were properly certified; and apprcpriate fire prevention, '

radiological, and housekeeping conditions were maintaine i The reviewed maintenance activities included:

i Work Request N Activity WR R110077A Maintenance of emergency diesel generator (EDG) starting air compresso WR R109535A Essential service water to aftercooler valve wor ,

Multiple work requests Preventative maintenance on emergency diesel generato No violations or deviations were identifie .

. 8. 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

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adequate procedures were used to perform the testing, whether test

instrumentation was calibrated, whether test results conformed with Technical Specifications and procedural requirements, and whether tests were performed within the required time limits. The inspectors determined that the test results were reviewed by individuals other

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than the personnel involved with the performance of the tests, and that any deficiencies identified during the testing were reviewed and resolved

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by appropriate management personne The inspectors' overview of the licensee's surveillance program showed that the licensee had developed and implemented a comprehensive and effective progra . - -.

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Procedure N Activity OSP-ZZ-00001 Control Room Shift and Daily Log Reading and Channel Check MTE-ZZ-QA001 MotorOperatedValveTesting(M0 VATS). ;

ETP-ZZ-ST012 Engineering Evaluation Test for Temperature Increase of Room With Diesel Running With Ventilation Fan Off and Outside Temperature Less Than 65 Degrees Fahrenhei OSP-GT-LL161 Containment Ventilation Isolation Valves Local Leak Rate Tes l OSP-NE-C0001 Diesel Generator Rocker Ann Prelub l l

OSP-NE-00002 Diesel Generator Periodic Test l OSP-KJ-V0001 Section IX Diesel Generator Aftercooler Mode 1 Valve Operability Tes OTN-NE-00001 Nonaal Operating Procedure Diesel !

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l ISL-GN-0P935 Loop Pressure: Containment Pressure l Protectio ISF-SE-0N428 Functicnal Nuclear: Nuclear Instrumentation Power Range N42.

, No violations or deviations were identifie . Fire Protection (64704)

Implementation of the licensee's fire protection / prevention program was routinely assessed by the inspectors during plant tours. The inspection included observation of housekeeping conditions, storage and control of combustible material, operability of fire protection / suppression systems, and fire brigade staffing and trainin Two unannounced and two announced fire brigade drills were monitored during the inspection interval. The response time of the brigade to assemble was satisfactor The manual fire equipment was noted to have been maintained; and at the completion of the drills, the equipment was returned to readiness status.

l The housekeeping and control of combustible materials and flammable

liquids were found to be satisfactory. A review of selected surveillances l

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for this area indicated that the surveillances were up to date. The operability of the fire protection / suppression equipment and systems was

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maintaine Fire watches and patrols were utilized in areas of the plant when required by the Technical Specification No violations or deviations were identifie . Emergency Preparedness (82301)

An inspection of emergency preparedness activities was perfermed to assess the licensee's implementation of the emergency plan and implementing procedures. The inspection included the monthly observation of emergency facilities and equipment, interviews with licensee staff, and a review of selected emergency implementing procedure No emergency preparedness drills were performed during this inspection interva No violations or deviations were identifie . Security (71881)

The licensee's security activities were observed by the inspectors during routine facility tours and during the inspectors' site arrivals and departure Observations included the security personnel's performance associated with access control, security checks, and surveillance activities, and focused on the adequacy of security staffing, the security response (compensatory measures), and the security staff's attentiveness and thoroughnes All trailers inside the fence have had the skirting renewe The skirting is stenciled with a note to contact security if there is a need to remove skirtin No violations or deviations were identifie . Quality Programs and Administrative Controls Affecting Quality (35701)

An inspection of the licensee's quality programs was performed to assess the implementation and effectiveness of programs associated with management control, verification, and oversight activities. The inspectors considered areas indicative of overall management involvement in quality matters, including the frequency of management plant tours and control room observations, and management personnel's attendance at technical, planning / schedule, and comittee meetings. The inspectors attended On-Site Review Comittee meetings and incident / event critiques and reviewed related documents, focusing on the licensee's root cause determinations and corrective actions. The inspectors accompanied licensee management on monthly plant tours, which focused on quality activities and material conditions withir, the plant. The inspection also included a review of quality records and selected quality assurance audit and surveillance activitie Performance in this area included the following aejor items:

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" Safety System Functional Assessment On February 2, 1988, the licensee notified the senior resident inspector of a potential deficiency associated with the height of the partial walls located in the essential service water (ESW) pump rooms. The partial walls separate the ESW pumps from associated electrical switchgear. The as-built drawings specify a wall height of six feet. The walls were actually constructed eight feet, nine inches high. The deficiency was identified by the licensee during the performance of a Safety System Functional Assessment (SSFA) of the ESW syste At the3:10 p.m., engineer architect following(an engineering Bechtel), reviewdetennined the licensee and discussions with that the correct wall height should be that specified in the as-built drawings, and that the existin Specificction (T/S) g3. wall action heightrequirement placed the plant The in Technical licensee made an oral request to NRC Region III for enforcement discretion. At l 4:05 p.m., Region III granted enforcement discretion to allow continued plant operatic At 5:25 p.m., the ESW Train B wall was restored to a height of six feet, Train B was declared operable, and T/S 3.0.3 was exited. On February 3,1988, the Train A partial wall was restored to a height of six feet, and the Limiting Condition for Operation related to ESW noerability (T/S 3.7.4) was satisfie 'ne

. licensee's evaluation in this matter is continuing. This matter is unresolved, pending further NRC revie (Unresolved '

Item 483/87036-01 (DRP))

b. 10 CFR 50.59 Review (37700)

A sample inspection of licensee design changes and modifications was performed by the NRC Project Manager (PM)-Callaway to ascertcin that chages are in confonnance with license requirements. The inspection :

included a review of change descriptions, design documents, and safety evaluations, and discussions with the licensee's engineering staf The following licensee 10 CFR 50.59 evaluations were reviewe Activity N Type of Change Description NE-860117 Final Safety Artlysis Revised the procedure Report (FSAR) Change for reactor vessel head :

removal and installatio !

CHP-860042 Design Change Blanked off the exhaust from rooms 1501 and ;

1512 (control reora dir l conditioning equipment roons) to prevent a possible unmenitored releas ,

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RFR-02852 Request for Resolution Evaluated diesel generator (DG) and '

ESW operability with their. respective supply fans out of servic ESW supply fans must be operable at all times.

e DG supply fans must be operable if ambient temperature is-greater-than 65 degrees Fahrenhei NE-860188 Engineering Technical _A procedure was Procedures written, for Mode 3 e operation, to determine how the reactor flow anomaly behaves with various combinations of reactor coolant pumps runnin CMP-84-0396 Design Change This change resulted in the installation of the containment breathing air system. This system provides breathing air for personnel working inside containmen ,

No violations or deviations were identifie . Training and Qualification Effectiveness (41400)

A performance evaluation of the licensee staff and contractors was performed to assess the effectiveness of the licensee's training and qualification program. The following items were considered:

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Program implementation (various work groups).

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Understanding of wor Event and problem causal factor Experience feedbac The inspection included personnel interviews, direct observation of training, operation, maintenance, and testing activities, observation of incident / event response, and a review of quality records and report No violations or deviations were identifie L -

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\ll 14. Regional Requests (92701) Quality of spent fuel racks fabricated by U.S. Tool and Die and its predecesso An NRC nspection of the U.S. Tool and Die facility performed in March 1987, identified U.S. Tool and Die quality assurance (QA)

program deficiencies concerning in-process examination and weld inspection in the fabrication af spent fuel racks. Because the spent fuel racks for the Callaway Plant were purcnased from Tool and Die and/or its predecessor, Watcher Associates, Inc., the licensee was requested to provide to the NRC the following information: The extent to which the U.S. Tool and Die quality assurance / quality control program was relied upon to-assure rack qualit . The licensee's in-factory and/or receipt inspection of the rack . What findings were made during the licensee's receipt inspection of the rack . If the licensee's receipt inspections found deficiencies in the racks, what corrective actions were take . Any additional planned actions or examinations to assure that the racks meet the original design and regulatory requirement An inspection was performed to assess the licensee's respense in this matter, including the licensee's identification and resolution of deficiencies associated with the spent fuel rack The licensee provided the requested information to the NRC in letter number VLNRC-1666 dated October 30, 198 Through a sample review of quality assurance records and inspection procedures and interviews with quality assurance personnel, the inspector determined that the licensee provided appropriate quality

. assurance / quality control overview and inspections and that the deficiencies identified were adequately dispositione The licensee's response in this matter is acceptable. This item is considered close Brown Boveri electric circuit breaker In a memo to the senior resident inspector, dated October 27, 1987, it was requested that the follow-up on Information Notice 87-41 by the licensee be assessed. The notice pertained to failures of Brown Boveri electric circuit breakers and to the manufacturer's repair letter addressing the problem. The memo requested that the licensee's actions be reviewed and to determine whether the generic implications

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were considere The licensee determined that the notice was not applicable to Callaway. The generic problem was not pursued, as the licensee.had not been notified of any similar problems with the type of breakers installed in the plant and had not experienced any similar problems with the breakers on sit This item is considered close . Unresolved Item Unresolved items are matters about which more information is required in order to ascertain whether it is an acceptable item, a violation, a failure to meet a licensee connitment, or a deviation. An unresolved item disclosed during the inspection is discussed in Paragraph 12.a. of the repor . Violations for Which a "Notice of Violation" Will Not be Issued The NRC uses the Notice of Violation as a standard method for formalizing the existence of a violation of a legally binding requirement. However, because the liRC wants to encourage and support licensee initiatives for self-identification and correction of problems, the NRC will not generally issue a Notice of Violation for a violation that meets the tests of ,

10 CFR 2, Appendix C, Section V.A. These tests are: (1) the violation was identified by the licensee; (2) the violation would be categorized as t Severity Level IV or V; (3) the violation was reported.to the NRC, if required; (4) the violation will be corrected, including measures to prevent recurrence, within a reasonable time period; and (5) it was not ,

a violation that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. A violation of regulatory requirements identified during the inspection for which a Notice of Violation will not be issued is discussed in Paragraph ,

17. Exit Meeting (30703)

The inspectors met with licensee represer.tatives (denoted under Persons Contacted) at intervals during the inspection period. The inspectors

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sunnarized the scope and findings of the inspection. The licensee representatives acknowledged the findings as reported herein. The '

inspectors also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents / processes as proprietar !

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