IR 05000483/1988001

SALP 8 Board Rept 50-483/88-01 for June 1987 - Aug 1988

ML20195E094
Person / Time
Site:	Callaway
Issue date:	08/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20195E093	List: IR 05000483/1988001 ML20195E086
References
50-483-88-01, 50-483-88-1, NUDOCS 8811070236
Download: ML20195E094 (28)

Text

-. .

.,

.

. .

%

<.

SALP 8

!

SALP BOARD REPORT U.S. NUCLEAR RE'iULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-483/88001 Inspection Report No.

i t

Union Electric Company Name of Licensee Callaway Station Name of Facility June 1, 1987 through August 31, 1988 Assessment Period 8811070236 ust031

{DR ADOCK 05000433 PDC (.

. . _ -

• .s l

.

,

SUMMARY OF RESULTS Overview Management continued to demonstrate a high degree of personal

. involvement in overall plant operation and quality programs; it has been aggressive and proactive in response to NRC safety concerns and in the support of quality improvement initiative The effectiveness of improvement initiatives was demonstrated during the last half of the assess,nent period, especially in improved plant operations and in a reduction of surveillance deficiencies and reportable events. Notwithstanding the favorable event reduction, the number of reactor trips attributed to performance errors remained high and were avoidable. Management's continued support of an open connunication environment, staff training, and a strong Quality Assurance program is evident. Staffing is viewed as a utility strength; licensee personnel are responsible and forthright in identifying and resolving problems, and display a positive safety attitude. The licensee continued to show overall improved performance and is a strong performe Rating Last Rating This Functional Area Period Period Trend Plant Operations 2 2 Improving Radiological Controls 2 2 Maintenance / Surveillance 1/2 1 Emergency Preparedness 1 1 Security 1 1 Engineering / Technical Support NR 2 Safety Assessment / Quality Verification NR 1 NR - Not Rated Other Areas of Interest None

. . ~ .

,

. .

.

III. CRITERIA o

The licensee performance is assessed in selected functional area Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee

'

activities or lack of meaningful observation Special areas may t e added to highlight significant observation The following evaluation criteria were used to assess each functional are . Assurance of quality, including management involvement and contro . Approach to the identification and resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement history.

, Operational events (including response to, analysis of, and corrective actions for).

, Staffing (including management). Effectiveness of training and qualifications program.

However, the NRC is not limited to these criteria and others may be ustd where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definition of these performance categories are as follows:

Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance

,

is being achieved. Reduced NRC attention may be appropriate.

> Category 2: Licensee management attention to and involvement in the I

performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet

regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being

'

achieved. NRC attention may be maintained at normal level Category 3: Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient. The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be

increased above normal level .

.

m

. .

.

Trend: The SALP Board may determine to include an assessment of the performance trend of a functional area. Normally, this performance

trend is only used where both a definite trend of performance is discernible to'the Board and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as

Improving Licensee performance was determined to be improving near the close of the assessment perio Declining Licensee performance was determined to be declining near the close of the assessment period, and the licensee had not taken meaningful steps to address this pattern.

,

,

i

-

_._ - - . , - _ .

- .

. .

.

~

IV. PERFORMANCE ANALYSIS _ _ _ , , _ . Plant Operations Analysis Evaluation of this functional area was based on the results of ten routine inspections by the resident inspectors and one inspection by regional inspector Enforcement history in this functional area was good and indicated no significant change in performance. There was one Severity Level IV and one Severity Level V violation compared with one Severity Level IV violation during the previous assessment perio The plant had a total of six reactor trips during the current 15-month assessment period, compared with seven reactor trips during the previous 12-month period, a slight improvemen However, this is still considered excessive and four of the six were avoidable . Two of the six trips were attributed to the plant operations area and both of them resulted from low-low steam generator levels which occurred during low power feedwater control transfer activities (less than 15% reactor power). The other four reactor trips occurred while above 90% reactor power; two of those trips resulted from instrument and control troubleshooting and surveillance activities, and two resulted from component failure To assist in evaluating plant performance, the NRC uses several performance indicators. Three of these are significant events, safety system actuations, and safety system failures. For Callaway, there were two significant events (both of which occurred in August 1987); four safety system actuations (three in October 1987 and one in January 1988); and six safety system failures (five in the latter part of 1987 and the sixth in January 1988). None of the safety systems actually failed, but were "technically" failed by the definition used for failur None of the performance indicator events posed any immediate safety or operational concern and there have been none since January 198 This is a positive tren With regard to this functional area, there was a favorable trend in LERs in both the total number and in the number attributed to personnel performance errors. Nine LERs were issued during this assessment period attributable to operations, with six of those attributed to personnel error During the previous assessment peiiod there were 15 LERs, with 9

-

attributed to personnel error A high level of management attention and effort has been directed at the reduction of operational event This attention, in the form of the Event Reduction Program, i

. ..

. .

,

has focused on root-cause determination and on the implementation of corrective measures. This program has been effective, as evidenced by a reduction of event frequency from 2.8 events per month during the previous assessment period, to 2.2 events per month overall during this assessment period. However, there has been less than one event per month during the last nine months indicating a significant improvemen The operating crews generally demonstrated excellent control room professionalism and morale and effectively supervised and controlled plant activities during routine operations, major outages, and off-normal events. Although there were a few perfonnance errors due to lack of attention to detail, the operating crews routinely displayed a high degree of attentiveness, good knowledge of plant status and regulatory requirements, and projected a positive safety attitud ,

procedure discipline was routinely demonstrated and was t

'

effective. The operating crews' performance reflected fauorably on individual attitudes, training, and qualificatio The plant had operated continuously for 120 days at the end of this assessment period. It had a 92.1% availability for calendar year 1988 through the end of August, and an 82.8%

availability for the operating cycle that began in early November 198 Housekeeping conditions within the plant were good throughout

,

this period. This was aided by assigning and posting area

'

responsibility to specific supervisors and by progress of the licensee's painting program. Control of combustible materials was satisfactor The licensee's fire protection organization was adequately staffed with well-qualified personnel. There is a full-time safety supervisor, who is a degreed fire protection engineer; and a safety coordinator (fire brigade instructor) who has degrees in both fire science and education, as well as work experience as a fire service officer. Based on observations i and interviews, fire watch personral appear to be adequately trained and knowledgeable of their assigned duties. The fire ,

brigades' firefighting techniques, the brigade leader's direction at the brigade station and enroute to the emergency, the number of brigade members responding, and the communications

,

interface between radiation protection personnel and fire i brigade personnel were all satisfactory. Improvements were needed, however, in reducing the amount of time spent setting up for extinguishing fires (from the time the fire brigade arrives on the fire scene to the time that water is applied on the fire). Also, improved attention was needed by the fire brigade to the fireground hazards (during a drill one brigade l

_ .

. .

.

~

member walked through the designated contaminated area that had been identified by radiation protection personnel).

Later fire drills showed improvement in these area Management's involvement in assurance of quality in plant operations has been continually evident and generally is goo Upper management and supervision perform frequent control room observations and plant walkdowns, attend "plan of the day" meetings, and hold informal "lessons learned" motivational meetings with operations department personnel. Programs have been implemented that have improved control room supervision and control effectiveness. These include restricting "at the controls" access, removing administrative task functions from the control room, and implementing computerized workmen's protection assurance (WPA) tagging activitie There was one example wi:ere management involvement in assuring quality was considered to have been marginally adequate. This was the observed poor control of basis documents supporting the emergency operating procedures (EOPs). In one case, no basis was documented for deleting a step when an emergency response guideline was translated into the corresponding plant E0P. In another case, the basis for a plant-specific parameter (temperature defining adverse containment) could not be located during the inspection. In general, there was no system for controlling the basis documents and their retrieval depended on the knowledge of individuals as to their locatio Staffing for plant operations continued to be excellent. The licensee has 33 licensed senior reactor operators (SR0s) and 20 licensed reactor operators (R0s). The plant is on a six-shift rotation with one shift always in training. Overtime

' is controlled and averages less than 5%, except during outage Management also is involved directly in operator qualification i

and requalification. This includes assessing operator performance during simulator evalustions and plant walkdowns, l and in development of a "Team Training" program in which an entire on-shift crew is kept together and trained as a uni This continued involvement and training program effectiveness is evident by the high success rate on operator licensing exam Four SR0s and three R0s replacement examinations were l administered by NRC during the assessment period, and all i

I candidates passed the examination. This success rate (100%)

exceeded the success rate (88.75%) for the previous assessment perio The licensee has been very responsive to NRC initiative Midway in the assessment period, the resident inspectors

identified an increasing trend in personnel errors by the

' operations staff. They discussed this with the licensee and as a result the licensee met with NRC regional management to

,

l

<

g-_ __

. .

a

'

discuss the problem, its causes, and corrective action The problem was corrected and there have been no such concerns during the last four months of the assessment perio . Performance Rating The licensee's performance is rated Category 2 in this area with an improving trend. The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations None B. Radiological Controls Analysis Evaluation of this functional area was based on two inspections performed by regional specialists and on observations by the resident inspector Enforcement history in this area was adequate and similar

'

to that of the previous assessment period, with two Severity Level IV violations in the current 15-month assessment period compared with two Severity Level IV violations during the previous 12-month assessment perio Both violations this period related to failure to follow procedures. Licensee corrective acticns for the violations were appropriat Two LERs were attributed to this functional area during this assensment period comp; red with four LERs during the previous assessment period. The LERs were timely and accurat Staffing levels, qualifications, and performance were generally goo Staffing has been stable. A planned minor reduction in the technician staffing level should not cause e significant degradation in program effectiveness; however, additional attention appears needed to address weaknesses concerning the generally poor quality of radiation worker practice deficiency (RWPD) and personnel contamination event (PCE) investigations including root-cause analyses. Near the end of the assessment period, the licensee began measures to correct these weaknesse Radiation protection (RP) technicians appear to be well-trained and qualified and display good radiological safety attitude Examples of good licensee staffing performance included reinstatement of a second health physicist position, appointment of an ALARA coordinator, improvements in the technician requalification program, and development of good health physics outage training. Job coverage by RP technicians was generally good, and there was adequate augmentation by well qualified contract RP technicians during outage _ _ _ - _ _ _ _ _ _ _ _ _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

. .

.

Increased management involvement was evident in a variety of performance improvement programs and initiatives, including a hot-particle detection and prevention program and contract radiochemical laboratory assistance. Management has increased the frequency of field t,bservations that focus. on plant radiological conditions and personnel performance. The licensee's quality assurance (QA) group provided a comprehensive assessment of the radiological control functions through its audit and surveillance activities. The QA group has conducted performance-based surveillances of as low as reasonably ,

achievable (ALARA) effectiveness and radiological work l practices. Management has been supportive of QA activities and was responsive to audit and surveillance finding Licensee responsiveness to NRC issues was generally acceptable during this assessment period; exceptions include the timeliness of improvements to the ALARA program, the quality of the RWPD and PCE reporting systems, and radiation work permit (RWP) and procedural compliance. Examples of good performance included improvements to the hot-tool crib decontamination facility and

,

correction of certain radiation monitor calibration criteri The licensee's approach to resolution of technical issues was generally good. Examples of this included development of an excellent hot-particle program, significant reduction of gaseous effluents by an effective leakage reduction program, an expanded ALARA/RWP dose-tracking computer capability, a contaminated leakage reduction / decontamination program, and numerous facility and equipment improvements. Personal radiation exposures for 1987 totalled 393 person-rem, which although significantly greater than the licensee's 1986 total of 224 person-rem was not considered to be excessive for the outage tasks. It appears that personal radiation exposures for

-

1988 will be under 50 person-rem, which is indicative of very good performance, even considering that no major outages have occurred in 1988. The licensee has made improvements in the ALARA program since the previous assessment period. Additional i ALARA improvements are planned to be implemented in time for the next major outage (April 1989). The number of personal contaminations remain somewhat high for the age of the plan The gaseous effluent and solid radwaste generated showed a ,

downward trend, which indicates conscientious licensee reduction programs. No transportation problems were identifie Radiological confinnatory measurement results continue to be very good with 98% agreement in 89 comparison Increased attention is warranted, however, to safe laboratory sample handling practices and to completion of calibration documentatio Interlaboratory cross check program results were generally good, but there were some minor disagreement P

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

- _ - _ _

-_ _J

_ ,_ _ _ _ _

. - - . _ _ _ _ _- ___ ____

. .

.

~ Performance Ratina The licensee'.. performance is rated Category 2 in this are The licensee's performance was rated Category 2 in the previous assessment perio . Recommendations None l T Maintenance / Surveillance Analysis

,

>

Evaluation of this functional area was based on the results i of ten routine inspections performed by the resident and six routine inspections by regional inspectors, and one special NRR inspection. Maintenance and surveillance were separate functional t areas in the previous assessment period but have been combined as one functional area for this assessmen Enforcement history remained essentially the sam Two Severity I Level IV violations were identified during the current 15-month assessment perio In the previous 12-month assessment period there were no violations in the maintenance area and two violations (one Severity Level IV and one Severity Level V)

'

in the surveillance are !

There were 12 LERs issued that related to this functional area compared with 15 issued during the previous assessment period i (11 in surveillance and 4 in maintenance). Nine of the current t

-

events were surveillance related and the other three occurred f

'

during maintenance troubleshooting activities. Two of the ,

events resulted from the failure to use or follow procedures, i

and four resulted from lack of attention to detail. Of the 11

'

surveillance related events, 5 occurred prior to this assessment period, but were identified through the licensee's proactive -

review and verification programs and reported during this -

I

'

assessment perio As noted in the plant operations functional area, there were two reactor trips attributed to surveillance activities, the ;

.

'

! same number as in the previous assessment perio The licensee has been responsive to NRC concerns to identify and to correct programmatic and procedural deficiencies in ,

surveillance, as well as to enhance performance. Corrective

, *

'

actions, which were effective, included implementation of a

'

Surveillance Task Force and supervision / work group discussion i I

QA surveillances were also focused in this area. There was

'

only one missed surveillance resulting from personnel error l

during the last 12 months of this assessment period, and it i

,

1 occurred near the end of the perio t I

'

_ ~

. .

,.

Maintenance and instrumentation and control supervision personnel have initiated self-evaluation checklists for observation of ongoing activities. Observations and events are discussed in

"motivational based" meetings that focus on performance enhancement The licensee has a comprehensive planning and scheduling program in place. The program is computer based and provides scheduling, tracking, and trending. Maintenance and surveillance activities are integrated into a 13-week cycl The program has prevented "wrong train events" and has been highly effective in maintaining equipment operability and in reducing unnecessary equipment operatio The licensee has initiated a reliability centered maintenance (RCM) process in its preventive maintenance (PM) progra The RCH process is .

'

designed to preserve system function, identify dominant failure modes, and establish priorities for function nee The NRC determined that the licensee's chain of command and implementation of its erosion / corrosion pipe wall thinning program was commendabl The erosion / corrosion program has good management support, concise and explicit procedures, and knowledgeable personne Management involvement and program effectiveness have been evident during plant outages and refueling activities. Major tasks have been well planned and implemented, as have continuing plant improvement programs. These programs include the reduction of plant equipment oeficiencies (work request (WR) backlog)

and maintaining control room annunciator "black board" status (annunciator deficiencies are classified as high priority work items).

There has been a significant reduction in the plant equipment WR backlo The WR backlog has averaged approximately 900 items during 1988, a reduction from approximately 1400 in 1987. WRs greater than 90 days old have been maintained at a relatively low 34% during this period. A minimal number of preventive maintenance items required deferral (less than 2%).

Items deforred were considered as having little significanc The noted lack of leaking valves fittings, and components are indici.siveofgoodmaterialcondItionsintheplan The

assignment of responsibility for area conditions to supervisors appears to be effectiv Maintenance and surveillance work for safety and safety-related systems and components was generally well-planned and professionally performed and detailed instructions, drawings, and procedures were used at the job site. The work and post-maintenance testing performed were well-documented. The lack of required rework is indicative of an effective maintenance and modification progra There was, however, a potential weakness in tracking technical issues identified during maintenance activities because the

a

. .

. ,

"

-

resolution of these issues was not documented or referenced on the work request. Although the planning and scheduling program was applied to balance of plant n'aintenance, there was notably less discipline in the performance of these tasks. For example, work, rework, and testing activities were not well-de:umented and, on occasion, there were incomplete or inadequate instruction Resolution of technical issues has been excellent. This was i demonstrated by the licensee's response to the discovery that a retaining wall separating the essential service water pumps from their respective load centers which was too high; and the response to an NRC Bulletin regarding counterfeit flanges.

'

The licensee maintains a well-trained and qualified maintenance and surveillance staff. Training has been determined not to be a root-cause in plant event The licensee has integrated licensed SR0s and R0s in planning and scheduling, outages, and maintenance and surveillance work groups. The staff demonstrated a positive safety attitude and displayed a positive individual and team spirit. Overtime was controlled and averaged less than 5% tota Staffing levels and qualifications were adequate to implement the routine chemistry programs. The chemistry department was

reorganized and combined with the radwaste department under the Superintendent, Chemistry and Radwaste who was reassigned from the health physics group. The chemistry supervisory staff was i reduced from two to one. The staff and technicians were experienced, so these changes did not impair the quality of the staff and appear to have improved overall management efficienc Licensee management involvement in ensuring quality in the chemistry area was generally adequate. The laboratory

facilities, including space and instrumentation, were adequate for monitoring the chemistry parameters. Primary and secondary water chemistry control programs conformed to the respective Electric Power Research Institute (EPRI) Guidelines, with waiver authority residing with the plant manager or his

alternate, i

Responsiveness to NRC initiatives in chemistry, including nonradiological confirmatory measurements, was good. Changes to improve their laboratory QA/QC programs were willingly and rapidly implemente The results of the nonradiological confirmatory measurements program were generally good, with 19 agreements in 30 comparisons initially and 100% agreement after reanalysi The disagreements appeared to be due to weaknesses in the QA/QC measurement program, which the licensee has agreed to upgrade.

l

l L

.

• Performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 in maintenance and was rated Category 2 in surveillance in the previous assessment perio . Recommendations None D. Emergency Preparedness Analysis Evaluation of this functional area was based on the results of four inspections conducted by regional specialists. One was a routine inspection; two inspections consisted of evaluations of annual emergency preparedness exercises; and one was a special safety inspection that consisted of an Emergency Response Facility Appraisal. One Severity Level IV violation was identified. There were no violations identified in the previous assessment period. An exercise weakness was identified in the 1987 exercise for an unsatisfactory medical drill; this was corrected and demonstrated satisfactorily during the 1988 exercise. An Emergency Response Facility Appraisal was conducted and the facilities generally were found to be acceptable. Corrective actions on open items and other areas of NRC concern have been timely and effectiv Emergency preparedness (EP) staffing has been adequately maintained; one member of the staff was a former licensed SR Shift augmentation capabilities for the emergency response organization were satisfactorily demonstrated through three call-in drills. These drills were well documented and critiqued by the license A single EOF organization replaced the combination of plant staff and corporate organizations that was used as the E0F organization until the 1988 exercise. This new all-corporate personnel EOF organization demonstrated its effectiveness and efficiency during the 1988 emergency exercis Responsiveness and involvement by . management have been positive, as evidenced by revision of the entir6 Fmergency Action Levels (EAls) tables in the Emergency Plan and Imolementing Procedures and reducing the volume from 53 to 27 pages, while still maintaining the technical content. This major EAL revision significantly improved the clarity of the EALs for control room and other technical personnel.

!

i

. .

.

-

The job task analysis for EP training is still being revise When this is completed, most plant. positions will include EP training as part of their training requirements. This is an improvement over the job task analysis undertaken in the prior assessment perio Several managerial positions with emergency response duties are being reevaluated from a training viewpoint to make the EP training requirement less burdensome and remain effectiv Offsite training was consistent and meaningful for both State and County participants. Meetings were held periodically on a wide range of emergency preparedness topics. Communications were being maintained between the licensee and the offsite agencie The QA group has continued to upgrade and increase the scope of the annual EP independent audit. Additional surveillances, review of EAL tables, and an independent assessment of security's ability to interact with the control room and TSC in a security event are now included in this audit. The interface between the the licensee and offsite agencies was also a portion of this independent audi Three events occurred in the assessment period that activated the radiological emergency response plan. The events were not serious and each was correctly classified as a Notification of Unusual Event; was based on the proper EAL; and proper notifications were made to the State, Counties, and the NRC within the required time limit Federal Emergency Management Agency Region VII's (FEMA VII's)

evaluation of the offsite agencies responses during the 1988 exercise identified several deficiencies. These deficiencies involved both the State of Missouri and the four involved Counties. The licensee's EP group responded (within a month of the exercise) to provide additional training, guidance, and help in revising emergency procedures that FEMA Region VII identified as needing correction. The licensee continued to be responsive to the needs of offsite emergency preparedness organization Other observations made by the inspectors indicated that:

• Emergercy equipment and facilities were maintained in a state of readines * Control room personnel promptly obtained and used procedures / drawings in response to exercise drills and event _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _

. .

.

• - Shift technical advisors (STA) were effectively integrated into event response STA involvement included event discussions, event classification, being cognizant of safety system performance, and status and trends of core cooling parameter * Comunication within the control room was considered to be excellent during the emergency exercises. Comunication during plant events appeared to be effective but less forma . Performance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 in the previous assessment perio > Recommendations None E. Security Analysis Evaluation of this functional area was based on the results of three inspections (one reactive and two routine) conducted by regional physical security inspectors, and routine

inspections by the resident inspectors to observe security i activitie A slight decrease in enforcement related performance occurre Two Severity Level IV and one Severity Level V violations were identified, compared with no violations during the previous assessment period. The violations were not indicative of significant programmatic weaknesses. An adverse trend

pertaining to excessive vital area door alarms caused by personnel errors was noted during an inspection in early

.

1988, but it was resolvtd by the end of the assessment perio Senior plant management was instrumental in initiating aggressive actions to reverse the trend.

Technical issues continued to be analyzed in a competent and timely manner. The excellent quality of the security plan addendumfortheservicebuildingconstructionproject was indicative of the security staff s analysis, planning, coordination, and implementation capabilities. Procedural guidance was generally excellent and of sufficient detail to enable efficient task performance. The procedural guidance for the criminal history check program required revision, however, to meet all regulatory requirements.

15

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

w

. .

..

-

Security event reporting continued to be conservative. Three security events were reported early in this assessmer.t perio Two of the events were caused by personnel error the remaining event was equipment related. Eventreportingguldancewas excellent, and security management was aggressive in .inalyzing trends, identifying root causes, and initiating effective corrective actions for the reportable and logged security event No security events have been reported since October 198 Responsiveness to NRC concerns continued to be another major strength of the security program. Enforcement issues, licensing matters, allegation review, and all security issues noted during inspections were addressed in a timely manne Resolutions of problems were technically correct and there was adequate staff and proper evaluation. The security staff has visited two sites during Regulatory Effectiveness Review inspections in order to identify potential problems that may apply to Callawa Assurance of quality was addressed in several way The QA audits of the security program were comprehensive, well-documented, and broad in scope. The QA audit of the safeguards information program was noteworthy. QA findings were closely monitored prior to closure and root causes were identified when possible. SpecialIzedtraining,beyond regulatory requirements, was provided for several security and training supervisors. Security management trend analysis and root-cause identification for security events also contributed to the assurance of quality for the security program. Additionally, response force weapons and equipment were upgraded during this assessment perio Staffing continued to be sufficient to support security operations. Strong supervision of day-to-day operations was evident and overtime has been adequately monitored and controlled. Staff functions assumed by security contractor personnel have been effectively integrated with licensee staff and high quality performance continued. Senior security managers have delegated authority appropriately to enable themselves to concentrate on oversight of all aspects of the security progra The security force training and qualification progran continued to be effective. The overall excellent performance of the uniformed security force attested to the program's 'oenefit Security officers were thoroughly knowledgeable of procedural requirements and confident of their capabilitie . Perfotmance Rating The licensee's performance is rated Category 1 in this are The licensee's performance was rated Category 1 in previous assessment perio _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _

. .

.

'

i

• i Recommendations Non Engineering / Technical Support Analysis This is a new functional area and consequently was not rated in previous SALPs. Evaluation of this functional area was based on the results of four inspections conducted by regional inspectors and several routine inspections conducted by the resident inspector Although enforcement history during the current assessment period showed a large number of violations (two Severity Level III and five Severity Level IV), only two of the violations related to activities that occurred during this assessment period (one Severity Level III violation and one Severity Level IV violation).

The other five violations related to activities that occurred prior to issuance of the operating license in 1984 but were identified during this assessment period. Since this area was not rated during the previous assessment period, no prior enforcement history is available for compariso One of the Severity Level III violations involved failure to reposition an essential service water valve which had been mispositioned as a result of weaknesses in the engineering review of the work control process. This violation was related to performance during initial preoperational activities. The other Severity level III violation, which occurred during this assessment period, involved failure to provide an adequate safety evaluation of a plant modification. This resulted in breaching of the control room electrical penetration seals and a Technical Specifications violation associated with operability of the control room emergency ventilation system. The Severity Level III violations resulted in civil penalties of $25,000 eac Five LERs issued during this assessment period related to this functional area. One LER, which was issued early in the assessment period, described two events of an inoperable control room emergency ventilation system (breaching of pressure boundaries and mispositioning of a flow balancing damper) and identified deficient safety and operability reviews performed during this period. The remaining four LERs identified deficient engineering reviews made prior to the issuance of the operating license. There were no LERs issued for deficient work performed in this assessment period since October 198 Management's high level of involvement to ensure quality in this area has been continually evident. Senior engineering management and staff, with the exception of a support group, are located at the facilit Management's philosophy, policy,

. .

.

. ar.d personnel responsibility are directed at superior performance and have been clearly communicated. Action has been implemented to enhance the effectiveness of engineering and technical support. Such actions include the assignment of engineers to backshifts; appointment of an engineering duty supervisor; and required system walkdowns by system engineer Other established routines include engineering personnel attendance at operations' morning briefings and "plan of the day" meetings, and operations department's representation at conceptual design and design change meetings. The corrective and enhancement actions have been effective. This is evidenced by the licensee's identification of and responsiveness to environmental qualification concerns and by the fact that there have been no adverse findings relating to perfctmance in this area since October 198 With the exceptions noted by the enforcement issues, the Engineering Department's approach to the resolution of technical issues from a safety standpoint was timely, generally sound, and professional. Although the 10 CFR 50.59 safety reviews were poorly handled in the control room emergency ventilation system modification work, other such reviews were well documented and demonstrated a sound technical basi Actions taken after the disclosure of the improper calibration of the overtemperature-deltatemperature trip function were aggressive, and appropriately resolved all technical concern There has been a continuing increase in engineering presence in the plant, noticeably relating to maintenance work, and in response to plant problems. Temporary modifications are current and in the past year have been reduced from approximately 35 to 17 based on effective engineering efforts. It appears that a good working relationship exists between engineering personnel and other work groups on sit The licensee consistently developed and implemented programs in response to NRC initiatives that met or exceeded NRC expectations with regard to schedule or content. It was the first licensee nationally to respond to the motor-operated valve testing program; and provided excellent responses to tre pipe wall thinning and defective fastener and flange test' rig program The licensee had nearly completed testing of act;essible suspect flanges at the time NRC temporarily suspended 11dustry's testing efforts; however, the licensee continued the testing program until all accessible flanges were tested and the test results were evaluated. Responsiveness to the control room ventilation issue and environmental qualification concerns were adequat Engineering and technical support staffing was adequate, with key positions identified and defined. The staff has adequate training and qualification programs. Related events occurring early in this assessment period appear to have been caused by the lack of a disciplined approach to problem resolution and

,

N

, .

were not indicative of inadequate trainin A positive

'

training attitude was evident in this are Examples include the temporary assignment of the superintendent of engineering to hot license training for SR0s. Specialized training courses were also conducted in Codes and Standards, Qualified Reviewer Refresher, and 10 CFR 50.59 evaluation . Performance Evaluation The licensee's performance is rated Category 2 in this .we Because this is a new area, no rating is available foe the previous assessment perio . Recommendations None G. Safety Assessment / Quality Verification Analysis This is a new functional area and conse vent.ly not rated in the previous SALPs. Evaluation of this functional area was based on results of routine inspections performed by the resident and regional inspectors. There were no violctions attributed to this functional area during this assessment perio Management continually demonstrated a high degree of personal involvement in quality programs. Corporate management personnel made frequent site visits and demonstrated personal involvement in ongoing activities, events, and quality improvement program The licensee maintained an open environment for the discussion of problems and improvement opportunities. This was evident in various site-wide departmental initiatives, including engineering routines to enhance engineering support effectiveness, motivational meetings, and a company-wide quality improvement process (QIP)

progra Both management personnel and staff were open and forthright in discussing events and corrective and enhancement activities with NRC personnel. Management's commitment was also demonstrated by its involvement in meetings with NRC relative to the vantage 5 (new fuel design) reload application to ensure the quality of the applicatio Management continued t demonstrate a high level of attention and commitment in the area of training and qualification. The Callaway Plant was the second to complete simulator performance testing. The licensee submitted certification of the Callaway Plant simulator to the NRC in November 1987. Management's involvement in training was evident in the assignment of licensed SR0s to key positions in various site work groups and in the assignment of the Superintendent of System Engineering to SRO hot license trainin ~ - .

. .

..

?

I

The licensee has been responsive to NRC initiatives and concerns. This was demonstrated in the response to defective (

fasteners, fittings, and flanges; in performance of the safety system functional assessment; in taking the lead plant cole for motor-operated valve actuator testing; and in fire protection technical specification revision. The licenseu responded well to all applicable generic letters and bulletins and has been equally responsive to both its own Technical Specification amendment and relief requests and to NRC questions resulting from reviews of 10 CFR 50.59 evaluations. All responses were acceptabl '

The licensee's safety review functions (onsite review committee (ORC) and independent safety engineering group (ISEG)) appeared to provide both comprehensive and critical self-assessment The ISEG performed comprehensive causal evaluations, employing accident investigation techniques, of both plant and industry events; conclusions and recommendations were factored into the licensee's experient.e feedback program. In May 1988, the ISEG performed a quality verification effectiveness review of the QA department activit es. The review determined that QA audits and surveillances were very comprehensive and well-otlanized, but minor suggestions for improvertent were i ntifie Manage- s support of QA activities was evident. The licensis site QA organization is professionally organized and staf)a As was noted in the pruious assessment period, about half of the QA staff had c wpleted operator licensing training ceurses or the STA certification training. One of the current QA supervisors had been an STA on shift prior to assud.ig his present position. 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 refueling outage, startup,

' and plant operating periods. Specifically noteworthy were QA verification activities in surveillance and testing; engineering activities including the ASME Section XI pump and valve testing program and the safety systems functional assessment prog (which was self-initiated); emergency preparedness; fire protection; radiological controls; and security. Site QA is functionally independent and assertive and was effective in the identification and resolution of quality concern QA personnel were actively involved in plant operations. As an example, in addition to programmatic audits, they performed comprehensive and extended (around the clock) surveillances of control rocn and refueling activitie QA communications with the NRC resident staff wsre open and forthright regarding QA ongoing activities and findings. During the region-based fire protection inspection, three licensee quality assurance audit

}

_

.__ . _ _ _

. .

.

reports were reviewed. This review determined that the audia were sufficiently detailed, well documented, performed as required, and had verified appropriate programmatic and implementation aspects of the fire protection program. QA personnel were actively involved in the licensee s problem identification and resolution process, and recent e;Jits and surveillances were "performance based." These audits included maintenance activity, survtillances, and a comprehensive audit of inservice pump and valve testing. The maintenance and surveillance groups were responsive to QA findings and enhancement recommendation A large number of technical issues were resolved during the assessment period, with 15 license amendments issued. An additional seven safety evaluations on other subjects were also issue The !icensee's technical support for these activities was excellen The licensee's applications and responses to staff questions addressed all of the staff's technical concerns on these issues. The technical support for the reload application, power uprating, inservice testing program, reactor vessel head closure studs, anticipated transient without scras (ATWS) rule, and pressure and temperature limits for the reactor ver,tel was excellen The Callaway Plant was among the first group of plants to receive a safety evaluation from NRR on the ATWS rule. Resolution of issues raised by the NRC staff was accomplished by technically thorough, punctual responses from the licensee. During this assessment period, the licensee submitted and the NRC approved the licensee's first ten year inservice testing (IST) program. Additionally, the licensee's technical support for event follovup was generally geo Plant management and operations department personnel were responsive to QA findings and enhancement recommendation . Perf ormanc_e_, Rating The licensee's performance is rated Category 1 in this are Because this is a new area, no rating is available for the previous assessment perio . Recommendations None (

_ _ _ - _ - _ _ - _

._

. .

.

V. SUPPOP. TING OATA AND SUMARIES Licensee Activities During the first three months of this assessment period, the Callaway Nuclear Power Station operated at ncrmal power levels of up to 100%, with the exception of a scheduled load reduction to repair a main feed pump check valve in early July 1987. Routino power operation continued until September 10, 1987, when the plant was shutdown for a scheduled refueling outage (Cycle 2). After restart in November, the plant experienced several power reductions and short outages for equipment repairs, performance of maintenance activities, and conduct of surveillance tests throughout the remaining months of the SALP perio Thelicenseereported21ESFactuations, including 2safetyinjections c (15 of the actuations were the result of personnel errors). Sx

'

reactor trips were reported. There were five automatic trips and one manual trip. Two trips were the result of personnel error, two were caused by component failures, and two were related to design m problems. Four of the trips occurred when operating above 15% power l and two at below 15% power. Significant outages /ma;or events are discussed below: On September 10, 1987, the plant began its scheduled refueling outage (Cycle 2). Major activities included ultrasonic examinationsofselectedfuelassemblies,testingandrepairs of fuel pin leaks, eddy current examinations of A' and 'B'

steam generator (SG) tubes, and minor repairs of the high pressure spindle. The plant attempted startup on November 6, 1988, be+ remained shut down for repair of the pt: king leak on the pressurizer relief block valv The unit was back on line in late November 198 . On January 4, 1988, the plant was automatically shut down from 100% power as a result of a reactor trip on low-low steam generator levels. It was caused by an instrumentation and control technician shorting out some circuitry while

'

troubleshooting an indicating light on the ESF status panel for a main feedwater isolatir, valv . On February 16, 1988, the plant was automatically shut down from 100% power after a turbine / reactor trip while the licensee was performing turbine trip tests. Ajumperwireusedinthe tests came loose and shorted the circuitr > On April 17, 1988, the plant automatically shut down from 80% p uer during a reactor startup on low level in SG. The trip was caused by the operators attempting to control SG 1evels using the main feedwater regulating valves at powers lower than norn.el because the bypass valves were indicating fully ope _

- - - _ - _

_

- .

.

' On April 21, 1988, the plant was manually tripped from 90%

power af ter a feedwater regulating vi,1ve plug separated from the stem. The plant remained shutdown, and the licensee began a scheduled maintenance outage on April 23, 1988. Majoractivities included repairs to a leak on the core thermocouple conoseal, pipe replacements, feed regulating and bypass valve repair and seal weldin . On May 2, 1988, the plant was automatically shut down from 100%

power after a reactor trip on low steam generator level. The trip was caused by a faulty signal from the turbine throttle pressure limiting circui . Inspection Activitiess Thirty-seven inspection reports are discussed in this SALP report (June 1, 1987 through August 31,1988) and are listed in Paragraph 1 of this section, Inspection Data. Table 1 lists the violations per functional area and severity level. Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summar . Inspection Osta Facility : Callaway Docket No.: 50-483 Inspection Report Nos.: 87013, 87015, 87017 through 87036, 88002 through 88005, and 88007 through 88017 Table 1 Number of Violations in Each Severity level Functional Areas III IV V A. Plant Operations 1 1 C. Radiological Controls 2 C. Maintenance / Surveillance 2 Emergency Preparedness 1 Security 2 1 Engineering / Technical Support 2 5 Safety Assessment / Quality Verification TOTALS III IV V T 13 2 Special Inspection Sumary Significant inspections conducted during this SALP 8 assessment period are listed below:

. .

._

.

.

- An emergency preparedness exercise was conducted June 2-4, 1987 (Inspection Report No. 483/87017). A special inspection was conducted August 4-7, 1987, regarding all four channels of overtemperature-deltatemperature trip setpoints which were inoperable t from November 1984 through June 1987 (Inspection Report No. 483/87024). A special inspection was conducted September 8-11, 1987, regarding control room emergency ventilation. Findings uring this inspection resulted in escalated enforcement actions and a $25,000 Civil Penalty (Inspection Report No. 483/87023). A specipl inspection and enforcement conference were conductedAugust24throughSeptember 11, 1987, regarding the licensee s essential service water system operabilit Findings of this inspection resulted in escalated enforcement actions and a $25,000 C1.il Penalty (Inspection Report No. 483/87028). An emergency preparedness exercise was conducted June 6-7, 1988 (Inspection Report No. 483/88010).

C. Escalated Enforcement Actions Two Severity Level III violations and proposed imposition of a Civil Penalty in the amount of $50,000 was issued to the licensee on November 4, 1987. This action was based on violations involving the inoperability of the control room emergency ventilation system because of the breaching of electrical penetrations to install a modification; failure to perform an adequate safety evaluation for the modification; and failure to take prompt corrective actions after a partially closed valve in the essential service water system was identified. Each of the violations was mitigated by 50% because of the prior good performance of the licensee. The licensee paid the $50,000 civil penalty on November 9, 1937, (Enforcement Notice 87-099, Case No. EA-87-194, Inspection Reports No. 483/87023 and No. 483/87028).

D. Confirmatory Action Letters None

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

_ - . _ _ _ _ _ ,

.

'

E. Licensee Amendments Issued Amendment N Description Date Issued 24 Allows for limited replacement June 8, 1987 of fuel rods with filler rods or vacancies.

J 25 Clarifies the ultimate heat sink July 21, 1987 specification and the two separate trains of cooling available for the ESW ' Clarifies the blocking, during July 29, 1987 normal plant shutdowns and startups of the auxiliary feedwater start signal Revises the reporting requirement September 21, 1987 for iodine spiking to be included in the Annual Report, and eliminates the requirement to shut down the plant after 800 hours0.00926 days <br />0.222 hours <br />0.00132 weeks <br />3.044e-4 months <br /> of operation with a dose equivalent I-131 value of 1 microcurie per gram or greate Modifies the tech specs to October 9, 1987 support a Westinghouse 17x17 Vantage 5 (V-5) fuel assembly fueled core.

.

! 29 Revises the definition of the October 14, 1987

fully withdrawn rod position from 228 steps to 225 steps or higher, 30 Revises the license and tech January 13, 1988

specs to remove certain fire

protection requirements, i

'

31 Deletes Item 1.a from Table 4. January 27, 1988 (radiation monitoring instrumenta-

'

tion) and revises Section 4.11. (explosive gas mixture) that references the wrong specification

for Table 3.1-1 Revises organization chart January 29, 1988 l 33 Increases the maximum isolation February 12, 1988 time for the containment mini purge isolation valves from 3 seconds to 5 seconds.

l

!

! 25

- _ _ - - .

. .

U I

Amendment No2 Description Date Issued 34 Adds testing requirements for February 17, 1988 the reactor trip bypass breakers prior to placing them in servic Increases core thermal power from March 30,1988 3411 MWt to 3565 MW Revises the plant heatup/cooldown May 24, 1988 ;

curves, the maximum allowable power operated relief valve setpoint curve, and the reactor i vessel surveillance capsule removal schedul ) 37 Deletes the offsite and unit June 21, 1988 organizational charges and adds  :

the essential aspects of the organizational structur Modified Paragraph 2.E of the June 21, 1988 liensee to require compliance with the amended physical ,

security pla F. Review of Licensee Event Reports Submitted by the Licensee Thirty-three LER's were issued in accordance with NUREG-1022 guidelines during this assessment period. Table 2 shows a cause code comparison of SALP cycle LER Nos. 87008 through 87032 i 88001 through 88008

'

Table 2 (12MO) (15M0) i Cause Areas SALP 7 SALP 8 [

No. (Percent) No. (Percent)

Personnel Errors 17 50.0% 17 51.4%

Design Problems 0 0.0% 2 6.1%

External Causes 0 0.0% 0 0.0%

Procedure Inadequacies 3 8.8% 6 18.2% ,

Component / Equipment 14 41.2% 6 18.2% i Other/ Unknown 0 0.0% 2 6.1%

!

TOTALS 34 33 i FREQUENCY (LERs/MO) .2  :

i NOTE: The above LER information was derived from review of LER's !

l performed by NRC staff and may not completely coincide with [

i the licensee's cause assignments.

!

I I

i

'