IR 05000483/1989004
| ML20245A465 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/13/1989 |
| From: | Defayette R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245A461 | List: |
| References | |
| 50-483-89-04, 50-483-89-4, NUDOCS 8904250213 | |
| Download: ML20245A465 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report'No. 50-483/89004(DRP)
Docket No. 50-483 License No. NPF-30
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' 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:
February 16 through March 31, 1989 Inspectors:
B. H. Little C. H. Brown hY b
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Approved By:
. W. DeFayett, Chief Reactor Projects Section 3A Date Inspection Summary Inspection from February 16 through March 31, 1989 (Report No. 50-483/89004(DRP))
Areas Inspected:
A routine unannounced safety inspection of plant operations, radiological controls, maintenance / surveillance, emergency preparedness, security,. safety assessment / quality verification, and regional and headquarters requests was. performed.
Results:
No violations were identified.
One unresolved item was opened -
pertaining to the operability of the auxiliary feedwater system (AFW) with
'a backup source of water or steam not available.
This unresolved item resulted from the otherwise satisfactory walkdown of the AFW system (Paragraph 2c). With the core at the end-of-life, the utility's operating crew demonstrated effective supervision and control of plant activities, with the exception of an improper valve lineup which resu'u d in dumping resin to
"radwaste" and a minor noble gas release (Paragrapn TC.
The short term actions for loss of shut down cooling, addressed in tae answer to GL 88-17, were found to be available prior to refuel 3 (Paragraph 7).
One event in each of the areas, radiological controls and security, were reviewed.
Performance in these areas were found to be generally acceptable (Paragraphs 2e and 5).
Maintenance and surveillance continue to be effectively planned, performed and supervised (Paragraph 3).
8904250213 890313
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FDR ADOCK 05000483
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DETAILS 1.
Persons Contacted
- 0. F. Schnell, Senior Vice President, Nuclear
- G. L. Randolph, General Manager, Nuclear Operations
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- J. D. Blosser, Manager, Callaway Plant C. ['. Naslund, Manager, Operations Support J. V. Laux, Manager, Quality Assurance J. R. Peevy, Assistant Manager, Technical Services
- W. R. Campbell, Manager, Nuclear Engineering M. E. Taylor, Superintendent, Operations D. E. Young, Superintendefit, Mair,tenance W. R. Robinson, Assistant Manager, Operations and Maintenance R. R. Roselius, Superintendent, Health Physics-T. P. Sharkey, Supervising-Engineer, Site Licensing G. J. Czeschin, Superintendent, Planning and Scheduling W. H. Sheppard, Superintendent, Outages G. R. Pendegraff, Superintendent, becurity L. H. Kanuckel, Supervisor, Quality Assurance Program G. A. Hughes, Supervisor, Independent Safety Engineer Group
- J. C. Gearhart, Superintendent, Operations Support, Quality Assurance J. J. Cassmeyer, Quality Assurance Engineer C. S. Petzel, Quality Assurance Engineer
- Denotes those present at one or more exit interviews.
In addition, a number of equipment operators, reactor operators, senior reactor operators, and other members of the quality' control, operations, maintenance, health physics, and engineering staffs were contacted.
2.
Plant Operations (71707, 71710)
a.
Operational Safety Verification Inspections were routinely performed to ensure that the licensee conducts activities at the facility safely and in conformance l
with regulatory requirements.
The inspections focused on the implementation and overall effectiveness of the licensee's control
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of operating activities, and on the performance of licensed and I
non-licensed operators and shift technical advisors.
The inspections included direct observation of activities, tours of the facility, interviews and discussions with licensee personnel, independer.t verification of safety system status and limiting conditions of
operation (LCO), and reviews of facility procedures, records, and reports.
The following items were considered during these inspections:
Adequacy of plant staffing and supervision.
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Control room professionalism, including procedure adherence,-
operator attentiveness, and response to alarms, events, and off-normal conditions.
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Operability of selected safety-related systems, including attendant alarms, instrumentation, and controls.
Maintenance of quality records and reports.
- The inspectors observed that control room supervisors, shift technical advisors, and operators were attentive to plant conditions,
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performed frequent panel walkdowns and were responsiv'e to off-normal alarms and conditions.
b.
Off-shift Inspection of Control Rooms The inspectors performed routine inspections of the control room during 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 inspectors determined that both licensed and non-licensed operators were attentive to their duties, and that the administrative controls relating to the conduct of operation were being adhered to.
c.
Engineered Safety Features (ESF) System Walkdown The operability'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, that equipment, instrumentation, valve and electrical breaker lineup status is in agreement with procedure checklists, and verification that locks, tags, jumpers, etc. are properly attached and identifiable.
Auxili.wy Feedwater (AFW) System Walkdown j
The inspectors performed a walkdown of the auxiliary feedwater (AFW) system piping and confirmed that the system was as shown on the "as-built" drawing.
(No actual pipe lengths or positions were measured.) The major components were found to be properly
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labeled.
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The valve positions and power supplies were found to be correct as called out on the normal operating procedure system lineup checklist (except as noted below).
The review of procedures showed that Procedure OTN-AL-00001 provides the required lineup with the plant at power.
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Components, breakers, and compartments were noted to be clean and satisfactorily maintained, i.e., no packing leaks were found, valve stems and cooling fans were properly lubricated, satisfactory nil l
levels were maintained in the motors, and no bent valve stems or missing handwheels were noted.
The AFW system hangers and supports were found to be as shown on the "as-built" drawings.
The hangers' physical conditions were satisfactory with no apparent attachment damage.
Instrument air and backup nitrogen accumulators for the turbine driven auxiliary feedwater pump (TDAFP) flow control valves were found to be properly aligned and were maintained at the necessary pressures.
Calibration and surveillance records indicated that the instruments were functioning satis factorily.
The setpoints and operating parameters were within the normal operating values.
The records showed that the pumps and valves were functioning within the required limits.
The instrumentation measuring and test equipment calibration dates were current.
On March 10, 1989, with the plant operating in Mode 1, during a walkdown of the TDAFP suction piping, the inspector observed a modification to the ESW train 'A' alternate suction piping to the TDAFP.
The modification involved the addition of a pipe stub, valve, and hose connection to provide alternate cooling water to the breathing and 'C' service air compressors.
The associated suction piping was isolated by valves and a freeze seal to permit work activities.
The inspector observed that the work was being accomplished in accordance with appropriate work documents, and was being monitored by quality control engineering and maintenance supervision.
The Callaway modification package (CMP-88-1032) contained the appropriate safety reviews and approvals.
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The inspector reviewed the equipment " operability status" in the control room and found that the TDAFP was considered operable and was not listed for Technical Specification (T/S) Limiting Condition for Operation (LCO) tracking.
T/S LC0 3.7.1.2 requires that three auxiliary feedwater pumps (includes the TDAFP) and associated flow paths be operable in Mode 1, 2, and 3.
Surveillance requirement 4.7.1.2.1 requires verifying that each non-automatic valve in the
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flow path be in its correct position.
The ESW Train 'A' flow path to the TDAFP was restored to normal lineup within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (within the allowed 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action requirement of LC0 3.7.1.2), and therefore, T/S compliance was not an issue.
However, the determination that the TDAFP remained
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l operable with an inoperable alternate suction flow path did not
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appear to meet the requirements as specified in LC0 3.7.1.2.
This matter was discussed with plant management on March 11, l
1989.
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Subsequent licensee evaluation (On-site Review Committee) determined
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that the TDAFP was inoperable when any of its suction, discharge or l
steam supply flow paths are inoperable, but that ESW or diesel j
generator inoperability does not render the TDAFP inoperable.
j The licensee's position was issued as T/S interpretation Number 50, i
dated March 14, 1989.
In addition, the licensee has initiated action
to obtain an engineering evaluation to determine if TDAFP operability requirements can be satisfied by only one steam supply and one alternate suction supply line.
LCO 3.7.1.2 specifies " associated flow paths" and "an operable steam supply system," and does not specifically address the redundant steam and alternate supply lines to the TDAFP.
The loss of either train of the ESW system results in the inoperability of one of the two motor driven AFPs and may (subject to an engineering evaluation) result in inoperability of the TDAFP e.g.; loss of an associated flow path.
The loss of two AFPs results in a six-hour shutdown action requirement.
As ESW trains have been periodically removed from service for preventive / corrective maintenance and testing for durations exceeding six hours, further review is required to assess prior licensee compliance with LCO 3.7.1.2.
This item is unresolved (483/89004-01(DRP)).
d.
Plant Material Conditions / Housekeeping The inspectors performed routine plant tours to assess material conditions within the plant, ongoing quality activities and plantwide housekeeping.
The inspectors also accompanied the licensee's management on monthly plant tours.
e.
Radiological Controls 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
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reports.
Event:
On March 18, 1989, a small (several factors of 10 below the release limits) release of noble gas occurred.
Although the release was not planned, the path was the normal vent path for the radwaste building and is constantly monitored.
The highest
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recorded level for a 10 minute time span was 0.000105 microcuries per milliliter.
(A microcurie is one millionth (0.000001) of a curie.)
Cause:
The operating crew attempted to place the boron thermo-regeneration system (BTRS) in service on March 18-to reduce the boron concentration in the reactor coolant.
A " fresh bed" of new resin had been installed several days before and a valve had been left partially open due to a design error.
When the BTRS was placed in service, this partially open valve allowed the new resin (70 cu.
f t.) and approximately 2,000 gallons of primary coolant to flow to the spent resin storage tank.
This amount of material over-filled
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the tank resulting in a rupture disc breaking and allowing the water to flow.to the radwaste sump.
The noble gas was released when the water reached the sump and a concentration of seven times the maximum permissible concentration (MPC) was reached inside the building.
(The alert level for this gas is 30 MPC.
At 30 MPC the workers in the building would be required to put on glasses to protect their eyes.) The gas from the water in the sump was drawn through filters so that no iodine or particulate was released.
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The event review team was called to the site to establish the root cause and to recommend corrective actions.
The resident inspector monitored the ieview as it progressed.
No violations or deviations were identified.
3.
Maintenance / Surveillance (62703, 61726)
Selected portions of the plant surveillance, test and 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 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
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systems to service; parts and materials that were used were properly
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certified; and appropriate fire prevention, radiological, and housekeeping conditions were maintained.
" a.
Maintenance The reviewed maintenance activities included:
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Work Request No.
Activity
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P400431 Maisture Separator Reheater 'O'
pressure relief valve trevatest.
P452085 Install return hose from the breathing air compressor to the ultimate beat sink.
W452073 Remove and reapply fireproofing on pipe hangers so hangers can be inspected.
W122222A Adjust packing on motor driven auxiliary feedwater pump to steam gererator 'B' flow control valve.
W122199 Trouble shoot N42 reactor power range meter.
C423145 Modified unit vent for new isokinetic probes (wider flow range CMP-85-0017).
W120182 Inspect Raychem heat shrink tubing and correct if required on reactor coolant pressure instrument BB-PT-0403.
W123069 Trouble shoot 0.7 amp on neutral center tap for emergency diesel gererator number 2.
b.
Surveillance The reviewed surveillance included:
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Procedure No.
Activity OSP-AL-00003 Auxiliary feedwater low suction pressure -
condensate storage tank to emergency service water valve operability.
OSP-AL-00002 Auxiliary feedwater to steam generator flow path verification.
OSP-AL-P001A Section XI motor driven auxiliary feedwater pump 'A' operability test.
OSP-AL-00001 Auxiliary feedwater system flow paths
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valve alignment.
OSP-AL-V002A Auxiliary feedwater and steam supply check valve operability.
MSM-ZZ-QWOO5 Mechanical snubber functional test.
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Procedure No.
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OSP-AL-V001C Turbine driven train - auxiliary feedwater valve operability.
ISL-GS-00A2B Containment hydrogen concentration analysis transmitte r.
ISL-EF-00P43 Loop - Pressure; Essential service water flow to air compressor 'A'.
ISF-BB-0P458 Functional Pressure; Reactor coolant system pressurizer pressure protection 'B' pressure transmitter.
MTE-ZZ-QA001 Motor operated valve actuation testing of motor driven auxiliary feedwater pump to steam generator 'B' flow control valve.
ETP-AE-ST002 Test to evaluate the use of variable pH for
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controlling feedwater venturi fouling.
OSP-AL-V001A Train 'A' auxiliary feedwater valve operability.
' IS L-SE-00N42 Loop - Nuclear; Nuclear instrument power range N42.
ISL-BB-T423B Loop - Temperature:
Reactor coolant temperature wide range (T cold).
ISL-BB-T443A Loop - Temperature:
Reactor coolant temperature wide range (T hot).
. Control room shift and daily log reading and channel checks.
ISL-GS-00 CIA Loop - Miscellaneous:
Containment hydrogen recombiner 'B'.
ISL-GG-00R28 Loop - Nuclear:
Fuel building vent radiation detector.
ISF-BB-0P403 (Performed after W120182) - Functional -
Pressure:
Pressure operated relief valve
(PORV) actuation' channel.
ISF-GT-00R32 Functional - Nuclear:
Containment atmosphere radiation detector.
ISL-SG-00A58 Loop - VI B; Seismic response spectrum recording system.
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'o violations or deviations were identified.
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4.
Emergency Preparedness (82301)
An inspection of emergency preparedness activities was performed to assess the licensee's implementation of the emergency plan and implementing procedures.
The inspection included monthly observation of emergency facilities and equipment, interviews with licensee staff, and a review of selected emergency implementing procedures.
FEMA held an unannounced " call-out" drill for the State and local emergency response personnel.
The licensee provided the drill controllers for the exercise.
This drill is part of a six year cycle of emergency response evaluations.
The inspector observed part of the drill at the emergency offsite facility and discussed the progress with one of the FEMA evaluators.
The results of the drill were satisfactory.
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No violaticas or deviations were identified.
5.
Security (71881)
The licensee's security activities were observed by the inspectors during routine facility tours and during the inspectors' site arrivals and departures.
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 thoroughness.
The licensee has taken positive action on previous concerns including vital area doors and vehicle control.
This action has resulted in a reduction in the number of occurrences.
During the inspection period, a visitor was found inside the protected area who had become separated from his escort for a short period of time.
The licensee took immediate corrective action.
Regional security personnel have the lead on this item.
No violations or deviations were identified.
6.
Safety Assessment / Quality Verification (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, self improvement programs, response to regulatory and industry initiatives, the fregtency of management plant tours and control room observations, and management personnel's attendance at technical and planning / scheduling rieetings.
The inspectors attended On-site Review Committee meetings and incident / event critiques and reviewed related documents, focus ng on the licensee's root cause
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The inspection also included
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a review of quality records cnd selected quality assurance audit and I
surveillance activities.
Performance in this area included the following j
major items:
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During a previous quality assurance program evaluation (Inspection Report
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No. 50-483/89001(DRP)) of operations and maintenance work control programs, a possible weakness in worker protection assurance (WPA) was noted.
The managements' response included increasing emphasis on proper performance of the WPA function and critiquing improper or incomplete WPA performance.
During this inspection period, two field performance evaluations were conducted on the WPA program.
The results of these evaluations indicate that weaknesses in the WPA program no longer exist.
The inspectors have discussed portions of the refueling outage evaluation program with the audit group. They have found it to provide a wide scope of work performance and maintenance evaluations to insure the quality of plant equipment.
The evaluations will be based primarily on field performance and procedure implementation.
No violations or deviations were identified.
7.
Inspection of Regional and Headquarters Requests (255101)
Temporary Instruction (TI) 2515/101 - Loss of Decay Heat Removal (Generic Letter (GL) Number 88-17).
An inspection of this matter was performed to verify the licensee's preparation for lowered inventory operation in accordance with " Loss of Decay Heat Removal" (GL 88-17), 10 FR 50.54(f), October 17, 1988.
The inspection was performed in accordance with TI 2515/101 " Inspection Requirements" and included the review of GL 88-17 and associated documents, the licensee's response " Expeditious Actions", ULNRC-1880, and NRC comments on the licensee's response to GL 88-17.
Inspection Findings a.
Training Through personnel interviews and the review of licensed operator training records the inspector verified that the licensee's requalification training included as " lessons learned," industry events relating to reduced inventory operations.
The training also included Technical Specifications, procedural and administrative changes.
Craft personnel (including contract maintenance personnel)
have received special pre-outage training relating to industry events associated with reduced inventory operations.
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b.
Containment Closure The licensee has implemented appropriate administrative controls and procedures for the control of containment openings and procedures for containment isolation in the event of loss of decay heat removal.
Procedures specify only one side of a penetration is worked at a time and also that the equipment hatch is closed during reduced inventory conditions.
In addition, personnel have been designated responsibility for the removal of hoses and cables, and closure of local leak rate test penetrations.
c.
Tf:mmature Indication Tha licensee nas provided two or more continuous coolant temperature indicators which monitor separate core locations.
The temperature indicators are independent except for the sharing of a single corn
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This variance is considered acceptable as an
" expeditious action," based on discussions with NRR staff.
d.
Reactor Coolant System (RCS) Water Level Indication Two mear,s of RCS level indication are provided; one is a pressure transmitter providing indication and alarm in the control room, the other is a Tygon hose located in containment.
Procedures provide for the resolution of level discrepancies, voiding as detected by thermocouple (TCs) and the periodic walkdown of the Tygon tube.
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RCS Perturbations l
The licensee has implemented procedures to preclude operations which would lead to RCS level perturbations (administrative Procedure APA-ZZ-150 Outage reparations and Execution).
In addition, Technical Specification changes to enhance stable reduced inventory operation has been submitted the the NRC
for approval.
f.
RCS Inventory The licensee has implemented procedures which specify means of adding inventory to the RCS in addition to the normal decay of heat removal system.
The procedures specify available water sources.
g.
Hot Leg Flow Paths
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The licensee's outage schedule limits blocking of more than two hot legs during the Cycle 3 refueling outage, and therefore has not performed calculations for conditions which would require a vent path.
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Loop Stop Valves l
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The Callaway plant does not contain loop stop valves.
The inspection showed that the licensee has implemented appropriate action to prevent and or to respond to the loss of decay heat removal z
during reduced inventory operations.
TI 2515/101 is considered closed.
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8.
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 commitment, or a deviation.
An unresolved item is identified in Paragraph 2c.
9.
Exit Meeting (30703)
The inspectors met with licensee representatives (denoted under Persons Contacted) at intervals during the inspection period.
The inspectors summarized 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 proprietary.
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