IR 05000483/1998003
ML20217A528 | |
Person / Time | |
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Site: | Callaway ![]() |
Issue date: | 04/17/1998 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20217A504 | List: |
References | |
50-483-98-03, 50-483-98-3, NUDOCS 9804220276 | |
Download: ML20217A528 (18) | |
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ENCLOSURE i
U.S. NUCLEAR REGULATORY COMMISSION
! REGION IV i
l Docket No.: 50-483 License No.: NPF-30 Report No.: 50-483/98-03 Ucensee: Union Electric Company Facility: Callaway Plant l Location: Junction Highway CC and Highway 0 l Fulton, Missouri l 1 l Dates: March 1 through April 11,1998 i
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l l Inspectors: D. G. Passehl, Senior Resident inspector )
j F. L. Brush, Resident inspector l R. V. Azua, Project Engineer l l l Approved By: W. D. Johnson, Chief, Project Branch B
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l j ATTACHMENT: Supplemental Information j
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9804220276 980417 PDR ADOCK 05000483 G PDR
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I EXECUTIVE SUMMARY Callaway Plant l NRC Inspection Report 50-483/98-03 l
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Operations l
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Control room communications, briefings, supervisory control, and self-checking were very good during the plant shutdown and cooldown in preparation for Refueling Outage 9 (Section O1.2).
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The licensee's preparations for entering mid!oop operation were good. The licensee complied with the recommended actions in NRC Generic Letter 88-17, " Loss of Decay Heat Removal." The licensee's preparations appropriately addressed shutdown risk, time to boil calculations, decay heat removal system availability, electrical power, reactor coolant system water level and temperature indications, and containment closure l (Section O3.1). !
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Licensee Event Report 98-002 reported the failure to maintain the position of the reactor (
building equipment hatch missile shield within the design basis during past refuel;ng I outages (Section 08.2).
Maintenance
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Material condition and housekeeping of accessible areas of the auxiliary building, the fuel I building, the essential service water pumphouse, and most areas of the turbine building were very good. The licensee erected scaffolding in all areas of the plant in preparation -
for the refueling outage. The work was well controlled and did not affect equipment operability (Ssetion M2.1).
Enaineering l i
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The licensee's review of 7162 preventive maintenance tasks for impact on equipment operability was extensive and thorough. The licensee identified 18 tasks that did not receive required formal safety evaluations. The licensee revised the tasks to eliminate the need to perform the evaluations (Section E3.1).
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Reoort Details Summarv of Plant Status The plant began the report period at 80 percent reactor power. On March 6,1998, operators increased reactor power to 83 percent. On March 17,1998, operators increased reactor power to 86 percent. On April 1,1998, operators decreased reactor powerin preparation for Refueling Outage 9. On April 3,1998, operators opened the main generator output breaker to start the refueling outag I l. Operations 01 Conduct of Operations 01.1 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations, in general, the conduct of operations was professional and safety-conscious. Plant status, operating .
problems, and work plans were appropriately addressed during daily tumover and )
plan-of-the-day meetings. Plant testing and maintenance requiring control room
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coordination were properly controlled. The inspectors observed several shift tumovers and noted no problem .2 Observation of Reactor Shutdown l Insoection Scope (71707)
l The inspectors observed portions of the plant shutdown and cooldown for Refueling Outage 9 from the control roo Observations and Findinas The inspectors observed very good communications within the control room and j between control room and field personnel. With very few exceptions, licensee personnel implemented three-way communications. Pre-evolution briefings were very thoroug Control room personnel exhibited very good supervisory control. Control room personnel used good self-checking techniques when manipulating plant equipmen Conclusions I The inspectors concluded that control room communications, briefings, supervisory control, and self-checking were very good during the plant shutdown and cooldown in
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preparation for Refueling Outage ~
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O1.3 Observations of New Fuel Receiot
- Insoection Scope (71707)
j The inspectors observed portions of new fuel receipt.
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Procedure OTS-KE-00003, " Unloading and Storage of New Fuel Assemblies and
- Fuel inserts," Revision 17, and l
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Quality Assurance Surveillance Report SP98-023, "New Fuel Receipt - Refuel 9." Observations and Findinas_-
l The inspectors observed portions of new fuel assembly receipt and inspection. The l licensee followed all procedural requirements. The licensee performed thorough
! inspections of the fuel assemblies. The licensee identified a bottom nozzle cap screw that was incorrectly installed on one fuel assembly. The fuel vendor's representative repaired the assembly with proper licensee oversight. The licensee found no similar problems on the remaining fuel assemblies.
! The inspectors reviewed the licensee's quality assurance surveillance Report SP98-023
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covering receipt of new fuel. The report documented some very good observation ! 02 Operational Status of Facilities and Equipment O2.1 Review of Eauioment Taaouts (71707)
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The inspectors walked down the following tagouts:
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Workman's Protection Assurance 25898 - Emergency Diesel Generator B and Below Ground Fuel Oil Tank, and l .
Workman's Protection Assurance 26340 - Emergency Diesel Generator B Keep i Warm Syste l l '
l The inspectors did not identify any discrepancies. The tagouts were properly prepared and authorized. All tags were on the correct devices and the devices were in the position prescribed by the tag i
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-3-O2.2 Enoineered Safetv Feature System Walkdowns (71707)
The inspectors used Inspection Procedure 71707 to walk down accessible portions of the following engineered safety features and vital systems: ;
- Auxiliary Feedwater Trains A, B, and T, and
. Essential Service Water Train Equipment operability, material condition, and housekeeping were acceptabl O3 Operations Prccedures and Documentation 03.1 IDsoection of Ooerations Prior to Midlooo inspection Scooe (71707)
The licensee planned to enter hot midloop operations in late April 1998 to remove steam generator nozzle dams. The inspectors examined the licensee's planned actions. The inspectors considered:
- Procedures
. Risk
. Training ,
. Time to boil calculations '
. Cecay heat removal system
. Makeup sources
- Electrical power
. Reactor coolant system water level indications ;
. Temperature indications
. Vent path
. Containment closure The inspectors reviewed the documents listed in the attachment. The inspectors also reviewed the licensee's training schedul Observations and Findinos Procedures l
l The licensee had appropriate normal, off-normal, and emergency procedures for midloop operation.
I aish The inspectors reviewed the licensee's shutdown safety assessment Procedure PDP ZZ-00015, " Shutdown Safety Management," Revision .
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The procedure provided instructions to evaluate the control and impact of evolutions which affect shutdown risk. The evaluation included:
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Reactor coolant system decay heat removal
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Reactor coolant system inventory control
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Maintenance of vital power supplies
. Reactivity control
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. Containment closure '
The inspectors observed that the risk assessment procedure provided satisfactory evaluation of activities affecting shutdown risk. The licensee properly implemented the procedure during the refueling outag Trainina l
The licensee provided training to operators prior to the outage. Licensed operators attended requalification training, which emphasized risk-significant evolutions for Refuel Outage 9. The training included a drain down of the reactor coolant system on the simulator. Other training included lessons leamed from previous events. In addition, the operating crew that performed the actual plant shutdown practiced the shutdown the previous day on the simulato l The inspectors found the licensee's training in preparation for the outage to be very goo Time to Boil Calculations The requirement for calculating time to boil was contained in Procedure OTN-BB-00002,
" Reactor Coolant System Draining," Revision 16. The procedure stated that time to boil calculations would be performed once per shift (every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) when reactor coolant system level was equal or less than 6 inches below the reactor vessel flange. The calculation was also to be performed within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of entering reduced inventory. The licensee defined reduced inventory as reactor coolant system water level less than 3 feet below the reactor vessel flange with fuel in the vesse The inspectors found that the licensee had satisfactory provisions for calculating the time to boi Decav Heat Removal Systern l Procedure OTN-BB-00002 lists the following indicators for monitoring residual heat removal pump pe formance:
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. Residual heat removal pump discharge pressure
. Residual heat removal pump discharge flow
. Reactor coolant system pressure I
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Residual heat removal pump suction valve position l .
Residual heat removal pump motor amps
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Residual heat removal system heat exchanger temperatures
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Core exit thermocouples
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Various main control board annunciators The inspectors found that the licensee had satisfactory methods to monitor decay heat removal system performanc Makeuo Sources Procedure OTN-BB-00002 required the licensee to have at least one centrifugal charging pump and one safety injection pump available during reduced inventor The pumps were required to be capable of taking a suction on the refueling water storage tank and discharging into the reactor coolant system. Guidance on placing the pumps into service was covered in Proceduce OTO-EJ-00001, " Loss of Residual Heat Removal System Flow," Revision 1 I The licensee had provisions to assure adequate makeup sources during reduced inventory condition Electrical Power Procedure OTN-BB-00002 implemented the following administrative controls during reduced inventory
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Switchyard access should be limited to operations department personne .
Access to the vital electrical switchgear rooms would be limited to operations department personnel and security or fire watch patrol .
Orange barricade tape to limit access should be placed around 13.8 kV nonvital switchgear (PA busses) and the cabinets housing relays for the main generator i (MA cabinets). l
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Workman's protection assurance tags should not be placed or cleared on any primary system or any major electrical syste l The inspectors observed that the licensee had properly implemented the administrative control Reactor Cooiant System Water Level Indications Procedure OTN-BB-00002 required, during reduced inventory, that at least two independent reactor coolant loop level indications be:
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. Capable of providing audible alarm in the control room There were two main control board indicators and a computer point for level indication !
with appropriate alarm setpoint Temoerature Indicatigna l Procedure OTN-BB-00002 required that at least two core outlet thermocouples be connected to provide alarm and indication in the control room. The thermocouples were required to be operable while in reduced inventory with the reactor vessel head in plac The licensee had several core outlet thermocouples to provide this functio Vent Path Procedure OTN-BB-00002 required that a formal safety evaluation be performed prior to installing nozzle dams in all four steam generators. The procedure also stated that if a 0.5 square foot or greater vent path was not installed then two safety injection pumps must be available. This was consistent with the licensee's response to Generic Letter 88-1 Containment Closure Procedures OTN-BB-00002 and OSP-GT-00003, " Refueling Containment Penetration Verification," Revision 6, contained sufficient guidance to ensure that containment closure could be achieved within 30 minutes if necessary. The 30-minute time constraint applied to a " hot core" (prior to refuel). After refueling, containment closure time was correlated to the time to boil. The licensee had appropriate guidance to track all containment breaches. The licensae also had proper contingency plans to close the breaches when require Conclusions The inspectors concluded that the licensee's preparations for entering midloop operation were good. The licensee complied with the recommended actions in Generic Letter 88-17. Actions appropriately addressed included shutdown risk, time to boil l calculations, decay heat removal system availability, electrical power, reactor coolant system water level and temperature indications, and containment closur l l
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I-7-08 Miscellaneous Operations issues (92901)
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0 (Closed) Insoection Followuo item 50-483/9707-03: containment penetrations and valves not shown in Final Safety Analysis Report Figure 6.2.4-1.
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The inspectors reviewed the licensee's Final Safety / nalysis Report Change Notice 97-039, which updated Figure 6.2.4-1. The inspectors walked down containment penetrations in piping penetration Rooms A and B and verified that the change notice reflected the actual plant configuration. The inspectors did not observe any discrepancie .2 (Closed) Licensee Event Reoort 50-483/98002: position of reactor building equipment l hatch missile shield during refueling outages was outside of design basi The inspectors reviewed the licensee's corrective actions, which included revising Emergency Plan Implementing Procedure EIP-ZZ-00231, " Response to High Winds /Tomado Watches and Wamings," Revision 4. The procedure was revised to ensure the missile shield was installed during high winds or potential tomadic activit Further, the licensee required that the missile shield be installed with the reactor vessel intemals removed and fuelin the vessel. The inspectors did not have any further ,
concem i The failure to maintain the position of the reactor building equipment hatch missile shield
- within the design basis during past refueling outages was a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy (50-483/9803-01).
II. Maintenance M1 Conduct of Maintenance i M1.1 General Q9mments - Maintenance Insoection Scooe (62707)
The inspectors observed or reviewed portions of the following work activities:
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Work Authorization P603530 - Perform MOVATS testing on essential service water to component cooling water Train A downstream control Valve EGHV0013;
. Work Authorization W186375 - Repair tube leak in component cooling water Train A room cooler;
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l . Work Authorization W618202 - Obtain as-found data on heater drain pump feeder )
Breaker PB0404; and i r I l
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Work Authorization W618172 - Obtain as-found data on 13.8 kV Bus from unit ,
auxiliary transformer Breaker PA010 I l Observations and Findinas The inspectors had no concems with the maintenance obrerved. All work observed was perfoiaed with the work packages present and in active use. The inspectors frequenti, observed supervisors and system engineers monitoring job progress, and quality control
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M1.2 General Comments - Surveillance
' insoection Scone (61726)
f The inspectors observed or reviewed all or portions of the following test activities:
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Test Procedure IDS-BB-OP456, " Reactor Coolant System Pressurizer Pressure Channel," Revision 15; l
. Test Procedure ISP-SA-2413A, " Diesel Generator and Sequencer Testing l (Train E>)," Revision 10; l
. Test Proc ( are OSP-NE-00248, " Standby Diesel Generator B 24 Hour Run and -
Hot Restart Test," Revision 1; l . Test Procedure ISL-NE-00N31, " Loop-Nuc, Nuclear instrumentation Source j Range N31," Revision 15; and l-l . Test Procedure ESP-AB-01000, " Main Steam Safety Valve Set Pressure Testing," Revision 1.
l Observations and Findinas Surveillance testing observed during this inspection period was conducted satisfactorily l
in accordance with the licensee's approved programs and the Technical Specifications.
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l M2 Maintenance and Material Condition of F.cilities and Equipment !
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L l M2.1 Review of Material Condition Durina Plant Tours ! inspection Scone (62707)
The inspectors performed routine plant tours to evaluate niant material condition.
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. Observations and Findinas Material condition and housekeeping of accessible areas of the auxiliary building, the fuel building, the essential service water pumphouse, and most areas of the turbine building were very good. During the refueling outage, the licensee began to correct material condition concems that were identified during the operating cycle. The licensee erected scaffolding in all areas of the plant in preparation for the refueling outage. The work was well controlled and did not aifect equipment operabilit During the -* fueling outage, four failures of nonsafety related General Electric Magne-Blast circuit breakers occurred. The affected breakers were in 13.8 kV and 4.16 kV switchgear. The licensee initiated an in-depth review of the events to determine the root causes. All safety-related General Electric Magne-Blast circuit breakers performed satisfactorily during engineered safety features actuation system testing earlier in the outag As a result of the failures, the licensee expanded the scope of the planned breaker i
maintenance and inspections during the refueling outage. The inspectors will review the (
results of the licensee's investigation during a future inspection (Inspection Followup ltem 50-483/9803-02).
M8 Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Violation 50-483/9720-01: temporary gauge on Emergency Diesel Generator A engin Licensee personnel failed to follow documented instructions during a preventive maintenance task on the Emergency Diesel Generator A engin The licensee determined that inadequate communication was the primary cause for the violation. Additionally, work instructions were not clearly writte The licensee's corrective actions for the violation included:
. Enhancing the shift turnover process to provide more detailed discussions on work status; and
. Clarifying work instructions in the preventive maintenance tas The inspectors had no further concerrs. Engineering department personnel developed an action plan to consider gerwric implications. The inspectors' review of the action plan implementation is discussed in Section E3.1.
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Diesel Generator A engin This licensee event report was reported as a result of Violation 50-483/9720-01. This licensee event report was closed based on the corrective actions described in Section M ,
111. Engineering E3 Engineering Procedures and Documentation l
5. Review of Enaineerina Action Plan 97-109 on Temocrarv Instrumentation Insoection Scone (37551)
l The inspectors reviewed Engineering Action Plan 97-10 '
The plan addressed:
- Temporary instruments put into service on operable systems; and j l
. Preventive maintenance tasks that could manipulate plant equipment without a l license impact review or formal safety evaluatio Observations and Findinos l I
Temocrarv instruments Put into Service On Operable Systems j i
Plant management issued a night order that strengthened control of temporary gauge ,
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Specifically, installation, use, and removal from service of 13mporary gauges was directed to be controlled by workman's protection assurance tags and Administrative Procedure APA-ZZ-00605," Temporary System Modifications," Revision 8. The night ,
order stated that under no circumstances should a temporary gauge be left valved in and i unattended. Otherwise, a formal safety evaluation was required to approve the temporary installation.
l The licensee later revised Procedure APA-ZZ-00605 to incorporate the above guidanc ,
l The licensee was in process of revising all department procedures to reflect the new l guidance in Procedure APA-ZZ-00605. The inspectors considered the licensee's
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progress in revising department procedures to be acceptabl !
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l' -11- 1 Preventive Maintenance Tasks That Direct Manioulations of Plant Eauioment Withoula l License Imoact Review or Formal Safetv Evaluation The licensee reviewed all preventive maintenance tasks to determine if any tasks ;
required manipulation of plant equipment in addition to directing maintenance. The l l licensee reviewed all 71S2 preventive maintenance tasks against the following criteria:
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Whether the preventive maintenance task required manipulation of any plant equipment or installed temporary instrumentation; e Whether the associated system was in service or considered operable when the preventive maintenance task was performed; and
. Whether the preventive maintenance instructions were agi from a reviewed procedur l
.The licensee found that 788 of the 7162 preventive maintenance tasks met all of the I criteria. The licensee then performed a safety evaluation screening on each of the 788 task )
The safety evaluation screening determined whether the preventive maintenance task was:
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A proposed change to the facility as described in the Final Safety Analysis Report;
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A change to the procedures as described in the Final Safety Analysis Report; or i
. A test or experimcat not described in the Final Safety Analysis Report or I Technical Specification The licensee found that 18 of the 788 preventive maintenance tasks met at least one of the three screening criterion. The licensee had the option of either performing formal safety evaluations on each of the 18 tasks or changing each task such that none of the l screening criterion applied. The licensee changed the tasks. The laspectors reviewed I the changes and had no concem Administrative Procedure APA-ZZ-00140, " Safety, Environmental, and Other Licensing 1 Evaluations," Revision 24, required, at Step 3.1.1.b, that a formal safety evaluation be performed on ai; activities which satisfied the screening criterion, j The inspectors consdered the 18 instances to be examples of a violation of the administrative procedure requirement. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll. of the NRC Enforcement Policy (50-483/9803-03).
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-12- Conclusions The inspectors concluded that the licensee's review of 7162 preventive maintenance tasks for impact on equipment operability was extensive and thorough. The licensee identified 18 tasks that did not receive required formal safety evaluations. The licensee i
revised the tasks to elirninate the need to perform the evaluation j E8 Miscellaneous Engineering issues (92903)
E8.1 (Closed) Inspector Followuo item 50-483/9714-05: response time discrepancy with control room ventilation radioactivity monitor Final Safety Analysis Report Table 7.3-7 stated that the response time of the control ;
room ventilation radioactivity Monitors GKRE04 and GKRE05 was less than 3.0 second Previous response times reported for Monitor GKRE04 and GKRE05 were 4.1 seconds and 3.8 seconds, respectivel l The licensee identified that the 3.0 second response time listed in Table 7.3.7 was an inadvertent carryover from the Preliminary Safety Analysis Report. The licensee was unable to identify any other instance where the 3.0 second response time value was listed, required, or relied upon by the NRC in approving the operating licens The licensee determined that Monitors GKRE04 and GKRE05 were designed to protect against the effects of a fuel handling accident or a waste gas decay tank rupture. The licensee identified that a control room ventilation system response time of less than 5.0 seconds would be sufficien The licensee submitted Final Safety Analysis Report Change Notice 97-047 to document the new response time. The inspectors did not identify any further concem IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 Radioloaical Controls at Power and Durina Refuelina Outagg Insoection Scooe (71750)
The inspectors observed radiological contro:s at power and during the refueling outage.
! Observations and Findinas The inspectors observed health physics persomel, including supervisors, routinely touring the radiologically controlled area ,
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- Contaminated areas and high radiation areas were property posted. Step off pads were
- conspicuous and well placed. Area surveys posted outside rooms in the auxiliary building were current. However, the inspectors observed that one of the two survey books at the radiological access contrcl area included out-of-date surveys for the two residual heat removal pump rooms. The licensee removed the survey book. The inspectors verified that the locally posted surveys were correct, l
l The inspectors checked a sample of doors, required to be locked for the purpose of radiation protection, and found no problems.
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The licensee identified some weaknesses involving dosimetry and radiological work permit usage during the outage. These issues will receive further review during a l
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radiological controls inspection scheduled for later this outage. The inspection results l will be documented in NRC Inspection Report 50-483/98-07. The inspectors identifiM ,
j no further concem !
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l V. Management Meetings l l l L X1 Exit Meeting Summary i
The exit meeting was conducted on April 10,1998. The licensee did not express a l l- position on any of the findings in the report.
l The inspectors asked the licensee whether any materials examined during the inspection j- 'should be considered proprietary. No proprietary information was identifie The inspectors informed the licensee of an inspection followup system numbering error
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in NRC Inspection Report 50-483/98-01.. The attachment titled " Items Opened, Closed, and Discussed" to that report incorrectly identified a noncited violation as 50-483/9801-02. The noncited violation should have been numbered 50-483/9801-03.
l The inspectors also informed the licensee that NRC inspection Report 50-483/98-02 had
[ conflicting instructions on responding to the Notice of Violation 50-483/9802-01. The L licensee was not required to respond.
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ATTACHMENT SUPPLEMENTAL INFORMATION l
PARTIAL LIST OF PERSONS CONTACTED Licenseg R. D. Affolter, Manager, Callaway Plant l H. D. Bono, Supervising Engineer, Quality Assurance Regulatory Support M. S. Evans, Superintendent, Health Physics J. M. Gloe, Supervisor, Maintenance G. A. Hughes, Supervising Engineer, Independent Safety Engineering Group R. T. Lamb, Superintendent, Operations J. R. Peevy, Manager, Emergency Preparedness /Org. tizational Development G. L. Randolph, Vice President, Nuclear M. A. Reidmeyer, Engineer, Quality Assurance Regulatory Support G. P. Scheperle, ALditor M. E. Taylor, Assistant Manager, Work Control INSPECTION PROCEDURES USED 37551 Onsite Engineering 61726 Surveillance Observations 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities 92901 Followup - Plant Ooerreons 92902 Followup - Maintenance 92903 Followup - Engineering l
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! ITEMS OPENED. CLOSED. AND DISCUSSED l
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l 4 l 9803-01 NCV Mispositioned reactor building equipment hatch missile shield ,
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l l 9803-02 IFl Expanded scope of magne-blast circuit breaker inspection j (Section M2.1).
9803-03 NCV No required safety evaluations on preventive maintenance j tasks (Section E3.1).
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! 9707-03 IFl Containment penetrations and valves not shown in Final j Safety Analysis Report (Section 08.1).
l j 98002 LER Mispositioned reactor building equipment hatch missile shield during refueling (Section 08.2).
, 9803-01 NCV Mispositioned reactor building equipment hatch missile shield
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during refueling (Section 08.2). l l
9720-01 VIO Temporary gauge on Emergency Diesel Generator A engine (Section M8.1).
! 97011 LER Temporary gauge on Emergency Diesel Generator A engine l (Section M8.2).
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l 9803-03 NCV No required safety evaluations on preventive maintenance tasks (Section E3.1).
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l 9714-05 IFl Response time discrepancy with control room ventilation i radioactivity monitors (Section E8.1).
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-3-1 MIDLOOP PROCEDURES AND DOCUMENTATION Generic Letter 88-17, " Loss of Decay Heat Removal"-
Special Operating Procedure OTS-BB-00002, " Draining Steam Generator U-Tubes Using Nitrogen Injection," Revision 3 :
Special Operating Procedure OTS-BB-00006, " Draining the Reactor Coolant System and
, Refueling Pool Without Fuel in the Reactor Vessel," Revision 2 Off-Normal Operating Procedure OTO-EJ-00001, " Loss of Residual Heat Removal System Flow," Revision 10 l Off-Normal Operating Procedure OTO-NB-00003," Loss of Power to NB01 and NB02 in Modes 5 and 6," Revision 3 Normal Operating Procedure OTN-BB-00002, " Reactor Coolant System Draining," Revision 16 General Operating Procedure OTG-ZZ-00007, " Refueling Preparation, Performance and Recovery," Revision 11 ,
l General Operating Procedure OTG-ZZ-00006, " Plant Cooldown Hot Standby to Cold ,
l Shutdown," Revision 17 i
l Surveillance Procedure OSP-GT-00003, " Refueling Containment Penetration Verification, ;
Revision 6 j Administrative' Procedure APA-ZZ-00150, " Outage Preparation and Execution," Revision 6 l !
Annunciator Response Procedure OTA-RL-RK065," Window 65A through 65F," Revision 3 Planning and Scheduling Procedure PDP-ZZ-00015, " Shutdown Safety Management,"
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