IR 05000483/1999005

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Insp Rept 50-483/99-05 on 990502-0612.Two Violations Noted & Being Treated as Noncited Violations.Major Areas Inspected: Operations,Maint,Engineering & Plant Support
ML20196H326
Person / Time
Site: Callaway Ameren icon.png
Issue date: 06/25/1999
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20196H256 List:
References
50-483-99-05, 50-483-99-5, NUDOCS 9907060228
Download: ML20196H326 (18)
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

' Docket No.: 50-483 License No.: NPF-30 Report No.: 50-483/99-05 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Fulton, Missouri Dates: May 2 through June 12,1999 Inspectors: D. G. Passehl, Senior Resident inspector J. D. Hanna, Resident inspector Approved By: D. N. Graves, Chief, Project Branch B ATTACHMENT: Supplemental Information l

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9907060228 990625 PDR ADOCK 05000483 0 PDR _

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EXECUTIVE SUMMARY l l

Callaway Plant i NRC Inspection Report No. 50-483/99-05 l Operations

  • Operations personnel demonstrated good communications, coordination, command and control, and procedure usage during routine control room activities, including shift turnovers. Management osersight of these activities was appropriate. Equipment operators were knowledgeable of responsibilities in their assigned areas (Section O1.1).

Maintenance

= The licensee was slow in recognizing the adverse trend in material condition for the essential service water system. The system experienced a number of vibration-induced problems. The licensee's completed and planned corrective actions were appropriate and comprehensive (Section M2.2).

  • The failure to meet flow rate surveillance requirements for the control room emergency ventilation system Train B from January 19,1996, until July 22,1998, was a violation of Technical Specificawns 4.7.6.c.1,4.7.6.c.3, and 4.7.6.e.1. This Severity Level I,V vic!ation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence-Solution Report 99-0259 (Section M8.3).

Enaineerina a The modification package to replace the orifice plates in the essential service water return lines from the component cooling water heat exchangers was properly prepare The licensee appropriately and successfully performed the required postmodification testing (Section E1.1). l

  • The inspectors conducted an abbreviated review of Year 2000 activities and documentation using Temporary Instruction 2515/141, " Review of Year 2000 (Y2K)

Readiness of Computer Systems at Nuclear Power Plants." Conclusions regarding the Year 2000 readiness review are not included in this summary. The results of this review will be combined with reviews of Year 2000 programs at other plants in a summary .

report to be issued by July 31,1999 (Section E1.2). l Plant Support

= The failure to provide minimum illumination of 0.2 foot-candles to outdoor portions of the i plant was a violation of Section 3.1.3.1 of the Security Plan. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence Solution Report 99-0995 (Section S2.1).

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a Report Details iSummarv of Plant Status i-The plant began the report period on May 2,1999, at 100 percent power. On May 28,1999,

, operators decreased reactor power to 93 percent due to a tube leak on Low Pressure Feedwater Heater 1 A. By May 30,1999, personnel had completed repairs and returned the

- plant to 100 percent reactor powe . Operations 01 Conduct of Operations

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01.11 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.' Procedure usage was good. Plant testing and maintenance requiring control room coordination were properly controlled. The inspectors observed several shift turnovers and noted no problem ]

' On May 14,1999, the inspectors performed a tour with an equipment operator assigned r- to the primary side of the plant. The operator demonstrated a good working knowledge

. of equipment and procedures. Overall, the operator performed wel . Operations! Status of Facilities and Equipment O2.1 ~ Review of Eauioment Taoouts (71707)

The inspectors walked down the following tagouts:

  • - Workman's Protection Assurance 30929 - Emergency Diesel Genarator A Engine 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 .

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-2-O2.2 Enaineered Safety Feature System Walkdowns (71707)

The inspectors walked down accessible portions of the following engineered safety features and vital systems:

. Essential Service Water

. Control Room Ventilation

. Emergency Diesel Generators i Equipment operability and housekeeping were very good. Except for the essential service water system downstream of the component cooling water heat exchangers, external equipment material condtion was also very good (see Section M2.2).

06 Operations Organization and Administration 0 Review of Evaluation and Accreditation Reoorts by the Institute of Nuclear Power Operations Inspection Scoce (7170_7_1

The inspectors reviewed the March 18,1999, interim report of the Institute of Nuclear j Power Operations' 1999 evaluation of Callaway Nuclear Plan j Observations and Findinas Personnel from the Institute of Nuclear Power Operations conducted an evaluation of

site activities during the weeks of January 25 and February 1,1999. The inspectors !

l completed a review of the report described abov I II. Maintenance M1 Conduct of Maintenance

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M1.1 General Comments - Maintenance  ;

t l Insoection Scope (62707)

The inspectors observed or reviewed portions of the following work activities:

  • Work Authorization C605888 - Relocate Emergency Light in the NK14 Battery Room to Eliminate Safety Hazard

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Work Authorization C575007 - Replace Feeder Breaker to Emergency Fuel Oil System Storage Tank A Fuel Oil Transfer Pump

Work Authorization P623207 - Clean and Repack coupling on Emergency Diesel Generator A Lubrication Keep Warm Pump Observations and Findinas The inspectors identified no substantive concerns. All work observed was performed with the work packages present and in active use. The inspectors frequently observed supervisors and system engineers monitoring job progress, and quality control j personnel were present when require '

M1.2 General Comments - Surveillance Inspection Scope (61726)

The inspectors observed or reviewed all or portions of the following test activities:

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  • Test Procedure ISL-GT-OR218, " Loop Nuc; Plant Unit Vent Effluent Radiation '

Detector," Revision 19

  • Test Procedure OSP-NB-00001," Class 1E Electrical Source Verification,"

Revision 9

  • Test Procedure OSP-KC-00007, " Fire Hose Station Visual Inspection,"

Revision 13

  • Test Procedure GSP-SH-00001, "Postaccident Monitor Channel Check," !

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Test Procedure OSP-SA-0016B," Train B Safety injection System Slave Relay Test," Revision 3

Test Procedure OSP-NE-0001 A, " Standby Diesel Generator 'A' Periodic Tests,"

Revision 5

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The surveillance testing was conducted satisfactorily in accordance with the licensee's approved programs and the Technical Specification ;

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-4-M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Material Condition Durina Plant Tours Inspection Scope (62707)

The inspectors performed routine plant tours, attended daily status meetings, and reviewed suggestion-occurrence-solution reports to evaluate plant material conditio Observations and Findinas l l

With the exception of the essential service water system downstream of the component cooling water neat exchangers (Section M2.2), external material condition and l housekeeping throughout the p' ant were very good Most deficiencies that existed in I the plant had already been identitd by ihe licensee for cr rective action. The licensee documented these discrepancies and initiated corrective actio M2.2 Essential Service Water Vibration Problems at the Component Coolina Water Heat I Exchanaers Inspection Scope (62707)

The essential service water system valves and piping at the outlet of the component cooling water heat exchangers have recently experienced several vibration-related problems. The licensee initiated suggestion-occurrence-solution reports ar'd other documents describing the problems and proposed actions. The inspectors attended the licensee's meetings and reviewed the status of the actions and recommendation During the orevious operating cycle, the licensee classified both trains of essential service water as Category (a)(1) per 10 CFR 50.65 (the Maintenance Rule). The licensee chose to extend the Category (a)(1) classification into the current operating cycl Observations and Findinas The portion of the system described consisted of:

. A 24-inch motor-operated butterfly valve at the inlet to the component cooling water heat exchanger;

  • A 24-inch motor-operated butterfly valve at the outlet from the component cooling water heat exchanger; and

. A flow restricting orifice plate and a downstream manual 16-inch butterfly valve, together in a bypass line around the outlet valv q

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j-5-When operating the system in a safety injection lineup, the inlet motor-operated butterfly valves (EFHV0051 and EFHV0052 for Trains A and B, respectively) are open. The outlet motor-operated butterfly valves (EFHV0059 and EFHV0060 for Trains A and B, respectively) are closed. The manual butterfly valves (EFV0058 and EFV0090 for Trains A and B, respectively) are throttled to ensure proper flow balanc Approximately 8000 gpm of essential service water system flow is established through the heat exchangers when operating an essential service water pump. The licensee determined the flow velocity through the 16-inch bypass line to be approximately 14 feet per second. The licensee determined that the vibration-related problems have occurred i due to the combination of high flow velocity and several flow directional changes within a l short distance of the outlet piping from the heat exchanger The licensee recently initiated Reliability Status Report NES99-089 which discussed the background surrounding the problems as well as the status of corrective actions and recommendations. The report included a discussion of nineteen noteworthy vibration-related problems dating back to 1996. Some of the problems noted were:

. broken or cracked valve yokes a broken, loose, or missing fasteners

. a cracked piping branch connection weld

- a broken pipe support strut in early June 1999, tM licensee held meetings to discuss short- and long-term corrective actions to resolve the vibration-induced problems. The short-term corrective actions included:

. performing extensive nondestructive examinations of the piping and pipe l supports; l

. performing visual inspections and testing of valves where significant vibration existed;

. reviewing design motor-operated valve differential pressures;

. modifying the size of the flow restricting orifice plates upstream of Valves EFHV0058 and EFHV0090;

. revising operating procedures for filling and operating the essential service water system;

. preparing work packages to replace the actuators and motors on Valves EFHV0059 and EFHV0060; and

. having all nonconforming material suggestion-occurrence-solution reports be reviewed by the onsite review committe >

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6-The inspectors' review of the modification to change the size of the flow restricting orifice plates upstream of Valves EFHV0058 and EFHV0090 is discussed in Section E1.1 of this repor The licensee completed most of the actions and did not identify any other significant problems. The inspectors determined that these actions provide a high degree of confidence that no further vibration-induced failures should occu The licensee identified several long-term actions that included:

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. performing an in-depth root cause evaluation of the failures; e evaluating the processes and programs to identify weaknesses that contributed to the high number of failures without having adequate remedial actions or management involvement;

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forming a team to review all" occurrence" problem reports over the last 2 years to identify any other adverse trends that have not been elevated to appropriate personnel; and

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having an independent assessment of the processes and program The inspectors identified no concerns with the licensee's nroposed and completed actions. The inspectors determined that the completed and planned actions were comprehensive. The inspectors also determined that the licensee was slow in recognizing the adverse trend in material conditio j l

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. Conclusions The licensee was slow in recognizing the adverse trend in material condition for the essential service water system. The system experienced a number of vibration-induced problems. The licensee's completed and planned corrective actions were appropriate and comprehensiv M8 Miscellaneous Maintenance issues (92902)

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M8.1 (Closed) Licensee Event Report 50-483/98001-00: Technical Specification 3.8. violation due to inoperable emergency exhaust system and missed Technical Specification 4.7.7.b.2 emergency exhaust surveillanc Supplement 1 of this licensee event report is discussed below (Section M8.2). This supplement clarified the scope of the reviews performed for corrective action. This item is closed based on th< discussion in Section M '

-7-M8.2 (Closed) Licensee Event Report 50-483/98001-01: Technical Specification 3.8. violation due to inoperable emergency exhaust system and missed Technical Specification 4.7.7.b.2 emergency exhaust surveillanc On January 9,1998, the licensee sent a charcoal sample offsite from Emergency Exhaust System Train B for laboratory analysis. This was in accordance with Technical Specification 4.7.7.b.2. Separately, on January 21,1998, the licensee declared Emergancy Diesel Generator A and Essential Service Water Train A inoperable for a scheduled maintenance outage. Soon after the maintenance outage began, the {

licensee received unsatisfactory results from the charcoal sample and declared Emergency Exhaust System Train B inoperabl ,

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Because Emergency Diesel Generator A was inoperable at the time Emergency Exhaust System Train B was inoperable, the licensee entered Technical Specification 3.8.1.1, Action d.1. This required the plant to be in Hot Standby within i 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. The licensee requested and received a Notice of Enforcement Discretion (see i NRC Inspection Report 50-483/98-02) to allow 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore Emergency Diesel

Generator A to operable status. The licensee completed the restoration successfully within the allowed outage tim On January 24,1998, the licensee successfully restored emergency exhaust system Train B to operable status, within the allowed outage time, after replacing the charcoa During the subsequent investigation, the licensee discovered that neither emergency exhaust system train had been properly tested since a 1996 revision to Technical Specification 4.7.7.b.2 was incorporated. Consequently, on January 30,1998, the licensee declared Emergency Exhaust System Train A inoperable. The licensee decided to immediately replace the Train A charcoal rather than wait for test result !

On February 1,1998, the licensee successfully restored Emergency Exhaust System Train A to operable status, within the allowed outage time, after replacing the charcoa The licensee later received test results for the "old" Tri.in A charcoal sent out for analysis. These results were within the limits specified by revised Technical Specification 4.7.7.b.2; therefore, Train A had been operabl .

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The NRC conducted a special reactive inspection into the circumstances of improper testing for both emergency exhaust system trains. The NRC identified a violation for the i failure to demonstrate that either emergency exhaust system train could meet the new I testing criteria specified by Technical Specification Amendment 118 (see NRC ,

. inspection Report 50-483/98-02 and Section M8.4 of this report). j The licensee determined the cause of the failure of the charcoal test sample surveillance for emergency exhaust system Train B to be degradation of the charcoa As indicated, the licensee replaced the Train B charcoal within the allowed outage tim The new charcoal was tested and met the limits specified by revised Technical Specification 4.7.7.b ;

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The licensee determined the cause of the failure to perform revised Technical l Specification 4.7.7.b.2 surveillanse to be a programmatic deficienc )

The licensee completed the following corrective actions:

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The licensee modified the program for implementation of approved Technical Specification amendments. The program established accountability and a method to identify, track, and positively close out all items associated with implementation of each new amendmen .

The licensee performed a review of 46 amendments issued since January 1, 1993. The scope of the review was to ensure that procedures were revised in ,

accordance with the implementation period and that surveillances were current l and performed to the revised procedures. This review, however, did not verify

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that surveillance results were acceptaole and past operability requimments were satisfie A subsequent review was performod, by quality assurance personnel, from November 1998 through March 1999, which verified acceptability of surveillance l results and past operability requirements. The licensee documented this review l in quality assurance Surveillance Report SP99-009. Quality assurance l personnel identified one instance where equipment operability was not properly established within the allowed implementation period. The licensee reported this in Licensee Event Report 50-483/99001-00. The inspectors' review of this report j is addressed in Section M8.3 of this repor The inspectors considered the licensee's root cause determination and corrective actions regarding the failure of the charcoal test sample to be accep!.able. The enforcement aspects of this licensee event report were already addressed in NRC Inspection Report 50-483/98-02. Therefore, this item is considered close ]

M8.3 (Closed) Licensee Event Repor150-483/99001-00: failure to implement Operating l License Amendment 106 requirements within 30-day implementation perio l I

On February 5,1999, licensee quality assurance personnel discovered that not all I surveillance requirements modified by Amendment 106 were satisfied within the allowed I 30-day implementation period. Amendment 106 revised testing requirements of the I control room emergency ventilation filtration system. The amendment was effective on I January 19,199 Specifically, the flow rate for the Control Room Emergency Ventilation System Train B did not meet the flow rate requirements of Technical Specification 4.7.6.c.1,4.7.6.c.3, j and 4.7.6.e.1 within the allowed 30 days following approval of the amendmen l l

l Amendment 106 revised the control room emergency ventilation filtration system flow I I

rate from 2000 cfm (+700/-200) to 2000 (+200/-200) cfm. The licensee administratively implemented the revised flow rate from Amendment 106 in Spring 1995 to support NRC i

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-9-approval and implementation of Amendment 96. (Amendment 96 allowed replacement of the containment spray additive system with a recirculation fluid pH control system.)

The licensee implemented Amendment 106 in 1995 using revised preventive maintenance procedures. On March 22,1995, the licensee performed the procedures and recorded a filtration system flow rate of 2140 cfm for the Control Room Emergency Ventilation System Train To ensure that the Technical Specification requirements in effect at the time were satisfied, the licensee re tested each ventilation system train to the existing surveillance procedures, since these procedures had not yet been revised to reflect Amendment 106. The licensee also performed the surveillance procedures for Train B on March 22,1995, after performing the preventive maintenance procedures. After some minor adjustments, the licensee recorded a final filtration system flow rate of 2229 cfm. Although this value met the existing Technical Specification for control room emergency ventilation system Train B, it did not meet the Technical Specification on January 19,1996, when Amendment 106 became effectiv On July 22,1998, the next surveillance test of Control Room Emergency Ventilation System Train B was performed. This test was successful; the licensee recorded a filtration system flow rate of 2170 cf Since then the licensee has successfully performed the testing of Control Room j Emergency Ventilation System Train B in accordance with Amendment 106. The i licensee also concluded, and the inspectors agreed, that the higher system flow did not l prevent the system from being able to perform its design safety function. Test results of Train A always met the Technical Specification requirements in effect, although the licensee had not revised the Train A surveillance procedures by the effective date of Amendment 10 The licensee determined that the cause of the failure to meet the flow rate requirements of Technical Specifications 4.7.6.c.1,4.7.6.c.3, and 4.7.6.e.1 was a programmatic deficiency within the process of implementing operating license amendment Contr;buting factors included:

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. Implementation of the operating license amendment requests was done via I commitments prior to amendment submittal to the NRC;

. Surveillance procedures were not revised in March 1995 to reflect the new flow rate requirements; and

. Licensee personnel not observing verbatim compliance with the Technical ,

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-10-The licensee implemented the following corrective actions:

. Programmatic deficiencies within the process of implementing license amendments were previously identified during the review of events associated with Licensee Event Reports 50-483/98001-00 and 50-483/98001-01 (see Sections M8.1 and M8.2 above);

. Training would be provided to appropriate personnel regarding this event and the need for verbatim compliance with the Technical Specifications; and

. Operating license amendments have undergone re-evaluation to ensure operability of plant equipment was maintained upon amendment approval. The licensee has not discovered any additional Technical Specification violation The inspectors agreed with the licensee's root cause and corrective action The licensee has had a history of documented problems pertaining to implementation of Technical Specification amendments. In addition to the above discussions, the inspectors identified an instance when the licensee failed to revise three component cooling water system valva surveillance procedures and make associated revisions to l the work control process in a timely manner following implementation of Technical j Specification Amendment 113 (see NRC Inspection Report 50-483/98-21,  ;

Section E3.1). Also, the licensee identified additional examples of problems which were j documented in the suggestion-occurrence-solution reporting system. Based on this, the l

inspectors determined that the licensee's performance in implementing Technical j

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Specification amendments was wea The inspectors determined that the failure to meet flow rate surveillance requirements for Control Room Emergency Ventilation System Train B from January 19,1996, until July 22,1998, was a violation of Technical Specifications 4.7.6.c.1,4.7.6.c.3, j and 4.7.6.e.1. The inspectors determined that this failure was a Severity Level IV violation. This Severity Level IV violation is being treated as a noncited violation, .

consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence-Solution Report 99-0259 (50-483/99005-01).

c. Conclusions The failure to meet flow rate surveillance requirements for Control Room Emergency l Ventilation System Train B from January 19,1996, until July 22,1998, was a violation of Technical Specifications 4.7.6.c.1,4.7.6.c.3, and 4.7.6.e.1. Although the documented system flow was greater than the Technical Specification allowed maximum, the i licensee concluded, and the inspectors agreed, that the system was always capable of meeting its design safety function. This Severity Level IV violation is being treated as a i noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence- I Solution Report 99-025 I

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M8.4 , (Closed)' Violation 50-483/98002-01: Technical Specification 3.8.1.1 violation due to inoperable emergency exhaust system and missed Technical Specification 4.7.7. i L emergency exhaust surveillanc f

. 1 This violation is closed based on the discussion in Sections M8.1 and M8.2 abov .(

lit. Engineerina E1 Conduct of Engineering

E1.1 ' Review of Modification Packages Insoection Scooe (37551)

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The inspectors reviewed Modification Package 99-1012. This modification replaced the orifice plates in the essential service water return lines from the component cooling _

water heat exchangers. The inspectors also reviewed the postmodification testin Observations and Findings

- The purpose of the modification was to reduce the cavitation occurring on essential'

service water retum piping just downstream from the component cooling water heat exchangers.,

The cavitation was occurring at Essential Service Water Train A Motor-Operated Valve EFHV0058 and at Essential Service Water Train B Motor-Operated Valve EFHV0090. These valves are throttled during a safety injection to establish the required essential service water flow through the component cooling water heat exchangers. The throttled positions for the valves was 32 degrees open (EFHV0058)

and 38 degrees open (EFHV0090). At these positions, the valves cavitate and generate a large amount of piping vibration. The valves and associated piping recently experienced several vibration-related problems (see Section M2.2).

The licensee identified a contributing cause of the vibration to be a design oversight in the sizing of flow restricting orifice plates located upstream of Valves EFHV0058

~ and EFHV0090.; The licensee developed Modification Package 99-1012, which evaluated the installation of replacement orifice plates that reduced the bore size from 11.132 inches to 8.00 inches. The purpose was to increase the pressure drop across j

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the orifice plates to allow Valves EFHV0058 and EFHV0090 to operate further open and reduce the cavitation.: .

The inspectors reviewed the postmodification testing. The testing consisted of an in-service leak test, a vibration test,'and flow balance. The testing was performed

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satisfactorily in accordance with the modification package test requirements., Installation of this modification, in concert with some operating procedure changes, significantly s-1 1

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reduced the general piping vibration. The final adjusted position of Valves EFHV0058 and EFHV0090 was 38 degrees open and 40 degrees open, respectivel The inspectors determined that the modification package was properly prepared. The licensee appropriately and successfully performed the required postmodification testin The licensee determined that there was not an unreviewed safety question. The inspectors identified no concern , Conclusions :

The modification package to replace the orifice plates in the essential service water

. return lines from the component cooling water heat exchangers was properly prepare The licensee appropriately and successfully performed the required postmodification testin E1.2 Abbreviated Review of Year 2000 Activities Insoection Scone (Tl 2515/141)

1 he inspectors conducted an abbreviated review of Year 2000 activities and documentation using Temporary Instruction (TI) 2515/141, " Review of Year 2000 (Y2K)

Readiness of Computer Systems at Nuclear Power Plants." Observations and Findinas The review addressed aspects of Year 2000 management planning, documentation, implementation planning, initial assessment, detailed assessment, remediation activities, Year 2000 testing and validation, notification activities, and contingency planning. The inspectors used NEl/NUSMG 97-07, " Nuclear Utility Year 2000 Readiness," and NEl/NUSMG 98-07, " Nuclear Utility Year 2000 Readiness Contingency Planning," as the

. primary references for this revie Conclusions regarding the Year 2000 readiness of Callaway plant are not included in this summary. The results of this review will be combined with reviews of Year 2000 programs at other plants in a summary report to be issued by July 31,199 '

IV. Plant Support R1 Radiological Protection and Chemistry Controls R General Comments (71750_)

The inspectors observed health physics personnel, including supervisors, routinely touring the radiologically controlled areas. Licensee personnel working in radiologically controlled areas exhibited good radiation worker practice :

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-13-Contaminated areas and high radiation areas were properly posted. Area surveys posted outside rooms in the auxiliary building were current. The inspectors checked a j sample of doors, required to be locked for the purpose of radiation protection, and found l no problem R2 Status of Radiological Protection and Chemistry Controls Facilities and l Equipment R2.1 Auxiliary Buildina Tour Insoection Scoce (71750)

The inspectors accompanied licensee personnel on a tour of radiologically controlled areas in the auxiliary building that were not normally accessible with the plant at powe Observations and Findinas The inspectors found material condition to be good. The radiologically controlled area was generally clean, although some minor housekeeping problems were identified. The inspectors and licensee personnel noted two small areas that had an excessive amount of rust and/or leftover priming material from previous work. The licensee initiated corrective action to clean the affected area S2 Status of Security Facilities and Equipment S2.1 Walkdown of Protectjd Area Barrier Insoection Scoce (71750)

The inspectors performed a walkdown of the protected area to determine compliance with the security plan. In particular, the general area illumination levels were assesse Observations and Findinas On May 20,1999, at approximately 2 a.m., during a nighttime tour of the protected area, the inspectors identified an area beneath the three bulk chemical storage tanks that appeared to be illuminated to less than 0.2 foot-candles. This was the limit in the licensee's security pla Upon request, the licensee measured the illumination and determined that the area beneath each of the three tanks measured 0.10 to 0.15 foot-candles. The licensee took compensatory action by installing temporary " stringer" lights to correct the deficienc License Condition 2.E of the licensee's facility operating license requires, in part, that 3 the licensee maintain in effect and fully implement all provisions of the NRC approved l physical security plan, including amendments and changes made pursuant to the i

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authority of 10 CFR 50.54(p) and 10 CFR 50.9 (:

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l l Section 3.1.3.1 of the licensee's security plan requires that outdoor portions of the plant be illuminated at night to a minimum of 0.2 foot-candles.

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l The licensee's failure to provide minimum illumination of 0.2 foot candles to outdoor l portions of the plant is a violation of Section 3.1.3.1 of the Security Plan. The inspectors

! determined that this failure was a Severity Level IV violation. This Severity Level IV l violation is being treated as a noncited violation, consistent with Appendix C of the NRC

! Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence-Solution Report 99-0995 (50-483/99005-02).

l l Conclusions The licensee's failure to provide minimum illumination of 0.2 foot-candles to outdoor portions of the plant was a violation of Section 3.1.3.1 of the Security Plan. The

inspectors determined that this failure was a Severity Level IV violation. This Severity Level IV violation is being treated as a noncited violation, consistent with Appendix C of the NRC Enforcement Policy. This violation is in the licensee's corrective action program as Suggestion-Occurrence-Solution Report 99-099 ,

V. Manaaement Meetinas X1 Exit Meeting Summary The exit meeting was conducted on June 14,1999. The licensee did not express a position on any of the findings in the repor The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie i l

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d ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. D. Affolter, Manager, Callaway Plant R. G. Barton, Shift Supervisor -

J. D. Blosser, Manager, Operations Support H. D. Bono, Supervising Engineer, Quality Assurance Regulatory Support G. L. Bradley, Operating Supervisor M. S. Evans, Superintendent, Emergency Preparedness {

J. M. Gloe, Superintendent, Maintenance i D. S. Hollabaugh, Superintendent, Design Engineering R. G. Howeth, Supervisor, instrumentation and Controls J. V. Laux, Manager Quality Assurance A. L Ledbetter, Shift Supervisor  !

I T. A. Moser, Superintendent, Systems Engineering G. A. Randolph, Vice President and Chief Nuc! ear Officer R. R. Roselius, Superintendent, Radiation Protection and Chemistry L. S. Sandbothe, Superintendent, Operations M. E. Taylor, Manager, Nuclear Engineering W. A. Witt, Assistant Manager, Callaway Plant INSPECTION PROCEDURES USED 37551 Onsite Engineering 61726 Surveillance Observations 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities ("

92700 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities 92902 Followup - Maintenance Tl 2515/141 Review of Year 2000 (Y2K) Readiness of Computer Systems at Nuclear Power Plants .

2 ITEMS OPENED AND CLOSED Opened 99005-01 NCV Failure to implement Operating License Amendment 106 requirements within the 30 day implementation period (Section M8.3).

99005-02 NCV Failure to provide minimum illumination per the security plan (Section S2.1).

Closed 98001-00 LER Inoperable Emergency Exhaust System and missed Technical Specification surveillance (Section M8.1).

98001-01 LER inoperable Emergency Exhaust System and missed Technical Specification surveillance (Section M8.2).

99001-00 LER Failure to implement Operating License Amendment 106 requirements within the 30-day imnlementation period (Section M8.3).

99005-01 NCV Failure to implement Operating License Amendment 106 requirements within the 30-day implementation period (Section M8.3).

98002-01 VIO Technical Specification violation due to inoperable emergency exhaust system and missed Technical Specification surveillance (Section M8.4).

99005-02 NCV Failure to provide minimum illumination per the security plan (Section S2.1).

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