IR 05000483/1999006

Insp Rept 50-483/99-06 on 990613-0724.One Severity Level 4 Violation Noted & Being Treated as Ncv.Major Areas Inspected:Operations,Maint & Plant Support

ML20210T934
Person / Time
Site:	Callaway
Issue date:	08/13/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20210T917	List: IR 05000483/1999006 ML20210T912
References
50-483-99-06, NUDOCS 9908190192
Download: ML20210T934 (10)

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ENCLOSURE l

I U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

l Docket No.: 50-483 I License No.: NPF-30 Report No.: 50-483/99-06 Licensee: Union. Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Fulton, Missouri Dates: June 13 through July 24,1999 Inspectors: D. G. Passehl, Senior Resident inspector J. D. Hanna, Resident inspector R. A. Gibbs, Resident inspector, Region 11 Approved By: D. N. Graves, Chief, Project Branch B ATTACHMENT: Supplemental Information 9908190192 990813 PDR ADOCK 05000483 G PDR

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l EXECUTIVE SUMMARY Callaway Plant NRC Inspection Report No. 50-483/99-06 Operations

The inspectors accompanied several operators during routine tours of the plant and found the tours to be thorough and well performed. The inspectors also verified that a portion of the containment isolation system was lined up in accordance with the operations surveillance procedure (Section O1.1).

Maintenance

The overall material condition and housekeeping of several plant systems were goo The inspectors reviewed open work requests and noted that there were few outstanding items. The inspectors identified a few minor housekeeping discrepancies for which the licensee initiated prompt corrective action (Section M2.1).

On March 9,1999, the licensee determined that Technical Specifications were not being properly implemented to response time test the engineered safety features actuation system (Licensee Event Report 50-483/99-002-00). The signals not properly tested were: (1) testing for steam generator water level low-low initiation of motor-driven auxiliary feedwater pump actuation; and (2) Containment Phase A isolation initiation of containment purge. Following discovery, the signals were tested and were satisfactor The failure to adequatoly test the engineered safety features actuation system constitutes a violation of Technical Specification 4.3.2.2. 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 99-0439 (Section M8.1).

Plant Support l l

The inspector concluded that, although radiation work practices were acceptable, the radiological survey map for work around the radwaste volume reduction skid did not accurately reflect a contaminated area boundary. This was contrary to licensee management expectations (Section RI.1).

Postings per 10 CFR 19.11 were not readily visible to all workers on the way to or from licensed activities. The licensee initiated an evaluation of their program for postings of notices to workers (Section R1.2).

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Report Details I

Summarv of Plant Status -

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The plant operated at 100 percent power throughout the inspection perio l. Operations '

0 11 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 _

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problems, and work plans were appropriately addressed during daily tumover and plan-of-the-day meetings. Plant testing and maintenance requiring control room coordination were properly controlled. The inspectors observed several shift turnovers and noted no problem The inspectors accompanied several operators during routine tours of the plant. The

. inspectors observed an inside primary operator's tour of the auxiliary building on June 17,1999, and found it to be thorough and well performed. The inspectors also verified that a portion of the containment isolation lineup was in accordance with Operations Surveillance Procedure OSP-GP-00001, " Containment Integrity Verification,"

Revision 9. Minor discrepancies (e.g., an unattached containment integrity tag) were referred to the . licensee and were promptly correcte O2 Operational Status of Facilities and Equipment i

~ O Review of Eauioment Taaouts (71707)

The inspectors walked down the following tagouts:

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• Workman's Protection Assurance 31212 - Class 1E Electrical Equipment Air Conditioning Unit SGK05 *- Workman's Protection Assurance 31170 - Control Room Filtration Fan Suction 1 Damper Operator GKHZ0019 The inspectors did not identify any discrepancies. The tagouts were properly prepared i and authorized. All tags were on the correct devices and the devices were in the !

. position prescribed by the tags. All components were in the proper position for the required system lineup.-

02.2 Enaineered Safetv Feature System Walkdowns (71707)

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

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• Emergency Diesel Generators A and B

• 4.16 KV safeguards power, red and yellow trains Equipment operability, material condition, and housekeeping were acceptabl . Maintenance M1 Conduct of Maintenance M1.1 General Comments - Maintenance Insoection Scope (62707)

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

• Work Authorization G619122-048 - Troubleshoot Control Room Air Conditioning Unit SGK04B

= Work Authorization P635748 - Flush Electrical Equipment Air Conditioning Unit SGK05B 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 personnel were present when require M1.2 General Comments - Surveillance Insoection Scoce (61726)

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

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

Revision 5

• Test Procedure ETP-EF-ST018," Essential Service Water System Train "A" Vibration Levels Under Varying System Alignments," Revision 0

• Test Procedure OSP-EM-V00018 " Safety injection System Train B Valve ;

Inservice Test," Revision 14

• Test Procedure OSP-EM-P001B," Safety injection Train B Inservice Test," ;

Revision 20 )

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- Test Procedure ISL-SE-00N44," Loop Nuc; Nuc Instrm Pwr Rng N44,"

Revision 16 Observations and Findinas The surveillance tecting was conducted satisfactorily in accordance with the licensee's approved programs and the Technical Specification M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Review of Material Condition Inspection Scope (62707)

The inspectors performed plant tours and reviewed licensee documents to evaluate plant material conditio Observations and Findinas The inspectors observed material condition and housekeeping of the following systems:

. Emergency diesel generators

. Residual heat removal

. Control room ventilation

. Safety injection

. Charging

. Auxiliary feedwater The overall material condition and housekeeping were good. The inspectors observed few boric acid or oil leaks on the applicable systems. The inspectors reviewed open ,

work requests and noted that there were few outstanding items. The inspectors identified a few minor discrepancies, such as loose material around the emergency i diesel generators, for which the licensee initiated prompt corrective actio M8 Miscellaneous Maintenance issues (92902)

M8.1 (Closed) Licensee Event Report 50-483/99002-00: missed Technical Specification surveillance due to misinterpretation of surveillance requiremen On March 9,1999, the licensee determined that Technical Specification 4.3.2.2 was not being properly implemented to response time test the engineered safety features actuation system. The signals not properly tested were:

. Steam generator water level low-low initiation of motor-driven auxiliary feedwater pump actuation; and

. Containment Phase A isolation initiation of containment purg .

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-4-The testing had not been performed completely since initial plant startup. The surveillances are required every 18 month The licensee determined that the balance-of-plant portion of the circuitry had been incorrectly omitted from response time testing. The licensee identified the cause to be misinterpretation of response time test criteria during initial surveillance test procedure developmen The licensee successfully tested the affected signals within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of identification of the discrepancy. Testing included the balance-of-plant engineered safety features actuation system portion of the circuit. The licensee revised the applicable surveillance procedures to ensure complete response time testing is performed every 18 month The inspectors identified no concern The licensee reported similar instances of failure to perform adequate safety oystem actuation testing in Licensee Event Reports 97005-00 through 97005-06. The inspectors discussed these reports in NRC inspection Reports 50-483/98-08, /98-22,

/98-25, /98-26, and /99-01. The licensee identified the issues discussed in these licensee event reports during reviews mandated by Generic Letter 96-01, " Testing of Safety-Related Logic Circuits." Generic Letter 96-01 did not require safety system actuation surveillance reviews for response time test criteria. This current licensee event report was identified during a review of engineered safety features actuation system testing by engineering staf Technical Specification 4.3.2.2 states that the " response time of Engineered Safety Features Actuation System function shall be demonstrated to be within the limit at least once per 18 months." The licensee failed to perform these surveillances as a result of inadequate procedures. The licensee revised the affected procedures and successfully performed the testing. The failure to test the engineered safety features actuation system constitutes a violation of Technical Specification 4.3.2.2. 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 Solstion Report 99-0439 (50-483/99006-01).

IV. Plant Support R1 Radiological Protection and Chemistry Controls R1.1 General Comments (71750) The inspector observed health physics personnel, including supervisors, routinely touring the radiologically controlled areas. Licensee personnel working in radiologically controlled areas exhibited good radiation worker practices with minor exception. The inspector checked a sample of doors required to be locked for the purpose of radiation protection and found no problem ,

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. On June 16,1999, the inspectors observed licensee personnel performing work on the radwaste volume reduction skid. The workers expanded the contaminated area boundary without updating the associated survey map. The licensee updated the map and initiated Suggestion-Occurrence-Solution Report 99-113 Procedure HDP-ZZ-03000, " Radiological Survey Program," Revision 20, stated that surveys should communicate complete radiological information to plant personnel. The inspector determined that management expectations for updating of survey maps were not met in this instanc NRC Inspection Report 50-483/98026 discussed a second instance of failing to update a survey map during spent fuel pool re-rack activities (Suggestion-Occurrence-Solution Report 99-0093). The corrective action for this event was to send an e-mail to health l

physics technicians informing them of the error and reminding them of the expectatio Also, there was a suggestion to " highlight" the item during health physics requalification sessions. The inspectors determined that the licensee's actions were ineffective in preventing recurrenc Conclusions ,

The inspector concluded that, although radiation work practices were acceptable, the radiological survey map for work around the radwaste volume reduction skid did not accurately reflect a contaminated area boundary. This was contrary to licensee management expectation R1.2 Postina of Notices to Workers Insoection Scoce (71750)

The inspectors reviewed posting of notices to workers per 10 CFR 19.11. This included posting of NRC Form 3, notices of violation involving radiological working conditions, regulations of 10 CFR Part 19 and Part 20, et.a Observations and Findinas The licensee maintains two locations for posting of official agency documents. One is located in the first floor north hall adjacent to the service building foyer. The second is i located in the Storeroom 1 annex. The inspectors also identified one unofficial posting at the radiological controls area access poin Part 19.11 of Title 10 of the Code of Federal Regulations states that " Documents, !

notices. or forms posted pursuant to this section shall appear in a sufficient number of I l places to permit individuals engaged in licensed activities to observe them on the way to or from any particular licensed activity . . . ."

The inspectors identified that the locations the licensee chose for the official pustings may not permit all individuals engaged in licensed activities to observe them. The inspectors also identified that the unofficial posting location at the radiological controls l

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area access point had an out-of date NRC Form 3 document. The licensee stated that they would evaluate the concern by initiating Suggestion-Occurrence-Solution Report 99-142 c. Conclusions Postings per 10 CFR 19.11 were not readily visible to all workers on the way to or from licensed activities. The licensee initiated an evaluation of their program for postings of notices to worker V. Manaaement Meetinas X1 Exit Meeting Summary The exit meeting was conducted on July 23,1999. 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 identified.

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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee R. D. Affolter, Manager, Callaway Plant J. D. Blosser, Manager, Operations Support i J. W. Dowling, General Supervisor, Maintenance R. E. Famam, Supcrvisor, Health Physics Operations

' M. R. Faulkner Superintendent, Security D. S. Hollabaugh, Superintendent, Design Engineering {

R. T. Lamb, Superintendent, Work Control J. V. Leux, Manager Quality Assurance S. J. Meyer, Senior Engineer, Quality Assurance M. A. Reidmeyer, Senior Engineer, Quality Assurance Regulatory Support R. R. Roselius, Superintendent, Radiation Protection and Chemistry i

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T. P. Sharkey, Supervising Engineer, Systems Engineering

' M. E. Taylor, Manager, Nuclear Engineering NRC l D. N. Graves, Chief, Project Branch B i

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-2-INSPECTION PROCEDURES USED 61726 Surveillance Observations I 62707 Maintenance Observations 71707 Plant Operations 71750 Plant Support Activities 92700 Onsite Followup of Written Reports of Nonroutine Events at Power Reactor Facilities i

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92902 Followup - Maintenance 92903 Followup - Engineering ITEMS OPENED AND CLOSED Ooened 99006-01 NCV Missed Technical Specification Surveillance due to misinterpretation of the requirements (Section M8.1).

Closed 99002-00 LER Missed Technical Specification Surveillance due to misinterpretation of the requirements (Section M8.1).

99006-01 NCV Missed Technical Specification Surveillance due to misinterpretation of the requirements (Section M8.1).