ML032050070
| ML032050070 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/24/2003 |
| From: | Gage P Operations Branch IV |
| To: | Randolph G Union Electric Co |
| References | |
| IR-03-010 | |
| Download: ML032050070 (15) | |
See also: IR 05000483/2003010
Text
July 24, 2003
Garry L. Randolph, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT:
CALLAWAY PLANT - NRC PROBLEM IDENTIFICATION AND RESOLUTION
INSPECTION REPORT 05000483/2003-010
Dear Mr. Randolph:
On June 6, 2003, the NRC completed a team inspection at your Callaway Plant. The enclosed
report documents the inspection findings which were discussed with you and other members of
your staff on June 6, 2003.
This inspection examined activities conducted under your license as they relate to the
identification and resolution of problems, and compliance with the Commissions rules and
regulations and the conditions of your operating license. Within these areas, the inspection
consisted of selected examination of procedures and representative records, observations of
activities, and interviews with personnel.
On the basis of the sample selected for review, the team concluded that in general, problems
were adequately identified, evaluated, and corrected with some exceptions. One exception
included a failure to promptly identify and correct an industry known deficient condition
affecting the functionality of multiple safety-related circuit breakers. Another exception involved
the failure to promptly identify and correct a voided condition affecting both trains of the
containment spray system even though abnormal system response to surveillance testing was
observed during several occasions dating back to 1995. These failures, reflected some
isolated problems with problem identification, extent of condition reviews, root cause
determinations, and corrective actions. One green finding was identified during this inspection
associated with the safety-related circuit breaker issue discussed above and is being treated as
a noncited violation, consistent with Section VI.A of the Enforcement Policy, and is described in
the subject inspection report. Additionally, a licensee-identified violation, which was of very low
safety significance, is listed in Section 40A7 of this report. If you contest the violations or
significance of these noncited violations, you should provide a response within 30 days of the
date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory
Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the
Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza
Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear
Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the
Callaway Plant facility.
Union Electric Company
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In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its
enclosure, and your response will be made available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records component of NRCs
document system (ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Paul C. Gage, Chief
Operations Branch
Division of Reactor Safety
Docket: 50-483
License: NPF-30
Enclosure:
NRC Inspection Report
50-483/03-03
cc w/enclosure:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855
John ONeill, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, N.W.
Washington, D.C. 20037
Mark A. Reidmeyer, Regional
Regulatory Affairs Supervisor
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, Missouri 65251
Manager - Electric Department
Missouri Public Service Commission
301 W. High
P.O. Box 360
Jefferson City, Missouri 65102
Union Electric Company
-3-
Ronald A. Kucera, Deputy Director
for Public Policy
Department of Natural Resources
P.O. Box 176
Jefferson City, Missouri 65102
Rick A. Muench, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
Dan I. Bolef, President
Kay Drey, Representative
Board of Directors Coalition
for the Environment
6267 Delmar Boulevard
University City, Missouri 63130
Manager
Quality Assurance
AmerenUE
P.O. Box 620
Fulton, Missouri 65251
Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, Missouri 65102-0116
Scott Clardy, Director
Section for Environmental Public Health
P.O. Box 570
Jefferson City, Missouri 65102-0570
Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, Missouri 65251
Technical Services Branch Chief
FEMA Region VII
2323 Grand Blvd., Suite 900
Kansas City, Missouri 64108-2670
Union Electric Company
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David E. Shafer
Superintendent, Licensing
Regulatory Affairs
AmerenUE
P.O. Box 66149, MC 470
St. Louis, Missouri 63166-6149
Union Electric Company
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Electronic distribution by RIV:
Acting Regional Administrator (TPG)
DRP Director (ATH)
Acting DRS Director (ATG)
Senior Resident Inspector (MSP)
Branch Chief, DRP/B (DNG)
Senior Project Engineer, DRP/B (RAK1)
Staff Chief, DRP/TSS (PHH)
RITS Coordinator (NBH)
Mel Fields (MBF1)
CWY Site Secretary (DVY)
ADAMS: Yes
No Initials: ______
Publicly Available Non-Publicly Available
Sensitive
Non-Sensitive
R:\\_CW\\2003\\CW2003-010RP-MCH.wpd
SRI:DRP/E
RI:DRS/OB
C:DRP/B
C:OB
MCHay
MHaire
DGraves
PGage
/RA/
/RA/ E
/RA/
/RA/
7/2/03
07/23/03
7/23/03
7/24/03
OFFICIAL RECORD COPY
T=Telephone E=E-mail F=Fax
ENCLOSURE
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket:
50-483
License:
Report:
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Junction Highway CC and Highway O
Fulton, Missouri
Dates:
June 2-6, 2003
Inspectors:
M.C. Hay, Senior Resident Inspector, Projects Branch B
M. Haire, Operations Engineer, Operations Branch
Approved By:
Paul C. Gage, Chief
Operations Branch
Division of Reactor Safety
-2-
SUMMARY OF FINDINGS
IR 05000483/2003-010; Union Electric Co; 06/02/03-06/06/03; Callaway Plant. Identification
and Resolution of Problems, Mitigating Systems.
The inspection was conducted by a senior resident inspector and an operations engineer. One
green finding of very low safety significance was identified during this inspection and was
classified as a noncited violation. The finding was evaluated using the significance
determination process.
Identification and Resolution of Problems
On the basis of the sample selected for review, the team concluded that problems were
adequately identified, evaluated, and corrected. The team identified a number of examples
pertaining to the failure to promptly identify and correct conditions adverse to quality. One long-
standing issue involving a failure to promptly identify and correct voided conditions affecting
both trains of the containment spray system suction piping following abnormal system response
during surveillance testing on multiple occasions dating back to 1995 was identified by the
team. Problem identification and resolution issues have affected Callaway historically and
corrective actions have been put in place to improve performance. The team noted that
engineering products reviewed effectively supported the corrective action process, were
technically adequate, and provided sufficient justification to support operability for degraded
conditions evaluated.
Cornerstone: Mitigating Systems
Green. The licensee failed to promptly identify, correct, or preclude recurrence of an industry
known potential significant condition adverse to quality associated with failures of Magne-Blast
4160 volt circuit breakers. The breaker failures were the result of a defective contact block
assembly used as control switches in the breaker control circuits.
The failure to promptly identify, correct, or preclude recurrence of the deficient condition from
affecting multiple safety-related components due to failures of Magne-Blast 4160 volt circuit
breakers was determined to be a violation of 10 CFR Part 50, Appendix B, Criterion XVI. This
violation is being treated as a noncited violation consistent with Section VI.A of the NRC
Enforcement Policy. This finding is greater than minor because if left uncorrected this condition
impacts the reliability and availability of all safety-related loads supplied by Magne-Blast 4160
volt circuit breakers. This finding was determined to be of very low safety significance since all
failures reviewed did not result in loss of a safety function for a single train for greater than its
Technical Specification allowed outage time.
Licensee-Identified Violations.
Violations of very low safety significance, which were identified by the licensee have been
reviewed by the inspectors. Corrective actions taken or panned by the licensee have been
entered into the licensees corrective action process.
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Technical Specification 5.4.1requires that the licensee establish, implement, and
maintain written procedures recommended in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Appendix A recommends maintenance procedures.
The failure to follow a maintenance procedure for installing a diesel generator
fuel injector resulting in Diesel Generator B failing a surveillance test and spilling
approximately 100 gallons of fuel oil on November 11, 2002, is being considered
a violation of Technical Specification 5.4.1. This was identified in the licensees
corrective action program as Callaway Action Request 200207472. This finding
is of very low safety significance because it did not result in loss of safety
function of a single train for greater than the Technical Specification allowed
outage time.
REPORT DETAILS
4. OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a.
Effectiveness of Problem Identification
(1)
Inspection Scope
The inspectors focused on reviewing items that were characterized in the licensees
corrective action process as requiring engineering evaluation for resolution. The
purpose of selecting these items was to assess the licensees efforts in response to an
NRC identified cross cutting issue that was determined to exist during the 2002
mid-cycle plant performance review. The NRC noted that a major contributor to the
cross cutting issue was inconsistent engineering evaluations that led to multiple
examples of ineffective problem identification and resolution issues. The NRC had
previously performed a Problem Identification and Resolution team inspection in
December of 2002. The results of the inspection are contained in NRC Inspection
Report 50-483/02-03.
The team reviewed approximately 80 items to determine if problems were being properly
identified, characterized, and entered into the corrective action program for evaluation
and resolution. Specifically the inspectors selected approximately 60 Callaway action
requests that were entered into the licensees corrective action process since April 2003.
The inspectors also reviewed several licensee audits and self assessments, including
one audit of the corrective action program. The effectiveness of the audits and
assessments were evaluated by comparing the audit and assessment results against
self-revealing and NRC-identified findings.
The inspectors evaluated the Callaway action requests to determine the licensees
threshold for identifying problems and entering them into the corrective action program.
Also, the licensees efforts in establishing the scope of problems were evaluated by
reviewing pertinent control room logs, work requests, system health reports, action
plans, and select engineering design calculations. The Callaway action requests and
other documents listed in the attachment to this report were used to facilitate the review.
(2)
Findings
The team determined that the licensee was generally effective at identifying problems
and entering them into the corrective action system. This was evidenced by the
relatively few deficiencies identified by external organizations that had not been
previously identified by the licensee during the review period. Licensee audits and
assessments were of good depth and identified issues similar to those that were self-
revealing or raised during previous NRC inspections. Also, during this inspection there
were no instances identified where conditions adverse to quality were being handled
outside the corrective action program.
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b.
Prioritization and Evaluation of Issues
(1)
Inspection Scope
The team reviewed approximately 60 Callaway action requests and supporting
documentation. This effort was accomplished to verify that licensees evaluation of
problems identified considered the full extent of conditions, operability of affected
systems, reportability requirements, generic implications, common causes, and previous
occurrences. In addition, the team reviewed the licensees evaluation of select industry
experience information to assess if issues applicable to the licensees facility were
appropriately addressed.
Specific documents reviewed during this inspection are listed in the attachment to this
report.
(2)
Issues
The issues reviewed by the team revealed that the proper categorization had been
assigned to identified issues. In general, problems were adequately evaluated and
corrected with some exceptions. One exception included a failure to promptly identify
and correct an industry known deficient condition affecting the functionality of multiple
safety-related circuit breakers. Another exception involved the failure to promptly
identify and correct a voided condition affecting both trains of the containment spray
system even though abnormal system response to surveillance testing was observed
during several occasions dating back to 1995. These failures, reflected some isolated
problems with problem identification, extent of condition reviews, root cause
determinations, and corrective actions.
The team reviewed Callaway Action Request 200200694 pertaining to the licensee
identifying an underlying problem associated with the effectiveness of past incident
investigations and/or evaluations to determine the extent of condition for equipment
problems. Although corrective actions to address this condition were still in progress the
team noted that a significant effort was being taken by the licensee to improve
performance in this area. Specifically, the licensee was in the process of developing
clear roles and responsibilities for each layer of management to improve the level of
oversight and guidance and increase the amount of communications between all levels
of the staff. The licensee was also in the process of developing and implementing an
equipment reliability improvement program that was projected to be fully implemented
by June of 2004.
Circuit Breaker Failures
Introduction. The licensee failed to promptly identify, correct, or preclude recurrence of
an industry known potential significant condition adverse to quality associated with
failures of Magne-Blast 4160 volt circuit breakers. The breaker failures were the result
of a defective contact block assembly used as control switches in the breaker control
circuits. The team determined this condition was a noncited violation of 10 CFR Part 50,
Appendix B, Criterion XVI, and a finding of very low safety significance.
-3-
Description. The team reviewed Callaway Action Request 200207398 pertaining to
failure of the motor driven auxiliary feedwater Pump A to start on November 8, 2002.
The root cause of the event was attributed to failure of the supply breaker to close due
to a faulty contact block. The team noted that this failure mechanism was also
attributed to breaker failures that affected component cooling water Pump B on
November 28, 2001, and safety injection Pump A on February 11, 1998. The licensee
also stated that additional failures due to this failure mechanism were documented prior
to 1998.
The team noted that contact block (CR2940 manufactured by GE) was identified as a
component whose reliability was questionable. NRC Information Notices 95-02 and 97-
08 both alerted licensees to the potential failure of GE Magne-Blast medium voltage
breakers to properly operate because of defective GE Type CR2940 contact blocks.
These information notices expected licensees to review this information for applicability
to their facilities and consider actions, as appropriate, to avoid similar problems.
The inspectors noted that these information notices addressed several acceptable
corrective actions that licensees had taken including jumpering out the susceptible
contacts, modification of the circuit, and in cases were these actions were not taken, to
verify continuity of the affected circuit immediately after each breaker closure. The
inspectors noted that continuity of the affected Magne-Blast breakers at Callaway could
be checked by ensuring a white indicating light was lit located in the switchgear rooms.
Callaways corrective actions for this particular issue included replacement of the
contact module every 12 years, and verification of function and contact resistance every
3 years. Also it was documented that equipment operators would verify the white lights
were illuminated during their rounds as required by Operations Procedure ODP-ZZ-
0016E. The inspectors reviewed this procedure and noted that these rounds were
performed once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The inspectors noted no action was required to be taken
immediately following breaker cycling and that failure of the contact module could go
unidentified until an operator performed their routine rounds to the switchgear rooms.
This could result in the potential for not promptly identifying a degraded condition in a
timely manner. In review of the identified failures the team noted that on November 28,
2001, a condition existed where component cooling water pump B was secured at
10:47 am and failure of the contact module was not identified until 2:57pm. In this
example a member of a maintenance team identified that the white light was out.
The team discussed their concerns with the licensee. In response the licensee initiated
Callaway Action Request 200304247 to evaluate feasibility for modification of the circuit
to remove the contact switch from the breaker closing circuit. The licensee also initiated
a control room standing order to verify that the closing circuit light is illuminated
immediately following each 4160 volt Magne-Blast breaker closure.
Analysis. The failure to promptly identify, correct, or preclude recurrence of the
deficient condition from affecting multiple safety-related components due to failures of
Magne-Blast 4160 volt circuit breakers was determined to be a violation of 10 CFR Part 50, Appendix B, Criterion XVI. This violation is being treated as a noncited violation
consistent with Section VI.A of the NRC Enforcement Policy. This finding is greater than
minor because if left uncorrected this condition could impact the reliability and
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availability of all safety-related loads supplied by Magne-Blast 4160 volt circuit breakers.
This finding was determined to be of very low safety significance since all failures
reviewed did not result in loss of a safety function for a single train for greater than its
Technical Specification Allowed Outage Time.
Enforcement. Title 10 of the Code of Federal Regulations, Part 50, appendix B,
Criterion XVI, Corrective Actions, requires that Measures be established to assure
that conditions adverse to quality, such as failures, malfunctions, deficiencies,
deviations, defective material and equipment, and nonconformances are promptly
identified and corrected. In the case of significant conditions adverse to quality, the
measures shall assure that the cause of the condition is determined and corrective
action taken to preclude repetition. Contrary to the above, the licensee failed to
promptly identify, correct, or preclude recurrence of the deficient condition from affecting
multiple safety-related components due to failures of Magne-Blast 4160 volt circuit
breakers. Because of the very low safety significance and the licensees action to place
the issue in their corrective action program (Callaway Action Request 200304247), this
violation is being treated as a noncited violation in accordance with Section VI.A.1 of the
NRC Enforcement Policy (05000483/2003010-01).
Containment Spray System Voiding
The team reviewed Callaway Action Request 200303918 pertaining to abnormal system
response that was identified during surveillance testing of containment spray Pump B on
May 22, 2003. This Callaway action request documented that following the start of the
containment spray pump, low motor current, nonexistent discharge pressure and very
little flow noise through the piping were observed for approximately 5 minutes.
Following the initial 5 minutes all indications returned to normal. Operations then re-
performed the surveillance, determined the problem was caused by a plugged sensing
line, and declared the pump operable. The team noted that questioning by the NRC
resident inspectors, who were concerned that voiding conditions could be affecting the
containment spray system, resulted in the licensee declaring the system inoperable.
The licensee subsequently determined that gas voiding of the suction piping had
occurred.
The team noted that this condition had previously been identified by the licensee on four
other occasions dating back to 1995, however they had failed to effectively determine
the root cause and implement effective corrective actions to preclude recurrence. The
team noted that the licensee was in the process of evaluating the root causes and
extent of this condition during the inspection. This issue will be dispositioned in NRC
Inspection Report 05000483/2003-004.
c.
Effectiveness of Corrective Actions
(1)
Inspection Scope
The team reviewed a variety of documentation to verify that the appropriate corrective
actions had been identified and implemented in a timely manner commensurate with the
safety significance of the issue, including corrective actions to address common-cause
or generic concerns. The team also evaluated the timeliness and adequacy of
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operability evaluations. The team reviewed corrective actions planned and implemented
by the licensee and sampled technical issues to determine whether adequate decisions
related to structure, system, and component operability were made by engineering. A
listing of specific documents reviewed during this inspection is included in the
attachment to this report.
(2)
Issues
The team determined that the majority of conditions adverse to quality were effectively
resolved in a timely manner. This conclusion was supported by the relatively few
examples (described in previous section) of repetitive issues identified that were a result
of ineffective corrective actions. The team determined that engineering products
supporting the corrective action process were timely, technically adequate, and provided
sufficient justification to support operability for degraded conditions.
4OA6 Exit Meeting
The team discussed the findings with Mr. Gary Randolf, Senior Vice President,
Generation, and other members of the licensees staff on June 6, 2003. Licensee
management did not identify any materials examined during the inspection as
proprietary.
4OA7 Licensee Identified Findings
The following violation of very low safety significance (Green) was identified by the
licensee and is a violation of NRC requirements which meet the criteria of Section VI of
the NRC Enforcement Policy, NUREG-1600, for being dispositioned as a noncited
violation.
Technical Specification 5.4.1requires that the licensee establish, implement, and
maintain written procedures recommended in Regulatory Guide 1.33, Revision 2,
Appendix A, February 1978. Appendix A recommends maintenance procedures.
The failure to follow a maintenance procedure for installing a diesel generator
fuel injector resulting in Diesel Generator B failing a surveillance test and spilling
approximately 100 gallons of fuel oil on November 11, 2002, is being considered
a violation of Technical Specification 5.4.1. This was identified in the licensees
corrective action program as Callaway Action Request 200207472. This finding
is of very low safety significance because it did not result in loss of safety
function of a single train for greater than the Technical Specification Allowed
Outage Time.
ATTACHMENT
PARTIAL LIST OF PERSONS CONTACTED
Licnesee
H. Bond, Supervisor, Operating Experience
S. Bond, Superintendent, System Engineering
M. Evans, Manager, Nuclear Engineering
B. Farnam, Superintendent, Health Physics
F. Forck, Supervisor, Human Performance
J. Hiller, Engineer
G. Hughes, Supervising Engineer, Quality Assurance
J. McGraw, Superintendent, Design Engineering
S. Menger, Acting Supervisor, Quality Assurance
K. Mills, Supervising Engineer, Safety Analysis
G. Randolf, Senior Vice President, Generation
M. Reidmeyer, Supervisor, Nuclear Regulatory Affairs
D. Rickard, Nuclear Engineering
T. Robertson, Corrective Action Program Engineer
R. Roseling, Superintendent, Training
S. Sandboth, Superintendent, Operations
J. Schnack, Supervising Engineer, Corrective Action Program
C. Slizewski, Acting Manager, Quality Assurance
NRC
M. Peck, Senior Resident Inspector, Callaway
J. Hanna, Resident Inspector, Callaway
R. Wink, Supervising Engineer, System Engineering
W. Witt, Plant Manager
ITEMS OPENED AND CLOSED
Opened and Closed
50-483/0310-01
Failure to implement effective corrective actions
DOCUMENTS REVIEWED
Procedures
Administrative Procedure APA-ZZ-00107, Review of Current Industry Operating Experience,
Revision 8
Administrative Procedure APA-ZZ-00320, Processing Work Requests, Revision 25
Work Management Procedure APA-ZZ-00322, Integrated Work Management Process
Description, Revision 0
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Administrative Procedure APA-ZZ-00500, Corrective Action Program, Revision 34
Administrative Procedure APA-ZZ-00520, Reporting Requirements and Responsibilities,
Revision 17
Administrative Procedure APA-ZZ-00542, Event Review, Revision 5
Corrective Action Documents
CAR200206287
CAR200206359
CAR200206585
CAR200206766
CAR200207024
CAR200207471
CAR200207806
CAR200207933
CAR200208066
CAR200300824
CAR200300943
CAR200301690
CAR200301941
CAR200303370
CAR200206323
CAR200206839
CAR200206970
CAR200207398
CAR200207492
CAR200207602
CAR200207751
CAR200208392
CAR200300954
CAR200301515
CAR200302450
Other Documents Reviewed
SEGR 02-10-005, ITR of the operability process
SPO3-004, QA audit, Corrective action program
SPO2-029, QA audit, Material Qualification
APO3-001, Design Control