ML20204G732
| ML20204G732 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/23/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | Asselstine, Palladino, Roberts NRC COMMISSION (OCM) |
| Shared Package | |
| ML20204G736 | List: |
| References | |
| FOIA-84-901 NUDOCS 8408310400 | |
| Download: ML20204G732 (4) | |
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UNITED STATES
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AUG 2 4 Igg 4 MEMORANDUM FOR: Chairman Palladino Commissioner Roberts Comissioner Asselstine Comissioner Bernthal Comissioner Zech FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
CONSIDERATION OF FULL POWER LICENSING OF THE CALLAWAY PLANT, UNIT 1
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Consideration of full power licensing of the Callaway Plant, Unit 1 is presently scheduled for September 7,1984.
Provided for your use is a copy of the Callaway briefing book, Enclosure 1, which includes:
1.
The Comission Briefing Slides 2.
The Proposed Full Pcwer Amendment and draft SSER #4 3.
A copy.of the Low Power License issued on June 11, 1984 4.
Technical Specification Certification Letter 5.
Region III Construction QA Report is provided for background and includes the Callaway SER and Supplements 1-3.
A recent fire protection inspection performed at the Wolf Creek Generating Station which is applicable to the Callaway Plant is presently under review by the staff. This is a subject of a Board Notification and will be reported to the Comission. contains a staff evaluation of Callaway Plant Operating Experience to date. A low power Operating License for the Callaway plant was issued to Union Electric Company (UE) on June 11, 1984 permitting operations up to and including 5 percent power.
It was expected at that time that the plant would be ready for a full power license about mid-August.
Since issuance of the low power license,.however, the staff has b'ecome concerned with the incidence of reported Licensee Event Reports (32) -- several of which inNolve personnel error.
Accordingly, the staff believes that demonstrated improvement in licensee operational performance is needed prior to authorizing operation above 5 percent power and has initiated a number of actions to achieve this objective.
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.-4, As a result, the staff believes that Comission consideration of full power licensing of Callaway, Unit 1 may be delayed from its presently scFeduled date to perhaps early October.
pp.0 Wiltlam 1.Dirch William J. Dircks Executive Director for Operations
Enclosures:
1.
Callaway Briefing Book 2.
Callaway SER and Supplements 1-3 3.
Evaluation of Operating Experience cc: SECY OPE OGC CONCURRENCES: *See previops concurrences [
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ENCLOSURE 3 STAFF EVALUATION OF CALLAWAY OPERATING EXPERIENCE TO DATE A low power Operating License for the Callaway plant was issued to Union 5percentpower.GE)onJune Electric Company 11, 1984 permitting operations up to and including It was expected that the plant would be ready for a full power license about mid-August. Since issuance of the low power license, however, the staff has become concerned with the incidence of Licensee Event Reports (32) -- several of which involve personnel error.
Each LER evaluation-determined that the event did not pose a threat to the health and safety of the public, particularly since operation had not achieved criticality.
However, collectively these events are of concern in that.similar events occurring at higher power where the consequences could be more significant.
Accordingly, the staff believes that demonstrated improvement in licensee performance,is needed prior to authorizing operation above 5 percent power.
The staff has initiated a number of actions as a result of the higher than expected incidence of LER's. These are as follows:
1.
A site visit was conducted by two Region III supervisors on July 24, and 25, 1984, to observe operations, discuss the high number of events, and convey Region III's concerns to licensee management.
The licensee was informed that Region III would not recomend issuance of the full power Operating License until its operational performance improved.
2.
The Regional Administrator met with UE corporate management on August 8, 1984 and reiterated the staff's concerns regarding the problems being experienced at Callaway. The licensee was told that Region III would not be supportive of the utility going through a " big learning curve" in putting the plant in operation and that NRC expected the utility to have most of the " bugs" worked cut of its system by the time the plant started power ascension to full power. UE stated it shared the staff's concerns, that they were disappointed over its performance to date, and described a number of actions being taken to correct identified weaknesses.
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E allaway was an essentially completed plant at the time of licensing.
C The SALP ratings had been "better than average" and, despite minimal prior operating experience at the plant, the NRC staff was expecting Callaway to proceed without unusual problems.
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, 3.
On August 14, 1984, six days after the meetin'g with UE, UE reported violations which rendered inoperable both trains of the containment spray system. 2/ These violations appear to involve at least two independent personnel errors by licensed individuals. The Regional Administrator conducted an Enforcement Conference with utility management on August 20, 1984. At that meeting, the licensee was informed that the generic concerns raised by the violation needed to be addressed prior to the plant achieving initial criticality (presently scheduled for September 9,1984). Mr. Keppler also suggested to UE that each shift demonstrate its proficiency in operating the plant at low power before issuance of an operating license above 5 percent power. UE has agreed to develop a program along these lines which will give it and the NRC staff added confidence that the operating crews are ready to commence power ascension and operate the plant at full power.
4.
Region III plans to augment its inspection activities once the plant enters Mode 3 (hot standby). This augmented inspection effort will include inspections on all shifts (although not 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day) and will focus on people performance, procedural adequacy, proper system alignments, and control of work activ.ities.
The problems experienced to date and the resultant activities being required by the staff will likely result in a delay of Comission consideration of full power operation of Callaway' until at least early October 1984. UE has a pending rate increase before the Missouri Public Service Comission which is predicated on attaining comercial operation by January 15, 1985. The schedules would forecast completion of the startup test program and declaration of comercial operation by the end of November. A substantive delay in approval of full power operation could effect this schedule.
_2] Escalated enforcement action is under consideration as a result of these violations 4
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.s UNION EtecTnic COMPANY C ALLAW AY PLA N T wasLsNo ADDag.s:
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September 10, 1984 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 s
ULNRC-919 DOCKET NLHBER 50-483 CALLAWAY PLANT UNIT 1 LICENSEE EVENT REPORT 84-029-00 TECHNICAL SPECIFICATION VIOLATION Gentlemen:
The enclosed Licensee Event Report is suheitted pursuant to 10 CFR 50.73(a)(2)(1) concerning the inoperability of the Containment Spray System.
h S. E. Miltenberger Manager, Callaway Plant
$ WA NV JTP/WRR/RRG/drs Enclosure cc: Distribution attached
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James G. Keppler USNRC Region III Office
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799 Roosevelt Road
. Glen Ellyn, IL 60137 ti American Nuclear Insurers c/o Dottie Sherman, Library The Exchange Suite 245 I'.
270 Farmington Aveune Farmington, CT 06032 II 1
Records Center l-Institute of Nuclear Power Operations 1-Suite 1500 1100 Circle 75 Parkway Atlanta, GA 30339 1
NRC Resident Inspector Missouri Public Service Commission D. F. Schnell J. F. McLaughlin J. E. Davis (Z40LER)
D. W. Capone R. L. Powers 1
A. C. Passwater/D. E. Shafer/D. J. Walker G. A. I!ughes W. R. Robinson (QA Record)
M. E. Taylor A. P. Neuhalfen q
R. A. McAleenan i
L. K. Robertson (470)(NSRB)
Merlin Williams, Wolf Creek SEM Chrono 3456-0021.6 3456-0260 240ULNRC G56.37 N. Date i
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,.,,.,,...,,,...,,..oe On 8/14/84 while in Mode 4 a review of k'orkman's Protection Assurance (kTA) revealed that the Containcent Spray Manual Isolation Valves were in the locked closed position. These valves being closed made the Containment Spray System inoperable which violated Technical Specification 3.6.2.1 requiring the Containment Spray System to be operable in Mode 4 The valves were subsequently opened, locked, and independently verified.
Further investiEation on 8/14/84 revealed that the afore-mentioned valves were also not entered in the Equipment Out of Service Log (EOSL).
Ir=ediate reviews of the Surveillance Master Tracking Log, outstanding k'ork l
Requests, outstanding kTA, and outstanding Temporary Modifications were initiated against the EOSL to cake it current. No additional discrepancies j
j were found for Mode 4, and the EOSL was brought up-to-date for Modes 1 through 3.
Due to the plant operating conditions, this event had no effect on power operations. There was no effect on public health or safety.
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O**N Callaway Plant Unit 1 0 l0 0l2 or 0 l3 0l 2l9 olslojolol4l8l3 8l4 rw a -. m ~ ~a:v.-unaenn On 8/14/84 while in Mode 4 a review of Workman's Protection Assurance (WPA) revealed that the Containment Spray Manual Isolation Valves (EN-V014 and EN-V018) were in the locked closed position. These valves being clcsed made the Containment Spray System inoperable which violated Technical Specification 3.6.2.1 requiring the Containment Spray System to be operable in Mode 4.
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On 5/7/84 containment Spray Manual Isolation Valves EN-V014 and EN-V018 were c1csed, locked and tagged on WPA 84-3252 to prevent inadvertent discharges into containment. Contrary to the requirement of ODP-ZZ-00002, Equipment Status Control, these valves were not entered in the Equipment Out of Service Log (EOSL).
On 5/9/84 Containment Spray Valves EN-V014 EN-V018 and EN-V097 were noted as exceptions upon completion of normal operating procedure OTN-EN-00001, Containment Spray System, but their status was not entered in the EOSL as required by Standing Order 84-24 On 8/3/84 during the review of WPA that could be eliminated in preparation for making the code change from Mode 5 to Mode 4, RFA 84-3252 for contain-cent Spray Valves EN-V014 and EN-V018 was not identified as being required for Mode 4 On 8/8/84 Teeporary Change Notice (TCN)84-945 to Operations Department procedure ODP-ZZ-00014, Operation Mode Change Requirements, was executed to delete the sign-off requirement for the review of the EOSL, WPA log, and the Temporary Modification log. This change was made in such a canner that it appeared to delete the requirement to perform the reviews.
On 8/10/84 Mode 4 was entered.
On 8/14/84 upon discovery of the Containment Spray Manual Isolation valves being locked closed, the valves were immediately opened, locked, and independently verified. Also when the EOSL was found to be out of date, immediate reviews of the Surveillance Master Tracking log, outstanding Work Requests, outstanding WPA, and outstanding Temporary Modifications were initiated against the EOSL to bring it up-to-date.
These reviews were corpleted and the EOSL brought up-to-date on 8/20/84. The individuals resporsible for not entering ES-V014 and ES-VOIS in the EOSL vere counseled by 8/30/84 The Plant Manager and/or the Assistant Plant Managers have also held a series of reetings with plant staff and support personnel. The purpose of these neetings was to enhance the communication of management's philesophy to all levels of the work force, highlight the recent Callaway events, and stress the necessity for ieproving individual perforcance, group per-I forvance, and communication. These seetings were completed 9/7/84 I
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0 l5 l 0 l 0 l 014 l8 l 3 8l4 0 l 2l 9 0l0 01 3 0F 0b T157 t7 mswo anece e eewr**.== sh **C Fer* JEEd'8d ith In addition, the content of Standing Order 84-24 has been incorporated into ODP-ZZ-00002, Equipment Status Control, and APA-ZZ-00310, Workman's Pro-I tection Assurance. This was accomplished on 8/20/84.
And finally, the Temporary Change Notice (TCN 84-945), which removed the requir gent for review of EOSL, WPA, and Temporary Modifications, was eliminated by a revision to procedure ODP-ZZ-00014, Operational Mode Change l
Requirements on 8/15/84. This revision also included the requirement to do the same reviews for all mode ascensions.
It previously applied to the change from Mode 5 to Mode 4 only. The individuals who initiated TCN 84-945 were counseled on 8/17/84 and 8/19/84 and had been aware of the limitation of the use of temporary changes, but had not intended for the l
TCN to delete the reviews of the EOSL, WPA, and Temporary Modifications.
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- Ihey had intended only to delete what they believed to be a redundant i
documentation of the reviews. As an added precaution, a letter was issued on 8/18/84 to Nuclear Operations personnel and contractors emphasizing the limitations on the use of temporary cha6ges.
Due to the plant operating conditions, this event had no effect on power operations. There was no effect on public health or safety.
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