ML20205A382
| ML20205A382 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/19/1999 |
| From: | Graves D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| NUDOCS 9903300369 | |
| Download: ML20205A382 (31) | |
Text
. . .- - -- - - . . _ _ . _ . . .
- 8 "%<g UNITED STATES e t NUCLEAR REGULATORY COMMISSION
- REGloN IV 611 RYAN PLAZA DRIVE, sulTE 400 4 ARLINGTON, TEXAS 76011-8064
.,,g MAR I 91999 Garry L. Randolph, Vice President and Chief Nuclear Officer Union Electric Company P.O. Box 620 Fulton, Missouri 65251
SUBJECT:
PLANT PERFORMANCE REVIEW (PPR) - CALLAWAY PLANT
Dear Mr. Randolph:
On February 11,1999, the NRC staff completed a PPR of the Callaway Plant. The staff conducts these reviews for all operating nuclear power plants to develop an integrated understanding of safety performance. The results are used by NRC management to facilitate planning and allocation of inspection resources. PPRs provide NRC management with a current summary of licensee performance and serve as inputs to the NRC's senior management meeting (SMM) reviews. PPRs examine information since the last assessment of licensee performance to evaluate long term trends, but emphasize the last 6 months to ensure that the assessments reflect current performance. The PPR for the Callaway Plant involved the participation of all technical divisions in evaluating inspection results and safety performance information for the period, May 10,1997, through January 25,1999. The NRC's most recent summary of licensee performance was provided in a letter of June 13,1997, and was discussed in a public meeting with you on July 2,1997.
As discussed in the NRC's Administrative Letter 9F 37 of October 2,1998, the PPR provides an assessment of licensee performance during the interim in which tne NRC has suspended its Systematic Assessment of Licensee Performance (SALP) program. The NRC suspended its SALP program to complete a review of its processes for assessing performance at nuclear power plants. At the end of the review period, the NRC will decide whether to resume the SALP program or terminate it in favor of an improved process.
The Callaway Plant was in Refueling Outage 9 at the beginning of the current period of detailed focus (April 22,1999). This outage began on April 3,1998, and continued until May 4. The /
plant was restored to 100 percent power on May 9 and remained essentially at 100 percent power until October 21, when elevated temperatures were found on the Phase B neutral bushing of the main transformer. Reactor power was reduced to 7-8 percent while the turbine was tripped so that repairs could be effected. On October 25, the plant was returned to 100 percent power. On November 29, the plant was placed in Mode 3 so that repairs could be made to a containment cooler fan. The plant was returned to 100 percent power on December 3. On December 5, an unisolable leak was discovered on the Main Feed Pump B suction vent piping, and the plant was downpowered to 71 percent to effect repairs. The plant resumed 100 percent power operation on December 6 and remained at 100 percent power throughout the rest of the assessment period..
Overall, performance at the Callaway Plant was acceptable. Performance in the area of operations continued to assure safe and conservative decision making, and the licensee 9903300369 990319 PDR ADOCK 05000403 C PDR
Union Electric Company effectively.irrplemented the maintenance and engineering programs. All three of these areas experienced some negative findings, but none indicated any programmatic concerns. The ongoing core axial offset anomaly problems were the primary engineering challenges related to normal power operations. Plant support performance was noted to be improving.
Plant operations safety performance included proper operator diagnosis and response to events. Effective communications and supervisory control were significant factors in this performance. Personnel errors identified during this assessment period appeared to be isolated and were not programmatic in nature. No inspection effods beyond the core inspection program are planned.
Maintenance performance in the field continued to be well performed. Some errors made by maintenance personnel were identified, but these were isolated instances and did not indicate any programmatic problems. Material condition of eculpment monitored during this assessment period was good. The core inspection program and a .>afety initiative inspection on motor-operated valves will be performed in the near future. This initiative is being performed at a sample of plants, in general, engineering support to the plant allowed for uneventful operations. All necessary modification packages were well prepared and executed, and procedural guidance was effective. The Technical Specification amendment submittals for the Electrosleeve steam generator tube repair were weak. Additionally, the attempt to redesign the core to eliminate the axial offset anomaly was unsuccessful and highlighted the inaccuracy of the fuel vendor's and utility's code modeling effods, it was determined that only core inspection need be conducted in the engineering area; however, continued focus will be maintained on your resolution of the axial offset anomaly.
The radiation protection program implementation improved during this assessment period.
Emergency preparedness performance also improved, but areas still exist where further improvement is needed, such as timely event classification. Performance in the physical security area was highlighted by corrective actions taken in response to the Operational Safeguards Response Evaluation. Housekeeping was generally good. Overall, goo <' fire protection program implementation was maintained. The core inspection program.will be implemented. Additionally, regional followup on fire protection hot short issues is planned.
Enclosure 1 contains a historical listing of plant issues, referred to as the Plant issues Matrix (PIM), that were considered during this.PPR process to arrive at an integrated view of licensee performance trends. The PIM includes items summarized from inspection reports or other docketed correspondence between the NRC and Union Electric Company. The NRC does not attempt to document all aspects of licensee programs and performance that may be functioning appropriately. Rather, the NRC only documents issues that the NRC believes warrant management attention or represent noteworthy aspects of performance, in addition, the PPR may also have considered some predecisional and draft material that does not appear in the attached PIM, including observations from events and inspections that had occurred since the last NRC inspection report was issued but had not yet received full review and consideration. This material will be placed in the PDR as part of the normalissuance of NRC inspection reports and other correspondence. Enclosure 2 provides definitions for some of the information listed in the PIM.
l
[
Union Electric Company This letter advises you of our planned inspection effort resulting from the Callaway Plant PPR I review. It is provided to minimize the resource impact on your staff and to allow for scheduling conflicts and personnel availability to be resolved in advance of inspector arrival onsite.
Enclosure 3 details our inspection plan for the next 8 months. The rationale or basis for each inspection outside the core inspection program has been provided in this letter so that you are aware of the reason for emphasis in these program areas. Resident inspections are not listed because of their ongoing and continuous nature.
Because of the anticipated chenges to the inspection program and other initiatives, this inspection schedule is subject to revision. Any changes to the schedule listed will be promptly discussed with your staff. If you have any questions, please contact me at (817) 860-8141.
1 Sincerely, -
Md David N. Graves, Chief Project Branch 8 -
Division of Reactor Projects Docket Nos. 50-483 License Nos. NPF 30 1
Enclosures:
- 1. Plant issues Matrix
- 2. General Description of PIM Table Labels
- 3. Inspection Plan cc w/ enclosures:
Professional Nuclear Consulting, Inc.
19041 Raines Drive Derwood, Maryland 20855 John O'Neill, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.
Washington, D.C. 20037 H. D. Bono, Supervising Engineer Quality Assurance Regulatory Support Union Electric Company P.O. Box 620 Fulton, Missouri 65251
_ _ ~ _ . _ _ _ _ _ _ .- - ._. _ _ _ _ . . . ._ . -
i l
. Union Electric Company j l
l Manager - Electric Department Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, Missouri 65102 Ronald A. Kucera, Deputy Director I Department of Natural Resources P.O. Box 176 I Jefferson City, Missouri 65102 I i'
Otto L. Maynard, President and Chief Executive Officer Wolf Creek Nuclear Operating Corporation J P.O. Box 411 Burlington, Kansas 66839 Dan I. Bolef, President l Kay Drey, Representative l Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 Lee Fritz, Presiding Commissioner' Callaway County Court House 10 East Fifth Street '
Fulton, Missouri 65151 Alan C. Passwater, Manager Licensing and Fuels .
AmerenUE One Ameren Plaza 1901 Chouteau Avenue P.O. Box 66149 St. Louis, Missouri 63166-6149 i J. V. Laux, Manager ,
Quality Assurance l Union Electric Company P.O. Box 620
' Fulton, Missouri 65251 l
l- Jerry Uhlmann, Director l State Emergency Management Agency P.O. Box 116 Jefferson City, Missouri 65101
Union Electric Company The Honorable Raymond Edwards Mayor of Chamois ,
Star Route. j Chamois, MO 65024 1
. Mr. John Backes Presiding Commissioner
- P.O. Box 826 1 Linn, MO 65051 ~
j Ms. Charlotte Townley Emergency Preparedness Coordinator P.O. Box 826 Linn, MO 65051 Mr. Carl Fowler ,
Osage County Sheriff - l P.O. Box 619 Linn, MO 65051 Ms. Tamira Prater !
Public Administrator Star Route Charnois, MO 65024 ;
Mr. Max Winkels Emergency Preparedness Coordinator P.O. Box 817 Fulton, MO 65251 Mr. Harry Lee Callaway County Sheriff P.O.' Box 817 Fulton, MO 65251 Mr. J. Eric Harness ;
Presiding Commissioner Montgomery County Courthouse 211 E. Third Montgomery City, MO 63361
1 I
Union Electric Company 1 Mr. Ron Hansen Director of Emergency !
Services Montgomery County Courthouce 211 E. Third i Montgomery City, MO 63361 !
Mr. John Whyte Montgomery County Sheriff j Montgomery County Courthouse l 211 E. Third !
Montgomery City, MO 63361
.l Mr. Charles Schlottach l Presiding Commissioner i Gasconade County l 119 E. First Street, Room 2 Hermann, MO 65041 1
Mr. Richard Hudson l I
Emergency Preparedness Coordinator Gasconade County 119 E. First Street, Room 2 Hermann, MO 65041 Mr. Robert Mathis Gasconade County Sheriff ,
119 E. First Street, Room 22 i Hermann, MO- 65041 Ms. Leoda Dunton Gasconade County Public l Administrator I 501 S. Second St. I Owensvil!e, MO 65066 The Honorable Robert Fisher Mayor of Fulton P.O. Box 130
' Fulton, MO 65251 Mr. Mick Herbert Chief of Police P.O. Box 130 Fulton, MO 65251 i
l l
^
l !
Union Electric Company Mr. Mike Miller Fulton City Administrator l
- P.O. Box 130 Fulton, MO 65251 i
The Honorable Samuel Birk Mayor of Morrison '
Route #1 Morrison, MO 65061 The Honorable James P. James Mayor of Mokane l P.O. Box 41 Mokane, MO 65059 The Honorable Ervin Elsenraat Mayor of Rhineland j P.O. Box 384 l Rhineland, MO 65069 ~ j Mr. Albert R. Theissen Assistant Emergency Director Route 1, Box 2 Rhineland, MO 65069 ,
I Mr. M. B. Ripp Russell Eastern Associate Commissioner 10 E. 5th Street Fulton, MO 65251 Ms. Eva Fine Western Associate commissioner 10 E. 5th Street Fulton, MO 65251 l
i l
l
.. I
- Union Electric Company IOR I 9 :S32 bec to DCD.f!E40-)
bec distrib. by RIV:
Regional Administrator Resident Inspector DRP Director DRS Branch Chiefs (3 copies) l DRS Director MIS System Branch Chief (DRP/B) RIV File Project Engineer (DRP/B) Chief, NRR/ DISP /PIPB Branch Chief (DRP/TSS) Chief, OEDO/ROPMS B. Henderson, PAO C. Gordon
W. D. Travers, EDO (MS: 16E15) -
Associate Dir for Projects, NRR Associate Dir. for Insp., and Tech. Assmt, NRR PPR Program Manager, NRR/lLPB (2 copies)
Chief, inspection Program Branch, NRR I Chief, Regional Operations and Program Management Section, OEDO W. Bateman, NRR Project Director (MS: 13E16) l l L. Burkhart, NRR Project Manager (MS: 13D1)
I l
i l
1 l
l l
DOCUMENT NAME: S:\DRP\DRPDIR\PPR\CWY To receive copy of document, indicate in box: "C" = Copy without enclosyreJ "E" = Copy with enclosures "N" = No copy RIV:DRP/B ., AC:DRP/B D:DF3g W 9 D:DRP ,
l RECONCUR RVAzua;dt D% DNGraves ? ATH8w(ft/ KEBrockman' DNGraves e 3/ lb /99 3/.i /99 3/ \h/99 3/ ' /99 3/, 'i /99 OFFICIAL ' RECORD COPY
.300105
Union Electric Company -8 MAR I 91999 bec to DCD (IE40) bec 6strib. by RIV:
Regional Administrator Resident inspector DRP Director DRS Branch Chiefs (3 copies)
DRS Director MIS System Branch Chief (DRP/B) RIV File i Project Engineer (DRP/B) Chief, NRR/ DISP /PIPB Branch Chief (DRP/TSS) Chief, OEDO/ROPMS B. Henderson, PAO C. Gordon T. Boyce, NRR/ DISP /PIPB Records Center, INPO C. Hackney, RSLO W. D. Travers, EDO (MS: 16E15) ,
Associate Dir. for Projects, NRR l Associate Dir. for Insp., and Tech. Assmt, NRR PPR Program Manager, NRR/lLPB (2 copies)
Chief, inspection Program Branch, NRR Chief, Regional Operations and Program Management Section, OEDO W. Bateman, NRR Project Director (MS: 13E16)
L. Burkhart, NRR Project Manager (MS: 13D1)
DOCUMENT NAME: S:\DRP\DRPDIR\PPR\CWY To receive copy of document, Indicate in box: "C* = copy without enclosttrets "E" = Copy with enclosures "N" = No copy RIV:DRP/B .i AC:DRP/B D:DF)I % $ D:DRP RECONCUR RVAzua;df/dW DNGraves D ATH8w~ d / KEBrockman'{d7 DNGravesA 3/10/99 3/gi /99 3/\f4/99 3/R/99 3/f S /99 OFFICIAL MECORD COPY
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 12/26/98 VIO IR 98-25 NRC OPS 18 1C 4B In violation of 10 CFR 50.59, the licensee made a de facto change to the facility as descnbed in Final Safety Analysis Report Section 6.3. Emergency operating procedure steps for transfer to cold leg recirculation did not agree with steps in Final Safety Analysis Report Table 6.3-8. The licensee did not evaluate and document the acceptability of the change to ensure that an unreviewed safety question did not exist. The violation existed from June 11,1984 (initial operat:ng license), until May 5,1998. The licensee changed the affected emergency operating procedure to match Table 6.3-8 after performing simulator scenarios and other evaluations. Also, the licensee initiated a change notice to correct discrepancies in other parts of Final Safety Analysis Report Section 6.3. This closes Unresolved item 50-483/98008-01. (No response was required for this violation).
12/03/98 NCV lR 98-25 SELF OPS 1A 3A The inspectors concluded that an operator's failure to recognize reactor power trending above 100 percent power to the overpower rod stop setpoint, as indicated by the nuclear instruments, was a violation of Technical Specification 6.8.1.a. The operator was attentive to core thermal power and reactor coolant system temperature but missed the nuclear instruments. Corrective actions included revising procedures to allow l xenon to stabilize prior to attaining full power, performing more frequent heat balance calculations, and conducting training. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
11/29/98 POS IR 98-25 NRC OPS 1A 3A Control room communications, briefings, supervisory control, and self-checking were very good during the plant shutdown to Mode 3 for replacement of the containtnent Cooler A fan motor.
10/08/98 NCV IR 98-22 SELF OPS 1A in violation of Technical Specification 6.8.1.a. a reactor operator failed to property implement the procedure for raising pressure in safety injection accumulator Tank C. As a result, the accumulator was inoperable for approximately 15 minutes. The licensee discussed the event with the operator, identified procedure and labeling enhancements, and proposed additional corrective actiore. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, conseent with Section Vll.B.1 of the NRC Enforcement Policy.
09/26/98 POS IR 98-2 t NRC OPS 1A 1B Operator response to an equipment failure, which caused a pressure transient and damaged valves in the boron thermal regeneration system, and the subsequent reduction of volume control tank level was good.
Operators quickly diagnosed the event and took actions which minimized the loss of water from the chemical and volume control system. The licensee successfully repaired the damaged valves and restored the system to service.
Jrnuary 25,1999 1 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 L iTE TYPE SOURCE ID SFA TEMFLATE ITEM CODE 09/26/98 POS IR 98-21 NRC OPS 1A 18 Control room operator response to the loss of main feedwater pump automatic speed control was very good.
The operators quickly recognized the condition and took manual control of the main feedwater pumps.
Operators quickly restored steam generator water level to the programmed band.
09/04/98 POS IR 98-20 NRC OPS SA 5B SC Conditions adverse to quality were generally being appropriately identified, evaluated and corrected .
09/04/98 NEG IR 98-20 NRC OPS 1A SC The occurrence of mispositioned components, however, continued to be a problem for which the corrective action process had not been effective. Because of the continuing identification cf tagging errors, corrective actions for workman's protection assurance performance deficiencies had not improved performance in this area.
08/15/98 NCV 1R 98-12 LIC OPS 1C in violation of Technical Specification 6.8.1.a. the licensee failed to establish a procedure requirement to isolate the reactor water makeup system during natural circulation shutdown as a result of incomplete procedure reviews for an internal commitment. The licensee took corrective actions to address this issue.
This violation was treated as a noncited violation in accordance with Section Vil.B.1 of the NRC Enforcement Policy.
07/22/98 NEG IR 98-12 NRC OPS 1C 3B On July 22,1998, the temperature of the ultimate heat sink pond approached the Technical Specification hmit of 90'F. Operator knowledge of procedure steps as ociated with ultimate heat sink pond operating temperature limits was weak. Equipment operator logs had conflicting guidance between t?mperature limsts stated in the logs and the normal operating procedure.
07/04/98 POS IR 98-11 NRC OPS 1A Control room decorum and professionalism were well-maintained. Distractions were minimized. Operators displayed proper communications. Control room logs were property maintained. Shift briefings appropriately covered upcoming events and evolutions.
05/23/98 POS 1R 98-08 NRC OPS 1A The licensee's communications, command and control, and cross-checking were thorough during fuel movement in Refueling Outage 9. The licensee effectively implemented foreign material exclusion controls around the refuel and spent fuel pools.
05/23/98 POS 1R 98-08 NRC OPS 1A The licensee effectively prepared for and implemented mid-loop operation during Refueling Outage 9.
04/30/98 NCV IR 98-21 LIC OPS 1A 1B In violation of Technical Specification 3.0.4, the licensee failed to ensure operability of the turbine-driven LER 98-005 auxiliary feedwater pump prior to entering Mode 3. This occurred as a result of a deficient Mode 4 to Mode 3 checklist. ihe licensee revised the checklist to ensure the system was in the proper lineup for plant startup.
This was a noncited violation.
January 25,1999 2 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE ,
04/19/98 POS IR 98-08 LIC OPS 3A Control room operators dernonstrated attentiveness to plant parameters by immediately recognizing and responding to an inadvertent transfer of water to the chemical and volume control system from the refueling cavity.
04/11/98 POS 1R 98-03 NRC OPS 1A 1C The licensee's preparations for entering mid-loop operation were good. The licensee complied with the recommended actior>s in NRC Generic Letter 88-17, " Loss of Decay Heat Removal." The licensee's preparations appropriately addressed shutdown risk, time to boil calculations, decay heat removal system availability, electrical power, reactor coolant system water level and !emperature indications, and containment closure.
04/04/98 POS IR 98-03 NRC OPS 1A Control room communications, briefings, supervisory control, and self-checking were ' ery good during the plant shutdown and cooldown in preparation for Ref=:ng Outage 9.
02/18/98 NEG IR 98-01 SELF OPS IA 2B 3A An equipment operator opened an incorrect breaker to a nonsafety-related mote control center whne hanging tags. The operator immediately reclosed the brei ker without prior control room authorization. The cailure to open the correct breaker was due to personnel errcr. The immediate re-closing of the breaker was a poor practice. The control room operators' response to this event was good.
01/21/98 POS IR 98-01 NRC OPS SB SC Th? licensee exhibited the proper enforcement perspectiv e when responding f , :ne simultaneous inoperability of auxiliary / fuel building emergency exhaust system filter adsorber Unit B and Emergency Diesel ,
Generator A. The licmsee requested and received a Notice af Enforcement Discretion. This item was the subject of a specialir.specticn. Sea IR 50-483/9802.
01/$ 7/98 POS IR 97-21 NRC OPS LA An operations department self-assessment report had good observations, conclusions, and recommendations.
01/15/98 NCV IR 98-03 LIC OPS 1A 1C Licensee Event Report 98-002 reported the failure to maintain the position of the reactor building equipment LER 98-002 hatch missile shield within the design basis during past refueling cutages. This violation was not cited, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
12/06/97 NEG IR 97-20 SELF OPS TA r.A 3A An equipment operator exhibited poor work practice and damaged an essential service water motor-operated valve actuator. The operator used a wrench on the handwheel in an attempt to manual;y open the valve. The valve was already open.
J:nuary 25,1999 3 Callaway Plant
PREDECISIONAL PLANT ISSUES M. ATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPL^.TE ITEM CODE
~
12/06/97 POS IR 97-20 NRC OPS 1A 2B 3A Operators maintained a heightened state of awareness to plant parameters during remodeling of the control ,
room. There was minimal impact on shift crews during the remode:ing. The work was performed when the i on-line maintenance risk was low.
10/25/97 POS 1R 97-17 NRC OPS 1A 3A Control room operator shift tumovers and briefings were good.
3 I
i l
i 6
I January 25,1999 4 Callaway Plant t
a PREDECISIONAL PLANT ISSUES MAiRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 11/25/98 NCV 1R 98-22 LIC MAINT 2B There were multiple examples of a violation of Technical Specification surveillance requirements as a result of LER 96-007 surveillances conducted while on-line instead of "At least once per 18 months during shutdown" and IR 97-14 subsequent plant mode changes made while relying on those surveillances. The licensee failed to pe: form these surveillances while shut down as a resu't of an incorrect survei!!ance data base. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation, consistent with Section Vll.B.1 of the NRC Enforcement Policy. The issue was first identified on December 11,1996.
10/21i98 POS IR 98-22 llc MAINT 2A 4C Overait, observed material condition and housekeeping were very good. The licensee corrected a material condition concern regarding high temperature on a main transformer bushing. No significant materni condition concems arose during the plant power reduction and subsequent increase. The licensee also identified a material condition deficiency regaiding degradation of essential service water Pump A and initiated appropriate corrective actions.
10/02/98 POS IR 98-18 NRC MAINT 28 Material condition of the essential service water system was good. System walkdowns combined with a review of Suggestion / Occurrence / Solution Reports, Maintenance Rule reports, and system health reports indicated that the essential service water system was in good material condition.
08/15/98 PO9 IR 98-12 NRC MAINT 2B The Predictive Program Summary report provided a useful tool for licensee personnel to summarize predictive program results. Certain equipment problems were discussed; the licermee has either resolved the problems or defined a clear path to resolution. There were no operability oi safety concems.
08/15/98 POS 1R 98-12 NRC MAINT 2A 2B Material condition was good based on the work backlog and plant tours. There were only 63 outstanding nonoutage corrective maintenance work requests. This was an vnprovement from the approximate 400 nonoutage corrective maintenance work requests that existed in early 1995. A small number of minor oil and water leaks were evident. The leaks were previously ider?fied by the licensee and were included in the licensee's maintenance program.
08/15/98 NEG IR 98-12 NRC MAINT 3A 3C Maintenance and health physics planning for an at-power - ator building entry was weak. There was confusion concerning the appropriate measures to ininimiu heat stress, and one person required assistance to leave the reactor build:ng. Personnel did not know the exact location of equipment which contributed to longer stay bmes. The work scope for the entry had increased; however, planning and coordination were not thorough. Maintenance personnel were unsure of the sequence of work to be performad and how health physics coverage was to be provided. The hcensee conduct d a thorough critique arx' identified a number of suitable corrective actions.
J nuary 25,1999 5 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCi_OSURE 1 2_ .
DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 07/10/98 POS 1R 98-15 NRC MAINT 2A The switchgear and surrounding areas were in good visual material condition with no deficiencies identified.
07/10/98 POS IR 98-15 NRC MAINT 4C The licensee's functional determination of the safety-related GE Magne-Blast breakers was acceptable; however, breakers were overdue for overhaul or refuroishment. The licensee's action plans for overhauling and upgrading safety-related breakers were adequate and deviations from vendor recommendations were adequately justified. The licensee's preventive maintenance for Magne-Blast ureakers was generally acceptable.
07/10/98 N':G T 18-15 NRC MAINT 4C With some exceptions, the resolution of circuit breaker issues expressed in NRC generic communications, industry operating experience reports, and vendor letters was marginal. Seven service advice letters and two information notices were incorrectly reviewed for plant applicability.
07/10/98 NEG IR 98-15 NRC MAINT 3C Procedures and communication paths for informiag the licensee's staff about operating experience and vendor-supplied information were not appear consistently applied. The team determined that this shortcoming was conducive to less than optimum coordination, duplication of effort for communications dealing with the same subject but from different sources, and an obstacle for important information to reach the appropriate or cognizant staff.
07/10/98 NEG IH 98-15 NRC MAINT 3A The calculation of direct current control circuits' voltage drop facked the normal rigor involving design inputs for safety-related calculations. The team was assured by a prelimina.y calculation that all equipment associated w4h the breaker close and trip circuits would have voltage above the required minimum-allowed voltage.
07/04/98 POS IR 98-11 NRC MAINT 2A 28 Material condition was good. The percentage of the total power generation for Cycle 9 that was lost due to maintenance-related causes was about 1 percent. This was below the licensee's goal of 2 percent and below the industry median fe: plants in the United States. The licensee operated the plant wi'h a " black board" in the control room during most of the current inspection report period.
05/02/98 NCV iR 98-21 LIC MAINT 2B 48 in violation of Technical Specification 3.2.5, the licensee failed to calibrate the feedwater temperature LER 98-004 detectors used to criculate reactor coolant system flow rate. The licensee <!etermined that personnel misinterpreted the associ, ted surveillance procedure. The licensee revised the procedure to ensure the ca:ibration would be performed within the required time frame The licensee determined that past flow rate calculations were acceptable because conservative calibration uncertainties were already included in the surveillance procedure. This was a noncited violation.
J:nuary 25,1999 6 Callaway Plant
\
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE . ITEM CODE l 04/30/98 POS IR 98-09 NRC MAINT 2B The procedures and records for inservice inspections, examiner qualificaticns, and repair and replacement of ASME Code Class 1,2, and 3 components that the inspector reviewed were good, and indicated that the inservice inspection program was being appropriately implemented.
04/19/98 VIO IR 98-08 SELF MAINT 1A An inadvertent transfer of 600 gallons of refueling cavity water to the chemical and volume control system was SLIV due to personnel error. Workman's protection assurance tagging was inadequate. Licensee personnel failed to follow the requirements of procedure APA-ZZ-0310.
04/17/98 POS IR 98-05 NRC MAINT 28 3B 5A Refueling Outage RF9 eddy current examination acquisition and analysis activities appeared effectively controlled, with good overall contractor performance noted.
03'03/98 POS IR 98-02 NRC MAINT 4B 4C The licensee's process for implementing Techncal Specification amend nents was well-defined and thorough, although the Icensee's failure to maintain all records associated with one license amendment package was identified.
03'03/98 VIO IR 98-02 NRG MAINT 2B 4B 4C The licensee failed to demonstrate during the 30-day implementation period of Technical Specification SLIV LER 98-001 Amendment 118 that either train of the auxiliary / fuel building emergency filter system adsorber would meet ED the new req eirements of Technical Specification 4.7.7,b.2. The licensee believed they did not have to demonstrata compliance with tr e requirements of Technical Specification Amendment 118 during the implementation period because they had satisfactory test results using prior test acceptance criteria. This reasoning was incorrect and resulted in the licensee not recognizing that both trains of the emergency exhaust system were inoperable when enforcement discretion was requeste<f. As a result, an incomplete notice of enforcement discretion wa1 requested by the licensee and granted by the NRC.
01/17!98 POS lR 97-21 NRC MAINT SA A maintenance department self-assessment was thorough. The assessment team identified strengths and opportunities for improvement.
01/17/98 WK IR 97-21 NRC MAINT 2A 5A Overall, the plant material condition was good. However, there were weaknesses in the licensee's identification of emergent material cond3 ion deficiencies. The inspectors identified four examples of material deficiencies that were not identified by licensee personnel during tours.
J nuary 25,1999 7 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM l CODE 12/17/97 LER LER 97-005 LIC MAINT 2B Licensee engineers determined that the surveillance test of safety related logic circuits did r. 4 provide circuit overlap verification of the P-11 permissive circuit. P-11 reinstates the safety injection functkm on low pressurizer or main steam line pressure on pressure increases, and a!!ows blocking of the safety injection function when decreasing RCS pressure. LER was revised on 8/22/97 to include identification of incomplete circuit testing of the main steam isolation valve bypass valves. LER was revised on 10/1/97 to include identification of the failure to completely test load shedder and emergency load sequencing contacts that inhibit the non-sequenced auto-start signals of several safety-related pumps during surveillance testing. LER was revised again on 10/17/97 to incorporate two additional surveillance tesdag deficiencies. The LER was revised on 11/10/97 to incorporate contacts in the emergency diesel generator trip bypass circuitry that had not been previously adequately tested. LER was revised on 12/19/97 to include identification of additK)nal deficiencies in completeness of surveillance testing. The LER was revised on 1/15/98 to include the identification of additional deficiencies regarding insufficient overlap betweeen test procedures.
12/06/97 NCV IR 97-20 LIC MAINT 2B Licensee Event Report 50-483/97-002 reported that containment isolation valves in the containment hydrogen LER 97-002 control system were not properly tested in accordance with Technical Specification 4.6.3.1. This item was identified by the licensee on 3/17/97.
11/18/97 NCV 1R 98-01 LIC MAINT 2B Certain portions of logic circuits in the solid state protection system were not being adequately tested by LER 97-010 procedures. The circuits inciuded the source range automatic P-10 block, feedwater iso!ation on P-14 steam generator hi-hi level, and feedwater isolation on a safety injection signal The cause was determined to be inadequate vendor information regarding testing methodology 10/29/97 VIO IR 97-20 NRC MAINT 2B 3A A preventive maintenance test on Emergency Diesel Generator A was not property contro!!ed. A differential SLIV LER 97-011 pressure gauge remained installed after the test was complete.
10/14/97 NCV 1R 98-08 LIC MAINT 2A The licensee failed to vent the safety-related centrifugal charging pumps, as a result of misinterpretation of LER 97-009 Technical Specification requirements. The licenwe took corrective actions to address this issue; therefore, a noncited violation was issued, as allowed by Section Vll.B.1 of the Enforcement Policy.
10/12/97 VIO IR 97-17 SELF MAINT 2B 3A Control room operators performed a slave relay test procedure for the auxiliary / fuel building emergency SLIV exhaust ventilation system Train 8 out-of-sequence and resulted in tripping the fan breaker.
J rmary 25,1999 8 Callaway Plant
_ _ _ _ = __
____ _ _ _ _ _ . _ - _ = _ _ -_
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 11/19/98 NEG IR 98-25 LIC ENG 4A 4B Although a formal safety evaluation to revise the Final Satsty Analysis Report through Change Notice 98-067 was thorough, engineers failed to identify that a proposed setpoint change for refueling water storage tank level required revision to an operations department alarm response procedure. Control room operators identified the problem and stopped the setpoint change prior to its implementation. The licensee initiated corrective action.
11/14/98 POS IR 98-22 NRC ENG 48 The licensee aggressively monitored and pursued solutions fc 5 axial offset anomaly. The licensee formed a task team to cddress options to improve axial offset and conserve shutdown margin.
10/02/98 STR IR 98-18 NRC ENG 4A The design and testing of the essential service water system were consistent with applicable licensing, design, and operations documents. White, the licensae had not initially established a clear analyttal basis tc; system operability with a degraded pump, testing practices were aggressive and the licensee had pivactively scheduled pump replacement as needed. Subsequent analysis confirmed that the as-found design was acceptable over the full range of allowed pump degradation.
10/02/98 STR 1R 98-18 NRC ENG 4A Procedural guidance was in place to ensure that changes to the plant were properly evaluated in accordance with the requirements of 10 CFR 50.59, " Changes, Tests and Experiments," and to appropriately update the Final Safety Analysis Report. The safety evaluations reviewed were well documented and properly concluded t ist no unreviewed safety questions existed.
10/02/98 STR 1R 98-18 NRC ENG 4A The team concluded that effective prvMfural controls were in place to ensure that affected calculations were reconciled when new or revised cak :stions were generated.
10/02/98 NCV IR 98-18 LIC ENG 4B The failure to test the pressurizer safety valve balancing devices in accordance with Technical Specification LER 98-007 4.0.5 is a violation. This nonrepetitive, licensee-identified and corrected violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy .
10/02/98 VIO IR 98-18 NRC ENG 4A The failure to provide adequate procedures for operations logging practices and failure to prescribe preventive SLIV maintenance instructions for switchyard voltage indicators, which were needed to assure operation in an analyzed condition, resulted in multiple failures to evaluate potential!v inoperable offsite power supplies.
These failures to provide adequate procedures were determined to be a violation of Technical Specification 6.8.1. No response is required for this violation.
Jrnuary 25,1999 9 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 10/02/98 VIO IR 98-18 NRC ENG 4A The load flow voltage drop calculation was not checked properly and included an incorrect assumption.
SLIV Emergency diesel generator load growth was not property monitored and evaluated as required by procedure.
These failures to follow design control procedures were detemiined to be a violation of 10 CFR Part 50, ,
Appendix B, Criterion V," Procedures, Instructions and Drawings? No response is required for this violation.
10/02/98 URI 1R 98-18 NRC ENG 4A One unresolved item was identified concerning design changes made to bypass torque switches, originally installed in safety-related motor-operated valve control circuits to prevent overtorque during valve closure.
The licensee committed to perform additional review to confirm the adequacy of their current design.
0926/98 NEG IR 98-21 NRC ENG 4C The licensee failed to revise three component cooling water system valve survebnce procedures and to make associated revisions to the work control process in a timely manner following implementation of Technical Specification Amendment 113.
07/CL4/98 POS IR 98-11 NRC ENG 48 The inspectors concluded that the formal safety evaluation for the continuous addition of ammonia hydroxide to the reactor coolant system was comprehensive. Plant and procedure changes discussed in the evaluation were implemented. The licensea followed the modification process when actions were initiated to improve the continuous addition pump's design following implementation of the modification.
05/23/98 POS IR 98-08 NRC ENG 4B Plant modifications were well designed and properly implemented. The modifications included installing a new essential service water pump, replacing essential service water valves, modifying the containment recirculation sump valves, and modifying the main feedwater regulating and bypass valves.
J;nuary 25,1999 10 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 05/20/98 LIC NRR Letter NRC ENG 4C Weak licensee performance identified regarding Electrosteeve Tech Spac Amendment request submittals.
WK NRC letter dated 5/20/98 assessed licensee performance as follows: " Based on our review of various submittals ...the staff has some concems with the completeness, technical acequacy and accuracy of these submittals. Several of your submittals were incomplete in that they either neglected to answer questions raised in a RAI, or they indicated that information was not yet d?veloped and therefore was not submitted.
Yet in both cases, the questions raised and information requested were not provided to the staff at a later time, until formally requested a second time by the staff, in adoition, some of the technical responses to issues raised in RAls were technica!!y inadequcte, mainly with respect to nondestructisa examination issues.
In some cases, regulatory requirements were not addressed and in other cases the technical basis provided to address technicalissues was inadequate. Lastiv, questions have been raised by the staff regarding the quality of the electrosteeve vendor's and your quality assurance review of submittals made to the staff. The staff has identified several examples, two of which were documented in the staff's December 18,1997, RAI, of inaccurate data being supplied to the staff in electrosleeve submittals. Union Electric's performance in this regard must be improved, or the staff will not be able to continue its review of the electrosleeving application."
05/13/98 LIC NRR Letter NRC ENG 4C Negative performance related to Technical Specification Amendment request dated August 8,1997 and NEG fo!!owup letters. Amendment requested that tolerance on Main Steam Safety Valves be increased from +1%/- t 1% to +3%/-1%. In docketed letter to the lic6nsee dated May 13,1998, NRC staff stated " Union Electric did not account for the test uncertainty in its safety analysis, and did not provide the staff with an adequate regulatory basis to allow excluding the test instrument uncertainty."
04/17/98 POS IR 98-05 NRC ENG 2B 5A The use of the plus point probe was viewed as an indx:ator of management support for examination initiatives that would provide for early detection of degradation.
04/17/98 POS 1R 98-05 NRC ENG SC The licensee appropriately responded to areas of weakness in the eddy current data analysis guidelines that were identified during a prior NRC inspection.
04/11/98 NCV IR 98-03 LIC ENG 2B 4B SC The licensee's review of 7162 preventive maintenance tasks for impact on equipment operability was POS extensive and thorough. The licensee identified 18 tasks that did not receive required formal safety evalcations. The licensee revised the tasks to eliminate the need to perform the evaluations. This violation was not cited, consistent with Section Vll.B.1 of the NRC Enforcement Policy.
t J nuary 25,1999 11 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 02/16/98 VIO IR 98-01 SELF ENG 2B 4A 4B Engineering department personnel failed to prepare an ade nie modification package for a core drill in an SL IV auxiliary building concrete wall During performance of the work. licensee personnel drified into a 13.8 kV cable. There was no personnelinjury. There was no significant impact on plant operation. Tne cable's protective devices tripped the supp!y breaker. The licensee's investigation and proposed corrective actions were good.
12/18/97 NEG Letter NRC ENG 4C Negative performance noted in that the licensee approved and provided poor quahty aubmittal to the staff.
NRC letter requesting additional information dated 12/18/97 identifies quahty deficiencies as follows: "Two examples of incorrect data being supplied to the NHC staff were recently identified. The NRC staff identified errors in Table 1.2 cf the September 10,1997 stbmittal In addition, the licensee notified NRC staff in the Sectember 10,1997 submittal that some data previously submitted to NRC staff was incorrect."
12/11/97 POS IR 97-19 NRC ENG 4B The actions taken in response to the axial offset anomaly were conservative and in accordance with regulatory requirements.
12/11/97 NEG 1R 97-19 NRC ENG 3B 48 A weakness was identified with respect to certain engineering staff knowledge of rod swap methodology 12/06/97 STR 1R 97-20 NRC ENG 1A 3A 4B Modifications to the unit vent flow transmitter, the emergency diesel generator lube oil and jacket water temperature control valves, and the control room were generally w311-planned and executed. The unit vent flow transmitter modification corrected a longstanding operator workaround.
W"25/97 POS IR 97-17 NRC ENG 4B The licensee's evaluation of the impact of changing the control rod insertion limits was thorough.
J;nuary 25,1999 12 Callaway Phnt
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 12/26/98 POS tR 98-25 NRC PS 1A 2A Overall, the condition of security facilities and equipment was very good. The protected area fence and vehicle barrier equipment were intact. All safeguards material was properly controlled. Security officers posted at vanous locations were alert. All security posts were property staffed.
11/30/98 POS !R 98-25 NRC PS 1A 3A Overall, radiological protection personnel support of the containment entry to replace the containment Cooler A fan motor was good. The radiological protection briefing was thorough. The radiological hazards at the job site were fully explained. Health physics technicians accompanied worker.',in containment and ensured that personnel were aware of the dose levels in the work area.
11/16/98 POS IR 98 22 NRC PS 1A 3A Observations of radiation worker radiological protections practices indicated good adherence to established practices, although radiological survey maps were not posted outside some rooms in the radwaste building, contrary to licensee management expectations.
10/30/98 VIO IR 98-24 NRC PS 1C Two examples of a violation of Operating License Section 2.C(5)(c) were identified. One example involved SLIV the failure to initiate a fire protection impairment permit and compensatory actions for an inoperable fire door between the control room and controt room pantry. The other example involved the failure to include several fire doors in the control building, and the elevator and dumbwaiter doors in the auxiliary building, in plant procedures to ensure that required survei!!nace inspections were performed and compensatory actions taken when they were inoperable.
10/30/98 STR IR 98-24 NRC PS 1C Overall, a good fire protection program was maintained. Effective moosures had been established to premt the occurrence of fires, minimize the magnitude of fires that may occur, and limit potential damage to ensure that safe shutdown capability was maintained.
10/3038 POS IR 98-24 NRC PS 1C 5A Quality assurance oversight of the fire protection program was effective. Audits were excellent in quality and resulted in meaningful findings that were property documented and tracked for closure in the corrective action program. Quality assurance surveillance activities provided good oerformance-based assessment of the fire protection program.
Jcnuary 25,1999 13 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 10/30/98 . ,i IR 98-24 NRC PS 1C 4A An unresolved item was ideritified regarding the potential for fire-induced circuit failures to prevent the LER 98-009 operation of equipment required for safe shutdown in the event of a fire that requires control room evac 1ation.
As a result of a finding in a Final Safety Analysis Report review effort. the licensee identified and reported in Licensee Event Report 50-483/98009 that the isohtion/ transfer switch control circuitry for a motor-operated valve required for post-fire safe shutdown did not have redundant fusing to protect it from the effects of a fire.
The licensee revised its attemative shutdown procedure to add manual actions to verify correct valve pcsition; however, the NRC will need to review further the licensee's evaluation regarding the survivability of components following spurious actuation to ensure that the alternative shutdown capability is consistent with the licensing basis.
10/15/98 STR 1R 98-23 NRC PS 1C 38 3C Management has increased its support of the emergency preparedness training program by increasing the number of training dri!!s. Program visibility and credibihty have improved.
10/15/08 POS IR 98-23 NRC PS 1C 3B 3C The process for augmenting the emergency respont9 organization was significantly improved by issuing pagers to all emergency response personnel.
10/15/98 NEG IR 98-23 NRC PS IC 3C Drill frequencies were not clearly described in the emergency plan arid implementing procedures.
10/15/98 POS IR 98-23 LIC PS 1C 5A The emergency preparedness drill program was unstructured and poorly controlled and documented in the past; however, program shortcomings wera recognized and appropriate improvements were planned or in progress.
09/18/93 STR IR 98-19 NRC PS 1C Housekeeping throughout the radiological controlled area was very good.
09/18/98 POS iR 98-19 NRC PS 1A 1C in general, an effective ALARA program was implemented. The 1998 exposure goa! of 15 person-rem was aggressive and on target. However, the ALARA coordinator had not followed the procedural requirements for the review of 120 of the 147 ALARA suggestions submitted in 1998. The station's 3-year exposure average of 149 person-rem for 1997 was a little above the industry average; however, it has continued to trend downward.
09/18/98 POS IR 98-19 NRC PS 1C 2B Two operational radianun protection quality assurance sun'eillances were completed since May 1998, which provided management with a good assessment of the areas reviewed. Overall, an adequate quality assurance audit program was maintained. No negative trends were identified during the review of radiological suggestion occurrence solution reports written sis.ce May 1998.
J;nuary 25,1999 14 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE fD SFA TEMPLATE ITEM CODE E
09/18/98 NEG IR 98-19 NRC PS 1C 28 The radiation protection audit and surveillance e::tivit;es had not reviewed 18 of 59 radia' ion protection program elements in more than 25 months with the average time interval between reviews of approximately 41 months.
09/18/98 STR IR 98-19 NRC PS 1C in general, the extemat/intemal exposure control programs were effectively implemented. All radiation areas were property posted. Proper thermoluminescent dosimeters were used for measuring neutron doses.
Respiratory equipment was properly issued to qualified personnel. Radioactive material, laundry, and trash containers were property labeled, posted, and controlled. A good radioactive source inventory and leak test program was in pla::e; however, source inventory results were not consistently recorded. An effective portable radiation survey instrument calibration program was maintained. Radiological surveys properly assessed personnel exposures.
08/12/98 POS IR 98-201 NRC PS *A 2A Performance drills and exercises during an Operational Safeguards Response Evaluation demonstrated the lecensee's ability to protect the plant's critical equipment. This closed Unresolved item 97201 J1.
08.'07/98 POS IR 98-17 NRC PS 1C Housekeeping in the radwaste building was very good 08'07/98 STR IR 98-17 NRC PS 1A 1C Overall, a good solid radioactive waste management program was in place The licensee's radwaste minimization program was effectively implemented. Since 1994, the total annual volume of solid radioactive waste generated has been reduced by approximately 63 percent. A very good transportation program for radioactive waste and materials was maintained. Shipping documentat:on was organized, easily retriavable, and packages were properly prepared for shipment.
08'07/98 POS 1R 98-1/ NRC PS SA An effective qualit/ assunnce program was in place. The biennial audit, when combined with surveitlance reports, provided management with a good assessment of the solid radwaste and transportation programs.
The licensee property assessed and captured recommendations from the department self-assessment. No negative trends were identified during the review of solid radwaste and transportation suggestion occurrence solution reports.
08/07/98 FOS 7 98-17 NRC PS 1A 3B A strong solid radwaste and transportation training program was maintained. The instructor assigned to provide initial and con $nuing solid radwaste and transportation training had an extensive practical and technical background in the above program areas. Lesson plans were organized, well written, and plant management was appropriateiy involved in the development and review of the plans.
Jinuary 25,1999 15 Callaway Plant
_ _ _ _ _ . _ _ _ _ = _ _ = _ = _ _
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 0&'04/98 VIO IR 98-17 NRC PS 1A 3A A violation of 10 OFR 71.111 was identified because dry active waste was stored within 10 feet of a SLIV permanent structure contrary to procedural requirements. The procedural requirement was in place to address potential fire protection concems. No response to this violation is required.
07/17/98 POS IR 98-13 NRC PS 1A 13 Housekeeping in the areas where effluent monitors and air cleaning systems were located was very good.
7/17/98 POS IR 98-16 NRC PS SA Quality assurance audits and surveillances were performed by qualified personnel and were very comprehensive and effectively evaluated the radiological environmental monitoring program.
07/1768 POS IR 98-13 NRC PS 1A 2B Ouaisty assurance oversight was effective. Audits were intrusive and thorough, providing management with a good assessment of the radiological effluent controls program. Audit findings were properly documented, tracked in the station's Suggestion Occurrence Solution Reporting System and closed ir a timely manner.
Quality assurance department surveillance reports were well written and property assessed the program areas reviewed. Suggestion Occurrence Solution Reports identified issues at the proper threshold to provide management with the tools needed to assess the program.
07/17/98 POS IR 98-13 NRC PS 1A 28 An effective training program was in-place for personnel responsible for the effluent moniotoring program.
Initial and continuing training program course materials were well organized, covering the subject areas needed to accomplish the required tasks and help ensure that the organization's technical competence was rPaintained.
07/17/98 STR 1R 98-13 NRC PS 1B 28 Overall, a good radioactive effluent monitoring program was maintained. A decreasing trend was noted in the radioactivity released through liquid effluents during 1996 and 1997. A good effluent monitor calibration and channel check program was in-place. Instrumentation used for analyzing effluent samples was properly maintained and calibrated. The engineering safety feature air fi!tration and adsorbtion units were properly maintained. Good in-place fdter and loboratory testing programs were implemented. System engineers responsible for the engineering safety feature filter ventilation systems were knowledgeable of their systems and appropriately involved in the filter testing program.
7/17/98 STR 1R 98-16 NRC PS IA 1C Overall, good radiological and meteorological monitoring programs were implemented. Meteorological data recovery was greater than 90 percent from 1995 through 1997. Environmental air sampling stations were maintained at a high standard for both cleanliness and reliability. Excellent sampling and handling practices were used for collectir'g environmental air samples.
January 25,1999 16 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DAT: TYoE SOURCE ID SFA TEMPLATE ITEM CODE ,
07/08/98 NEG IR 98-12 NRC PS 3B A worker was unaware of radiological conditions near the pump suction line in residual heat removal pump room A. The worker failed to review the radiological survey data prior to entering the work area. This was an additional example of previously cited violation 50-483/98-07-02 and is not being cited separately. The licensee's corrective actions for the cited violation were incomplete at the time this current violation was identified. The licensee will include corrective actions to this event in conjunction with corrective actions for the previous violation.
07/04/98 POS IR 98-11 NRC PS 1C 3A The licensee effectively prepared for and implemented the process for shearing racwaste f lters. The licensee effectively implemented ALARA work practices. Personnel dose for the project was below the licensee's goal.
07/02/98 NEG IR 98-14 NRC PS 1B 5A 5B Documentation was incomplete or unclear for two unusual events. The emergency preparedness department did not participate in the formal event review process; therefore, the events were not property used to assess and improve emergency plan implementation. The corrective action program procedure was revised to include emergency preparedness department participation in future assessments for events that involve emergency plan implementation.
07/02/98 POS IR 98-14 NRC PS 1C 3C 28 Overac, implementation of the emergency preparedness program was generally good. Emergency response facilities wcm operationally maintained, and appropriate equipment and supplies were readily available at 'he primary facilities. The emergency preparedness training program was properly implemented. Emergency preparedness department staffing and supervision had stabiH2ed. A full-time superintendent was named, and staffing levels and assignments were well cafined. There was enough depth in the emergency response organization to ensure continuous staffing.
07/02/98 NEG IR 98-14 NRC PS 1C 2A SC The need to perform additional NRC review of backup emergency operations fact!ity capabilities was identified because a radio base station to communicate with offsite field monitoring teams was not available at the backup facility. The absence of a radio base statica was identified by the licensee in March 1998 but was not corrected until the issue surfaced during this inspection.
07s02/98 WK IR 98-14 NRC PS 1B 3C 3B The second crew did not classify one of tiree events in a tim 9ty manner because an emergency operatir;g procedure conflicted with an emergency implementing procedure. The procedure for emergency operating procedure usage stated that emergency action level determination commences after exiting the reactor trip procedure. The classification procedure required classification when abnormal readings indicate an emergency situation has occurred. The first crew did not have the same problem because it entered the reactor trip procedure later in the scenario. The delayed classification was identified as a perfe mance weakness.
Anuary 25,1999 17 Callaway Plant
PREDECISIONAL PLANT 3SSUES MATRIX ENCLOSURE 1 E \TE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 05/23/98 POS IR 98-08 NRC PS 3A Health physics personnel provided thorough coverage of the containment recirculation sump inspections and reactor vesset upper internals re-installation. The licensee implemented effective radiological controls.
05'01/98 VO IR 98-07 NRC PS 1A A violation of Technical Specification 6.11 was identified for the failure to properly label 36 bags SLIV (coritainer/ packages) of radioactive material with the appropriate radiological information to permit individuals handling or using the containers to take precautions to avoid or minimize their exposure.
05/01/98 POS IR 98-07 NRC PS SA One radiation protection department self-assessment was performed since January 1997. The assessment provided a veri g~0d evaluation cf the a.eas reviewed, and appropriate recommendations were identified for program improvements.
05/01/98 VIO IR 98-07 NRC PS 1A A violation of Technical Specification 6.11 was identified for the failure to conspicuously post a High Radiation SLIV Area.
05'01/08 NEG 1R 9807 NRC PS SA Quality assurance audit teams were not comprised of personnel with strong radiation protection backgrounds in the areas being audited. The audits covered the appropriate prograin areas; however, they did not provide an in-depth review of the areas audited.
05/01/98 POS IR 98-07 NRC PS 1A In generaf, the external exposure controls program was effectrvely implemented. Danger (tocked) High Radiation Areas were properly controlled and posted. Ctation workers knew the proper response to electronic dosimeter atarms. Housekeeping was very good throughout the radiological controlled area. An effective internal exposure controls program was in place. Continuous ai monitors and HEPA filter ventilation were appropriately used to monitor and limit airbome exposures. The internal dose assessment program was effectively implememed. Personnel contamination incidents and events were property handled, and radiation protection personnel stationed at the radiological controlled area exit provided appropriate guidance to station workers who alarmed the personnel contamination moni' ors. Good controls were in place to prevent the spread of radioactive contamination.
05'01/98 STR 1R 98-07 NRC PS 1A 1C A very good ALARA program was implemented. Effective chemistry shutdown plans and controls were in place which reduced steam generator channel head dose rates about 27 percent. Station management demonstrated their support for the ALARA program by delaying the start of the refueling outago by 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in an effort to decontaminate the reactor coolant system and reduce the general area dose rates. The outage exposure goal of 185 person-rem was established using past best performance and industry experience in conjunction with appropriate involvement by activity coordinators and the outage review board.
Jrnuary 25,1999 18 Callaway Plant
PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE ,
04!30/98 POS IR 98-10 NRC PS 1C 38 Emergency response organization personnel were trained as described in the licensee emergency plan and training procedure. The quahfcations of each duty section will be reviewed prior to it assuming interim duty responsibdities. The training program will be enhanced oy clarifying the process for use of dnlis/ exerciser for qualification purposes and by establishing controls over course content.
04/27/98 ViO IR 98-07 NRC PS 1A A violation of Technical Specificatbn 6.8.1 was identified because workers failed to understand the SLIV restrictions / limitations of the radiation work permit and did not maintain an awareness of the work area radiologicrst conditions.
04/25/98 VIO IR 98-07 NRC PS 1A A violation of Technical Specification 6.11 was identified for tne failure to property label 36 bags SLIV (container /pacWes) of radioactive material with the appropriate radiological information to permit individuals handling or ; the containers to take precautions to avoid or minimize their exposure.
04/17/98 PCS IR 98-05 NRC PS 2B The licensee has successfully maintained iron transport to the steam generators at low levels since adoption in 1993 of ethanolamine for pH control.
04/15/98 VIO IR 98-13 NRC PS 1A 1C A violation of 10 CFR 20.1501(a) was identified involving the failure to perform radiological surveys prior to, or SLIV at the start of, grinding / needle gun work within the containment building.
04/10/98 NEG 1R 98-04 NRC PS 1A A discrepancy was identi'ied in which requirements in a secunty procedure did not agree with requirements in the secunty plan. The " Compensatory Measures" security procedure speci'ied, in part, that inc: eased vehicle patrots may be used during periods of fog, rain or sun glare, to compensate for intruders that are not visible at the perimeter zone by closed circuit television (CCTV) cameras. The security plan requires that a partial tai!ure of the CCTV surveillance and assessment system be compensated by stationing members of the security force in position to observe the effected perimeter zones. There were no events identified which included implementation of this procedure.
04/10/98 NEG IR 98-04 NRC PS 1C A program had not been established to load test the security diesel generator. In May 1997, the licensee committed to developing a procedure to load test the security diesel generator, no completion date was established. The licensee was in the process of developing a load test procedure and conducting a load test by May 1998.
Jrnuary 25,1999 19 Callaway Plant
q PREDECISIONAL PLANT ISSUES MATRIX ENCLOSURE 1 DATE TYPE SOURCE ID SFA TEMPLATE ITEM CODE 04/10/98 STR 1R 98-04 NRC PS 1A 1C Performance in the physical security area remained good with no trend changes. An effective testing and maintenance program was conducted and properly documented. Effective protected and vital area barriers and detection systems were maintained. The twriers and detec* ion systems provided proper delay and detection to attempted unauthorized entry. A good program for reporting security events was in place. A comprehensive secunty training program had been implemented. An effective program to protect safeguards information was in place. Compensatory measures were properly implemented.
02/28/98 NEG IR 98-01 NRC PS 2B 3A 3B The licensee nearly failed to perform a prejob radiological survey for a residual heat removal pump surveillance test. Health physics personnel had not been notified that vibration readings would be taken on the pump motor greater than 8 feet above the floor. The quality of the health physics port.On of the pre-job briehng was weak. The communications between an equipment operator and heatth physics personnel at the radiological controlled area access point was also weak.
02/28/98 NCV IR 98-01 LIC PS 1C 3A There were four examples of licensee personnel failing to properly log into the computer-based electronic dosimetry oystem prior to entering the radiologically controlled area. The personnct wore the correct dosimetry but inadverten*ly did not sign h under their own name. The licensee responded appropriately to each error.
11/20/97 POS IR 97-20 NRC PS 1A The licensee's response to a security threat was approoriate. Proper notifications were made and appropriate EN 33290 contingency actions were implemented. A Notification of Unusual Event was declared. On 12/4/97, the PN IV licensee retracted the portion of the event notification related to 10 CFR 73.71 when it was determined that 069 the threat was noncredible.
10/31/97 STR !R 97-18 NRC PS 5A Security program audits and surveillances were thorough and excellent quality.
10/31/97 STR 1R 97-18 NRC PS 1C A very good program for searchiag personnd packages and vehicles was maintained.
10/31/97 STR 1R 97-18 NRC PS 1C The access authorization program was a stre 9th in the overall security program.
10/31!97 NEG IR 97-18 NRC PS 1C The manual transfer of emergency power from the diesel generators to the radio sepeater for the on-site radio system had not been addressed in an implementing procedure.
10/31/97 STR IR 97-18 NRC PS 2A Very good radio and telephone communication systems were maintained.
10/25/97 POS IR 97-17 NRC PS 2A Material condition of equipment in the radwaste evaporator building was good. Housekeeping showed improvement.
Jrnuary 25,1999 20 Callaway Plant
f 1 ENCLOSURE 2 Gt NER A1. DtNCRIPTION OF Pl%I TAIll.E I. AItt i S Astiert date of an esent or sigCficant iwuc for stume items that hate a clear date of occurrence, the date the source of the inforsomtian w as issued tsuch as the LER datch er, for inspectice repwis, the last
- d. I the inspectiem perimi.
Type .or categorisatum uf the iwuc - see the T3pe item Code table.
Et NAl.P t uncthusal Area Codes: OPS for Operatisms; hl % INT for Maintenance; ENG for Engineering; and PS for Plant Support.
brrcri Tlw dorunwnt that contains the inue information: IR for NRC laspection Report or EER for Licenser Esent Reguwt.
Ifi identification of
- ho diwoscred imse: N f.w NRC; i. for I.icensee; or S for Self identifying tesents).
Issw Ikscripn*n Iktails of the swue fran the EER test or from the BR Esecutise Sununaries Cedes Template Cules - see laide.
T)PE ITEAR ColWN 3 Pentumal Perfwmance: A - NwM Operaties; B - Operations During Transients; and C - Prograno and Processes EA Enforcement Action f.etter with Cisil Penalt) 2 Material Condition:A - Equipme .t Condition or 8 - Programs and Processes tD Enf'wcenwnt Ibcretion - No Cisil Penalt) 3 Ilumen Performance: A Work Perfornw ice; B - Knowledge. Skills, and Abilities / Training; C - Work Stre ngth Oserall Strag linnsee Perfwnience W eak new Oserall % cak IJcenwe Performance 4 Engineering / Design: A - Design; B - Engineering Support t Progrann and Processes t
- Escalated Enforcenwnt Item - % aiting Final NRC Action 5 Preldem Identification and Resolution: A - Identification; B - Analysis; and C- Resolution
%10 \ inistim I.esci I. II, Ill, or IV NOTES:
scs Nm-Cited %dation
- Eels are apparent siciations of NRC requirements that are being considered for escalated enforcement action in accordance with the %eneral Statement of Policy and Procedure for NRC Enforcesnent Action"(Enforcenwat DEV Iksiatime from 4.icenwe Canuratnwnt to NRC PolicyI. NUREG.1600. fles.eser, the NRC has not reached its naal enforcer. ant decision on the issues identified Indisidual Gomi inspection Finding by the Eels and the Pl%1 entries may be modified w hen the final decisions are made. Before the NRC makes its twine enforcement dec'.Aon. the licensee will be provided with an opportunity to either (I) erspmd to the apparent Negatise Indisidual P=w Inspection Finding *iadation or (2) request a predecisional enforcement conference.
ItR licenwe Esent Repwt to the NRC **
URIs are unress4ved items shout which more information is required to determine whether the issue in q' session is an nacptalde item, a desistion, a nonconformance,or a violation. However, the NRC has not reached its final t RI ** Caresidied item frma Inspection Regure conclusions on the inues and she PIM entries may be modified = hen the final conclusions are made.
Ixemang licen4ng twue fran NRK MINC Miwetlaneous - Emergency Preparedness Finding (EPL Ikdared Enwrgency. Nonconfwmance Inne, etc. __
TEMPl ATE CODES J:nuary 25,1999 Callaway Plant
CALLAWAY PLANT INSPECTION PLAN IP - Inspecten Procedure Tl - Temporary Instruction Core Inspection - Minimum NRC Inspection Program (mandatory all plants)
INSPECTION TITLE / NUMBER OF DATES TYPE OF INSPECTION /CC' !TS PROGRAM AREA INSPECTORS Tl 2515/140 Periodic Verification of Design-Basis Capability 3 03/29/99 - 04/02/99 Safety Initiative of Safety-Related Motor-Operated Valves (GL 96-05)
!?92904 Followup on Plant Support (MOV hot shorts) 1 03/29/99 - 04/02/99 Followup IP 83750 Occupational Radiation Exposure 1 07/19-23/99 Core inspection IP 71001 Requalification Program 2 08/9-13/99 Core inspection IP B2301 Evaluation of Exercises for Power Reactors 4 09/13 - 16/99 Core inspection IP 73753 Inservice inspection 1 10/04-08/99 Core Inspection IP 84750 Radioactive Waste Prooram implementation 1 10/25-29/99 Core inspection IP 81700 Physical Security Program 1 10/25-29/99 Core inspection Jcnuary 25,1999 Callaway Plant
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _