ML20212H161
| ML20212H161 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/09/1998 |
| From: | Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Randolph G UNION ELECTRIC CO. |
| Shared Package | |
| ML20212H165 | List: |
| References | |
| 50-483-98-01, 50-483-98-1, NUDOCS 9803120321 | |
| Download: ML20212H161 (5) | |
See also: IR 05000483/1998001
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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MEGloN IV
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611 MYAN PLAZA DRIVE.sulTE 400
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MAR -9 1998
Garry L Randolph, Vice President and
Chief NuclearOfficer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT: NRC INSPECTION REPORT 50-483/96 01 AND NOTICE OF VIOL.ATION
Dear Mr. Randolph:
From January 18 through February 28,1998, a routine inspection was conducted at your
Callaway Plant reactor facility. The enclosed report presents the scope and results of that
inspection.
During the 6-week period covered by this inspection, your conduct of activities at the Callaway
Plant was generally charactenzed by safety-conscious operations, maintenance practices, and
careful radiological controls. Homver, a violation of NRC requirements occurred in the
ragineering area. This violation involved the failure to prepare an adequate modification work
puckage for core drilling in an auxiliary building concrete wall. As a result, personnel drilled into
a 13.8 kV power cable.
The NRC has concluded that information regarding the reason for the violation, the corrective
actions taken and planned to correct the violation and prevent recurrence is already adequately
addressed on the docket in this inspection report. Therefore, you are not required to respond to
this letter unless the description therein does not accurately reflect your corrective actions or
your position. In that case, or if you choose to provide additional information, you should follow
the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its
enclosures, and your response will be placed in the NRC Public Document Room.
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Should you have any questions concoming this inspection, we will be pleased to discuss them
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with you.
Sincerely,
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$.____,,
William D. Johnson, Chief
Project Branch B
Division of Reactor Projects
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ADOCK 05000483
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Union Electric Company
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Docket No.:
50-483
License No.: NPF-30
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Enclosures:
2. NRC Inspection Report
50-483/96-01
cc wfenclosures:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855
Gerald Chamoff, Esq.
Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge
.
2300 N Street, N.W.
Washington, D.C. 20037
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H. D. Bono, Supervising Engineer
Quality Assurance Regulatory Support
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
Manager- Electric Department
Missouri Public Service Commission
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301 W. High
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- P.O. Box 360
Jefferson City, Missouri 05102
Ronald A. Kucera, Deputy Director
Department of Natural Resources
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P.O. Box 176
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- Jefferson City, Missouri 65102
Otto L. Maynara. *Vesident and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
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Union Electric Company
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Dan 1. Bolef, President
Kay Drey, Representative
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
AmorenUE
One Ameren Plaza
1901 Chouteau Avenue
P.O. Box 66149
St. Louis, Missouri 63166-6149
J. V. Laux, Manager
Quality Assurance
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
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Union Electric Company
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MAR - 9 1998
E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (IE01)
cc distrib. by RIV:
Regional Administrator
Resident inspector
DRP Director
DRS-PSB
Branch Chief (DRP/B)
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Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS)
DOCUMENT NAME: R:\\_CW\\CW801.DGP
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MAR - 91998
E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDGSK)
bec to DCD (IE01)
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Regional Administrator
Resident inspector
DRP Drector
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Branch Chief (DRP/B)-
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RIV File
Branch Chief (DRP/TSS)
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DOCUMENT NAME: R:\\_CW\\CW801.DGP
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ENCLOSURE 1
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Union Electric Company
Docket No.:
50-483
Callaway Plant
License No.: NPF-30
During an NRC inspection conducted on January 18 through February 28,1998, a violation of
NRC requirements was identified. In accorda see with the " General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below-
Criterion V of 10 CFR Part 50, Appendix B, requires that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings appropriate to the
circumstances.
Contrary to the above, on February 16,1998, instructions in Work Authorization C612323 did
not provide adequate guidance for concrete core drilling work. As a result, licensee personnel
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drilled into a 13.8 kV power cable in an auxiliary building concrete wall.
This is a Severity Level IV violation (Supplement 1) (463/9801-02).
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i:,e NRC has concluded that information regarding the reason for the violation the corrective
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actions taken and planned to correct the violation and prevent recurrence and the date when full
compliance was achieved is already adequately addressed on the docket in this inspection
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report. However, you are required to submit a written statement or explanation pursuant to
10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or
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your position. In that case, or if you choose to respond, clearly mark your response as a " Reply
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to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission,
ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional
Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy
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to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of
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the date of the letter transmitting this Notice of Violation.
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if you contest this enforcement action, you should also provide a copy of your response to the
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Director, Office of Enforcement, United States Nuclear Regulatory Commission,
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Washington, DC 20555-0001.
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Because your response, v gu choose to provide one, will be placed in the NRC Public
Document Room, to the extent possible, it should not include any personal privacy, proprietary,
or safeguards information so that it can be placed in the Public Document Room without
redaction. If personal privacy or proprietary information is necessary to provide an acceptable
response, then please provide a bracketed copy of your response that identifies the information
that should be protected and a redacted copy of your response that deletes such information. If
you request withholding of such material, you must specifically identify the portions of your
response that you seek to have withheld and provide in detail the bases for your claim of
withholding (e.g., explain why the disclosure of information will create an unwarranted invasion
]
)
.
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of personal privacy or provide the information required by_10 CFR 2.790(b) to support a request
for withholding confidential commercial or financial information). If safeguards information is
necessary to provide an acceptable response, please provide the level of protection described in
Dated at Arlingtor;, Texas
this 9th day of March 1998
--
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ENCLOSURE 2
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-483
License No.:
Report No.:
50-483/98-01
Licensee:
Union Electric Company
Facility:
Callaway Plant
Location:
Junction Highway CC and Highway O
Fulton, Missouri
Dates:
January 18 through Februar 28,1998
Inspector.
D. G. Passehl, Senior Resident inspector
F. L. Brush, Resident inspector
Approved By:
W. D. Johnson, Chief, Project Branch B
Attachment:
Supplemental information
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EXECUTIVE SUMMARY
Callaway Plant
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NRC Inspection Report 50-483/98-01
' Ooerctions
The licensee exhibited the proper enforcement perspective when responding to the
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' simultaneous inoperability of auxiliary / fuel building emergency exhaust system filter
adsort>er Unit B and Emergency Diesel Generator A. The licensee requested and
received a Notice of Enforcement Discretion (Section 02.1).
An equipment operator opened an incorrect breaker to a nonsafety-related motor control-
center while hanging tags. The failure to open the correct breaker was due to personnel
error. The operator immediately reclosed the breaker without prior control room
authorization. The control room operators' response to this event was good
(Section 04.1).
Enoineerino
Engineering department personnel failed to prepare an adequate modification work
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package for a core drillin an auxiliary building concrete wall. During performance of the
work, licensee personnel drilled into a 13.8 kV cable. The cable's protective devices
tripped the supply breaker which prevented any personalinjury. There was no significant
impact on plant operatiens. The licensee's investigation and proposed corrective actions
were good (Section E4.1).
Plant Sucoort
There were four exarpples of licensee personnel failing to properly log into the computer-
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based electronic dosimetry system prior to entering the radiologically controlled area.
The personnel wore the correct dosimetry but inadvertently did not sign in under their
own name. The licensee responded appropriately to each error (Section R4.1).
The licensee nearly failed to perform a pre-job radiological survey for a residual heat
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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 portion of the pre-job briefing was weak. The
corr.munications between an equipment operator and health physics personnel at the
radiological controlied area access point were also weak (Section R4.2).
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Report Details
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Summarv of Plant Status
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The plant began the report period at 74 percent power. On January 20,1998, operators
increased reactor power to 77 percent. On January 30,1998, operators increased reactor
power to 80 percent,
l. Operations
01
Conduct of Operations
01.1 General Comments (71707)
The inspectors conducted frequent reviews of ongoing plant operations. In general, the
conduct of operations was professional and safety-conscious. Plant status, operating
problems, and work plans were appropriately addressed during daily tumover and
plan-of the-day meetings. Plant testing and maintenance requiring control room
coordination were property controlled. The inspectors observed several shift tumovers
and noted no problems.
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O2
Operational Status of Facilities and Equipment
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O2.1
Notice of Enforcamont Discretion
a.
Insoection Scooe (71707)
The inspectors reviewed the licensee's Notice of Enforcement Discretion request. The
auxiliary / fuel building emergency exhaust system filter adsorber Unit B was inoperable
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while Emergency Diesel Generator A was inoperable.
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b.
Observations and Findinos
On January 21,1998, at 7:39 e m, the licensee declared Emergency Diese! Generator A
inoperabn. for a scheduled system outage. Later that day, at 2 p.m., the licensee
declared auxiliary / fuel building emergency exhaust system filter adsorber Unit B
inoperable. This was due to unsatisfactory test results for penetration of methyliodide
into the charcoal. The licensee had sampled the auxiliary / fuel building emergency
exhaust system filter adsorber Unit B charcoal approximately 2 weeks earlier.
Coincidently, the licensee received the charcoal test results during the Emergency Diesel
Generator A outage.
Methyl iodide was used to simulate the ability of the charcoal to remove isotopes which
could be released into the auxiliary building or fuel building during a design basis
accident. The charcoal did not meet the requirements of Technical Specification 4.7.7.b.2.
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Technical Specification 3.8.1.1, Action d.1, required that with Emergency Diesel Generator A
inoperable, all required systems, subsystems, trains, components, and devices that depend on
Emergoncy Diesel Generator B as a source of emergency power be also operable. If these
conditions were not satisfied within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the licensee was required to place the reactor in Hot
Standby within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Cold Shutdown within the followng 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. The
auxiliary / fuel building emergency exhaust system filter adsorber Unit B received emergency
power from Emergency Diesel Generator B.
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On January 21,1998, during a conference call with NRC personnel, NRC Region IV granted an
oral Notice of Enforcement Discretion. Consequently, the licensee had until 4 p.m., on
- January 22,1998, to restore Emergency Diesel Generator A to an operable status. The granting .
- of the oral Notice of Enforcement Discretion request was later documented in Notice of
Enforcement Discretion 98-04-001.
The inspectors verified that the licensee property took the compensatory actions discussed
during the conference call. These actions included performing no fuel handling and performing
no discretionary work that could cause a plant transient or affect the operability of other systems.
The inspectors also verified that the licensee took the compensatory actions required by the
Technical Specifications.
Subsequently, the licensee restored Emergency Diesel Generator A to operable status within
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the allowable time. The licensee issued Licensee Event Report 98-001. The event will be
further reviewed and results documented in NRC Inspection Report 50-483/98-02.
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c.
Conclusions
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The inspectors concluded that the licensee properly responded to the simultaneous
inoperability of auxiliary / fuel building emergency exhaust system filter adsorber Unit B
and Emergency Diesel Generator A.
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02.2 Review of Eauioment Taaouts (71707)
The inspectors walked down the following tagouts:
Workman's Protection Assurance 25253 - Emergency Diesel Generator A, and
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Workman's Protection Assurances 23795 an' 25365 - Motor-Driven Auxiliary
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Feedwater Pump B.
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The inspectors did not identify any discrepancies. The tagouts were properly prepared
and authorized. All tags were on the correct devices and the devices were in the position
prescribed by the tags. The inspector also performed a walkdown of Workman's
Protection Assurances 23795 and 25365 after the tagouts were cleared. All components
were in the proper position for the required system lineup.
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O2.3 Enaineered SafeNfeature System Walkdowns (71707)
The inspectors walked down accessible portions of the following engineered safety
features and vital systems:
_ Component Cooling Water Train A;
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Ultimate Heat Sink Cooling Tower Trains A and B; and
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Auxiliary Feedwater Trains A, B, and T.
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- Equipment operability, material condition, and housekeeping were acceptable.
04
Operator Knowledge and Performance
04.1
incorrect Breaker inadvertentiv Ooened
a.
lQaR9 don Scone (71707)
The inspectors reviewed the licensee's response and corrective actions when an
equipment operator inadvertently opened an incorrect breaker when hanging worker
protection tags.
The inspectors reviewed.
Suggestion-Occurrence-Solution Report 98-0219;
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Operations Department Procedure ODP-ZZ-00310, " Workman's Protection
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Assurance Tagging," Revision 4;
Administrative Procedure APA-ZZ-00310,' Workman's Protection Assurance and
Caution Tagging," Revision 11;
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Workman's Protection Assurance Gystem Tagout Control Sheet 25319; and
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Motor Control Center PG 20N, Electrical Circuit index.
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b.
Observations and Findinas
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On February 18,1998, an equipment operator opened the incorrect breaker on nonvital
Load Cecter PG 20, thereby deenergizing Motor Control Center PG 20N. The operator
immediately realized the error and reclosed the breaker.
Plant components affected included:
One reactor cavity cooling fan;
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One pressurizer enclosure fan;
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Various sump pumps; and
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Centrifugal charging Pump B auxiliary tube oil pump.
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There was no significant impact on the plant.
The inspectors observed the control room operators' response to the event. The control
room supervisor exhibited good command and control. There was good communication
within the control room and between control room personnel and operators in the plant.
The operators thoroughly reviewed plant status before restoring the affected equipment.
The licensee determined that two equipment operators had identi6ed the correct breaker -
to be racked "Jt. However, prior to opening this breaker, the operators contacted the
control room to discuss a question concoming the breaker's as-found position. When the
operators retumed to the load center, they did not reverify the breaker that was to be
opened. One of the equipment operators opened the breaker next to the correct one.
The licensee commenced an investigation using the corrective action program and
initiated Suggestion-Occurrence-Solution Report 98-0219. The licensee determined that
the root cause of this event was personnel error when the equipment operators failed to
perform adequate self-checking and dual verification.
The inspectors determined that the immediate reciosing of Breaker PG 2003 for the
motor control center PG 20N without notifying the control room was a poor practice. The
licensee agreed.
Administrative Procedure ODP-ZZ-00310, " Workman's Protection Assurance Tagging,"
Revision 4, Step 4.1.11.2.2, required that each individual verify the correct component
prior to operating the component.
The tagout control sheet for Workman's Protection Assurance 25319, Tag 3, specified
that a tag be hung on the breaker for the chemical and volume control system chiller
Unit SBG02. However, the equipment operator opened the breaker for Motor Control
Center PG 20N.
Failure to follow the tagging procedure was not a violation since Motor Control
Center PG 20N was not safety-related and the event had no effect on safety-related
equipment.
NRC Inspection Reports 50-483/9614 and 50-483/9611 document other examples of
tagging errors.
c.
Conclusions
The inspectors concluded:
Failure to open the correct breaker was due to personnel error.
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The immediate reciosing of Breaker PG 2003, without control room authorization
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was a poor prad!ce that did not meet the licensee's expectations,
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The control room c,perators' response to this event was good.
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11. Maintenance
M1 -
Conduct of Maintenance
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M1.1 General Comments - Maritanance
a.
Inspechon Scope (62707)
The inspectors observed or reviewed Wions of the following work activities:
Work Authorization W194654 - Repack lube oil cooler end joint on Emergency
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Diesel Generator A;
Work Authorization P590451 - Calibrate emergency fuel oil day Tank A level
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Transmitter JELT0012;
Work Authorization C610817 - Replace Emergency Diesel Generator A
intercooler heat exchanger tube side drain Valve KJV0786A;
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Work Authorization P591254 - Record motor current waveform data on residual
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heat removal Pump B motor;
Work Authorization P496148 - Service limitorque operator on condensate storage
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tank to motor-driven auxiliary feedwater Pump B isolation Valve ALHV0034; and
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Work Authorization P582717 - Change oil on motor-driven auxiliary feedwater
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Pump B.
b.
Observations and Findinas
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The inspectors found no concems with the maintenance observed. All work observed
was performed with the work packages present and in active use. The inspectors
frequently observed supervisors and system engineers monitoring job progress, and
quality control personnel were present when required.
M1.2 General Coiwivients - Surveillance
a.
Inspection Scoce (61726)
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The inspectors observed or reviewed all or portions of the following test activities:
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Test Procedure OSP-EJ-P0018, "Section XI Residual Heat Removal Train B
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Operability," Revision 22;
Test Procedure OSP-EJ-V001B, "Section XI Train B Residual Heat Removal
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Valve Operability," Revision 10;
Test Procedure OSP-AL-P0018, "Section XI Motor-Driven Auxiliary Feedwater
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Pump B Operability," Revision 19; and
Test Procedure OSP-JE-P001 A, " Emergency Fuel Oil Pump A Section XI
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Surveillance," Revision 19.
b.
Observations and Findmgs
With the exception of the surveillance activity discussed in Section R4.2, the surveillance
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testing observed during this inspection period was conducted satisfactorily and in
accordance with the licensee's approved programs and the Technical Specifications.
M2
Maintenance and Material Condition of Facilities and Equipment
M2.1 Review of MatenrJ Condition Durina Plant Tours
a.
Inspection Scope (62707)
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The inspectors performed routine plant tours to evaluate plant material condition.
b.
Observations and Findinas
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The inspectors observed a small number of oil and water leaks that were already
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identified by the licensee.
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The inspectors observed an approximate 0.5 gpm essential service water leak
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from one end bell of component cooling water Heat Exchanger EEG01 A. The
licensee had already identified the deficiency and initiated Work
Authorization W176793 to replace the end bell gasket during the Spring 1998
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refueling outage.
The inspectors identified a srnali pool of oil beneath the Emergency Diesel
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Generator B engine. The licensee determined that there was no impact on
operability. The licensee also determined that the leak did not warrant immediate
repair because of the complexity of the repair and the very small leak rate.
Licensee workers had previously identified the pool but had not initiated proper
action to clean the area. The licensee cleaned up the oil and continued to
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monitor the leak.
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in addition, the inspectors made the following observations:
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The inspectors identified that the "open" light was not lit on the auxiliary shutdown
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panel condensate storage tank to motor-driven auxiliary feedwater Pump A
isolation valve hand indicator Switch AL-HlS-00348. The licensee had not
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identified this deficiency. The inspectors had observed the light to be lit the
previous day.
The licensee discovered a blown fuse in the motor-driven auxiliary feedwater -
Pump A control circuit. With the fuse blown, the valve was not operable from the
auxiliary shutdown panelin the event of a control room evacuation. The licensee
entered the appropriate Technical Specification action statemen* for the remote
shutdown panel. Electricians replaced the fuse and the licensee exited the action
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statement within the allowable time.-
The inspectors identified an unusual noise from a cooling fan on the main
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transformer C phase. The licensee determined that the fan motor had a bad
bearing. There was no short term impact on plant operation since the plant was
at reduced power and the outside air temperature was cool. The licensee
replaced the fan motor.
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Conclusions
- The inspectors concluded that overall, the plant material condition was good.
M8
Miscellaneous Maintenance issues (92902)
M8.1 (Closed) Licensee Event Reoort 50-483/97-010-00: inadequate testing of the actuation
logic of the feedwater isolation and turbine trip instrumentation.
On November 18,1997, the licensee discovered that certain logic circuits of the .
Westinghouse Solid State Protection System were not adequately tested in accordance
with Technical Specification 4.3.2.1-Sa. The licensee discovered this after notification of
a similar deficiency at another nuclear plant.
Technical Specification 4.3.2.1-Sa required a monthly actuation logic test of the
feedwater isolation and turbine trip instrumentation. The three functions which were
inadequately tested were
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source range automatic P-10 block;
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feedwater isolation on P-14 steam generator hi-hi level; and
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feedwater isolation on a safety injection signal.
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The test was inadequate because the circuit was configured with multiple inputs tied
together so that failure of one input would not be detectable.
On December 11,1997, at 8:30 a.m., the licensee entered Technical Specification 4.0.3.
The licensee wrote work instructions to test the affected logic circuits. The tests were
satisfactory. The licensee exited Technical Specification 4.0.3 within the allowable time.
The licensee revised the surveillance procedures to include tests for the three functions.
The failure to demonstrate operability of the circuits was 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 (50-483/9801-01).
lit Engineering
E4
Engineering Staff Knowledge and Performance
E4.1
Core Drillina into a 13.8 kV Cable
a.
Inspection Scone (37551) -
The inspectors reviewed the licensee's response and corrective actions after
maintenance personnel drilled into a 13.8 kV cable.
The inspectors reviewed:
Modification Work Authorization Document C612323, install piping for the laundry
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decontamination facility;
Suggestion-Occurrence-Solution 98-206;
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Temporary Modification Package 98-E003, disconnect damaged cable tv nonvital
Load Center PG 25; and,
Temporary Modification Package 98-E004, install temporary power from nonvital
.
Load Center PG 26 to PG 25H.
b.
Observations and Findinos
At 7:54 a.m. on February 16,1998, while performing a core drill in an auxiliary building
concrete wall, licensee personnel drilled into a 13.8 kV cable. The ground fault
protection devices for the cable tripped the feeder breaker which prevented any
personnel injury. When the breaker tripped, a number of nonsafety-related load centers
in the turt>ine building were deenergized. Additionally, fuel building Load Center PG 25N
was deenergized.
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The unit experienced a decrease of electrical output of approximately 30 megawatts due
to loss of balance-of-plant efficiency. The major operating systems or components that
were affected included:
several low pressure feedwater heater normal dump valves;
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the steam generator blowdown system;
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an auxiliary / fuel building normal exhaust fan;
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a fuel pool cleanup pump;
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a fuel building air supply fan; and
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fuel building lighting.
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At 1:54 p.m., the licensee restored the turbine building load centers using normal cross
ties to other sources. At 9:24 p.m. the next day, the licensee re-energized fuel building
Load Center PG 25N.
The licensee disconnected the damaged cable and installed a temporary feeder cable
from a nearby locd center. The inspectors did not observe any problems with the
temporary modification packages used to install the temporary cable and to disconnect
the damaged cable. All systems and components were then restored. The licensee was
evaluating the means for permanent repair at the end of this inspection period. The
licensee halted core drills and anchor bolt work until the immediate corrective actions
were identified and implemented.
The licensee determined that the root cause of the event was personnel error.
Responsible engineering personnel did not review electrical drawings while planning the
work package to determine if there were any conduits in the wall. As a result,
modification Work Authorization C612323 did not contain adequate instructions.
Criterion V of 10 CFR Part 50 Appendix B requires that activities affecting quality shall be
prescribed by documented instructions, procedures, or drawings appropriate to the
circumstances. The failure to prepare an adequate modification work package was a
violation (50-483/9801-02).
The licensee initiated the following corrective actions:
Revising various engineering department procedures to clarify required reviews
-
for modifications;
Improving access to unscheduled conduit field sketches;
+
Evaluating proper use of core drill machine ground fault devices; and,
-
Training personnel on corrective actions.
-
The licensee resumed core drilling after satisfactorily implementing the immediate
corrective actions. This included revising procedures and conducting training.
I
.
9
-10-
c.
Conclusions
The inspectors concluded that the licensee failed to prepare an adequate work package
for the core drill. The inspectors also concluded that the licensee's investigation and
proposed corrective actions were good.
IV. Plant Sunnort
R1
Radiological Protection and Chemistry (RP&C) Controls
R1.1
General Comments (71750)
1
The inspectors observed health physics personnel, including supervisors, routinely
4
touring the radiologically controlled areas. Licensee personnel working in radiologically
controlled areas exhibited good radiation worker practices.
1
Contaminated areas and high radiation areas were properly posted. Area surveys
j
posted outside rooms in the auxiliary building were current. The inspectors checked a
l
sample of doors, required to be locked for the purpose of radiation protection, and found
no problems.
R4
Staff Knowledge and Performance
R4.1
Personnel Entered the Radioloaical Control Area Under the Wrona Name
a
insoection Scope (71750)
The inspectors reviewed instances when personnel entered the radiological controlled
area under the wrong name,
j
The inspectors reviewed:
Suggestion-Occurrence-Solution Reports 97-1434,98-26,98-83, and 98-146;
.
and
Administrative Procedure APA-ZZ-1000,"Callaway Plant Health Physics
Program," Revision 12.
b.
Observations and Findinos
The licensee identified four occurrences, since December 15,1997, in which personnel
entered the radiological controlled area under the wrong name. The licensee
documented the four occurrences using the corrective action system.
.
.
-11-
The licensee's electronic dosimetry system was computer based. Normally, personnel
entering the radiological controlled area entered their badge number manually or
electronically using a bar code reader. On three of the four occasions, workers manually
entered the wrong badge number. On the fourth occasion, the bar code reader failed to
read the correct badge nunter.
The electronic dosimetry system was set up so that personnel have to verify that the
name and other information was correct prior to entering the radiologically controlled
area. On four occasions, personnel did not verify that the name was correct.
The licensee initiated several corrective actions, on a progressive scale, following each
occurrence. The event dates and corrective actions were as follows:
December 15,1997 - The licensee coached the individual involved. The licensee
.
sent the Suggestion-Occurrence-Solution report to the licensing department for
trending;
January 7,1998 - The licensee coached the individual involved. Since this and
-
the previous incident involved personnel from the same department, the licensee
sent the Suggestion-Occurrence-Solution report to that department for action;
January 21,1998 - The licensee assigned the Suggestion-Occurrence-Solution
report to the individual's department, to the health physics department, and to the
nuclear information systems department. Plant management issued a directive to
all department heads to review these incidents with employees. In addition, the
licensee explored improvements to the computer-based electronic dosimetry
system.
I
February 4,1998 - Senior plant management issued instructions to ensure all
-
plant personnel correctly process through the computer-based electronic
dosimetry system. A description of the problems was placed on the computer-
based electronic dosimetry screens, with a caution to ensure the worker was
signing in property.
In addition, on February 26,1998, the licensee held a stand down meeting with all site
personnel to discuss the events.
,
The inspectors reviewed the licensee's corrective actions and had no concems.
Administrative Procedure APA-ZZ-1000, Step 4.1.5.1b reqtired that each individual
entering a radiological controlled area know and comply with radiation work permit
requirements. The inspectors observed that there were 19,683 entries into the
radiological controlled area from December 1,1997, through February 23,1998. The
inspectors considered the four errors to be examples of one violation of the
i
-
.
-12-
administrative procedure requirement. 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 (50-483/9801-03).
1
c.
Conclusions
.
The inspectors concluded that personnel failed to properly log into the computer-based
electronic dosimetry system prior to entering the radiologically controlled area. The
licensee appropriate;y responded to each error.
_
I
R4.2 Radioloaical Controls for a Residual Heat Removal Pumo Test
j
a.
{nsoechon Scone (71707)
The inspectors attanded the pre-job briefing and observed portions of the residual heat
removal Train B operability surveillance test identified in Section M1.2.
The inspectors reviewed:
Radiation Work Permit 98-00501;
-
Test Procedure OSP-EJ-P0018, "Section XI Residual Heat Removal Train B
-
Operability," Revision 22; and
Suggestion-Occurrence-Solution Report 98-111.
-
b.
Observations and Findinas
The test required an equipment operator to access portions of the residual heat removal
pump motor more than 8 feet above the floor for vibration measurements. Radiation
Work Permit 98-00501 required that health physics personnel survey the area when
accessing areas greater than 8 feet above the floor. The licensee had not performed the
survey prior to the test.
A health physics monitor assigned to the auxiliary building entered the residual heat
removal pump room prior to beginning the test. During discussions, the health physics
monitor realized that the equipment operator would access the area greater than 8 feet
above the floor. The health physics monitor performed the required survey and
personnel successfully completed the test.
The inspectors and the licensee determined that the equipment operator assigned to
take the vibration measurements did not adequately discuss the scope of the test with
health physics personnel ahead of time. Specifically, the equipment operator did not
inform the health physics personnel that the test required access more than 8 feet above
the floor. Further, health physics personnel were not present at the pre-job briefing in the
control room to discuss radiological concems.
.
.
-13-
The licensee wrote Suggestion-Occurrence-Solution Report 98-111 to initiate corrective
,
actions. The licensee has initiated changes to the applicable residual heat removal
{
pump and containment spray pump surveillance procedures to ensure performance of
i
surveys prior to testing.
'
c.
Conclusions
The inspectors concluded that the quality of the health physics portion of the pre-job
bnefing was weak. Communications between the equipment operator and health
physics personnel at the radiological controlled area access point were also weak.
V. Manaaement Meetinos
X1
Exit Meeting Summary
,
i
The exit meeting was conducted on February 27,1998. The licensee did not express a
position on any of the findings in the report.
j
The inspectors asked the licensee whether any materials examined during the inspection
should be considered proprietary. No proprietary information was identified.
.
-
,
ATTACHMENT
SUPPL FMENTAL INFORMATION
PARTIAL LIST OF PERSONS CONTACTED.
Licensee
l D. L. Bettenhausen, Supervising Engineer, Quality Assurance
H. D. Bono, Supervising Engineer, Quality Assurance Regulatory Support
D. G. Cornwell, General Supervisor, Maintenance
G.' J. Creschin, Superintendent, Training
M. S. Evans, Superintendent, Health Physics
R. E. Fernam, Supervisor, Health Physics, Operations
i
M. R. Faulkner, Assistant Superintendent, Security
'
L. H. Kanuckel, Supervisor Engineer, Engineering
- C. D. Naslund, Manager, Nuclear Engineering
D. W. Neterer,' Assistant Superintendent, Operations-
J. R. Peevy, Manager,' Emergency Preparedness / Organizational Development
G. L. Randolph, Vice President, Nuclear
.,
M. A. Reidmeyer, Engineer, Quality Assurance Regulatory Support
R. R. Roselius, Superintendent, Chemistry' and Radwaste
M.- E. Taylor, Assistant Manager, Work Control
W. A. Witt, Superintendent, Systems Engineering
INSPECTION PROCEDURES USED
IP 37551:
Onsite Engineering
IP 61726:
Surveillance Observations
IP 62707:
Maintenance Observations
IP 71707:
Plant Operations
IP 71750:
- Plant Support Activities
IP 92902:
Followup - Maintenance
ITEMS OPENED, CLOSED, AND DISCUSSED
Opened
.9801-01
NCV Inadequate testing of the actuation logic of the feedwaterisolation and
turbine trip instrumentation (Section M8.1).
9801-02
Core drilling into a 13.8 kV cable (Section E4.1)
9801-03
NCV Personnel inadvertently entered the radiologically controlled area under
the wrong name (Section R4.1)
.
.
-2-
Closed
97-010-00
LER
Inadequate testing of the actuation logic of the feedwater isolation and
turbine trip instrumentation (Section M8.1).
9801-01
NCV Inadequate testing of the actuation logic of the feedwater isolation and
turbine trip instrumentation (Section M8.1).
9801-02
NCV Personnel inadvertently entered the radiologically controlled area under
j
the wrong name (Section R4.1)
'
Discussed
98-001-00
LER
inoperable auxiliary / fuel building emergency exhaust Train B
(Section O2.1)
.