ML20214L349

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Partially Withheld Memo Forwarding Evaluation of Gap 840928 Late Allegations Re Safety Deficiencies Affecting Operation of Plant at Power Levels Greater than 5%
ML20214L349
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/16/1984
From: Dircks W
NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
To: Asselstine
NRC COMMISSION (OCM)
Shared Package
ML20214L071 List:
References
FOIA-84-901 NUDOCS 8705290281
Download: ML20214L349 (11)
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OCT 161984 MEMORANDUM FOR: Comissioner Asselstine FROM: . William J. Dircks Executive Director for Operations

SUBJECT:

CALLAWAY - LATE ALLEGATIONS AND READINESS TO PROCEED BEYOND LOW POWER OPERATION i

During the October 4,1984, Comission meeting authorizing the staff to issue a full power operating license amendment, you requested to be advised of (1) the staff's evaluation of the late allegations about +.he Callaway plant -

i provided to the Commission by a Government Accountability Project (GAP) letter i

2 dated September 28, 1984, and (2) the staff's acceptance of the Callaway plant readiness to proceed beyond low power operation.

The staff's evaluation of the GAP allegations is provided in Enclosure I. The staff utilized the criteria outlined in Policy Issue " Late Allegations",

SECY-84-249A, dated August 31, 1984, in their review and assessnent of the 48 allegations provided by GAP. Based on the information provided, the staff review determined that there are no allegations which would affect the Callaway plant's ability to operate safely at power levels greater than five l percent.

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Commissioner Asselstine 2 DRAFT i

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The staff's evaluation of the Callaway plant operating experience is provided in Enclosure II. For this evaluation we considered the number and nature of-

) licensee events, operating crew personnel actions in response to events, nanagement and supervisory control of normal and off-normal operating condi-l tions and events, conduct of shift turnovers, operator knowledge of procedures, plant conditions and control room alarm conditions. Additionally, consideration was given to attitudes and professionalism of personnel, and readiness of equipment. Region III has. concluded that the Callaway operating

.l crews have gained sufficient experience through the low power. testing and mode i

I changes by the different crews such that they are now ready to proceed to power j levels greater than five percent.

The staff will be prepared to discuss these matters further if you'wish.

1 William J. Dircks Executive Director for Operations i

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s Commissioner Asselstine 3 DRAFT

Enclosures:

I. Late Allegations Evaluation II. Cal 1'away Plant Operating Experience cc w/ enclosures:

Chairman Palladino Commissioner Roberts

, Connissioner Bernthal Commissioner Zech J. G. Keppler, RIII G. H. Cunningham, ELD R. C. DeYoung, IE H. R. Denton,tiRR i

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i ENCLOSURE I t

LATE ALLEGATIONS EVALUATION At 1:00 p.m. CDT on October 5,1984, a telephone conference was held with  ;

representatives of Region III, IAE, and NRR, to review and assess the 48 i

allegations filed by the Government Accountability Project (GAP). For this review the staff utilized the criteria outlined in Policy Issue -

" Late Allegations " SECY 84-249A, dated August 31, 1984. The purpose of the review was to determine which allegations, if any, would require resolution prior to the Callaway Plant being authorized to exceed five percent reactor power.

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The criteria utilized requires a substantive review of each allegation to determine whether the allegation is reasonable and appears competent and i

l whether the allegation represents a significant safety issue or managenent Concern.

l The review placed the allegations in the seven categories identified below:

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l Categorization of GAP Allegations i

A. Allegations that do not fall within the NRC area of responsibility - __

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l l 8. Generic GAP issues -

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i C. Nonsafety-related issues -

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Issues describing conditions which are not code violations and, therefore, are acceptable - '

- l l I E. l Issues previously addressed and closed out in inspection reports, 50.55(e) reports, hearings, or old alle gations '

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F. Issues requiring inspection i

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The review determined, based on the information provided by GAP, that there were no allegations which offered specific new information, not previously known to staff, which would reasonably be expected to involve sizeable failures of systems that contain radioactivity or of the ECCS systems; therefore, staff I

determined there are no allegations which would affect the Callaway Plant's I

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ability to operate safely at power levels greater than five percent.

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The staff has had personal discussion or telephone conversations with represen-tatives of GAP on October 4, 5, and 8,11,12,15,1984, for the purpose of obtaining the af fidavits which GAP relied upon to prepare the allegations. l i

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We plan to complete resolution of all the issues, in a timely manner, and to document the results in inspection report 84-45. Additionally, we plan to continue to pursue actions to obtain the affidavits from GAP.

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, . i EN_ CLOSURE II CALLAWAY PLANT OPERATING EXPERIENCE RegionIIIinitiatedanaugmentedinspectionprogram(AIP)attheCallaway Plant on August 29, 1984, when the plant first entered operational Mode 3 (HotStandby). In addition to the Callaway senior resident inspectors, the program utilizes other Region III resident inspectors and regional based inspectors. The program was inplemented to provide Region III with additional onsite inspection of operational activities during Mode 3, initial startup and ,

power ascension to better assess the licensee's personnel and plant readiness for full power operation. .

The AIP has provided coverage on portions of all shifts on a seven day schedule and will remain in effect until such time as we are satisfied with the licensee's operating experience. l l The Alp inspectors observed attentiveness of operators and their responsiveness to plant parancters and plant conditions, that plant evolutions and testing ere l planned and properly authorized, procedures are used and followed, equipment status changes are appropriately documented and communicated to appropriate  ;

shift personnel, that operating conditions of plant equipment are effectively monitored and corrective action is initiated, as required, and that control room activities are conducted in a professional manner.

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.s Evaluationofthelicensee'soperatingexperiencefromenteringMode3(Hot Standby) to the initial approach to criticality (Mode 2) indicates that:

The operators were aware of and complied with technical specifications, that plant operating and administrative procedures were utilized and adhered to, and that plant temperatures during heatups and cooldowns were closely monitored and plotted.

Shift supervisors held detailed briefings of crews prior to changing plant lineups or equipment status. The shift technical and operating shift advisors were integrated into these briefings.

Activities involving starting or stopping major plant equipment were communicated within the control room and announced over the plant loud speakers.

The response to technical questions presented to personnel by NRC inspectors indicated that both supervisors and operators had good working knowledge of plant status, technical specification and procedures. The shift crew's performance during plant evolutions demonstrated the crew's ability to effectively operate the plant.

Theoperators' response (s)toabnorr.a1conditionsandalarmsdemonstrateda good working knewledge of plant systems and procedures. Operators were attentive to alarms and initiated appropriate technical specification action and surveillance requiren,ents. Initial operator response and recovery 2

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- actions in response to abnonnal conditions were ~ appropriate and performed in a professional manner.  :

Shift turnovers were perfonned in 'a very detailed and professional manner, i and included a review of logs, control room panel walkdowns and detailed discussions of past, current and planned activities.

t Shift personnel frequently referred to plant procedures and drawings during the processing of work requests and. temporary modifications. Test and surveillance procedures were properly authorized and scheduled. Plant incidents and reportable events were appropriately documented and comunicated. l Evaluation of the licensee's operating experience during the initial approach tocriticality(Mode 2),onOctober1,1984,startupandcorephysicstesting {

i and during operations at power levels below five percent as of October 15, 1984, ,

indicate that:  ;

I Plant procedures, including cperating, adninistrative and test procedures j utilized during operational mode changes, stortup testing activities, and routine and non-routine events are generally well written, contain adequate detail and are understood and followed by shift crews. l l

Shift crews are knowledgcable of system details and plant status and demonstrate a disciplined approach to plant operations.

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i Shift turnovers are detailed and professional, and include log reviews, ,

control room panel walkdowns and detailed discussion of plant conditions, F

testing in progress, and discussions of past, current, and planned activities. .

f In response to NRC questions the shift crews demonstrated a good knowledge ,

of plant-systems and technical specifications which indicates adequate training, knowledge, attitude and ability to operate the plant safely during all plant operating modes.

After issuance of the los power license, Region III became increasingly concerned with the incidence of Licensee Event Reports, several of which involved personnel error. Since the Enforcement Conference with licensee management on August 20, 1984, the frequency of licensee events involving personnel errors has decreased. Factors which may have contributed to the reduction of personr.e1 errors include the licensee's restriction of personnel  ;

access in the control room, assignment of the Superintendent of Operation and ,

assistants on shift as shift coordinators, removal of certain administrative functions from the control room, implementation of a 4 shift,12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift '

rotation schedule to reduce the number of shift turnovers and provide additional personnel on shift, and a series of treetings conducted with plant personnel erphasizing the need to reduce personnel errors. Additionally, Region Ill's eugnented inspection program was implemented on August 29, 1984.

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4 During the Enforcement. Conference, the licensee agreed to develop a program which would give then and the NRC staff confidence that the i operating crews are ready to comence power ascension and operate the plant at full power. On September 10,'1984, the licensee submitted a plan to accoroplish additional operating evolutions, which was acceptable to Region III. These evolutions have been completed satisfactorily.  ;

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l l Based on the results of the augmented inspection program, the reduced i frequency of personnel errors at the Callaway plant, and the licensee's successful completion of ~ additional operating evolutions, we conclude that the i licensee has demonstrated that they can operate the Callaway plant safely at all power levels. .

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