ML20214L363
| ML20214L363 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/16/1984 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20214L071 | List: |
| References | |
| FOIA-84-901 NUDOCS 8705290285 | |
| Download: ML20214L363 (10) | |
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00T 16 ss4 MEMORANDUM FOR:
Harold R. Denton, Director, Office of Nuclear Reactor Regulation FROM:
James G. Keppler, Regional Administrator, Region III
SUBJECT:
CALLAWAY READINESS FOR FULL POWER LICENSE By letter dated August 23, 1984, you requested Region III to verify that Union Electric Company completed actions which they had committed to complete prior to exceeding five percent power operation. to License NPF-25 identifies certain actions required to be completed by the licensee before reacning certain operational modes.
Also, during the October 4, 1984, Commission meeting authorizing the staff to issue a full power operating license amendment, the Commission expressed an interest in (1) the Staff's evaluation of the late allegations about the Callaway Plant provided to the Commission by a Government Accountability Project (GAP) letter dated September 28, 1984, and (2) the Staff's acceptance of the Callaway Plant readt-ness to proceed beyond low power operation.
Commissioner Asselstine asked to be advised on these subjects prior to issuance of the license.
A discussion of the status of the actions which Union Electric Company had committed to complete prior to exceeding five percent power operation is provided in Enclosure (1).
We have reviewed these items and determined that they have been satisfactorily completed.
A discussion of the status of the items the licensee is required, by Attachment 1 to License NPF-25, to complete before proceeding to Operational Mode 1 (Power Operation) is provided in Enclosure (2). We have reviewed these items and determined that they have been satisfactorily completed.
The Staff's evaluation of the GAP allegations is provided in Enclosure (3).
The staff utilized the criteria outlined in Policy Issue
" Late Allegations",
SECY-84-249A, dated August 31, 1984, in their review and assessment of the 48 allegations provided by GAP.
Based on the information provided, the Staff ng review determined that there are no allegations which would affect the Callaway g o.
Plant's ability to operate safely at power levels greater than five percent.
Og5 Our evaluation of the Callaway Plant operating experience is provided in Enclosure (4),
for this evaluation we considered the number and nature of licensee events, operating crew personnel actions in response to events, h
management and supervisory control of normal ano of f-normal operating condi-fu.v tions and events, conduct of shift turnovers, operator knowledge of procedures, d El plant conditions and control room alarm conditions.
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was given to attitudes and professionalism of personnel, and readiness of
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equipment.
Region III has concluded that the Callaway operating crews have gained Informatien in this record was delcted g 4,,, g 4,, cp g C
in accordance with th fredm of Information M
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H. R. Denton 2
sufficient experience through the low power testing and mode changes by the different crews such that they are now ready to proceed to power levels greater than five percent.
Based on our inspections of commitments, evaluation of outstanding allegations, and evaluation of the Callaway Plant operating experience at power levels less than five percent, we recommend issuance of a full power operating license.
James G. Keppler Regional Administrator Attachments:
Enclosure (1)
Enclosure (2)
Enclosure (3)
Enclosure (4) s e
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ENCt050RE 1 VERIFICATION OF FIVE PERCENT COMMITMENTS FOR CALLAWAY Region III determined that the licensee.has properly completed those items reported in Safety Evaluation Report Supplements 3 and 4 which were committed to being complete prior to exceeding five percent power operation. The SSER item and the verification conducted by Region III are identified below:
Item SSER Pare Verification Completion of Westinghouse 4
3-3 Closed in I.R. 84-32 Field Change Notice SCPM 10622 SetpointAdjustmentsofBarton 4
3-5 Closed - To be documented Differential Pressure Indicating
'in I.R. 84-42 Switches Retraining of Shift Crew on 4
13-6 Closed in I.R. 84-32 Revised Advisor Procedure Install Properly Marked Chart 3
22-4 Closed in I.R. 84-32 Par,er on Recorders Labeling of Hagen Controllers 3
22-4 Closed in I.R. 84-32 Change in Meter Location for 3
22-4 Closed in I.R. 84-32 Panel RLO77 Fo I A-B&-901 lb3L
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ENCLOSURE 2 I
VERIFICATION OF ITEMS REQUIRED BY ATTACHMENT 1 TO LICENSE NPF-25 Region III has reviewed the licensee's actions required by Attachment 1 to the Callaway Low Power License NPF-25, and has verified that all of the required actions have been satisfactorily completed.
Items E and F are actions which were not required to be complete at this time, and should remain as license conditions upon issuance of the Full Power Operating License.
The required actions and the verification conducted by Region III are identified below:
Item Action Verification A.
CRDM Cooling Test (CS-03GN02)~
Closed in I.R. 84-32 B.
Test ESF Actuation System and RPS instrumen #
Closed in I.R. 84-32 tation channels or demonstrate by other means that instrumentation systems are acceptable C.1.
Natural Circulation Test (ETT-22-09240)
Closed - To be documented in I.R. 84-42 2.
Document the adequacy of the margin to trip Closed in I.R. 84-34 for 4160V, Class IE breakers under maximum load conditions 3.
Perform an evaluation to determine the repre-Closed in I.R. 84-35 sentativeness of lodine and particulate samples collec.ted by the Unit Vent Sampling System 4.
Modify door 33044 (Turbine Building to Closed in I.R. 84-32 Auxiliary Building) for post-accident sampling route 5.
Evaluate the adequacy of the mounting of Closed in I.R. 84-39 the diesel generator control panels D.
Resolve deficiencies on the licensee's Closed - To be Ducumented Master Tracking System in I.R. 84-42 E.
Implement Radiation / Chemical Technician Not Complete - Remain Refresher Training within Six Months as License Condition Following Fuel Load F.
Install a permanent area monitor on the Not complete - Remain Manipulator Crane Prior to Entering Mode 6 as License Condition (Refueling Mode)
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Item Action Verification G.I.
Install and test emergency lighting in the closed - To be documented areas needed for operation of safe shutdown in I.R. 84-45 equipment and access / egress routes 2.
Implement adequate communitsilons to support Closed - To be documented shutdown from outside the Control Room in I.R. 84-45 3.
Prepare and impier.ent procedtres for local' Closed in I.R.'s closing of PORV block valves in the event of 84-32, 84-41 spurious PORV actuation during a control room fire 4.
Prepare and inplement procedures specifying Closed in I.R.
on-shift staffing levels to support concurrent 84-32 remote shutdown and fire brigade activities 5.
Prepare and implement procedures for manual Closed in IR's loading EDG's if required during a control 84-32, 84-41 room fire 6.
Prepare and implement procedures for periodic Closed in IR's verification of EDG fuel oil availability and 84-32, 84-41 EDG fuel oil transfer pump restoration in the event pump control is disabled during a control room fire 7.
Test Control Room Halon systems Closed - To be documented in I.R. 84-45
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i ENCLOSURE 3 LATE ALLEGATIONS EVALUATION At 1:00 p.m. CDT on October 5, 1984, a telephone conference was held with representatives of Region III, I&E, and NRR, to review and assess the 48 l
allegations filed by the Government Accountability Project (GAP).
For this review the staff utilized the criteria outlined in Policy Issue -
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" 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 i
power.
l The criteria utilized requires a substantive review of each allegation to determine whether the allegation is reasonable and sounds competent and I
whether the allegation represents a significant safety issue or management i
Concern.
j The review placed the allegations in the seven categories identified below:
Categorization of GAP Allegations A.
Alle ations that do not fall within the NR_C area of responsibility -
B.
Generic GAP issues -
C.
Nonsafety-related issues -
D.
Issues describin conditions w ch are not code violations and, therefore, j
are acceptable
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E.
Issues previously addressed and closed ut in ins ection re orts 50.55(e) l Nuiibnikin'm'iblin' ~
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The review determined, based on the information provided by GAP, that there j
were no allegations which offered specific new information, not previously known j
to staff, which would reasonably be expected to involve sizeable failures of systems that contain radioactivity or of the ECCS systems; therefore, staff i
j determined there are no allegations which would affect the Callaway Plant's j
ability to operate safely at power levels greater than five percent.
i The staff has had personal discussion or telephone conversations with represen-2 tatives of GAP on October 4, 5, and 8,11,12,15,1984, for the purpose of obtaining the affidavits which GAP relied upon to prepare the allegations.
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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 Additionally, we plan to continue to pursue actions to obtain the affidavits from GAP.
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s' ENCLOSURE 4 CALLAWAY PLANT OPERATING EXPERIENCE Region III initiated an augmented inspection program (AIP) at the Callaway Plant on August 29, 1984, when the plant first entered operational Mode 3 (Hot Standby).
In addition to the Callaway senior resident inspectors, the program utilizes other Region III resident inspectors and regional beced inspectors. The program was implemented 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 cd 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 operatingexpeNence.
I The AIP inspectors observed attentiveness of operators and their responsiveness to plant parameters and plant conditions, that plant evolutions and testing are planned and properly authorized, procedures are used and followed, equipment status changes are appropriately documented and communicated to appropriate shift personnel, that operating cedditions of plant equipment are effectively l
monitored and corrective action is initiated, as required, and that control room activities are conducted in a professional manner.
Evaluation of the licensee's operating' experience from entering Mode 3 (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 plent lineups or equipment status.
The shift technical and operating shift advisors were integrated into these briefings.
Activities involving starting or stoppinh major plant equipment were communicated within the control room and announced over the plant loud speakers.
' The response to technicar 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.
The operators' response (s) to abnormal conditions and alarms demonstrated a s
good working knowledge of plant systems and procedures.
Operators were s
3 attentive to alarms and initiated appropriate technical specification action and surveillance requirements.
Initial operator response and recovery Fa t F -% -Ro \\
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actions in response to abnormal conditions were appropriate and performed in a professional manner.
.nd included a review of logs, control room panel wal discussions of past, current and planned activities.
during the processing of work requests and temporary m and surveillance procedures were properly authorized and scheduled.
Test incidents and reportable events were appropriately documented and Plant communicated.
Evaluation of the licensee's operating experience during the initial approach to criticality (Mode 2), on October 1, 1984, startup and core physics testi and during operations at power levels below five percent as of October 15 ng indicate that:
, 1984, utilized during operational mode changesPlant procedures, includ startup testing activities, and detail and are understood and followed by shift crews. routine demonstrate a disciplined approach to plant operations. Shif Shift turnovers are detailed and professional, and include log reviews control room panel walkdowns and detailed discussion of plant conditions testing in progress, and discussions of past, current, and planned activities.
of plant systems and technical specifications which in training, knowledge, attitude and ability to operate the plant safely during all plant operating modes.
After issuance of the low 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, personnel errors has decreased. the frequency of licensee events involving Factors which may have contributed to the reduction of personnel 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 /> snift rotation schedule to reduce the number of shift turnovers and provide personnel emphasizing the need to reduce personnel errors. ad Region III's augmented inspection program was implemented on August 29 Additionally,
, 1984.
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During the Enforcement Conference, the licensee agreed to develop a' program which would give them and the NRC staff confidence that the operating crews are ready to commence power ascension and operate the plant at full power. On September 10, 1984, the licensee submitted a plan to accomplish additional operating evolutions, which was acceptable to Region III. These evolutions have been completed satisfactorily.
Based on the results of the augmented inspection program, the reduced frequency of personnel errors at the Callaway plant, and the licensee's successful completion of additional operating evolutions, we conclude that the licensee has demonstrated that they can operate the Callaway plant safely at all power levels.
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