IR 05000483/2002003

IR 05000483-02-003, on 12/02/2002-12/18/2002, Union Electric Company; Callaway Plant; Biennial Inspection of the Identification and Resolution of Problems

ML030770857
Person / Time
Site:	Callaway
Issue date:	03/17/2003
From:	Gody A Operations Branch IV
To:	Randolph G Union Electric Co
References
IR-02-003
Download: ML030770857 (16)

Text

rch 17, 2003

SUBJECT:

NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 50-483/02-03

Dear Mr. Randolph:

On December 18, 2002, the NRC completed an inspection at your Callaway plant. The enclosed report documents the inspection findings, which were discussed on December 18, 2002, with Mr. Ron Affolter, Vice President - Nuclear, and other members of your staff. An additional exit was conducted via telephone with Mark Reidmeyer, on January 30, 2003, to clarify the status of issues pending from the initial exit meeting.

This inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

Within these areas, the inspection included selected examination of procedures and representative records, observations of activities, and interviews with personnel.

On the basis of the sample selected, the team concluded that, in general, problems were properly identified, evaluated, and corrected. However, the results of the safety conscious work environment survey you conducted identified that approximately 20 percent of the individuals responding felt that they had received negative repercussions for identifying an issue. The Commissions Policy Statement for nuclear employees raising safety concerns without fear of retaliation was published in the Federal Register 61 FR 94 on May 14, 1996. The Policy Statement indicated that the NRC expects that licensees and other employers subject to NRC authority will establish and maintain safety-conscious environments in which employees feel free to raise safety concerns, both to their management and to the NRC, without fear of retaliation. We understand that your actions related to this area are under development at this time. We will continue to monitor this area in future inspections.

Based on the results of this inspection, the NRC has identified an issue that was evaluated under the risk significance determination process as having very low safety significance (Green). The issue involved a failure to properly post a high radiation area and is being treated as a noncited violation, consistent with Section VI.A of the Enforcement Policy. If you contest the violation or significance of the noncited violation, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear

Union Electric Company -2-Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with copies to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at the Callaway plant.

In accordance with 10 CFR 2.790 of the NRCs "Rules of Practice," a copy of this letter, its enclosure, and your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Anthony T. Gody, Chief Operations Branch Division of Reactor Safety Docket: 50-483 License: NPF-30

Enclosure:

NRC Inspection Report 50-483/02-03

REGION IV==

Docket: 50-483 License: NPF-30 Report: 50-483/02-03 Licensee: Union Electric Company Facility: Callaway Plant Location: Junction Highway CC and Highway O Fulton, Missouri Dates: December 2-18, 2002 Inspectors: P. Harrell, Chief, Technical Support Staff R. Bywater, Senior Resident Inspector, Projects Branch D J. Hanna, Resident Inspector, Projects Branch B J. Dodson, Regional Operations Officer Accompanying S. Green, Reactor Engineer Personnel:

Approved By: Anthony T. Gody, Chief Operations Branch Division of Reactor Safety

-2-SUMMARY OF FINDINGS IR 05000483-02-03; Union Electric Company; 12/2/2002-12/18/2002; Callaway Plant; biennial inspection of the identification and resolution of problems.

The inspection was conducted by a staff chief, and a senior resident, resident, and region-based inspector, with a reactor engineer accompaniment. One Green noncited violation was identified. The significance of most findings is indicated by their color (Green, White, Yellow, Red), using NRC Manual Chapter 0609, "Significance Determination Process (SDP)."

Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process,"

Revision 3, dated July 2000.

Identification and Resolution of Problems Issues associated with a failure to identify and adequately evaluate an operability issue associated with the auxiliary feedwater system and two examples of inadequate corrective actions for conditions adverse to quality provided indications that the licensee had weaknesses in their problem identification and resolution program. The team found the licensee effectively implemented changes to address these problem identification and resolution program weaknesses. Problems were identified at the proper threshold and entered into the corrective action program. Risk information was effectively used to prioritize the extent of evaluation and to determine the schedule for implementation of corrective actions. Corrective actions, when specified, were typically implemented in a timely manner. During interviews workers indicated no reluctance to place safety issues into the problem identification and resolution program.

However, a licensee survey indicated that some employees felt that they had received negative repercussions for raising issues (Section 4OA2).

Cornerstone: Occupational Radiation Safety Green. The licensee failed to maintain a high radiation area properly posted. This was identified as a violation of Technical Specification 5.7.1.a. This violation is being treated as a noncited violation, consistent with Section VI.A of the NRC Enforcement Policy. The licensee documented this issue in their corrective action process.

This finding involves the radiation safety cornerstone, the program and process attribute was affected, and is more than minor because failing to maintain a high radiation area properly posted could result in unnecessary personnel exposure. The finding is characterized under the significance determination process as having very low safety significance because this violation did not involve ALARA (as-low-as-reasonably-achievable) planning and controls, no personnel overexposure occurred, substantial potential for personnel overexposure did not exist, and the finding did not compromise the licensees ability to assess dose (Section 4OA7).

Report Details 4. OTHER ACTIVITIES 4OA2 Identification and Resolution of Problems a. Effectiveness of Problem Identification (1) Inspection Scope The team reviewed selected items across the seven cornerstones of safety to determine if problems were being properly identified, characterized, entered into the corrective action request (CAR) system, and appropriately resolved. The team reviewed reports of events, conditions, problems, deficiencies, and industry problems, as documented in NRC Bulletins and Information Notices. The team also reviewed approximately 150 CARs, dated January-December 2002, to verify that the licensee was identifying concerns/problems and the identified concerns/problems were being properly resolved. The selection of the CARs reviewed was based on the inclusion of concerns/problems from each performance area contained in the Reactor Oversight Process. The specific items reviewed are provided in an attachment to this report.

The team performed numerous plant tours in an effort to identify deficient conditions existing in the plant. This effort was conducted to determine if conditions existed that the licensee had not identified and entered into the CAR system for appropriate resolution. Plant walkdowns focused on three risk-significant systems: (1) emergency diesel generators, (2) auxiliary feedwater system, and (3) essential service water system.

The team also interviewed personnel involved with the wide variety of aspects related to implementing and maintaining a fully functional problem identification and resolution program. These interviews were conducted to assess each individuals working knowledge of the CAR system and to ensure that each individual utilized the CAR system as proscribed in the licensees Procedure APA-ZZ-00500, Corrective Action Program, and the applicable NRC requirements.

(2) Issues and Findings During the performance of the inspection attributes discussed above, no findings of significance were identified. During plant tours, the team did not identify any safety-significant issues. The team did identify a small number of minor non-conforming or degraded conditions that did not affect the functionality or operability of the safety systems reviewed. Once the licensee was informed by the team, each of these issues were entered into the licensees corrective action program in a timely manner. Even though these minor issues were identified by the team and not the licensee, given the small number and minor nature of these issues, the team concluded the licensees threshold for identification of problems could be improved but was satisfactory.

-2-a. Prioritization and Evaluation of Issues (1) Inspection Scope The team reviewed approximately 150 CARs and supporting documentation, including an appropriate analysis of the cause of the problem. This effort was accomplished to verify that licensees evaluation of the problems identified, considered the full extent of conditions, generic implications, common causes, and previous occurrences. In addition, the team reviewed the licensees evaluation of selected industry experience information to assess if issues applicable to the licensees facility were appropriately addressed.

Specific documents reviewed during this inspection are listed in the attachment to this report.

(2) Issues and Findings The issues reviewed by the team revealed that the proper categorization had been assigned and the identified issue appropriately evaluated. Although some minor concerns were identified with the evaluation of identified problems, these concerns were not risk- or safety-significant, generally indicating a minor attention-to-detail tendency. Overall, the licensees program for prioritization and evaluation of issues was found by the team to be satisfactory.

The team also reviewed a sampling of noncited violations issued in 2002, to confirm that the licensee appropriately implemented actions to prevent recurrence. The team did not identify any subsequent problems that occurred as a result of inadequate corrective actions, except as discussed below.

During review of the corrective action effectiveness for Noncited Violation 2001005-02, the team determined that corrective actions were not effective in resolving the problem, in that the same concern occurred again after completion of the implementation of the corrective actions. See Section 4OA7 for additional discussion on this issue.

c. Effectiveness of Corrective Actions (1) Inspection Scope The team reviewed a variety of documentation to verify that the appropriate corrective actions had been identified and implemented in a timely manner commensurate with safety significance of the issue, including corrective actions to address common-cause or generic concerns. A listing of specific documents reviewed during the inspection is included as the attachment to this report.

The team also reviewed the issues related to Violation 2002007-01, which was issued in NRC Inspection Report 50-483/2002-07. This violation was related to the licensees discovery of foreign materials in the auxiliary cooling water system.

-3-(2) Issues and Findings One example of ineffective corrective actions was identified, which involved the failure to properly post a high radiation area. This issue is described in Section 4OA2b above. Based on a review of the licensees records, the team identified no further examples of ineffective licensee corrective actions.

Based on review of the actions taken by the licensee, and the reviews documented in NRC Inspection Report 50-483/2002-09, the team determined that the licensee had implemented effective corrective actions to address the identified issues related to Violation 2002007-01. As a result, this violation is considered to be closed. See Section 4OA3 for additional discussion.

d. Assessment of Safety Conscious Work Environment (1) Inspection Scope The team interviewed 10 individuals from the licensee's staff. These interviews assessed whether conditions existed that could potentially challenge the establishment of a safety conscious work environment.

Corrective actions associated with CAR 200202966 were reviewed to determine if the licensee was responsive to the concerns identified in a survey they had conducted of their staff. The survey was conducted to determine if the licensees staff believed they received negative repercussions for writing CARs.

(2) Issues and Findings Licensee employees interviewed by the team demonstrated a willingness to identify issues and enter them into the corrective action program. Nevertheless, a review of CAR 200202966 identified that approximately 20 percent of the individuals responding to the licensees survey felt that they had received negative repercussions for identifying an issue. At the time of the inspection, licensee management had not taken actions to address the survey results.

Subsequent to the inspection, licensee management stated that an additional survey of their staff would be conducted by an outside firm. Once completed, licensee management indicated that an action plan to address the identified issues would be formulated.

4OA3 Event Followup (Closed) Licensee Event Report 50-483/2002-001 and 50-483/2002-001-001: Manual Auxiliary Feedwater Feedwater (AFW) Pump Actuation and Subsequent Gas Binding of the A Motor-Driven Auxiliary Feedwater Pump. In December 2001, AFW Pump A failed to provide sufficient flow and pressure to the steam generators following an on-demand start. The failure of the pump to perform its intended safety function occurred as a result of foreign material blocking the suction of the pump. The foreign material was identified as having originated in the condensate storage tank.

-4-A special inspection was performed to review the details of the failure of AFW Pump A.

The details of this inspection are documented in NRC Inspection Report 50-483/2002-007. This inspection identified a violation for the failure to promptly identify and correct a significant condition adverse to quality. During a followup inspection, as documented in NRC Inspection Report 50-483/2002-09, the actions taken to correct and prevent recurrence of this significant condition were reviewed. Since the licensee had not completed the corrective actions, a final review of the actions was completed during this inspection. Based on the review, and the reviews completed previously, this event report is considered closed.

4OA6 Meetings including Exit Exit Meeting The inspectors discussed these findings with Mr. Ron Affolter, Vice President - Nuclear, and members of the licensees staff in a meeting on December 18, 2002. Licensee management acknowledged the findings presented. An additional exit was conducted via telephone with Mark Reidmeyer, on January 30, 2003, to clarify the status of issues pending from the initial exit meeting.

4OA7 Licensee-Identified Violations The team identified an example of where a high radiation area was not posted in accordance with regulatory requirements. Review of this CAR revealed that, on November 19, 2002, an iron worker removed the cavity access cage, on which the high radiation area posting was attached. By removal of the cage, the radiation area posting was removed, and as a result, the entrance to a high radiation area was not properly posted. The team considered this an isolated performance deficiency.

Technical Specification 5.7.1.a requires, in part, that each entryway to such an area

[high radiation area] be barricaded and conspicuously posted as a high radiation area.

The removal of the access cage with the posting attached is a violation of Technical Specification5.7.1.a, in that, the area was no longer conspicuously posted as a high radiation area. Since this violation did not involve ALARA (as-low-as-reasonably-achievable) planning and controls, no personnel overexposure occurred, substantial potential for personnel overexposure did not exist, and the finding did not compromise the licensees ability to assess dose; this violation is not more than very low significance, and is being treated as a noncited violation.

ATTACHMENT KEY POINTS OF CONTACT Licensee PARTIAL LIST OF PERSONS CONTACTED C. Smith, Supervisor, Health Physics - Dosimetry K. Gilliam, Supervisor, Health Physics - ALARA F. Rosser, Supervisor, Radiation Protection M. Reidmeyer, Supervisor, Regional Regulatory Affairs R. Roselius, Superintendent, Radiation Protection and Chemistry D. Trokey, Coordinator, Emergency Preparedness G. Pendergraff, Performance Coordinator, Protective Services Department L. Graessle, Superintendent, Protective Services S. Batten, Supervisor, Security Shift M. Dunbar, Manager, Security V. McGaffic, Superintendent, Performance Improvement R. Wink, Supervising Engineer, Safety Related Mechanical Systems K. Duncan, Senior Reactor Operator G. Kremer, Engineer C. Dale, Safety Analysis Engineer K. Mills, Supervising Engineer, Safety Analysis NRC M. Peck, Senior Resident Inspector, Callaway ITEMS OPENED AND CLOSED Opened 2002003-01 NCV Failure to Maintain a High Radiation Area Properly Posted Closed 2002003-01 NCV Failure to Maintain a High Radiation Area Properly Posted 2002007-01 VIO Failure to Promptly Identify and Correct a Significant Condition Adverse to Quality 2002-001 and LER Manual Auxiliary Feedwater Feedwater (AFW) Pump 2002-001-001 Actuation and Subsequent Gas Binding of the A Motor-Driven Auxiliary Feedwater Pump DOCUMENTS REVIEWED

-2-The following documents were reviewed by the team to accomplish the objectives and scope of this inspection:

1. CARs 200001969 200201601 200203616 200205200 200206900 200100166 200201614 200203655 200205234 200206903 200100168 200201661 200203737 200205364 200207022 200102148 200201779 200203830 200205365 200207047 200102390 200201828 200203867 200205539 200207131 200103509 200202154 200203983 200205651 200207215 200104974 200202241 200203996 200205698 200207277 200200069 200202298 200204065 200205710 200207283 200200085 200202469 200204095 200205714 200207231 200200121 200202496 200204125 200205808 200207297 200200123 200202887 200204127 200205816 200207360 200200178 200202921 200204162 200205820 200207363 200200299 200202978 200204163 200205826 200207371 200200402 200202994 200204228 200205840 200207473 200200369 200203018 200204238 200205883 200207475 200200509 200203023 200204425 200206003 200207522 200200584 200203049 200204538 200206086 200207636 200200671 200203050 200204547 200206107 200207707 200200683 200203056 200204598 200206134 200207674 200200704 200203108 200204624 200206207 200207694 200200811 200203142 200204626 200206213 200207805 200201038 200203216 200204669 200206218 200207816 200201101 200203240 200204719 200206271 200207854 200201232 200203245 200204803 200206276 200207872 200201266 200203249 200204820 200206510 200207876

-3-200201271 200203304 200204889 200206567 200207968 200201374 200203437 200204987 200206620 200208045 200201378 200203567 200205077 200206664 200103053 200201493 200203594 200205097 200206711 200103262 200201517 200203612 200205121 200206894 200103722 200103939 200204566 200104044 199903524 200107296 200208280 200106307 200102270 200200281 200200669 200200881 200201211 200202204 200202342 200202507 200203057 200203080 200203262 200203412 200203694 200203939 200204210 200204398 200205319 200207398 200208280 200203615 200205150 200206895 200000669 200203017 200204041 200202678 200200485 200100515 200201591 200107423 2. Calculations HPCI - 92 - 005, Rev 0 HPCI - 93 - 0003, Rev 0 HPCI - 0102, Rev 1 HPCI - 02 - 05, Rev 0 HPCI - 02 - 06, Rev 0 AL-16 AL-16 ADD1, Rev 3 AL-16 ADD3, Rev 3 AL-30, Rev 1 3. Procedures Number Title Revision HDP - ZZ - 01300 Internal Dosimetry Program 20 HDP - ZZ - 01500 Radiological Posting 16 HTP - ZZ - 04175 Eberline Model PM-7 Portal Monitor Operation 0 APA - ZZ - 01102 Security Threats, Sabotage, Tampering, or Loss of 13 Company Property APA - ZZ - 00204 Safeguards Information 24 EIP - ZZ - SK001 Response to Security Events 0

-4-Number Title Revision EIP - ZZ - 00102 Emergency Implementing Actions 30 HTP - ZZ - 01203 RWP Access Control 28 HTP - ZZ - 01101 Administrative Controls for Radiation Shielding 9 HDP - ZZ - 03000 Radiological Survey Program 21 APA-ZZ-00143 10CFR50.59 Reviews 0 EDP-ZZ-03000 Containment Coatings 6 OSP-SA-00003 Emergency Core Cooling System Flow Path 15 Verification and Venting OTN-EM-00001 Safety Injection System 20 MSE-NK-QB011 Refueling Outage Inspection and Surveillance of NK11 11 Battery and Battery Charger NK21/NK25 APA-ZZ-00140 Environmental and Other Licensing Evaluations 29 OSP-AL-P0002 Turbine Driven Aux Feedwater Pump Operability 36 Inservice Test OSP-NE-00001B Standby Diesel Generator B Periodic Tests 12 OSP-AL-P001A Motor Driven Aux Feedwater Pump A Inservice Test 32 APA-ZZ-0500 Corrective Action Program 33 4. Drawings M-22EJ01(Q), Residual Heat Removal System, Rev 44 M-22EM01(Q), High Pressure Coolant Injection System, Rev 28 M-22EM02(Q), High Pressure Coolant Injection System, Rev 18 M-22EM03, High Pressure Coolant Injection System Test Line, Rev 11 M-22EP01(Q), Accumulator Safety Injection, Rev 11 M-22KJOSQ, Piping and Instrumentation Diagram Standby Diesel Generator B Exhaust, FO & Starting Air System, Rev 12 5. Other Documents

-5-Emergency Preparedness Performance Indicator Details and Data (3Q01 - 2Q02)

Plant Security Engineering System Health Report (2Q01 - 2Q02)

Request for Resolution, Request for Resolution (RFR) 21157, Rev A 10CFR50.59 Reference Manual, Rev 0 Unqualified Containment Coatings Log - December 5, 2002 RFR 08600A, Evaluation of Perma-Shield Storage in Reactor Building RFR 16628A, Evaluation of Temporary Power Cart Storage in Reactor Building RFR 19268, ECCS Flowpath Verification RFR 19275B, ECCS Flowpath Verification RFR 19278, ECCS Flowpath Verification Centralized Action Tracking System (CATS) 46906, Review of NRC Information Notice 1995-21.

CATS Action 55273, Review of NRC Information Notice 1997-33.

CATS Action 55505, Review of NRC Information Notice 1997-40.

CATS Action 57527, Review of NRC Information Notice 1997-78.

Letter ULNRC-03916, Response to Generic Letter 98-04" S687083 - Surveillance Task Sheet for TDAFP Inservice Test S693437 - Surveillance Task Sheet for TDAFP Inservice Test TCN 97-0452 - Temporary Change Notice (TCN)

TCN 02-0765 Temporary Change Notice Form TSB CN 02-055 - Callaway Plant Primary Licensing Document Change Form CWCM035A - Callaway Work Control - Inquiry List Centralized Action Tracking System (CATS) Action 46906, "Review of NRC Information Notice 1995-21."

Equipment Out-of-Service List 9798 - Operability Determination