ML20137E815

SALP Rept 50-483/85-01 for Dec 1983 - May 1985.Area of Plant Operations Will Need Continued Attention Due to High Number of Plant Trips

ML20137E815
Person / Time
Site:	Callaway
Issue date:	08/21/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20137E809	List: ML20137E802 ML20137E815
References
50-483-85-01, 50-483-85-1, NUDOCS 8508260080
Download: ML20137E815 (40)

See also: IR 05000483/1985001

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SALP 5

SALP BOARD REPORT

U. S. NUCLEAR REGULATORY COMMISSION

REGION III

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

50-483/85001

Inspection Report

Union Electric Company

Name of Licensee

Callaway Plant

Name of Facility

December 1, 1983 - May 31, 1985

Assessment Period

8008260000 850821 3

PDR ADOCK 0500

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I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on a

periodic basis and to evaluate licensee performance based upon this infor-

mation. SALP is supplemental to normal regulatory processes used to ensure

compliance to NRC rules and regulations. SALP is intended to be sufficiently

diagnostic to provide a rational basis for allocating NRC resources and to

provide meaningful guidance to the licensee's management to promote quality

and safety of plant construction and operation.

An NRC SALP Board, composed of staff members listed below, met on July 26,

1985, to review the collection of performance observations and data to assess

the licensee's performance in accordance with the guidance in NRC. Manual

Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of

the guidance and evaluation criteria is provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety performance

at Callaway for the period December 1, 1983 through May 31, 1985.

SALP Board for Callaway:

Name Division Title

J. F. Suermann DRP Acting Section Chief

L. E. Kanter DRP Acting Project Inspector

S. D. Richardson DI/IE Chief, Sec 1, ORP8

P. R. Pelke DRP Project Inspector

J. Hind DRSS Director

W. L. Forney DRP Chief, Projects Section 1A

B. H. Little DRP. Senior Resident Inspector

C. J. Paperiello DRS Director

L. A. Reyes DRS Chief, Operations Branch

W. D. Shafer DRSS Chief, EP&EB

R. L. Spessard DI/IE Deputy Director

L. R. Greger DRSS Chief, FRPS

M. C. Schumacher DRSS Chief, IMEPS

B. J. Youngblood NRR-DL Chief, LB No. 1

T. W. Alexion NRR-DL Project Manager - Callaway

M. P. Pht', lips DRSS Chief, EPS

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E. G. Gretri. nan DRP Deputy Director-

i J. R. Kniceley DRSS Safeguards Inspector

P. R. Wohld DRS IST Inspector

R. Hasse DRS Reactor Inspector

, J. Neisler DRS Reactor Inspector

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R. D. Lanksbury DRS Acting TPS Section Chief

M. J. Farber DRP Reactor Inspector

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II. CRITERIA

The licensee's performance is assessed in selected functional areas

depending whether the facility is in a construction, preoperational,

or operating. phase. Each functional area normally represents areas

significant to nuclear safety and the environment, and are normal

programmatic areas. Some functional areas may not be assessed because

of little or no licensee activities or lack of meaningful observations.

Special areas may be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess

each functional area.

1. Management involvement in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history

5. Reporting and analysis of reportable events

6. Staffing (including management)

7. Training effectiveness and qualification.

However, the SALP Board is not limited to these criteria and others may

have been used where appropriate.

Based upon the SALP Board assessment, each functional area evaluated is

classified into one of three performance categories. The definition of

these performance categories is:

Category 1: Reduced NRC attention may be appropriate. Licensee manage-

ment attention and involvement are aggressive and oriented toward nuclear

safety; licensee resources are ample and effectively used so that a high

level'of performance with respect to operational safety or construction

is being achieved.

Category 2: NRC attention should be maintained at normal levels. Licen-

see management attention and involvement are evident and are concerned

with nuclear safety; licensee resources are adequate and are reasonably

effective such that satisfactory performance with respect to operational

safety or construction is being achieved.

Category 3: Both NRC and licensee attention should be increased. Licen-

see management attention or involvement is acceptable and considers

nuclear safety, but weaknesses are evident; licensee resources appear to

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety or construction is being

achieved.

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Trend: The SALP Board has also categorized the performance trend in each

functional area rated over the course of the SALP assessment period. The

categorization describes the general or prevailing tendency (the perfor-

mance gradient) during the SALP period. ~ The performance trends are

defined as follows:

Improved: Licensee performance has generally improved over the course-

of the SALP assessment period.

Same: Licensee performance has remained essentially constant over

the course of the SALP assessment period.

' Declined: Licensee performance has generally declined over the course

of the SALP assessment period.

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III. SUMMARY OF RESULTS

The licensee's overall performance has improved over the course of this

SALP assessment period. Generally, performance of the facility has

remained constant or has trended' upward from the previous evaluation

period to the current one.

Rating Last Rating This

Functional Area Period Period Trend

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A. Plant Operations NR 2 Improved

B. Radiological Controls 1 2 None

C. Maintenance NR 2 Improved

D. Surveillance NR 2 Same

E. Fire Protection 2 l' Improved

F. Emergency Preparedness' NR 2 None

G. Security 2 2 Improved

H. Initial Fuel Loading NR 1 Same

-I. Construction Completion

Activities 2 2 None

Ja. Electrical 2 1 Improved

b. Instrument and

Control Systems * 1 1 Same

K. Preoperational

Testing 2 2 Improved

L. Startup Testing NR 1 Improved

M. Quality Programs and

Administrative Controls NR 2 Improved

N. Licensing Activities 1 1 Same

• Ja. and b. are combined under heading Electrical Power Supply and

Distribution.

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IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

Portions of twelve inspections were performed in this area by

the resident inspectors and specialist inspectors which

included direct observation of operating activities relating

to systems and equipment line-ups and operability verification

prior to and during initial fuel loading, plant heatup, startup

testing, and power operation. The inspections included a

review of logs and records, interviews with plant personnel

and followup of significant operating events to ascertain

facility operations in conformance with the Technical Specifi-

cations and administrative procedures. In addition, Region

III implemented an Augmented Inspection Program at Callaway.

The program provided additional inspection coverage of

operations activities from plant entry to Mode 3 (hot standby)

on August 29, 1984 through initial plant startup and power

ascension testing (90 to 100% power level) on November 30,

1984. The augmented inspections were performed by four

Region III based and four resident inspectors in addition to

the Callaway assigned resident inspectors. The inspections

focused on control room activities including supervision.and

operator performance during normal plant operation and off-

normal events, and included observations and discussions with

plant. personnel during maintenance and testing activities.

Four violations were identified as follows:

a. Severity Level III - Failure to have two independent-

containment spray systems operable in Mode 4 (hot shut-

down) as required by Technical Specifications (Report

No. 50-483/84-36).

b. Severity Level V - Failure to follow procedures for

maintenance of operable control room recorder charts

(Report No. 50-483/84-42).

c. Severity Level IV - Failure to perform Technical

l Specification Action Statement for an inoperable Halon

System (Report No. 50-483/85002).

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i d. Severity Level IV - Two examples of failure to follow

! procedures regarding internal reporting and timeliness

! of initiating a Startup Field Report (Report No. 50-483/

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84-11).

Violation "a" resulted in the imposition of a Civil Penalty

of Twenty-Five Thousand Dollars ($25,000). The Civil Penalty

, was imposed due to the significance of the violation and to

emphasize the importance of conducting activities in full

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compliance with the facility license. The monetary anount of

the civil penalty imposed reflected a 50% mitigation which

was based on the following: (1) the violation was identified

by the licensee's staff and promptly reported; (2) corrective

. actions taken by the licensee were prompt and extensive; and

(3) the licensee's administrative controls providea an oppor -

tunity for discovery of the violation prior to initial

criticality.

Violation "b" is considered a minor isolated operator oversight

which wcs included as one of the three examples of failure to

follow procedures. The other two examples are included in the

functional area, Quality Programs, and Administrative Controls.

Violation "c" involved two discrepancies: (1) opening of the

fire door to a Halon protected room was not identified as

having impacted Halon System operability for approximately

two days; and (2) the subsequently issued incident report was

dispositioned incorrectly as "no Technical Specification

Violation".

Violation "d" was identified during the performance of a QA

program review. The event was the introduction of exhaust

gases from the auxiliary boiler into the control room

resulting from the combination of wind direction and air

inversion. The event was neither appropriately reported nor

timely resolved until an NRC inspector brought the matter to

the licensee's attention.

Although the aoove violations directly involved plant

operations, other violations which indicate direct or indirect

involvement by plant operations are discussed in other func-

tional areas in this report. In addition, NRC inspection of

Licensee Event Reports (LERs) determined that plant operations

personnel were involved in procedural and Technical Specifica-

tion violations for which Notices of Violations were not cited.

.These. violations were of lesser safety significance, which the

licensee identified, thoroughly evaluated, factually reported,

and provided prompt corrective measures. Overall, the number

of LERs generated during the assessment period is excessive,

but'a downward trend has-been noted. Four emergency classified

" Unusual Events" occurred during this assessment period. Three

of these resulted from equipment deficiencies and one from a

procedural deficiency. LERs are summarized in the " Supporting

Data and Summaries" section of this report.

There were twenty-nine (29) reactor trips which occurred

during the period from September.23, 1984 through May 31,

1985. Of these, three were planned as engineering tests,

eighteen related to equipment deficiencies, five resulted

from procedure deficiencies, and three resulted from

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personnel errors. During the last three months of 1984, sixteen

unplanned reactor trips occurred. Ten unplanned reactor trips

occurred during the first five months in 1985. While this

indicated a downward trend, the number of unplanned trips

resulted in challenges to safeguards systems and is considered

unacceptable. NRC followup inspection determined that the

licensee has been responsive in this matter. In addition to

comments provided by the onsite Review Committee, the licensee

has obtained evaluations and recommendations from the Quality

Assurance staff, the Senior Operation Advisory Panel, the

Independent Safety Engineering Group, and INPO Assistance Visits

and factored them into event corrective measures.

Following preoperational testing, plant operations experienced

difficulties in integration and control of multiple work acti-

vities. The activities related to the resolution of plant

deficiencies, system preparations for initial fuel loading,

preventive maintenance, and surveillance testing. Unplanned

events, which were indicative of inadequate control of work

activities occurred on May 6, 1984 (water spill in the reactor

containment building) and between June 1 and 3,1984 (Loss of

Residual Heat Removal (RHR) Pump Suction, Inadvertent Safety

Injection Actuation Signals, and overfilling of the Ultimate

Heat Sink). The events were caused by a combination of:

Personnel error - failure to precisely follow procedures.

Procedural deficiencies - insufficient or inadequate

guidance or inadequate caution statements.

Lack of system familiarization - indications misinter-

preted or unawareness on the part of personnel.

Mental fatigue - long working hours and hectic work

pace created an environment conducive to mental errors.

Test hardware design - the test switches are easily

mispositioned by unintended actions which are not

readily detectable.

NRC followup inspection, including Region III Management site

visits, determined that the licensee's upper management was

actively involved in the determination of root causes and the

implementation of correctional measures. In addition to

implementing corrective action for the personnel errors and

equipment and procedural problems, the licensee initiated a

12-hour four shift rotation system with increased number of

operators per shift, and increased supervision of shift activi-

ties through the assignment of the superintendent of operations

and his assistants on shift. The licensee's corrective

measures resulted in prompt improvement and satisfactory

control of work activities.

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Inspection of licensee performance relating to Control Room

behavior was performed by the resident inspectors and Region

III inspectors assigned to the Augmented Inspection Program.

The extended coverage provided observation of the licensee's

shift crew performance during days, off-shift and weekends,

including shift turnovers.

NRC inspections determined that this area was given a high

level of management attention and support. The licensee's

administrative controls specified requirements for maintenance

of professional operator conduct and control room activities,

potentially distracting activities, and restricting control

room access. The inspectors observed that the licensee's

administrative controls were adhered to by the operating

shift crews.

The control room operators and supervisors were attentive to

-plant conditions and displayed a professional attitude toward

the control and operation of the plant. Plant alarms, and

both planned and unplanned events were promptly responded to,

appropriately communicated, and logged. The operating logs,

status bo~ards, and equipment out of service logs were being

maintained and reflected current plant and system conditions.

Administrative and operating procedures were adhered to.

Crew shift relief and turnovers were performed in a thorough

manner and included discussions of past, current, and planned

activities, the review of logs, and panel walkdowns. Control

room access is limited and enforced. The licensee modified

the-shift supervisor's office (window access) for the

processing of work packages, which has resulted in noise and

traffic reduction in the control room. The inspector noted

that licensee management and quality assurance personnel

provided frequent inplant observations of the shift crews'

performance.

During the assessment period, operations personnel received

their initial licensed operator examinations. The following

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initial examinations were administered to Callaway personnel:

31 - Senior Reactor Operator (SRO), 20 - Reactor Operator (RO),

and 1 - Instructor Certification. Of these initial examinations,

19 R0s, 28 SR0s, and 1 instructor passed, which resulted in an

overall pass rate of 95% for R0s, 90% for SR0s, and 100% for

instructors. Tne one R0 and the three SR0s who failed their

initial examinations subsequently passed their reexaminations.

The overall composite pass rate for initial examinations was

92%, which far exceeds the national average for all licensees

(which is 80%). The initial testing results at this plant are

especially impressive considering the percentage of examinees

passing the initial cold licensing examination is generally

much less than 80%. All individuals who were examined at the

Callaway plant eventually received their licenses, resulting in

a 100% pass rate, with 92% of the candidates being successful

on their first attempt. A major strength of the Callaway

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training department, for which they are to be commended, is that

the department personnel have consistently been cooperative and

helpful in their interfacing with NRC licensing examiners. This

positive attitude is considered a strength.

2. Conclusion

The licensee is rated Category 2 in this area. This rating

is based on inspection findings of initial weaknesses in the

control of work activities-and the number of reactor trips

and events experienced during this assessment period. NRC

recognizes the high level of professionalism achieved in the

control room conduct, performance, and management's attention

and involvement. An improved trend in overall performance was

noted in plant operations. This area was not rated in the

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previous assessment period.

3. Board Recommendations

This is the first rating in this area and the Board notes the

encouraging performance trend in overall plant operations and

recognizes the high level of management attention given in this

area. However, the number of reactor trips and events are

considered to be excessive and the Board recommends that the

the licensee and the NRC continue to focus attention in this

area, particularly those events involving equipment deficiencies

and personnel error.

B. Radiological C'ontrols

1. Analysis

Six inspections were conducted during this assessment period by

region based inspectors. These inspections included radiation

protection, radioactive waste management, TMI Action Plan Items,

environmental protection, and confirmatory measurements. The

plant was in preoperational and startup modes during much of the

assessment period. The plant was operational during the last

five months of the assessment period; two of the inspections

were conducted near the end of the operational period. The

resident inspectors also reviewed this area during routine

inspections. No violations or deviations were identified.

Staffing continues to be a licensee strength. The staff is

stable and well organized with no significant turnover to date

other than internal promotions t.nd technician transfers among

the radiation protection, chemistry, and radwaste groups.

Qualifications, education, and experience levels within the

staff are good and should improve with the licensee's practice

of assigning technicians full time to specialized subgroups.

Staffing levels are high by design to minimize reliance on

contractor personnel.

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Positive management involvement is evident: in the organiza-

tional structure which places supervisors and foremen in charge

of specialized activities such as primary chemistry, secondary

chemistry, counting room, dosimetry, and health physics opera-

tions; in the good procedures and QA/QC programs in the counting

room and chemistry laboratory; and in the ample quantities of

well maintained, good quality equipment and instrumentation. By

contrast, licensee management weaknesses were evident concerning

implementation of TMI Action Items related to dose commitment

evaluations for collection of iodine and particulate samples and

PASS backup samples, shielding evaluation of the areas surround-

ing accident samplers, and particulate and iodine sampling

representativeness. In response to. inspector concerns in this

area, the licensee agreed to conduct an in-depth evaluation of

their conformance to. selected TMI Action Items.

Responsiveness to NRC initiatives was adequate during this

assessment period. The li ensee has resolved several of the

TMI Action Item problems r;'erenced above and has proposed

corrective actions for the remainder, although action to resolve

an issue concerning iodine plateout in sample lines has been

slow and. necessitated repeated inspector attention. Other poten-

tial problems identified during this assessment period were

generally addressed timely and acceptably.

The training program, although not comprehensively reviewed

during this assessment period, appears acceptable. The

licensee is progressing toward INPO certification of their

training program.

A conservative approach to resolution of radiological control

issues is generally exhibited. Personal radiation exposures

for the first six months of operation were about 30 person-rems.

Although radiation exposures are normally expected to remain

low during early plant operation, the first six months' expo-

sures are lower than average for new plants, reflecting good

exposure control-program design / implementation. The licensee's

dosimetry program is well designed and implemented and has

received NVLAP certification. Although liquid and airborne

effluents were not specifically inspected this assessment

period, three unplanned radioactive releases occurred. All

releases were quantitatively minor but-two (temporary liquid

tank overflow, and steam generator blow down release due to

improper valve lineup) were noteworthy because of errors which

contributed to the releases. Additional weaknesses in this

area include a main.tenance backlog which has hindered timely

correction of numerous leaks in contaminated or potentially

contaminated systems in the radwaste building and the lack of

sealing of concrete surfaces in areas susceptible to radioactive

contamination from system leaks.

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In addition to the TMI monitor problems referenced above, monitor

problems were encountered during this SALP period concerning

the failure to install a required manipulator crane area monitor

and a personnel error which resulted in a temporary loss of

iodine and particulate sampling capability. The licensee's

responses to these monitor problems-were acceptable.

The licensee demonstrated a satisfactory capability for-

measuring radioactivity in effluents. At the beginning of

the assessment period, prior to operation, the licensee failed

to achieve agreement in analyzing a spiked charcoal filter.

Prompt action was taken to evaluate the problem and reanalysis

after recalibration achieved agreement. The most recent com-

parison (May 1985) resulted in 35 agreements in 36 comparisons.

Conduct of the Radiological Environmental Monitoring Program

during this period was satisfactory with no significant dis-

crepancies noted in review of the Annual Operating Report.

This area was audited twice by the licensee.

2. Conclusion

The licensee is rated Category 2 in this area. This is a

reduction from the previous SALP period, which included only

preoperational activities and which did not include a compre-

hensive review of TMI Action Plan Items. No discernible

performance trend was evident during the assessment period.

3. Board Recommendations

~None.

C. Maintenance

1. Analysis

Inspections were performed by the resident inspectors, the

Augmented Inspection Team, and Region Based Inspectors. Inspec-

tions included a review of the maintenance programs, staffing,

and staff training. In addition to selected preventive and

corrective maintenance and system modifications checks to verify

that these activities were completed in accordance with Technical

Specifications and the licensee's quality assurance program

requirements, followup inspections were performed on significant

equipment problems. Discussions were held with craftsmen,

maintenance supervision and plant management. Three violations

were identified as follows:

a. Severity Level IV - Failure to identify and correct

nonconforming conditions (Report No. 50-483/84-36).

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b. Severity Level IV - Failure to follow procedures:

4 three examples involving reactor coolant pump seal.

removal and containment personnel air lock repair

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(Report No. 50-483/84-36).

, c. Severity Level V - Failure to follow procedures:

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completion of maintenance without obtaining required

Quality Control (QC) inspector's signoff (Report

No. 50-483/84-36).

t Violation "a" is significant in that it resulted in an

" Unusual Event" (initiation of safety injection on August

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.13,1984) and involved a Bechtel design drawing error,

procedure deficiency, and untimely corrective maintenance

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(work to relamp the partial trip Status Panel, authorized

on July 28, 1984, was not accomplished until after the safety

injection event).

Violation "b" examples indicated a need for greater attention

in maintenance activities relating to work performance, iden-

tification of work affecting a Limiting Condition for Operation,

and maintaining the Equipment Out of Service Log.

Violation "c" was identified as an example of a procedural

violation involving work groups bypassing QC witness points, t

i and the need for greater licensee attention in that area.

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Two LERs were issud relating to I&C maintenance during this

assessment period (84-019 and 84-027). One resulted from an

inadvertent ESF actuation caused by a breaker being opened

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upon panel installation, and the other resulted from Fuel

Building Isolation and Control Room Ventilation Isolation

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Signals when power was removed from the wrong skid.

Early in this assessment period, during completion of pre-

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operational testing, NRC inspectors identified the need for

! stronger controls in the areas of maintenance, surveillance,

. temporary alternation and protection of equipment. NRC's

concern in these areas was included in the previous SALP 4

j functional area of preoperational testing, and discussed with

the licensee during resident inspector exit meetings and

Region III visits. With regard to maintenance activities, the

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NRC concerns'related to procedure adequacy, detailed planning,

scheduling, and protection of equipment.

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Management involvement in this functional area has been evident

and effective in bringing about improvement in the overall con-

duct of maintenance activities. The licensee performed an

extensive. procedure review to clarify and correct procedural

errors, assigned a superintendent of I&C to strengthen super-

I yision in that area, and assigned personnel having senior

operator licenses to planning, scheduling, and maintenance

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supervisory positions. The licensee employs journeymen level

crafts for performance of electrical and mechanical maintenance

activities. During this assessment period the licensee has

implemented a formal comprehensive training program which

includes fundamental, plant specific, and on-job (practical

factors) training. In plant maintenance supervision and plant

engineering support of maintenance activities has been evident.

NRC inspections subsequent to the initial fuel load determined

that the licensee has implemented an adequate maintenance

program. Only minor isolated deficiencies have been noted

with improving performance trends evident in overall maintenance

activities. The licensee's first planned (ten day) maintenance

outage was well planned and executed, and it received extensive

QC coverage and QA overview.

2. Conclusion

The licensee is rated Category 2 in this area. During this SALP

period an improved performance was noted. This area was not

rated in the previous assessment period.

3. Board Recommendations

None.

D. Surveillance

1. Analysis

Inspection of surveillance activities were routinely performed

by the resident inspectors during plant walkdowns, and by

inspection team members assigned to the Augmented Inspection

Program. These inspections included the review of Technical

Specification surveillance activities, procedure adherence,

records and reports. Examination of inservice testing consisted

of two inspections. These inspections dealt with the implemen-

tation of the licensee's inservice test program for pumps and

valves. Procedures were reviewed, testing was observed, and

discussions were held with personnel performing activities. One

violation was identified as follows:

Severity Level IV - Failure to control a

surveillance test that resulted in the

functional degradation of the capability

of redundant ECCS. equipment.

The violation appeared to result from a misunderstanding of

plant safety requirements but was not repetitive of previously

identified items, nor did it appear symptomatic of more signi-

ficant underlying problems.

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Six reportable licensee events, including two reactor trips,

resulted from two procedural and four personnel errors by

I&C technicians performing surveillance activities during

this period. While preventable, the number of events are not

considered significant in comparison to the high level of

surveillance activities which occurred during the initial

startup and power operations. NRC inspection determined that

the licensee has developed and implemented a comprehensive

surveillance program. Deficiencies identified have been

promptly documented, evaluated, and corrected.

Direct management involvement in program development improve-

ment has been evident. Surveillance activities and preventive

and corrective maintenance tasks are computer programmed.

This program was developed during the last few months of this

assessment period and fully implemented on June 1,1985. It

appears that the planning and scheduling program is very

effective in the control of surveillance and maintenance

activities.

An in-depth inspection of the licensee's program for inservice

testing of pumps and valves indicated that the program was

generally well defined, scheduled, and controlled by a knowl-

edgeable staff. A high quality pump vibration program, beyond

minimum code requirements, has been developed by the licensee

which appears to be as good as any observed in Region III and

has already proved valuable in sophisticated analyses for pump

degradation for both safety and non-safety related pumps.

Procedures reviewed were generally adequate and included appro-

priate acceptance criteria, and test results were reviewed in a

timely manner. Observation of field testing indicated that some ,

improvements were needed in the efficiency of test conduct, the l

adequacy and accuracy of test procedures, and the proficiency

of test personnel. These improvements should come with more

experience. The licensee was very receptive to comments and

suggestions by the NRC and indicated a conservative and con-

scientious attitude toward maintaining a quality test program.

2. Conclusion

The licensee is rated Category 2 in this area. This is the

first assessment of this functional area.

3. Board Recommendations

None.

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E. Fire protection

1. Analysis

Two inspections of the licensee's fire protection program were

conducted during this assessment period. Inspections in this

area were routinely performed by the resident inspectors which

included observation of on-shift fire brigade training exer-

cises and maintenance of fire protection equipment. Additional

inspections included a review of the licensee's implementation

of their fire protection program and safe shutdown capability

and a review of the licensee's_ completion of nine fire protection

license conditions and other related open fire protection issues.

All inspection findings (i.e., inadequate emergency lighting

installed, spurious signal deficiency, and communication system

inadequacies, detector wire not installed, and Halon system

check valve replacement) were addressed in a timely and accept-

able manner including operator training on the revised safe

shutdown procedures. Regarding the spurious signal deficiency,

the licensee completed installation of five new isolation

switches and modified two existing isolation switches to achieve

adequate isolation of equipment needed for hot standby from

potential spurious signals which could have originated from the

postulated control room fire. Procedure revisions were also

completed to accomplish manual diesel generator loading in the

event of a control room fire.

Subsequent to the two inspections, License Condition C.(5)(a)

regarding the south electrical penetration room Halon system

operability, the thermal detectors inside containment, and

installation of the passive fire protection system were also

completed.

Inspection of the' licensee's housekeeping performance was

included during routine plant walkdowns by the resident

inspectors and Region III inspectors assigned to the

Augmented Inspection Program. Housekeeping conditions were

also assessed during NRC Region III Management and

Commissioner's visits.

Early in the assessment period, localized housekeeping

discrepancies were identified (Report No. 50-483/83-32).

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Inspection determined that the licensee's quality assurance

staff, during a surveillance, had identified similar house-

keeping deficiencies and had issued a Request for Corrective

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Action. The licensee was responsive in this matter and issued

directives reinforcing strict housekeeping and associated work

'

practices, which resulted in improved housekeeping practices

and conditions.

1

16

l

.

-

.

Following preoperational testing, the licensee implemented

an aggressive housekeeping program to upgrade the plant to

operational readiness conditions. This effort received

licensee upper management attention and resources. The

licensee's program was effective in achieving and maintaining

satisfactory to excellent housekeeping conditions throughout

the plant, with one exception identified in NRC Inspection

Report No. 50-483/84-48. Scrap work materials and trash had

accumulated in localized areas in the auxiliary building.

Although the accumulation did not present a fire hazard or

impede personnel access, it created a potential for unnecessary

contaminated waste. The licensee promptly removed the trash

and similar conditions have not recurred. During these reviews,

no violations or deviations were identified. The licensee's

fire protection program appears to be implemented adequately

at this time.

2. Conclusion

The licensee is rated Category 1 in this area. This rating is

based on improved performance during this period. The licensee

was rated Category 2 in the previous assessment period.

3. Board Recommendations

None.

F. Emergency Preparedness

1. Three inspections were conducted which included an emergency

preparedness appraisal, a followup appraisal of open items and

observations of an emergency exercise, and an inspection of all

phases of the licensee's emergency preparedness program. Among

the areas inspected were emergency detection and classification,

protective action decisionmaking, notifications and communica-

tions, shift staffing and augmentation, training, and licensee

audits. In addition, any activations of the licensee's emergency

plan which resulted in an emergency classification were reviewed.

No violations or deviations were identified as a result of these

three inspections.

Although 42 open items were identified in the appraisal, these

were completed satisfactorily by May 11, 1984. These items

included: installation and calibration of certain equipment;

related procedural development and training; and procedure

updates. Also included was the installation and operational

testing of the Prompt Public Notification System. The Federal

Emergency Management Agency (FEMA) observed and approved this

, demonstration on April 19, 1984. The completion of these open

l items in approximately four months after having been identified

by Region III demonstrated a concerted and coordinated effort by

licensee management to ensure adequate attention was directed

l to this functional area.

l

i

17

L

- -_ -_-_.- .- . -. .-.-. . ._-- __. . . _ _ - . - .

.

-

.

The training orogram was well organized including lesson plans,

, objectives, course matrix, and training records for all emer-

gency response personnel. Minimum training requirements have

been established for each training position. Walk-throughs and

interviews with Shift Supervisors, Shift Technical Advisors,

Emergency Coordinators, and other key technical personnel

indicated that they were competent and well trained in their

emergency functions. Retraining has also been scheduled'to

re-familiarize personnel with the emergency plan and any

changes to it. The training program is well defined and

implemented to accommodate feedback experience and critique

suggestions from exercises and drills to improve the program.

The licensee's response to NRC concerns has been good as well

as timely. Strong management support for the emergency

preparedness program from the Corporate Office has been evident.

The Manager, Nuclear Safety and Emergency Preparedness, reports

to the corporate position of General Manager, Engineering,

directly under the Vice President Nuclear. The Manager and his

staff are all located at the plant site. Overall, emergency

preparedness staffing of key positions is good.

Three shift augmentation drills were conducted by telephone

contact only. Timely augmentation by onsite emergency response

personnel was not satisfactory as demonstrated by these drills.

Further, corrective actions implemented have not been effective.

The licensee's first emergency exercise conducted in March 1984

was well coordinated, orderly, and timely. No major weaknesses

were identified by the NRC inspection team in that exercise.

However, the most recent exercise conducted just after the end

of this SALP period clearly indicated that communication problems

existed which resulted in the inability of the licensee to

provide timely, technical information to the NRC in an emergency.

Another problem identified during the exercise related to what

constitutes " plant activities" versus "offsite activities" as

they relate to where decisions are made (TSC or E0F). The

decisions to use containment spray, hydrogen recombiners, or

venting containment are three good examples of "offsite con- l

'

sequences" decisions that must be coordinated with the EOF prior

,

to implementation, but which were decided in the TSC.

2. Conclusion

The licensee is rated Category 2 in this area with no discernible

!- trend. The licensee was not rated in the previous assessment

period.

1

!

1

18

_ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ . , _ - , , , . . - _ _ _ . _ . . . _ _ _ _ _ _ . . _ _ _ . _ _ _ . _ _ _ . . _ _ _ _ _ - . . . _ _ _ _ _ , _ - _

_ . -__ - _ _ _ _ __ _ ______ _ . __ _

.

-

..

i

3. Board Recommendations

The licensee needs to increase their attention in resolving

communications problems and in appropriately defining what

'

constitutes an "offsite consequences" decision which would

be made at the EOF.

G. Security

1. Analysis

! Nine inspections (five preoperational, two special, and two

'

routine) were conducted by region based physical security

inspectors during the assessment period. One inspection

>

reviewed material control and accountability requirements for

stored fuel. The two routine and two special inspections

were conducted after the license was issued. The resident

inspectors also made periodic inspections of security activi-

'

! ties, assessing routine program implementation, and.providing

initial response to security events.

1

Three Severity Level IV violations were identified during the

assessment period:

,

a. Severity Level IV - Material Control and Accountability:

4

Procedural requirements pertaining to a QA audit of SNM

s records and storage of SNM in a designated location were

not complied with (Report No. 483/84-17-05).

!

l b. Severity Level IV - Protection of Safeguards Information:

I

Some Licensee Event Reports (LERs) which contained Safe-

! guards Information were not properly marked and controlled

(Report No. 483/84-33-01). ,

1

c. Severity Level IV - Compensatory Measures

4 Required compensatory measures were not implemented

(Report No. 483/84-33-02).

i

'

The violations were noted early in the assessment period and

were satisfactorily corrected. The violations were not

repetitive and did not indicate any generic or programmatic

problems. The last two routine inspections showed improvement

. in the areas that had been cited for the above violations. The

! licensee's corrective action has been effective, as indicated

by the lack of recurrence of the violations.

<

a

! 19

i

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- _ _ .._- ___ _ _ _ . _ _ . - _ _ _ _ _ _ _ _ _ - _ _ - - _ _ . - _ . _ _ _ . _ _ - _ . _ _ _ _ - -.I

.

-

.

-

One area of concern was identified during the last routine

inspection which addressed the operation and installation of

a portion of the protected area perimeter intrusion detection

system. Although proper compensatory measures were being taken,

compensatory measures are permitted and designed for short term

implementation and not to replace failed equipment for the long

term. The licensee has been utilizing compensatory measures for

an extended period of time. The licensee plans to devote the

necessary resources to design and install an adequate intrusion

detection system. .The licensee has a clear understanding of the

issue and has the technical expertise to resolve the concern.

The licensee has been responsive to NRC concerns. Areas of

concern appear to receive the same level of site security manage-

ment review as violations receive. Senior site management

support for the security program has been good. Management has

been aggressive in assuring a high level of performance.

Management has established policies and procedures that are

well written, distributed to appropriate personnel, and are

effectively enforced, which contributes to the adequate

implementation of the security program.

Except for the perimeter alarm system concern, there are no

other technical security issues with respect to plant safety

that require resolution nor are there any regulatory issues

which require a licensee response. The licensee's response to

NRC concerns is usually timely. Required security plan

submittals are completed in a timely manner and are technically

accurate. Physical security event reports required by 10 CFR

73.71(c) are submitted in a timely manner and contain adequate

details.

The site Quality Assurance (QA) Department is frequently

involved in site activities and has been active in the per-

formance of thorough and complete audits which have been

effective in uncovering weaknesses in the security system.

Appropriate actions were taken by site management in response

to audit recommendations. Audit personnel are qualified and

experienced in the area of physical security. Key positions

within the security organization are identified and authorities

are defined in security implementing procedures.

The training and qualification program contributes to an

adequate understanding of job responsibilities and fair

adherence to procedures with a modest number of personnel

errors. The staffing and management of the onsite control

guard force is adequate.

The licensee has stressed and implemented excellent communica-

tions between security personnel and site management. The

benefits of this are evidenced by an increase in guard morale

during the second half of the assessment period.

20

_. _ _ - - . - . _- _ _ .-

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.

4

2. Conclusion

The licensee is rated Category 2 in this area, which is the

same SALP rating given in the previous assessment period. The

licensee's performance during the first half of the assessment

period was essentially constant, but progressively improved

,

during~the.latter half of the assessment period.

3. Board Recommendations

None.

H. Initial Fuel Loading

1. Analysis

Inspection of this functional area consisted of two inspections

<

by both regional and resident inspectors. The initial reactor

~

core was loaded during this evaluation period. Loading activi-

ties were inspected by both region based and resident inspectors,

as well as NRC Management. Minor problems were identified

involving the operability of the fuel handling equipment, and

one instance involving the lack of appropriate work authoriza-

tion for troubleshooting fuel handling equipment was noted. No

violations or deviations were identified. Overall activities

witnessed by the inspectors appeared well handled by Union

Electric management and staff. The licensee showed a cautious

approach to nuclear safety considerations and was responsive to

suggestions made by the inspectors. A contracted fuel loading

crew added the_ necessary experience to perform this first time

task for the utility.

2. Conclusion

l The licensee is rated Category 1 in this area based on their

overall quality performance in handling the fuel loading

'

activities. This area was not rated in the previous assessment

. period.

! 3. Board Recommendations

,

None.

I. Construction Completion Activities

1. Analysis

The inspection activities in this area, which were limited

because construction was essentially complete, consisted of

'

four inspections by regional based inspectors. Areas examined

included a review of quality records for containment penetra-

, tions and structural steel installation activities, preservice

,

21

. _ _ _ .

- _

_ - _ _ _ -- __ -- _ _ _ _-.

_

- _

.

.

.

inspection of piping systems, testing of pipe support and'

restraint systems, snubber surveillance and testing, steam

generator snubber installation and qualification and functional

testing, review of activities related to the feedwater small

bore piping damaged by jammed sliding supports, followup _on

actions related to a previous inspection finding, and the

quality records for reactor vessel internals installation acti-

vities. No violations or deviations were identified.

For the areas examined, the inspectors determined that the.

management control systems met regulatory requirements and

records were found to be complete, well maintained, and

available. No major strengths or weaknesses were noted.

2. Conclusion

-

The licensee is rated Category 2 in this area as in the

previous assessment period.

3. Board Recommendations

None.

J. Electrical Power Supply and Distribution

1. Analysis

Portions of eight inspections were performed to examine the

licensee's control in the electrical and instrument and

control installation and inspection activities. The inspec-

tions were performed by the resident inspector and region

based inspectors,

a. Electrical

The electrical activities examined during this period

included determination of programmatic and procedural

adequacy; verification of electrical cable installations

and terminations; electrical cable tray and conduit

installation; cable tray and conduit supports and welding;

and the preservation of installed materials and components.

Two violations were identified in the electrical area:

Severity Level V - Failure to establish acceptance criteria

for torquing bolts in Class 1E relay panels (Report No.

50-483/83-28).

Severity Level V - Diesel generator panels were not

installed in accordance with seismic analysis testing

(Report No. 50-483/83-26).

22

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.

The violations were isolated and were not indicative of

any programmatic deficiencies. No corrective action was

necessary as a result of either violation. Continued

management involvement has resulted in further reduction

in the number of violations identified in the electrical

area during each SALP period. Electrical performance has

shown a continuous improvement through the last three

-assessment periods. Licensee and NRC inspection activity

in this area was completed during this appraisal period.

b. Instrument and Control Systems

'

Inspections in the instrument and control area examined

the licensee's organization and its control of activities

involving: installation and inspection of instrument and

control cable; tubing and tube supports; installation

inspection and welding; environmental qualification docu-

mentation; and quality assurance records. One inspection

included a walkdown of the instrumentation systems to

compare the as-built configuration with design documents,

as-built drawings, and the FSAR. No violations were

identified in the instrument and control area during this

appraisal period. The inspections were performed by the

resident inspector and region based inspectors. Licensee

and NRC construction inspection activity was completed

during this SALP period.

The licensee's aggressive management involvement in both

the electrical and the instrument and controls area is

evident by: the lack of significant violations identified

by NRC inspectors; effective controls over installation

and inspection activities that minimize deficiencies; and

an effective program for the identification and prompt

correction of deficiencies. Continued improvements in

quality assurance personnel staffing and training and the

added financial incentives for quality assurance auditors

to assist in maintaining an experienced and qualified

staff are further evidence of management's involvement in

assurance quality in the construction, testing, and

operation of the Callaway plant.

2. Conclusion

The licensee is rated Category 1 in the electrical and instru-

ment and controls area. The previous rating was Category 2

in the electrical . area and Category 1 in the instrument and

controls area.

3. Board Recommendations

None.

23

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. K. Preoperational Testing

1. Analysis

-The preoperational testing inspection program included-

inspections by both region based and resident inspectors.

During the assessment period the region based inspectors

performed an intensive program of eight inspections which

involved a continuous weekly presence onsite. Portions of

three inspections by the resident inspectors were devoted to

this area. The inspection effort included reviews of pre-

operational test procedures and results packages, observation

of preoperational test performance, and evaluation of overall

test program implementation. Measuring and test equipment

programs, plant equipment protection, temporary modification

control, and in process maintenance control were also observed.

The violations identified during this period involved procedural

inadequacies, failure to follow procedures, inadequate admin-

~

i istrative controls, and failure to protect installed plant

equipment. Sixteen violations were identified as follows:

(1) Severity Level V - Failure to obtain required approval

for a test change and failure to properly document

reverification of prerequisites prior to restarting a

test (Report No. 50-483/83-27).

(2) Severity Level V - Failure to provide adequate acceptance

criteria in a preoperational test (Report No. 50-483/83-27).

(3) Severity Level IV - Failure to provide adequate pre-

requisites for a preoperational test and conducting-a

preoperational test without a properly approved procedure

(Report No. 50-483/83-32).

(4) Severity Level IV - Failure to provide adequate adminis-

trative control to prevent interference between temporary

alterations, maintenance, and testing activities (Report

No. 50-483/84-01).

(5) Severity Level IV - Failure to verify that a system compo-

nent would function as designed (Report No. 50-483/84-01).

(6) Severity Level IV - Failure to adequately review a

preoperational test results package (Report No. 50-483/

84-04).

(7) Severity Level IV - Failure to protect safety-related

electronics equipment from on going construction activi-

ties (Report No. 50-483/84-04).

<

(8) Severity Level IV - Failure to provide adequate controls

to prevent bypassing of required tests and inadvertent

operation (Report No. 50-483/84-04).

24

.m -- _ y -

_

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.

(9) Severity Level IV - Failure to provide proper protection

for equipment during maintenance activities (Report

No. 50-483/84-19).

(10) Severity Level V - Failure to control temporary modifica-

tions (Report No. 50-483/84-19).

(11) Severity Level IV - Failure to adhere to procedures;

changing a preoperational test procedure without processing

a Minor Change Notice (Report No. 50-483/84-23).

(12) Severity Level IV - Failure to provide large pump and fan

motor starting limitations which resulted in exceeding

the duty cycle for a Safety Injection Pump Motor (Report

,

No. 50-483/84-23).

(13) Severity Level V - Failure to adequately document justifi-

cation for disposition of Startup Field Report (Report

No. 50-483/84-23).

(14) Severity Level V - Failure to adequately review a pre-

operational test result package (Report No. 50-483/84-23).

(15) Severity Level V - Failure to perform diesel generator

test procedure as required and failure to adequately

review diesel generator test results package (Report

,

No. 50-483/84-31).

(16) Severity Level IV - Failure to adequately review pro-

cedures and test results packages (Report No. 50-483/

84-34).

The licensee was rated Category 2 in this area in SALP 4 based

on indicated weaknesses in the area of procedural inadequacies.

This rating was based primarily on inspections in the areas of

program implementation, preoperational test procedure reviews,

and preoperational test witnessing. During this assessment

i

period (SALP 5), the emphasis shifted from procedure review and

test witnessing to in-depth reviews of the preoperational test

results evaluations performed by the licensee as part of their

test approval program.

The preoperational test program was completed in a safe and

efficient manner. Its accomplishment was greatly enhanced by

the approach taken by the licensee management in conducting the

program. A staff'of knowledgeable, experienced test engineers

and technicians was assembled to develop and conduct the program.

The schedule was aggressive and optimistic yet schedular

pressures were not allowed to impact the quality of the effort.

25

_- _ _ - _ _

.. ._- - - . - _ - . _ _ __.

.

.

.

Management commitment to quality was evidenced by the activity

of the Startup QA group. This group was staffed primarily with

people who were experienced in preoperational test programs.

Their oversight, consisting of frequent surveillance of test

activities and recurring audits of preoperational test

administration, resulted in a heightened attention to detail

which in turn helped maintain a high level of quality as the

pace of, testing increased.

In SALP 4 the' Board recommended an increase in NRC and licensee

attention to the area of of administrative controls in response

to an inspector concern over control of multiple activities.

Licensee responsiveness to NRC concerns subsequently resulted

in significant upgrading of both preoperational programs and

permanent plant administrative controls.

The large number of violations identified is a direct result of

the number of inspector-hours expended on the project, the large

number of results evaluations reviewed by the inspectors, and

the level of detail applied by the inspectors during the reviews.

Due to the large number of results packages reviewed, the

inspectors did not conclude that the number of violations was

excessive or that it was indicative of a significant weakness.

The licensee was prompt and responsive in initiating thorough

corrective action to assure that safety related systems func-

tioned as designed. The number and severity of the violations

identified are consistent with other facili. ties undergoing

preoperational testing. Over 2700 inspector-hours were expended

in preoperational program inspection for an approximate average

of 170 hours0.00197 days <br />0.0472 hours <br />2.810847e-4 weeks <br />6.4685e-5 months <br /> of inspection per violation. None of the defici-

encies identified by the licensee or the violations identified

by the inspectors resulted in the invalidation of any preopera-

tional tests. It should also be noted that of the sixteen

violations identified during this assessment period only two

were in the area of procedural inadequacy. This improvement in

an area of concern from the previous SALP is indicative of the

effectiveness of the licensee's corrective action.

The overall preoperational test program was judged acceptable

based on the results of the intensive inspection effort by the

NRC. No significant technical deficiencies were identified,

all systems required for safe operation of the plant were veri-

fied to function as designed, and the documentation necessary

to support this conclusion was properly prepared, reviewed,

approved, and stored.

2. Conclusion

The licensee is rated Category 2 in this area. The licensee

was rated Category 2 in the previous assessment period.

3. Board Recommendations

l None.

l

26

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.

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.

L. Startup Testing

1. Analysis

The startup testing inspection program included inspections

by both region based and resident inspectors. During the

assessment period, the region based inspectors performed two

inspections entirely devoted to startup testing and portions

of four other inspections examined the startup program.

Portions of two inspections by the resident inspectors were

devoted to this area. The inspection effort included review

of the administrative controls for the startup test program,

review of startup test procedures, witnessing of startup

testing, and review of startup test results' packages.

The violations identified during this period involved procedural

adherence and inadequate evaluation of startup test results

packages. Two violations were identified as follows:

Severity Level V - Failure to adhere to procedure

for storage of Quality Assurance Records (Report No.

50-483/84051).

Severity Level V - Failure to adequately evaluate or

document evaluation of startup tests (Report No. 50-483/

85004).

During the assessment period the region based inspectors con-

ducted reviews of the startup test program controls, startup

test procedures, and startup test results evaluations.

The licensee was responsive to NRC suggestions on improving the

administrative controls for the startup test program. Incor-

poration of these suggestions resulted in close adherence to

4

test procedures, thorough documentation of test deficiencies,

and few violations identified by the inspectors.

The violations identified in the startup test program were

minor. The violation for storage of Quality Assurance Records

involved a misinterpretation of a requirement and failure to

take advantage of a waiver granted in the Final Safety Analysis

Report by NRR. Licensee response was immediate, thorough, and

the deficiency was corrected within hours of its identification.

The violation for inadequate evaluation involved failure to

,

detect technical discrepancies in the test data. The licensee's

engineering staff responded immediately to the issues identified

by the inspector. The evaluations we're thorough and correct

and assured that all systems required for safe operation of the

plant functioned as designed.

The precritical phase of the. program was completed in a slightly

longer than average time period due primarily to equipment

problems. The licensee's test organization used this delay to

27

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.

good advantage by using the extra time to re-examine their test

procedures, walk them down in the plant, and conduct them on

the simulator. This extra effort resulted in a significant

reduction in the. number of procedural problems usually encoun-

tered during the conduct of a test and significantly improved

the quality of the overall test program, It is also the primary

reason for the rapid completion of the power ascension phase of

the program.

The resident inspectors witnessed the actual testing during the

program to ensure that administrative controls were followed,

test procedures were followed, all deficiencies were identified,

. and that testing activities did not compromise plant safety.

All tests were conducted in a careful, professional manner.

Only one test suffered any substantial disruptions and this was

due to equipment malfunctions which occurred during the test.

The startup test program was judged exceptional based on the

innovative use of the plant simulator to review test procedures,

'

the limited number of test problems encountered, the limited

number of violations identified by the inspectors, and the safe

< and expedient manner in which the program was conducted.

2. Conclusion

The licensee is rated Category 1 in this area. This area was

not rated in the previous assessment period.

3. Board Recommendations

None.

M. Quality Programs and Administrative Controls Affecting Quality

1. Analysis

The licensee's Quality Assurance (QA) Program, including

quality verification and oversight activities, was routinely

assessed by the resident inspectors during observations of <

plant activities in the areas of testing, operations, main-

tenance'and surveillance. The licensee's implementation of

its QA program was also inspected by the Augmented Inspection

Team members and during routine programmatic inspections by

Region based inspectors as.follows:

The inspection documented in Report No. 50-483/83-31 was

, conducted to review the licensee's preoperational testing

Quality Assurance Program and its implementation associated

with auditing, surveillance, and test monitoring. The

inspection indicated that the licensee had established and

implemented an effective program with qualified personnel.

!

28

!

__ __ _ _ .,_ _ _ _ __ _ _ ___. _. . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ , _ . . _

~

.

.

.

Inspections were performed to determine the adequacy of the

operational Quality Assurance Program for: startup activities;

maintenance; design changes and modifications; surveillance test-

ing and calibration control; QA/QC administration; tests and

experiments; records; surveillance; audits; receipt, storage,

'and handling of materials; document control; calibration and

control of measuring and test equipment; non-licensed training;

offsite review committee and, corrective actions. Three viola-

tions were noted during these inspections:

a. Severity Level V - Failure to document a procedure

violation (Report No. 50-483/84-42).

b. Severity Level V .The records vault did not fully comply

with Regulatory Guide 1.88 and ANSI 45.2.9 requirements

(Report No. 50-483/84-11).

c. Severity Level IV - Failure to follow procedures regarding

control of test and measuring equipment (Report No. 50-483/

84-11).

These items were isolated in nature and did not involve pro-

grammatic breakdowns. Corrective action was timely.

In response to allegations from QC inspectors, additional

inspection activity in the area of quality control program

and procedures was conducted and identified a potential

violation related to QC inspector certification / qualification.

Inadequate QC procedures (lack of specific instructions and

criteria in some areas) combined with procedure implementation

deficiencies were found. The inspection determined that there

were no hardware problems with plant systems inspected by QC

inspectors whose certifications were questionable and that

there were no problems in the areas inspected by the inspectors

for which they were certified. The NRC inspection determined

that the QC program deficiencies received management's prompt

attention and were thoroughly evaluated and corrected by the

licensee. The report documenting this activity was still

under review at the end of the appraisal period and will be

considered in the next appraisal period.

During QA program inspections, a total of 25 inspection items

were identified. Twenty-two of these items were closed during

the assessment period, indicating aggressive management action

in addressing NRC concerns.

Management's high degree of attention and personal involvement

in quality programs has been continually evident at Callaway.

The operating crews demonstrate a high degree of professional

conduct during routine operation and the ability to effectively

29

.

-

.

control unplanned events. This reflects favorably on operator

attitude and on operator selection training, and supervisory

influence.

A major strength relates to licensee's selection and staffing

of operations and support organizations including key advisory

personnel. Oversight functions have been adequately staffed

and effectively utilized in the evaluation process of opera-

tional activities and plant events. These activities include:

Onsite Review Committee (ORC), Independent Safety Engineering

Group (ISEG), Senior Operations Advisory Panel (SOAP), Operating

Advisors (0A), Compliance, and Quality Assurance (QA). Observa-

tion of group performance and individual discussions with group

members show them to be dedicated and capable people who are

responsive to industry and NRC activities.

The licensee's Site QA Organization is professionally organized

and staffed. The QA audit and surveillance programs are well

defined.and effectively implemented. QA engineers have provided

~

extensive surveillance coverage (including off-shifts and l

weekends) during fuel loading, initial preparation for startup, I

and power ascension periods. NRC inspection has determined

that the site QA is functionally independent and assertive and

has been effective in the identification and resolution of

quality concerns. Management's support of QA activities has

been evident.

The licensee has continually provided a high degree of attention

and resources to the area of unplanned events, not only in

evaluating them but also in instituting corrective and preven-

tive measures to preclude their recurrence. Reportable events

are promptly identified, reported, thoroughly evaluated, and

appropriately corrected. The number of reportable events,

including reactor trips, continued to remain high during the

assessment period. However, an improved trend was noted during

the last six months of the assessment period.

2. Conclusion

The licensee is rated Category 2 in this area. This rating

is based on a significant Technical Specification violation

discussed in Section A, QC program deficiencies, and licensee

events. This is offset by the high degree of management atten-

tion to quality programs and the favorable trend towards

decreasing the frequency of events. This area was not rated

in the previous assessment period.

3. Board Recommendations

None.

l

!

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N. Licensing Activities

1. Analysis

The basis for this appraisal was the licensee's performance in

support of SSER inputs which constitute SSER#3 and SSER#4, which

were issued in May and October,1984, respectively. The basis

for this appraisal also includes amendment requests and

responses to generic letters which have been reviewed and

evaluated by the staffs since the issuance of the full power

license on October 18, 1984. The subject involved include

the following:

Generic Reviews: Plant-Specific Reviews:

dmergency Response Capability Organizational Changes

Salem ATWS . Shift Advisors

Fire ~ Protection Initial Test Program Changes

Inadequate Core Cooling Appendix J Exemption

Post-Accident Sampling Overpressure Protection

Detailed Control Room Design Appendix R Concern

Equipment Qualification Batch Waste Release Tanks

Instrumentation and Controls Source Range Monitors

Safeguards

The licensee's performance evaluation is based on a considera-

tion of five of the seven attributes specified in NRC Manual

Chapter 0516. These are:

Management Involvement and Control in Assuring Quality

Approach to Resolution of Technical Issues from a

Safety Standpoint

Responsiveness to NRC Initiatives

Reporting and Analysis of Reportable Events

Staffing

For the remaining two attributes (enforcement, and training

and qualification effectiveness), no basis exists for an Office

of Nuclear Reactor Regulation (NRR) evaluation for the func-

tional area of Licensing Activities.

a. Management Involvement and Control in Assuring Quality

During the present rating period the licensee's management

demonstrated active participation in licensing activities

and kept abreast of all current and anticipated licensing

actions. In addition, the management's involvement in

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licensing activities assured timely response to the require-

ments of the Commission's rules related to Fire Protection

and Environmental Qualification of Electrical Equipment.

The implementation schedules for compliance with tnese

rules _were being met by the licensee.

In the area of post-accident sampling, the staff found

consistent evidence of prior planning and assignment of

priorities. The licensee had also provided all the

necessary information t.o close out this item during the

rating period. In the area of instrumentation and controls,

the licensee understood staff policy and made adequate

decisions based on management review. An appropriate level

of management was present at all review meetings held with

the licensee.

In one instance, the staff cited poor performance because

a submittal requesting a technical specification change

was misleading.

b. Approach to Resolution of Technical Issues from a Safety

Standpoint

The licensee's management and its staff have demonstrated

sound technical understanding of issues involving licensing

actions. Its approach to resolution of technical issues

has demonstrated extensive technical expertise in all

technical areas involving licensing actions. The decisions

related to licensing issues have routinely exhibited con-

servatism in relation to significant safety matters. The

licensee's clear understanding of the staff's concerns

assured sound technical discussions regarding resolution

of safety issues. '

In the review of the design for automatic actuation of the ,

'

shunt trip for the reactor trip breakers, the staff noted

that the licensee had a clear understanding of the issue

and that a technically sound approach was used to effect

a timely resolution. In the review of the licensee's

emergency response capability, the staff also noted that

the licensee had technically sound justification to support

all of the sub-issues for their emergency response cap-

ability when there were deviations from the guidance in

Regulatory Guide 1.97. With regards to heavy load

handling, the information provided by the licensee was

concise and technically sound and required no followup

action en the staff's part for clarification or requests

i

for additional information.

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c. Responsiveness to NRC Initiatives

The licensee has been generally responsive to NRC initia-

tives. During.the rating period, the licensee made efforts

to meet the established commitments as illustrated by its

responses to TMI action items and compliance with the rules

related to Fire Protection and Environmental Qualification

of safety-related electrical equipment. In several subject

areas the licensee responded well to concerns raised by the

staff. The requested information was provided in a timely

manner and considered to be thorough. On the other hand,

in other subject areas, the staff witnessed a lack of

timeliness to respond to the staff's concerns, or a large

number of requests for additional information to resolve

a concern.

d. Reporting and Analysis of Reportable Events

Event reports filed per 10 CFR 50.72 and 50.73 during

the rating period have been reviewed. Review of these

reports indicates that reporting is generally timely and

forthright.

e. Staffing

As a result of NRR review of the licensee's staffing for

the facility, the staff found that the key positions with

Union Electric and at the site are clearly identified,

and responsibilities are well defined. Union Electric's

licensing staff (including SNUPPS) is competent and

knowledgeable.

During low power and power ascension testing the licensee

elected to change to a four-shift operation, using 12-hour

shifts, to more effectively support the testing. The

staff found that this schedule would increase the parti-

cipation and experience base of each individual during

the startup program, and would also allow for training

and vacation time.

2. Conclusion

The licensee is rated Category 1 in this area. No trend was  !

noted during this assessment period.

3. Board Recommendations

None.

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V. SUPPORTING DATA AND SUMMARIES

A. -Licensee Activities

During this SALP period, the following activities of interest

occurred:

1. June 11, 1984 - Licensee was issued Low Power (five percent)

Operating License No. NPF-25.

2. June 13 through June 20, 1984 - Initial Fuel Loading.

3. October 2,1984 - Initial Criticality.

4. October 18, 1984 - Licensee was issued Full Power Operating

License No. NPF-30.

5. October 19, 1984 - Mode 1 (commenced Power Ascension Testing).

6. December 19, 1984 - Power Ascension Testing completed, unit

turned over to Load Dispatching.

7. March 29 through April 11, 1985 - Scheduled Maintenance Outage.

8. June 5, 1985 - Emergency Preparedness Exercise.

B. Inspection Activities

The inspection program at Callaway during the evaluation period

consisted of routine resident and region based inspections. A

special Augmented Inspection Program (NRC Region III) was performed

during this SALP period (August 29 through November 30,1984).

Violation Data

'

Facility Name: Callaway Unit 1

Docket Number: 50-483

Inspection Report Nos: 83-26 through 83-33

84-01 through 84-51

85001 through 85014

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TABLE 1

INSPECTION ACTIVITY AND ENFORCEMENT

Functional No. of Violations in Each Severity Level

Areas I II III IV V

A. Plant Operations 0 0 1 4 3

B. Radiological Controls 0 0 0 0 0

C. Maintenance 0 0 0 0 0

D. Surveillance 0 0 0 1 0

E. Fire Protection 0 0 0 0 0

F. Emergency Preparedness 0 0 0 0 0

G. Security 0 0 0 3 0

H. Initial Fuel Loading 0 0 0 0 0

I. Construction Completion

Activities 0 0 0 0 0

Ja. Electrical 0 0 0 0 2

b. Instrument and Control

Systems 0 0 0 0 0

K. Preoperational Testing 0 0 0 10 6

L. Startup Testing 0 0 0 0 2

'M. Quality Programs and

Administrative Controls 0 0 0 0 1

N. Licensing Activities 0 0 0 0 0

TOTALS 0 0 1 18 14

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C. Investigations and Allegation Review

Eleven major investigative activities took place.

'

This included:

1. RIII-83-A-0117; Allegations concerning hot functional testing.

Allegation closed on December 15, 1983.

2. RIII-84-A-0015; Five alleged welding deficiencies.

Allegation closed on June 18, 1984.

.

3. RIII-84-A-0022; Alleged use of marijuana and cocaine by document

reviewers in the Daniel International Quality Services Group.

Allegation closed June 18, 1984.

4. RIII-84-A-0047; A11eger heard void when tapping on containment

liner near spray ring (occurred 1.5 years ago).

Allegation closed on June 18, 1984.

5. RIII-84-A-0060; Heat numbers applied to pipe hanger after the

hanger had been erected.

Allegation closed on September 13, 1984.

6. RIII-84-A-0081; Three allegations - spring beneath fuel

building, seepage in auxiliary building, and mud found in

( cooling tower concrete pour.

Allegation closed on October 26, 1984.

7. RIII-84-A-0082; Twenty-four allegations concerning construction

deficiencies.

Allegation Closed on October 26, 1984.

8. RIII-84-A-0138; Forty-eight allegations concerning construction

deficiencies. The technical issue (s) of the allegations were

reviewed and closed on February 5, 1985. Three of the alle-

gations were referred to the Office of Investigation on

October 23, 1984. .

Closure of the three allegations is pending.

9. RIII-84-A-0170; Three allegations - aquipment accepted without

inspection, employment discrimination, and unqualified Quality

Control (QC) Manager.

Allegation closed on Februcry 15, 1985,

10. RIII-85-A-0021; Failure to follow procedures in the certification

l of two Level 3 Quality Control inspectors.

Allegation closed on April 1, 1985.

! 11. RIII-85-A-0105; Unqualified and untrained boilermaker welders

were sent to Callaway, Duane Arnold and Wolf Creek.

'

Allegation closed on August 1, 1985.

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- _ _ _ _ _ _ _ _ _ _ _ _ ___ ._ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _________ ____ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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D. Escalated Enforcement Action

1. Civil Penalty

A civil penalty was issued to the licensee on October 9, 1984

based upon a Severity Level III citation involving a violation

of a Technical Specification Limiting Condition for Operation.

The violation involved operation in Mode 4 with both containment

spray systems inoperable (Personnel Error).

Tbo licensee paid the full $25,000 (twenty-five thousand

dollars) fine on January 18, 1985. Final Enforcement Actions

took place on February 5, 1985. This case is considered

closed.

2. Orders

No orders were issued.

E. Management Conferences Held During Appraisal Period

1. Management meeting held June 13, 1984 to discuss the licensee's

role as the Callaway Plant begins operation, and to discuss the

NRC's Regulatory Activities for an operating plant.

2. Management meeting held July 7, 1984 at NRC HQS, to discuss a

full power license for the Callaway Plant (Commission briefing).

3. Enforcement Conference August 20, 1984, regarding the imposition

of a Civil Penalty of $25,000 for a personnel error caused

Technical Specification violation.

4. Confirmatory Action Letter July 6,1984 regarding actions to

be taken to address a potential tampering incident.

F. Review of Licensee Event Reports, Construction Deficiency Reports

and 10 CFR 21 Reports Submitted by the Licensee

1. Licensee Event Reports (LERs)

The licensee issued 24 LERs during 1985. Fifty LERs, security

events excluded, were issued during 1984 from the date the

Callaway plant received its low power license (June 11, 1984)

until the end of calendar year 1984. Because the Callaway plant

was under construction in 1983 and was not required to submit

LERs during that phase, there were~no LERs issued during 1983.

The following observations were noted for LERs issued during

1984 and 1985:

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j a. The information in the narrative sections was generally

sufficient to provide the reader with a good understanding

of the event.

I

l b. There were no significant problems with the forms provided

l .by the licensee.

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LICENSEE EVENT REPORTS

l SALP 5 PERIOD

June 11 through January 1 through

Proximate Cause* December 31, 1984 May 1, 1985

Personnel Error 18 7

Design 1

Defective Procedures 6 1

Equipment Failure 25 15

1

Other 1

Total

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50 24

• Cause-assigned by the licensee.

2. Construction Deficiency Reports (CDRs: 50.55(e)s)

Sixteen CDRs were submitted by the licensee under the

requirements of 10 CFR 50.55(e). Two were retracted.

3. Part 21 Reports

i Seven 10 CFR 21 reports were submitted by the licensee during

this assessment period.

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G. NRR Supporting Data and Summary

1. NRR/ Licensee Meetings

May 22, 1985, SNUPPS SPDS

March 18, 1985, Reload for Cycle 2

August 22, 1984, SNUPPS Safe Shutdown Analysis

August 15, 1984, SNUPPS Safe Shutdown Analysis

August 14, 1984, SNUPPS Safe Shutdown Analysis

t August 10, 1984, SNUPPS Safe Shutdown Analysis

July 13, 1984, SNUPPS DCRDR

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May 9,1984, Prelicensing Meeting

April 27,1984, Containment Integrity Technical Specifications

March 15, 1984, Containment Mini-Purge

February 17, 1984, Slave Relay Testing

February 16, 1984, QA Program

February 15, 1984, QA Program

January 25, 1984, Preservice Inspection Program

2. NRR Site Visits

May 9, 1984 - Members of the staff toured several plant areas

including the control room simulator, post-

accident sampling system, radwaste system, and

auxiliary feedwater system.

3. Commission Briefings

October 4,1984, Full Power Amendment

4. Schedular Extensions Granted

See license amendment e and f below.

5. Reliefs Granted

None.

6. Exemptions Granted

October 5,1984 - A partial exemptfor of Appendix J to

10 CFR 50 was granted to allow for reiuced pressure testing

of containment air locks when containtent integrity is not

required by the technical specifications.

7. License Amendments Issued

a. A change to allow for blockage of both source range

flux doubling switchover signals in order to perform

a reactor startup,

b. A change to allow for the addition of two 100,000

gallon tanks in order to provide sufficient storage

time for secondary effluent to allow sample analysis

and to show acceptability of the water prior to release

to the environment.

c.- A change to allow for the addition of two managerial

positions to the plant organization and to allow for

the addition of another member to the onsite review

committee.

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d. A change to provide compensatory actions when two source

range monitor channels are out of service,

~

e. A change to the deadline for the environmental qualifi-

cation of electrical equipment important to safety from

March 31, 1985 to November 30, 1985.

f. A change to delay the first three containment tendon

surveillances by.six months in order to allow the con-

tractor to assist another plant where tendon anchor head

failures were discovered,

g. A change to reduce the level of detail on the offsite

organizational chart and to more accurately represent

the operational chain of command on the unit organiza-

tional chart.

8. Emergency Technical Specifications Issued

None.

9. Orders Issued

None.

10. NRR/ Licensee Management Conferences

None.

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