ML20137E815
ML20137E815 | |
Person / Time | |
---|---|
Site: | Callaway |
Issue date: | 08/21/1985 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
To: | |
Shared Package | |
ML20137E809 | List: |
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
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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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
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
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practices, which resulted in improved housekeeping practices
and conditions.
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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.
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
'
i
- _ _ .._- ___ _ _ _ . _ _ . - _ _ _ _ _ _ _ _ _ - _ _ - - _ _ . - _ . _ _ _ . _ _ - _ . _ _ _ _ - -.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
_. _ _ - - . - . _- _ _ .-
'
.
-
.
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
'
.
-
.
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
-_. _
~
.
-
<
.
. 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 -
_
,
'
.
-
.
(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
_
.
-
.
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
-. .-. , -. . - . . _ - ___
'
.
-
.
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
!
l
30
!
'
.
-
.
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
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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
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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.
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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.
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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.
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Allegation closed on August 1, 1985.
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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.
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l b. There were no significant problems with the forms provided
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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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- 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,
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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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