ML20204G823

Forwards Govt Accountability Project 840928 Request,On Behalf of Citizens Concerned About Callaway,That Commission Suspend Low Power License Pending Investigation of Allegations.W/O Ltr.Draft Ack Ltr W/Fr Notice Encl

ML20204G823
Person / Time
Site:	Callaway
Issue date:	10/12/1984
From:	Lieberman J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20204G736	List: ML20204G732 ML20204G823 ML20206P139 ML20206P196 ML20206P254 ML20206P277
References
FOIA-84-901 2.206, NUDOCS 8410290244
Download: ML20204G823 (28)

Text

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g, UNITED STATES NUCLEAR REGULATORY COMMISSION D ;j WASHING TON, D. C. 20555

.....f October 12, 1984 PEMORANDUM FOR: Harold R. Denton, Director Office of Nuclear Reactor Regulation FROM: James Lieberman, Director '

and Chief Counsel Regional Operations and Enforcement Division Office of the Executive Legal Director

SUBJECT:

10 CFR 2.206 REQUEST REGARDING CALLAWAY UNIT 1 Enclosed for your action is a letter dated September 28, 1984, which was filed by the Government Accountability Project on behalf of the Citizens Concerned About Callaway and others. The letter requests that the Comission suspend the low-power license for Callaway Unit 1 pending an investigation of the allegations stated in the letter and the performance of any appropriate reinspections to determine the extent of problems raised by the allegations. The Comission has referred the letter to the staff for appropriate action in accordance with 10 CFR 2,206. Although the issues raised in the petition could be handled a'ppropriately by IE, I suggest that l NRR take the lead on this petition in view of the near-term full power licensing of the Callaway plant.

It is my understanding that your staff and Region III have already reviewed l

the petition and have determined that imediate action to suspend the low-power license or to refuse the granting of a full-power license is not warranted. I also understand the petition was briefly discussed at last Thursday's Comission meeting on the full-power license for Callaway Unit 1.

Accordingly, we have drafted for your use an acknowledgement letter with a j Federal Register notice, to the petitioners indicating that their request ,

for immediate relief has been denied. Further information describing the i basis for this interim denial should be inserted by your staff or Region III as appropriate.

I You should also note that the acknowledgement letter asks the petitioners to come forward with the affidavits from which the allegations in the letter are said to derive. We discussed the approaches to obtaining the affidavits with Darrell Eisenhut, Bert Davis and other members of the Region III staff ,

[ and agreed initially to seek the affidavits informally through the acknow-  !

l ledgement letter and a meeting with GAP, but to leave open the possibility f

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of issuing a subpoena if GAP will not promptly submit the affidavits. We are assisting Region III in developing a memo to obtain subpoena approval from the Commission in the event that the " informal" method does not work.

We will assist your staff in developing a final response to the petition.

If you need further information from the licensee in taking final action, we can assist your staff in drafting an appropriate request to the licensee for such information under 10 CFR 50.54(f). Please ensure that I am provided copies of all correspondence related to the petition and that I am asked to concur on all staff correspondence.

James Lieberman, Director and Chief Counsel Regional Operations and Enforcement Division Office of the Executive Legal Director Encicsures: (1) Petition (2) Draft Letter and Notice cc: R. DeYoung, IE J. Keppler, RIII D. Eisenhut, NRR J. Holonich, NRR E. Christenbury, OELD Distribution B. Berson, RIII R. Perlis, OELD J. Axelrad, IE '

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Docket No. STN 50-483 (10CFR2.206)

I Louis Clark, Executive Director i Government Accountability Project 1555 Connecticut Avenue, N.W.

Suite 202 Washington, D.C. 20036

Dear Mr. Clark:

On September 28, 1984, Ms. Varricchio and Ms. Garde of the Government Accountability Project submitted a letter on behalf of the Concerned l

Citizens About Callaway which requested "immediate action" by the Com-mission to suspend the low-power operating license for Callaway Unit 1.

In accordance with the Commission's usual practice, the request was referred to the staff for appropriate action pursuant to 10 CFR 2.206.

The letter requested suspension of the low-power license pending an investigation of the allegations in the letter and the completion of any necessary reinspections to determine the scope of identified problems. As l a basis for this action, the letter points to, among other things, various alleged construction deficiencies related to welding, electrical cabling, and concrete placement, poor construction drawing, undue pressure on quality l control inspectors and drug and alcohol abuse at the site. The NRC received the letter only a few days before the Commission's scheduled meeting on authorization of a full-power license for Callaway Unit 1. In preparing for that meeting, the staff reviewed the information contained in the letter, and the staff informed the Conmission that the matter raised by the letter l

j did not warrant immediate action by the Commission to suspend the low-power I l

license or stay issuance of a full-power license. ]I

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[NRR/ Region III: Add other information regarding our position on immediate action; e.g., have we been aware of such allegations and taken appropriate action already].

I would also note with respect to the request that quality assurance including the adequacy of welding and concrete placement was a primary issue in the operating license proceeding for Callaway Unit 1. Both the Licensing Board and the Appeal Board concluded from the evidence on the record that there was no general breakdown in quality assurance procedures and that there was reasonable assurance that the Callaway plant could be operated safely. See LBP-82-109, 16 NRC 1826 (1982), aff'd, ALAB-740, 18 NRC 343 (1983). .

s Although no immediate action is warranted, the staff will continue to review the request and reach a final determination on it within a reasonable time in accordance with 10 CFR 2.206. In that regard, the letter states that the allegations forming the basis for the request have been compiled from affidavits of former plant workers; however, these affidavits were not included with the letter to the Commission. I ask that you would provide me or NRC Region III with the affidavits. As I am sure you will agree, it is difficult for the staff to adequately assess the need for further action in the absence of the information which forms the basis for the request.

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The NRC Region III staff has made several attempts to obtain the affidavits from Ms. Garde and Ms. Varicchio of your staff. Despite their efforts, and Mr. Keppler's letter to Ms. Garde of September 27, 1984, your staff has not as yet provided us with the affidavits. The staff is prepared to meet with you, to protect where possible the identity of the allegers ', and to meet with the allegers to obtain factual information concerning the allegations. I suggest that I and other senior NRC staff officials meet with you in the next week to discuss prompt submission of the affidavits to the NRC. I will contact you regarding such a meeting.

A copy of a notice is being filed with the Office of the Federal Register for publication is enclosed for your information.

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

as stated  ;

cc: Union Electric Co.

Missouri Public Service Commission B. Garde

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NUCLEAR REGULATORY COMMISSION

[ Docket No. STN 50-483]

UNION ELECTRIC C0.

(Callaway Plant, Unit 1)

Request for Action Under 10 CFR 2.206 Notice is hereby given that the letter dated September 28 1984, the Govern-ment Accountability Project, on behalf of Concerned Citizens About Callaway and others, has requested that the Commission suspend the low-power license for Callaway Unit 1 pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problems identified during the investigation. The allegations concern chiefly improper constructidn practices and other improper conduct by plant workers such as a drug or alcohol abuse on the site. The letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff will take appropriate action on the request within a' reasonable time.

A copy of the petitioner's letter is available for public inspection in the Connission's public document room at 1717 H Street, N.W. , Washington, D.C.

20555 and in the local public document room at .

Dated in Bethesda, Maryland, this day of October 1984.

FOR THE NUCLEAR REGULATORY COMMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation

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6 Harold Denton, Director October 17, 198{

Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re -' Callaway Nuclear Power Plant, Unit 1 Authorized by NRC Operating License No. NFP-25

Dear Mr. Denton:

It is our understanding that on October 16, 1984 the NRC - '

Regional Administrator for Region III made a final recommendation to your office that the Callaway Nuclear Power Plant be granted ,

its full power operating license. This recommendation was made aft'er his insufficient consideration of the 2.206 petition filed by GAP on October 2, 1984 which contained 48 safsty related and cost overrun allegations. Mr. Keppler has evidentally concluded from the allegations as generally stated in the petition that there was nothing which would preclude the full operation of the Callaway Nuclear Power Plant. This conclusion was based on the petition alone and not on other available substantiating evidence.

This hasty action on the part of the Regional Administrator clearly reflects an indifferent attitude towards the concerns of those workers who have made allegations of safety significance.

In addition, this action falls far short of a good faith effort to execute an effective quality assurance program within the NRC.

If and when the full power operating license for the Callaway Nuclear Power Plant is granted, please give us 14 days notice to consider and pursue our other legal remedies.

Sincerely,

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Billie P. Garde Citizens Clinic Director l Michele varricchio Staff Associate hN(k 4 k O Ok AM ls EDO 000060 /

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DUE: 11/08/84 EDO CONTROL: 000060 FROM: DOC DT: 10/17/84 FINAL REPLY:

DILLIE P. GARDE MICHELE VARRICCHIO, OAP TO:

DENTON

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FOR SIGNATURE OF: en DENTON ROUTING:

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DIRCKS CALLAWAY PLANT FULL POWER OPERATING LICENSE ROE REHM ASSIGNED TO: NRR DATE: 10/23/84 STELLO CONTACT: DENTON GEP_RLER DEYOUNG SPECIAL INSTRUCTIONS OR REMARKS: GCLNNINGHAM

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s Docket No. 50-483 License No. NPF-25 EA 84-97 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:

This refers to a routine safety inspection conducted by Mr. P. R. Pelke of this office during the period of July 30 through August 3 and August 13 through 17, 1984, of activities authorized by NRC Operating License No. NPF-25 at the Callaway Plant, Unit 1. The results of the inspection were discussed on August 20, 1984, during an enforcement conference held in the NRC Region III office between you and other members of your staff and myself and other members of the NRC Region III staff. During this inspection, the NRC reviewed the circumstances associated with a violation of a technical specification limiting condition for operation.

From August 10 to August 14, 1984, the Callaway Plant operated in Mode 4 with both Containment Spray Systems inoperable in violation of the technical specifications. It is recognized that your staff identified and promptly reported this violation to the NRC. Although the safety significance of the violation is less than it would have been had it occurred at power operation after the plant had achieved initial criticality, I am concerned about your operating the facility in violation of a Technical Specification Limiting Condition for Operation. To emphasize the importance the NRC places on:

(1) conducting licensed activities in accordance with established procedures, (2) providing adequate attention to detail to minimize personnel errors, and (3) being cognizant of abnormal conditions that may exist during facility operations, we propose to impose a civil penalty for the violation identified in Item I as set forth in the Notice of Violation and Proposed Imposition of Civil Penalty enclosed with this letter.

This violation, as well as the other violations described in the enclosed Notice, have been categorized at severity levels in accordance with the NRC ,

Enforcement Policy, 10 CFR Part 2, Appendix C, as revised, 49 FR 8583 -

(March 8, 1984). The base civil penalty amount for a Severity' Level III .

violation of this type is $50,000. However, since the violation (1) was  !

identified by your staff and promptly reported, (2) corrective actions were '

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Union Electric Company 2 GCT101984 prompt and extensive, and (3) your administrative control systems provided an opportunity for discovery prior to initial criticality, I am decreasing the amount of the civil penalty by 50L' After consultation with the Director of the Office of Inspection and Enforcement, I have been authorized to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $25,000.

You are required to respond in writing to the Notice attached to this letter.

" In preparing your response, you should follow the instructions specified in the Notice. Your response should specifically address corrective actions you have taken or plan to take to improve the management effectiveness for ensuring that technical specification requirements are met and abnormal facility conditions are identified. Your written reply to this letter and the results of future inspections will be considered in determining whether further enforcement action is appropriate.

With respect to Item II.B as set forth in the Notice of Violation, the inspection showed that action had been taken to correct the identified violation and to prevent recurrence. Consequently, no reply to this violation is required and we have no further questions regarding this matter at this time.

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosure will be placed in the NRC Public Document Room.

The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

Sincerely, .

James 'G. Kep er Regional Administrator

Enclosure:

Notice of Violation and Proposed Imposition of Civil Penalty cc w/ enc 1:

W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager ,

R. L. Powers, Assistant Manager QA l K. Drey l Chris R. Rogers, P.E. l Utility Division, Missouri l Public Service Commission '

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY ,

Union Electric Company Docket No. 50-483 Callaway Plant License No. NPF-25 Unit 1 EA 84-97 During a routine inspection at the Callaway Plant site during the period of July 30 through August 3 and August 13 through 17, 1984, the NRC reviewed the i circumstances associated with a violation of a technical specification limiting condition for operation. The violation involved operation in Mode 4 with both Containment Spray Systems inoperable. This violation was identified and promptly reported to the NRC by the licensee.

To emphasize the importance the NRC places on: (1) conducting licensed l activities in accordance with established procedures, (2) providing adequate attention to detail to minimize personnel errors, and (3) being cognizant of

! abnormal conditions that may exist during facility operations, the Nuclear Regulatory Commission proposes to impose a civil penalty in the amount of Twenty-five Thousand Dollars ($25,000) for this matter. This penalty reflects a reduction of 50% from the base penalty of $50,000 for a Severity Level III violation in recognition of the licensee's prompt reporting and extensive corrective actions. In accordance with the NRC Enforces,ent Policy, 10 CFR i

Part 2, Appendix C, as revised, 49 FR 8583 (March 8, 1984) and pursuant to Section 234 of the Atomic Energy Act of 1954, as amended ("Act"), 42 U.S.C.

2282, PL 96-295 and 10 CFR 2.205, the particular violation and the associated civil penalty is set forth in Section I below:

I. Civil Penalty Violation Technical Specification 3.6.2.1 states, "Two independent Cont'ainment Spray Systems shall be OPERABLE with each Containment Spray System capable of taking suction from the RWST and transferring suction to the containment sump." This requirement is applicable for operational Modes 1, 2, 3, and 4.

Technical Specification 3.0.3 states, "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION i requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ACTION shall be initiated to place the unit in a MODE in which the specification does not apply by placing it, as applicable, in:

a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, 1

j b. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

c. At least COLD SHUTOOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. l Aw

F 00T 1 ; sa4 Notice of Violation 2 Contra,ry to the above, at 6:30 a.m.(CDT) on August 10, 1984, the licensee entered operational Mode 4 (hot shutdown) with Containment Spray manual isolation valves EN-V014 and EN-V018 closed and, therefore, with both Containment Spray Systems inoperable. The plant remained in Mode 4 with both valves closed until the closed valves were subsequently identified by the licensee and opened at 10:50 a.m.(CDT) on August 14, 1984.

This is a Severity Level III violation (Supplement I).

(Civil Penalty - $25,000)

II. Violations Not Assessed A Civil Penalty A. 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected..."

The Callaway Plant FSAR, Section 17.2.16, states in part, " Measures shall be established to assure that conditions adverse to quality are promptly identified, reported, and corrected..."

Contrary to the above, adequate measures were not established to assure that conditions adverse to quality were promptly identified and corrected in that a deficient Bechtel design drawing resulted in a card associated with bistable 456B being installed incorrectly.

Although this condition existed since November 1983, it was not detected during preoperational testing and the licensee did not become aware of it until this condition caused an inadvertent safety injection which occurred on August 13, 1984 when bistable 456B was tripped during a loop calibration surveillance procedure,. Additionally, the trip status of 456B was unknown because the indicator light for it on the Partial Trip Status Panel located in the Control Room was burned out. Work Request No. 30748 to relamp the Partial Trip Status Panel was authorized on July 28, 1984, with a requested completion date of August 1,1984, although the work was not accomplished until August 13, 1984, after the inadvertent safety injection occurred.

This is a Severity Level IV violation (Supplement I).

B. 10 CFR Part 50, Appendix B, Criterion V, states in part, " Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings."

Contrary to the above:

. 1. On August 3, 1984, during the removal of the No. I seal for Reactor Coolant Pump "C", Steps 5.8.4 and 5.8.5 of Procedure MPM-BB-QP001 were not accomplished. The seal was removed by

n Notice of Violation 3 IW s hand rather than by tiie required extension tray mounted to the articulated arm. .

2. Work Request No. 31368, dated August 12, 1984, was written to repair the drive mechanism for the exterior door to the containment personnel air lock. Block (009) of the Work Request incorrectly stated that outage of this equipment would not affect a Limiting Condition for Operation (LCO). Procedure APA-ZZ-00320, Revision 3, " Initiating and Processing Work Requests," states, "The approval authority should check the appropriate box if this component could causte an LCO, whether or not the specific work request requires that the component be OSS (Out of Service)." With the exterior door out of service, the plant was subject to the action statement of the LCO in Technical Specification 3.6.1.3.

3. Procedure ODP-ZZ-00002, Revision 1, " Equipment Status Control,"

states in part, "When a... component, or device which is safety-related or is otherwise required to be operable to satisfy technical specifications...is determined to be out of service the shift supervisor shall initiate Attachment 1, Equipment Out of Service Log Sheet...." While the exterior door to the containment personnel air lock was inoperable during repairs on August 13, 1984, the shift supervisor did not make an entry in the Equipment Out of Service log to indicate the door was inoperable.

This is a Severity Level IV violation (Supplement I).

I The inspection showed that action has been taken to corr,ect the items of noncompliance identified in II.B. and to prevent recurrence.

Consequently, no reply to these items of noncompliance is required and we have no further questions regarding this item.

Pursuant to the provisions of 10 CFR 2.201, Union Electric Company is hereby required to submit to the Director, Office of Inspection and Enforcement, ,

U. S. Nuclear Regulatory Commission, Washington, D.C., 20555, with a copy to the i Regional Administrator, U. S. Nuclear Regulatory Commission, Region III,  !

799 Roosevelt Road, Glen Ellyn, IL 60137, within 30 days of the date of this Notice a written statement or explanation, including for each alleged violation except II.B: (1) admission or denial of the alleged violation; (2) the reasons for the violation, if admitted; (3) the corrective steps which have been taken and the results achieved; (4) the corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Consideration may be given to extending the response time for good cause shown.

Under the authority of Section 182 of the Act, 42 U.S.C. 2232, this response

, shall be submitted under oath or affirmation.

E

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I Notice of Violation 4 II D Within the same time as provided for the response required above under 10 CFR 2.201, Unio'n Electric Company may pay the civil penalty in the amo.unt of

$25,000 or may protest imposition of the civil penalty, in whole or in part, by a written answer. Should Union Electric Company fail to answer within the

time specified, the Director, Office of Inspection and Enforcement, will issue l an order imposing the civil penalty proposed above. Should Union Electric I Company elect to file an answer in accordance with 10 CFR 2.205 protesting the l civil penalty such answer may: (1) deny the violation listed in this Notice in whole or in part; (2) demonstrate extenuating circumstances; (3) show error 2

in this Notice; or (4) show other reasons why the penalty sbauld not be imposed.

In addition to protesting the civil penalty in whole or in part, such answer may request remission or mitigation of the penalty. In requesting mitigation of the proposed penalty, the five factors contained in Section V(B) of 10 CFR Part 2, Appendix C should be addressed. Any written answer in accordance

! with 10 CFR 2.205 should be set forth separately from the statement or explana-tion in reply pursuant to 10 CFR 2.201, but may incorporate statements or i explanations by specific reference (e.g., giving page and paragraph numbers) to avoid repetition. The Union Electric Company's attention is directed to the j other provisions of 10 CFR 2.205, regarding the procedures for imposing a

civil penalty.

j Upon failure to pay any civil penalty due, which has been subsequently determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attorney General, and the penalty, unless compromised,

remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282.

i i FOR THE NUCLEAR REGULATORY COMISSION

! James G. Keppler a Regional Administrator Dated t Glen Ellyn, Illinois this/c g of October 1984 j

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Docket No. 50-483 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:

This refers to the routine safety inspection conducted'during the period July 30 through August 3 and August 13 through 17, 1984, of activities at the Callaway Plant, Unit 1, authorized by NRC Operating License No. NPF-25. The results of the inspection were discussed during an enforcement conference conducted in the NRC Region III office on August 20, 1984. The report setting forth the results of the inspection and enforcement conference is enclosed.

In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter. Such application must be consistent with the requirements of 2.790(b)(1). If we do not hear from you in this regard within the specified periods noted above, a copy of this letter and the enclosed inspection report will be placed in the Public Document Room.

A separate letter is enclosed that sets forth certain matters of concern and the item of noncompliance found during this inspection. The responses directed by this letter are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

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Union Electric Company 2 00TIsis, We will gla,dly discuss any questions you have concerning this inspection.

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Sincerely, tt James G. Kep ler Regional Administrator

Enclosure:

Inspection Report No. 50-483/84-36(DRP) cc w/ enc 1: >

W. H. Weber, Manager, Nuclear Construction i

S. E. Miltenberger, Plant Manager R. L. Powers, Assistant Manager Quality Assurance DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII Region IV K. Drey Chris R. Rogers, P.E.

Utility Division, Missouri Public Service Commission SNUPPS i

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O U. S. NUCLEAR REGULATORY COMMISSION REGION III s

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

Docket No. 50-483 License No. NPF-25 Licensee: Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Callaway Co., M0 Inspection Conducted: July 30 - August 3 and August 13 - 17, 1984 Enforcement Confer ce: August 20, 1984 0 .

ifilea Inspector: ). R. Pelke /

Date RFU) M k CV Approved By: W. L. Forney, Chief /0-/9-84/

Projects Section 1A Date Inspection Summary Inspection on July 30 - August 3 and August 13 - 17, 1984 (Report No.

50-483/84-36(DRP))

• Areas Inspected: Routine, unannounced safety inspection of an event in which both Containment Spray Systems were inoperable while the plant was in operational Mode 4, review of an inadvertent safety injection on August 13, 1984, observation of Reactor Coolant Pump "C" seal removal, review of containment personnel air lock repair activities, verification of Technical Specification requirements, and review of licensee event reports. This inspection involved a total of 67 inspector-hours onsite by one inspector.

Results: Of the six areas inspected, no items of noncompliance or deviations were identifierf in two areas, three items of noncompliance were identified in the remaining areas (failure to have two independent Containment Spray Systems operable during Mode 4 - Paragraph 2; failure to take timely corrective actions - Paragraph 4; and failure to follow procedures - Paragraphs 5 and 6).

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DETAILS

1. Persons Contacted

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Union Electric Company .

• • D. F. Schnell, Vice President - Nuclear

• • S. E. Miltenberger, Manager, Callaway Plant "D. C. Poole, Advisor to Manager, Callaway

• • R. L. Powers, Assistant Manager, QA

• A. C. Passwater, Superintendent, Licensing G. A. Patrissi, Fire Protection Consultant C. H. Fuhlage, Assistant Engineer, Compliance B. Dampf, Acting Assistant Safety Supervisor

• • S. Petzel, QA Engineer

• • R. H. Leuther, Superintendent, Maintenance /

• • J. D. Blosser, Assistant Superintendent, Maintenance

• • J. W. Knaup, Assistant Engineer

• • C. D. Naslund, Superintendent, I&C

• • W. A. Norton, QA Engineer

• • J. T. Patterson, Assistant Superintendent, Operations

• T. A. Baxter, Shaw, Pittman, Potts - Trowbridge Burns B. L. Scott, Site Security Supervisor USNRC

• • James G. Keppler, Regional Administrator

• A. B. Davis, Deputy Regional Administrator

• J. A. Hind, Director, DRSS

• • R. F. Warnick, Chief, Projects Branch 1

• W. F. Forney, Chief, Projects Section 1A

• J. R. Creed, Chief, Safeguards Section

• G. L. Pirtle, Physical Protection Specialist j

• • B. Berson, Regional Counsel -

• D. S. Morisseau, Training and Assessment Specialist, NRR  !

• J. Holonich, Project Manager, NRR l

• Denotes those attending the management meeting on August 8, 1984.

• • Denotes those attending the exit interview on August 17, 1984.

• Denotes those attending the enforcement conference on August 20, 1984.

The inspector also contacted other licensee and contractor personnel l during the inspection.  !

2. Isolation of Both Trains of the Containment Spray System On August 14, 1984, at 2:43 p.m.(CDT), the NRC was notified by the

. licensee that both Containment Spray Systems were manually isolated during operational Mode 4. A chronology of events follows:

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May 7, 1984

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Containment Spray manual isolation valves EN-V014 and EN-V018 were_ closed, locked and tagged on Workmans Protection. Assurance (WPA) s Form 84-3252 to prevent inadvertent discharge into containment. A Senior Reactor Operator failed-to. enter the valves in the Equipment Out-of-Service. Log per ODP-ZZ-00002.

May 9, 1984 A Senior Reactor Operator completed the Contain-ment Spray Valve Lineup Procedure OTN-EN-00001 with exceptions annotated for valves EN-V014 and EN-V018 (WPA 84-3252) and valve EN-V097 (WPA 84-3014). All three valves were in the closed position. The Senior Reactor Operator failed to enter the three valves in the Equipment Out-of-Service Log as required by Standing Order 84-24. '

August 3, 1984 A Senior Reactor Operator performed a review of the Workman's Protection Assurance log in preparation for entering Mode 4 as required by ODP-ZZ-00014.

i This review identified containment spray additive tank valve EN-V097 as being closed per WPA 84-3014, which was subsequently released and restored to normal operational lineup and appropriately noted on the valve lineup procedure OTN-EN-00001c The Senior Reactor Operator failed to identify valves EN-V014 and EN-V018 on WPA 84-3252 which were required for Mode 4.

i August 5, 1984 A Senior Reactor Operator reviewed the WPA log i

prior to starting plant heatup. This did not include a review of.the WPA's-for Mode 4 but only for those required to be cleared pri,or to heating up the plant to 170'F.

August 5, 1984 A Senior Reactor Operator, while reviewing the status of system lineups for OTG-ZZ-00001, 4

Attachment 1,-initially approved the operational condition of the Containment Spray System as required by Step 3.22 of OTG-ZZ-00001. However, after discussion with another Senior Reactor Operator, he decided that due to outstanding WPA's he would withdraw his approval. -This was shown as a line out on OTG-ZZ-00001, Step 3.22.

4 August 6, 1984 The Operations Supervisor verified that WPA 84-3085-i had been cleared and documented this verification on OTN-EN-00001, Checklist 3.

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l August 7, 1984 A' Senior Reactor Operator reviewed OTG-ZZ-00001, Step 3.22 and OTN-EN-00001 checklists. Based i upon properly executed checklists and the verifi-cation of the WPA that was done on August 6, 1984, he signed off that step. .

August 8, 1984 Two Senior Reactor Operators executed a Temporary Change (TCN) to ODP-ZZ-00014 which, in part, e deleted the sign-off requirement for the review

! of the Equipment Out-of-Service Log, the WPA Log review, and the Temporary Modifications Log l review. .The intent was to take credit for '

other sign-offs in the OTG procedures. Th'e  :

. TCN was performed in such a manner that it negated the requirement to perform a separate review prior to making the mode change. Technical Specification 6.5.3.1.a requires that for changes to procedures which may involve a change ,

in intent of the approved procedure, the person authorized to approve the procedure shall approve the change prior to implementation. The use of the TCN to ODP-ZZ-00014 circumvented the review by the required authority.

August 10, 1984 A Senior Reactor Operator completed Attachment 54 of ODP-ZZ-00014, Operational Mode Change Require-ments, and approved changing modes. At 6:30 a.m.

on August 10, 1984, the plant entered Mode 4.

August 14, 1984 A Reactor Operator found WPA sheet 84-3252 showing valves EN-V014 and EN-V018 closed while  !

looking for another WPA. The valves were subse-quently opened, locked open, and independently i verified.

Failure to have two independent Containment Spray Systems operable during Mode 4 is a violation of Technical Specification LCO 3.6.2.1 (483/84-36-01).

l On August 14, 1984, the Plant Manager.immediately initiated a review of i i

the WPA log, Equipment Out-of-Service Log, valve lineups, and outstanding l i Temporary Modifications. Valve lineups were re-verified for the Residual Heat Removal, Safety Injection, Centrifugal Charging Pump, Containment Spray and Auxiliary Feedwater Systems. This review was completed on l August 15, 1984. The licensee identified several causes and took correc--

tive actions to prevent recurrence as follows:

a. Equipment Out-of-Service Log (EOSL) was not' current. The licensee-reviewed the EOSL against the Surveillance Master. Tracking log, outstanding work requests, outstanding Workman's Protection Assurance, and outstanding temporary modifications. This review was completed on August 20, 1984.

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b. Improper application of procedures. Licensee management met with reactor personnel and discussed the necessity for adherence to procedures. This was completed on August 19, 1984.

c. P'ersonnel errors. .

(1) Review of the WPA log did not identify the problem. The licensee reviewed the events with operations personnel and re-emphasized the necessity for accuracy in performance of activities. This was completed on August 22, 1984.

(2) Personnel did not follow Standing Order 84-24. The licensee reinstructed personnel on the requirement for compliance with procedures and orders. This was completed on August 22, 1984.

The applicable portions of Standing Order 84-24 were incorporated into Procedures ODP-ZZ-00002 and APA-ZZ-00310 by August 20, 1984.

This was accomplished by issuing TCNs 84-1013 and 84-1014 which require that when any Technical Specification related equipment is out of service as a result of WPAs, the equipment shall be entered in the Equipment Out-of-Service Log.

(3) Temporary Change 84-945 to Procedure ODP-ZZ-00014 inadvertently removed the requirement for review of WPAs, EOSL, and temporary modifications prior to mode change. Procedure ODP-ZZ-00014 was revised by August 15, 1984 to remove the changes made by TCN 84-945.

The individuals involved were counseled on August 17 and 19, 1984.

The individuals were aware of the limitations on the use of temporary changes. They had not intended for TCN 84-945 to delete the reviews, but only to delete what they believed to be redundant documentation of the reviews. A letter was issued to operations personnel and contractors on August 18, 1984, re-emphasizing the limitations on the use of temporary changes.

Although the closed valves were identified on August 14, 1984, by an operator while looking through the WPA log for another WPA, the licens'ee believes the monthly status survey of WPAs per APA-ZZ-00310 would have detected the closed prior to initial criticality. The monthly survey which was started on August 15, 1984, consists of a review of all outstanding WPAs that have been in effect longer than one month. WPA 84-3252 (showing valves EN-V014 and EN-V018 closed) was issued on May 7, 1984, and would have been included in the review.

3. Enforcem M Lonference An Enforcement Conference was held in the Region III office on August 20, l 1984 as a result of the Callaway Plant being in operational Mode 4 with both Containment Spray Systems inoperable. The purpose of the conference was to (1) discuss the violations, their significance and causes, and the licensee's corrective actions, (2) determine whether there were any aggra-vating or mitigating circumstances, and (3) obtain other information which would help determine the appropriate enforcement action.

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The licensee was informed that the generic concerns raised by the violation needed to be addressed prior to the plant achieving initial criticality.

The licensee was requested to have each shift demonstrate its proficiency in operating the plant at low power before Region III recommends operation above 5 percent power. The licensee agreed to develop a program which will give them and Region III confidence that the operating crews are ready to commence power ascension and operate the plant at full power.

4. I,nadvertent Safety Injection At 12:35 p.m.(CDT), August 13, 1984, while the plant was in Mode 4 (hot shutdown), an I&C technician performing a technical specification instru-ment calibration for Mode 3 inadvertently initiated a safety injection.

Approximately 1200 gallons of water from the RWST were injected into the primary system via the Boron Injection Tank. The primary system was not solid at the time and the safety injection was terminated by an operator after two minutes. The licensee declared an Unusual Event at 12:37 p.m.

and terminated the Unusual Event at 1:12 p.m. All systems functioned as designed. The licensee held a press conference at 4:30 p.m. to brief the news media on the event.

The I&C technician was performing loop calibration surveillance procedure ISL-BB-0P455 when the event occurred. The procedure required the trip of bistable 455B. Bistable 456B was also tripped due to an incorrect installa-tion per a Bechtel design drawing. The trip status of 456B was unknown because the indicator light for this bistable was burned out on the Partial Trip Status Panel (58069) located in the control room. Both channels in the tripped condition made up the required logic for permissive P-11 (2 out of 3). P-11 arms the logic for safety injection on low pressurizer pressure. Since a low pressure condition actually- existed in the plant, a safety injection was initiated.

The inspector identified the following items that contributed to the inadvertent safety injection:

a. The Bechtel design drawing, which was deficient, allowed the card associated with bistable 456B to be installed incorrectly. This i nonconforming conilition existed since November 1983 and was not i detected during preoperational testing. '

b. Procedure ISL-BB-0P455 required that Loops BB-0P456, BB-0P457, and I BB-0P458 must be operable (not in test) as an initial condition to prevent an inadvertent rafety injection. The procedure limited the definition of operable by the phrase "(not in test)" and made no reference to the Partial Trip Status Panel. The licensee is revising Procedure ISL-BB-0P455 and associated procedures. This will remain an open item pending the inspector's review of the revised procedures 1

(483/84-36-02).

c. The I&C technician relied on the indication of the Partial Trip Status Panel without consideration of a work request sticker attached to the panel. ,

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!' d. The Shift Supervisor authorized the surveillance activity without reliable indication of the partial trip status.

e. Work Request No. 30748 to relamp the Partial Trip Status Panel w'as authorized on July 28, 1984, with a requested. completion date I of August 1, 1984. The work was not accomplished until August 12, i 1984, after the safety injection.

i Failure to promptly identify and correct nonconforming conditions, as

, described in paragraphs (a) and (e), is an item of noncompliance with

. 10 CFR 50, Appendix B, Criterion XVI (483/84-36-03).

5. Observation of Reactor Coolant Pump "C" Seal Removal On August 3,1984, the inspector observed the removal of the No.1 seal for RCP "C". The current revision of Procedure MPM-BB-QP001 was being used at the work area. Documentation indicated that required QC hold-points had been witnessed by the QC inspector. During the removal of

. the seal runner, it was. discovered that the extension tray (A-11) was not mounted to the articulated arm assembly. The articulated arm assembly is used to swing the seal runner from the motor stand to the area outside for further removal. The Maintenance Foreman stopped the crew and told them to wait until the extension tray was found and installed. The extension tray could not be located at.the work area.

i A discussion took place between the Westinghouse Pump Representative and the Maintenance Advisor. As a result of the discussion, the Main-

. tenance Advisor directed the Maintenance Foreman to have the seal runner removed from the pump area by hand.

Subsequent review of the controlling procedure by the inspector after leaving the work area, revealed that Steps 5.8.4 and 5.8.5 required the runner to be removed by the extension tray mounted on the articulated arm. The Westinghouse Representative and the Maintenance Advisor did not realize at the time that use of the extension tray was a procedural require-ment. Although the Maintenance Foreman had been following the procedural steps and was aware of the requirement to use the extension tray, he did not recognize that removing the seal runner by hand constituted a proce-dural violation because he felt that the action met the intent of the procedure. Removing the runner by hand is not significant from a safety standpoint (no damage occurred). However, violation of a procedural step which was possibly influenced by a vendor representative is a concern.

Failure to follow procedures is an example of noncompliance with

, 10 CFR 50, Appendix B, Criterion V (483/84-36-04(a)).

The licensee provided the inspector with written results of its investiga-  !

tion into this incident, including corrective action and actions taken to j prevent recurrence. The Maintenance Advisor and Maintenance Foreman have  :

been verbally reprimanded for failure to assure verbatim procedure compli - )

ance. A meeting was held with QA, QC, the System Engineer, the Maintenance Foreman, the Maintenance Advisor and the Maintenance Superintendent to ,

discuss the incident and identify the cause. During this meeting the necessity to adhere to procedure requirements was reemphasized to all I 7 j

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supervision and staff personnel involved with the activity. Additional

, training is scheduled for all Maintenance Foremen on procedure requirements.

A post-job review of the procedure for seal replacement is scheduled and the procedure will be revised based on the experience learned during the .

job. ' .

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6. Containment Personnel Air Lock Repair Activities During a plant tour on August 14, the inspector learned from an employee that the drive mechanism for the exterior door to the containment personnel air lock (door 1507A) had been repaired. Through additional discussions with the employee, the inspector became concerned that the work may not have been adequately controlled. The inspector requested the licensee's QA staff to investigate this activity and provide documentation that it was adequately controlled. On August 17, the licensee provided the following information:

a. WR No. 31386 was written on August 12 to swap the cam follower from the personnel air lock with one from the emergency hatch drive box to allow operation until spare parts arrived. Technical Specifica-tion 3.6.1.3(a) requires that "Each containment air lock shall be OPERABLE with both doors closed except when the air lock is being used for normal transit entry and exits..." Procedure APA-ZZ-00320, Revision 3, " Initiating and Processing Work Requests," states, "The approval authority should check the appropriate box if this component cculd cause an LCO, whether or not the specific work request requires that the component be 005." Contrary to the above, WR No. 31386, Block (009), "Will outage on this equipment result in an LC0?" was checked "no".

b. Procedure ODP-ZZ-00002, Revision 1, " Equipment Status Control,"

paragraph 4.1.1, states in part, "When a... component, or device i

which is safety related or is otherwise required to be operable to satisfy Technical Specifications...is determined to be out of service the Shift Supervisor shall initiate Attachment 1, Equipment Out-of-Service Log Sheet. . ." Contrary to above, work was performed on door 1507A which rendered the door inoperable for a period of time on August 13 which placed the plant under the Action Statement of Technical Specification 3.6.1.3. The door was not declared "out-of-service" and the plant was not declared to be under an Action Statement. The requirements of the Action Statement were met in that the door was back in service within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

I Failure to follow procedures is an example of noncompliance with 10 CFR 50,- 1 Appendix B, Criterion V (483/84-36-04(b)). The licensee initiated a Request for Corrective Action (RCA P8408-296) on August 16 to document the noncompliance.

7. Verification of Technical Specification Requirements During Mode 5 the inspector observed that the following Technical Specification requirements were satisfied:

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TS 3.5.4: The inspector observed that both safety injection pumps were inoperable in that their motor circuit breakers were secured in the open position.

Th 3.7.10.1(a) and (b): The inspector observed that the. levels of the fire suppression water supply tanks were greater than 31 feet

and the fuel oil day tanks were greater than 3/4 full. Surveillance i

records documented that the fire pumps had been tested in accordance with Procedure OSP-KC-00001, and the diesel fire pump batteries had been checked for electrolyte level and voltage once per 7 days in accordance with Procedure MSE-KC-FB001, Diesel Battery Check.

8. Licensee Event Report Followup Through direct observations, discussions with licensee personnel, and review of records, the following event report was reviewed to determine that reportability requirements were fulfilled, immediate corrective action was accomplished, and corrective action to prevent recurrence had been accomplished in accordance with Technical Specifications.

4 (Closed) LER 84-01: Missed Hourly Fire Watch. On June 12, 1984, from 1600 to 1700, hourly fire watch patrols for four rooms in the Control Building were missed in violation of Technical Specification Action Statement 3.7.11.a. Door locks had been. changed and new keys were not promptly made available to the fire watch personnel, causing the missed patrols. Licensee action to prevent recurrence included instructing the locksmith to coordinate future lock changes with fire watch supervision and key room personnel, and instructing key room and fire watch personnel to-utilize the building master key for any further instances of this type.

The inspector interviewed a fire watch supervisor, fire watchmen, and key room personnel and identified a concern that verbal instruction may not be sufficient to prevent recurrence. Subsequently, the Site Security Supervisor issued a memorandum to the Lock and Key Control Supervisor and revised fire watch post orders to address the inspector's con'cern.

The inspector reviewed Procedure ODP-ZZ-06200, Requirements for and Duties of Tech Spec Fire Watches, reviewed fire watch records for July 22 through July 26, 1984, and observed the continuous fire watch in Auxiliary Building Room 1328. No instances of missed fire watches were identified.

9. Management Meeting On August 8, 1984, Region III representatives met with licensee repre-sentatives (as denoted in Paragraph 1) to discuss Region III's concerns regarding the problems being experienced at Callaway. The following items.

were discussed:

a. The licensee presented an overview of all licensee events which had occurred. The frequency of events caused by personnel errors appears

to be excessive. The licensee described a number of actions being l , taken to correct weaknesses in this area.

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b. On August 5, 1984, the licensee implemented an interim work schedule for operations personnel utilizing four crews instead of six. Two 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts are used instead of the previous 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shifts. The licensee was requested to submit a letter to NRR describing the new w'ork schedule. The licensee presented the following fou,r crew schedule advantages: .

(1) Increased supervision per shift (6 crew manning distributed l over 4 crews). I i

(2) Increased participation in startup activities.

(3) Two shift changes per day, improved communications between

- shifts.

(4) Increased personnel on duty to support plant activities.

(5) Reduced number of 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> shifts.

(6) More firmly established days off.

c. The licensee discussed overtime in general and also the overtime history of the personnel involved in three LERs. The data did not show any obvious correlation between overtime and personnel errors.

10. Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. An open item disclosed during the inspection is discussed in Paragraph 4.b.

11. Exit Interview The inspector met with licensee representatives denoted in Paragraph 1 on August 17, 1984, to discuss the scope and results of the inspection.

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DUE: 10/24/84 BILLIE OARDE EDO CONTROL: 000004 MICHELE VARRICCHIOjGAP DOC DT: 09/28/84 FINAL REPLY:

TO:

COMMISSIONERS FOR SIGNATURE OF: ~

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SECY NO:

DENTON DESC ROUTING:

2.206 LOW - CALLAWAY POWER LICENSE NUCLEAR PLANT - REQUEST SUSPEND DENTON KEPPLER ASSIGNED TO: ELD .

DATE: 10/02/84 CONTACT: CUNNINGHAM SPECIAL INSTRUCTIONS OR REMARKS:

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E Docket No. STN 50-483

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Ms. Billie Garde-irector of.CitJzen (Clinic Govfrnment-Accountability Project

. 1555. Connecticut Avenue, N. W.

L Suite 202 Washington, D. C. 20036

Subject:

Acknowledgement of GAP Letter dated September 28, 1984, Requesting Suspension of Low-Power License and Denial'of. Full-Power License i for Callaway Plant, Unit No. 1 t - .

! On September 28,1984,- Ms. Michele Varricchio and yourself ' submitted a letter on behalf of the Concerned Citizens About Callaway which requested "immediate action" by the Comission to suspend the low-power _ operating license for j Callaway Unit 1. In accordance with the Comission's usual practice, the re-quest was referred to the staff for appropriate action pursuant to 10 CFR 2.206.

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The letter requested suspension of the low-power license pending an invesii-i gation.of the allegations contained in the letter and completion of any neces-l sary reinspections to determine the scope of identified problems. As a basis I for this action', the letter points to, among other things, various alleged con-j struction deficiencies related to welding, electrical cabling, concrete place-ment, poor construction drawings, undue pressure _on quality control -inspectors, and drug and alcohol abuse at the site.. The NRC received the letter only a few days before the Comission's scheduled meeting on authorization

of a' full--

power license for Callaway Unit 1. In preparing for-that meeting, the staff j' reviewed the information contained in the letter and informed the Comission that- the concerns raised by the letter did not warrant imediate action by the

• Comission to suspend' the low-power license 'or stay issuance _ of a full-power..

license. ,

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Several members of my staff along with personnel from the NRC Region III office l and the Office of Inspection and Enforcement have reviewed the allegations. -As 4- a result of its evaluation, the staff has determined that there is. sufficient

. evidence.to conclude that the low-power license should not be suspended and l

that the full-power -license should be issued. (License NPF-30~ granting full- ,

~ power operation of the Callaway Plant, Unit I was issued-to Union Electric ~  !

i. Company on October _ 18,1984.) The basis for the staff determination is: )

l (1) several allegations were previously reviewed by the staff and closed; .l

[" these are documented in_ reports; i

i t

ll30

_ _. _. _ . _ _ . _ _ . ._ , __ _. __ _ _ ~ _ _ _.

Ms. Billie Garde (2) many of the allegations identified areas where the alleger believed there was a concern; however, in all such instances, the necessary requirements were met; and (3) several allegations were too broad and, based on previous NRC and licensee inspections, evaluations, and reviews, no problems had been identified.

I would also note that with respect to quality assurance, including the adequacy of welding and concrete placement,.this subject was a primary issue in the oper-ating license proceeding for Callaway Unit 1. Both the Licensing Board and the Appeal Board concluded from the evidence on the record that there was no general breakdown in quality assurance procedures and that there was reasonable assur-ance that the Callaway plant could be operated safely. See LBP-82-109, 16 NRC 1826 (1982), aff'd,ALAB-740,18NRC343(1983).

Although no immcdiate actier is warranted, the staff will continue to review the request and reach a final determination on it within a reasonable time in accordance with 10 CFR 2.206. In that regard, your letter states that the allegations forming the basis for the request have been conpiled from affi-davits of former plant workers. These affidavits have been received by the staff and based on its review, the staff has deternined that the affidavits, in general, do not provide any additional details concerning the allegations.

However, in the absence of more specific information su por@Iie petition, 3 it is difficult to assess the need for further action. The NRC staff pre-pared to meet with you and the allegers, whose identity 1 be pr ted where possible, to obtain factual information concerning t e allegations.

With respect to the letter dated October 17, 1984, also frcm Ms. Varricchio and yourself, GAP stated that the actions on the part of the staff in review-ing the allegations in the September 28, 1984 letter were hastily done and did not consider other available evidence. Additionally, GAP requested that it be given 14 days notice prior to issuance of the full-power operating license.

At no time did the NRC treat the concerns in a hasty or haphazard manner. The staff decision to issue the full-power license was based on a review of avail-able information. The information you submitted was not of sufficient speci-ficity to cause the staff to change its position.

The staff was unable to give GAP the 14 days notice it requested since the full-power license was scheduled for issuance on October 18, 1984. The licensee had satisfied all of the restrictions prohibiting operation above 5% of rated power and had satisfactorily completed its low-power test program; therefore, a 14 day delay in issuing the license was not justified. -

v -,

Ms. Billie Garde As noted above, the staff is prepared to meet with the allegers to ensure that all avenues of information are explored. By permitting the NRC to discuss the concerns directly with the allegers, GAP will be assured that a thorough review of the allegations has been performed. Otherwise, the staff has no basis to change the conclusions drawn above. I suggest that a meeting be held with the NRC and GAP within the next week to discuss this proposal. The staff will con-tact you regarding such a meeting.

A copy of a notice being filed with the Office of the Federal Register for pub-lication is enclosed for your information.

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page e

-F

, - - - - - - ... - ry -

• Ms. Billie Garde As noted above, the staff is prepared to meet with the allegers to ensure that all avenues of information are explored. By permitting the NRC to discuss the concerns directly with the allegers, GAP will be assured that a thorough review of the allegations has been performed. Otherwise, the staff has no basis-to change the conclusions drawn above. I suggest that a meeting be held with the NRC and GAP within the next week to discuss this proposal. The staff will con-tact you regarding such a meeting.

A copy of a notice being filed with the Office of the Federal Register for pub-lication is enclosed for your information.

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page DISTRIBUTION:

Tee attached page

• SEE PREVIOUS PAGE FOR CONCL..dENCES DD:NRR D:NRR ECase HDenton 10/ /84 10/ /84 LB#1:DL LB#1:DL OELD AD:L:DL D:DL RIII JHolonich:kab *BJYoungblood JLieberman TNovak DEisenhut *JKeppler 10/25/84 10/26/84 10/ /84 10/ /84 10/ /84 10/25/84 ma

WITS ITEMS 000004 [acknowledgiment letter (1st part)]

i 000060 (closes this item)

DISTRIBUTION: CALLAWAY 2.206 Dated:

Docket File NRC PDR L PDR NSIC EDO Reading WDircks JHolonich P0'Connor MRushbrook LB#1 R/F TNovak/ Peggy MJambor/ Marie S. Burns, OELD KBowman, #000004 CMiles VYanez ASLP ASLAP ACRS(16)

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.. 'I 7590-01 NUCLEAR REGULATORY COMMISSION DOCKET N0. STN 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 Request for Action Under 10 CFR 2.206 Notice is hereby given that by letter dated September 28, 1984, the Government Accountability Project, on behalf of Concerned Citizens About Ce11away and others, has requested that the Commission suspend the low-power license for Callaway Unit 1 pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problems identified during the investigation. The alle-gations concern primarily improper construction practices ard other improper conduct by plant workers such as a drug or alcohol abuse on the site. The letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff will take appropriate action on the request within a reasonable time.

A copy of the petitioner's letter is available for public inspection in the Commission's Public Docunent Room at 1717 H Street, N. W., Washington, D. C. 20555 and in the local public document room at Fulton City Library, 709 Market Street, Fulton, Missouri 65251 and at the Olin Library of Washington University, Skinker and Lindell Boulevards, St. Louis, Missouri 63130.

Dated in Bethesda, Maryland, this day of 1984.

FOR THE NUCLEAR REGULATORY COMISSION Harold R. Denton, Director ,

Office of Nuclear Reactor Regulation i l

i

' 7590-01 NUCLEAR REGULATORY COMMISSION

,e DOCKET N0. STN 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 Request for Action Under 10 CFR ?.206 Notice is hereby given that by letter dated September 28, 1984, the

. Government Accountability Project, on behalf of Concerned Citizens About Callaway and others, has requested that the Comission suspend the low-power I

license for Callaway Unit 1 pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections .of the plant as a result of problems identified during the investigation. The alle-gations concern prinarily improper construction practices and other improper l conduct by plant workers such as a drug or alcohol abuse on the site. The i letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff will take appropriate action on the request within a reasonable time.

A copy of the petitioner's letter is available for public inspection in

the Comission's Public Document Rocm at 1717 H Street, N. W., Washington, 1

D. C. ?0555 and in the local public document room at Fulton City Library,

{

709 Market Street, Fulton, Missouri 65251 and at the Olin Library of

}

, Washington University, Skinker and Lindell Boulevards, St. Louis, Missouri j 63130.

! Dated in Bethesda, Maryland, this day of 1984.

FOR THE NUCLEAR REGULATORY COMISSION Harold R.'Denton, Director

Office of Nuclear Reactor Regulation DD:NRR D:NRR

' ECase HDenton 10/ /84 10/ /84:

LB#1:DL LB#1:DL DELD AD:L:DL D:DL RIII JHolonich:kab BJYoungblood JLiberman -TNovak DEisenhut JKeppler 10/ /84 10/ /84 10/ /84 10/ /84 10/ /84 10/ ./84

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Docket No. STN 50-483 Mr. Louis Clark, Executive Director Government Accountability Project 1555 Connecticut Avenue, N. W.

Suite 202 Washington, D. C. 20036

Subject:

Acknowledgement of GAP Letter dated September 28, 1984, Requesting Suspension of Low-Power License and Denial of Full-Power License for Callaway Plant, Unit No.1 On September 28, 1984, Ms. Michele Varricchio and Ms. Billie Garde of the Government Accountability Project (GAP) submitted a letter on behalf of the Concerned Citizens About Callaway which requested "immediate action" by the Comission to suspend the low-power operating license for Callaway Unit 1.

In accordance with the Comission's usual practice, the request was referred to the staff for appropriate action pursuant to 10 CFR 2.206.

The letter requested suspension of the low-power license pending an investi-gation of the allegations contained in the letter and completion of any neces-sary reinspections to determine the scope of identified problems. As a basis for this action, the letter points to, emong other things, various alleged con-struction deficiencies related to welding, electrical cabling, concrete place-ment, poor construction drawings, undue pressure on quality control inspectors, and drug and alcohol abuse at the site. The NRC received the letter only a few days before the Commission's scheduled meeting on authorization of a full-power license for Callaway Unit 1. In preparing for that meeting, the staff reviewed the information contained in the letter and informed the Comissien that the concerns raised by the letter did not warrant imediate action by the Comission to suspend the low-power license or stay issuance of a full-power license.

Several members of my staff along with personnel from the NRC Region III office

• and the Office of Inspection and Enforcement have reviewed the allegations. As a result of its evaluation, the staff has determined that there is sufficient evidence to conclude that the low-power license should not be suspended and that the full-power license should be issued. (License NPF-30 granting full-pcwer operation of the Callaway Plant, Unit I was issued to Union Electric Company on October 18,1984.) The basis for the staff determination is:

(1) several allegations were previously reviewed by the staff and closed, these are documented in reports;

t Mr. Louis Clark (?) many of the allegations identified areas where the alleger believed there was a concern; however, in all instances, the necessary require-ments were met; and (3) allegations were too broad and, based on previous NRC and licensee inspections, evaluations, and reviews, no problems had been identified.

I would also note that with respect to quality assurance, including the adequacy of welding and concrete placement, this subject was a primary issue in the oper-ating license proceeding for Callaway Unit 1. Both the Licensing Board and the Appeal Board concluded from the evidence on the record that there was no general breakdown in quality assurance procedures and that there was reasonable assur-ance that the Callaway plant could be operated safely. See LBP-82-109, 16 NRC 1826 (1982), aff'd, ASLB-740, 18 NRC 343 (1983).

Although no immediate action is warranted, the staff will continue to review the request ard reach a final determination on it within a reasonable time in accordance with 10 CFR 2.206. In that regard, your letter states that the l allegations forming the basis for the request have been compiled from affi-davits of former plant workers. These affidavits have been received by the staff and based on its review, the staff has determined that the affidavits, in general, do not provide any additional details concerning the allegations.

As I am sure you will agree, it is difficult for the staff to adequately assess the need for further action in the absence of the information which forms the basis for the request. Region III is prepared to meet with you and the allegers, whose identity will be protected where possible, to obtain factual information concerning the allegations. I suggest that a meeting be held with the NRC and GAP within the next week to discuss this proposal. The staff will contact you regarding such a meeting.

i With respect to the letter dated October 17, 1984, also from Ms. Garde and Ms. Varricchio, GAP stated that the actions on the part of the staff in review-ing the allegations in the September 28, 1984 letter were hastily done and did not consider other available evidence. Additionally, GAP requested that it be given 14 days notice prior to issuance of the full-power operating license.

The staff decision to issue the full-power license was based on a review of the available information. At no time did the NRC treat the concerns in a hasty or haphazard manner; however, because of the lack of specifics in the allegations and affidavits, it is not possible for the staff to identify any areas where the allegations represent a valid safety concern. This conclusion is based on the reasons previously discussed.

I 6

Mr. Louis Clark As noted earlier, the staff is prepared to meet with the allegers to ensure that all avenues of information are explored. By permitting the NRC to dis-cuss the concerns directly with the allegers, GAP will be assured that a thor-ough review of the allegations has been performed. Otherwise, the staff has no basis to change the conclusions drawn above.

Finally, the staff was unable to give GAP the 14 days notice it requested since the full-power license was scheduled for issuance on October 18, 1984. Because the licensee had satisfied all of the restrictions prohibiting operating above 5% of rated power and had satisfactorily completed its low-power test propran, a 14 day delay in issuing the license would not have been justified.

A copy of a notice being filed with the Office of the Federal Register for pub-lication is enclosed for your information.

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page 1

i

)

s l

i DISTRIBUTION: (WITS ITEM 000004) CALLAWAY 2.206 Dated: __,

Docket File NRC PDR L PDR NSIC ED0 Reading

, WDircks JHolonich P0'Connor MRushbrook

LB#1 R/F

TNovak/ Peggy MJambor/ Marie OELD i KBowman, #000004 CMiles 4 VYanez l ASLP l ASLAP

! ACRS(16) i JKeppler l

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. l 7590-01 NUCLEAR REGULATORY COMMISSION t

DOCKET N0. STN 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 Request for Action Under 10 CFR 2.206 Notice is hereby given that by letter dated September 28, 1984, the Government Accountability Project, on behalf of Concerned Citizens About Callaway and others, has requested that-the Commission suspend the low-power license for Callaway Unit 1 pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problems identified during the investigation. The alle-gations concern primarily improper construction practices and other inproper conduct by plant workers such as a drug or alcohol abuse on the site. The letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff will take appropriate action on the request within a reasonable time.

A copy of the petitioner's letter is available for public inspection in the Commission's Public Document Roem at 1717 H Street, N. W., Washington, D. C. 20555 and in the local public document room at Fulton City Library, 709 flarket Street, Fulton, Missouri 65251 and at the Olin Library of Washington University, Skinker and Lindell Boulevards, St. Louis, Missouri 63130.

Dated in Bethesda, Maryland, this day of 1984.

FOR THE NUCLEAR REGULATORY COMISSION Harold R. Denton, Director

- Office of Nuclear Reactor Regulation l

r

7590-01 NUCLEAR REGULATORY COMMISSION e

DOCKET NO. STN 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 Request for Action Under 10 CFR 2.206 Notice is hereby given that by letter dated September 28, 1984, the Governnent Accountability Project, on behalf of Concerned Citizens About Callaway and others, has requested that the Commission suspend the low-power license for Callaway Unit 1 pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problems identified during the investigation. The alle-gations concern primarily improper construction practices and other improper conduct by plant workers such as a drug or alcohol abuse on the site. The letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff will take appropriate action on the request within a reasonable time.

A copy of the petitioner's letter is available for public inspection in the Commission's Public Document Room at 1717 H Street, N. W., Washington, D. C. ?0555 and in the local public document room at Fulton City Library, 709 Market Street, Fulton, Missouri 65251 and at the Olin Library of Washington University, Skinker and Lindell Boulevards, St. Louis, Missouri 63130.

Dated in Bethesda, Maryland, this day of 1984.

FOR THE NUCLEAR REGULATORY COMISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation DD:NRR D:NRR ECase HDenton 10/ /84 10/ /84 LB#1:DL LB#1:DL DELD AD:L:DL D:DL RIII JHolonich:kab BJYoungblood JLiberman TNovak DEisenhut JKeppler 10/ /84 10/ /84 10/ /84 10/ /84 10/ /84 10/ /84

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.***. November 7,1984

,PRINCipALSTAFI ,

Docket No. STN 50-483 v uWR h

• 9/RA RC N -

PA0 ML --

SGA CL --

Ms. Billie Garde E1C p

$1 -

Director of Citizens Clinic DN I Government Accountability Project 1555 Connecticut Avenue, N. W.

Suite 202 Washington, D. C. 20036

Subject:

Acknowledgement of GAP Letter dated September 28, 1984 Requesting Suspension of Low-Power License and Denial of Full-Power License for Callaway Plant, Unit No. 1 On September 28, 1984, Ms. Michele Varricchio and yourself submitted a letter on behalf of the Concerned Citizens About Callaway which requested "immediate action" by the Commission to suspend the low-power operating license for Callaway Unit 1. In accordance with the Commission's usual practice, the re-quest was referred to the staff for appropriate action pursuant to 10 CFR 2.206.

The letter requested suspension of the low-power license pending an investi-gation of the allegations contained in the letter and completion of any neces-sary reinspections to determine the scope of identified problems. As a basis for this action, the letter points to, among other things, various alleged con-struction deficiencies related to welding, electrical cabling, concrete place-ment, poor construction drawings, undue pressure on quality control inspectors, and drug and alcohol abuse at the site. The NRC received the letter only a few days before the Commission's scheduled meeting on authorization of a full-power license for Callaway Unit 1. In preparing for that meeting, the staff revicwed the information contained in the letter and informed the Commission that the concerns raised by the letter did not warrant immediate action by the Commission to suspend the low-power license or stay issuance of a full-power license.

Several members of my staff along with personnel from the NRC Region III office I and the Office of Inspection and Enforcement have reviewed the allegations. As a result of its evaluation, the staff has determined that there is sufficient evidence to conclude that the low-power license should not be suspended and that the full-power license should be issued. (License NPF-30 granting full- l power operation of the Callaway Plant, Unit I was issued to Union Electric Company on October 18,1984.) The basis for the staff determination is:

4 (1) several allegations were previously reviewed by the staff and closed; these are documented in reports; 2r ww owem p

d D '$ no

Ms. Billie Garde November 7,1984 (2) many of the allegations identified areas where the alleger believed there was a concern; however, in all such instances, the necessary requirements were met; and (3) several allegations were too broad and, based on previous NRC and licensee inspections, evaluations, and reviews, no problems had been identified.

I would also note that with respect to quality assurance, including the adequacy of welding and concrete placement, this subject was a primary issue in the oper-ating license proceeding for Callaway Unit 1. Both the Licensing Board and the Appeal Board concluded from the evidence on the record that there was no general breakdown in quality assurance procedures and that there was reasonable assur-ance that the Callaway plant could be operated safely. See LBP-82-109, 16 NRC 182,6 (1982), aff'd, ALAB-740,18 NRC 343 (1983).

Although no immediate action is warranted, the staff will continue to review the request and reach a final determination on it within a reasonable time in accordance with 10 CFR 2.206. In that regard, your letter states that the allegations forming the basis for the reouest have been compiled from affi-davits of former plant workers. These affidavits have been received by the staff and based on its review, the staff has determined that the affidavits, in general, do not provide any additional details concerning the allegations.

However, in the absence of more specific information supporting the petition, it is difficult to assess the need for further action. The NRC staff is pre-pared to meet with you and the allegers, whose identity will be protec'ted where possible, to obtain factual information concerning the allegations.

)

With respect to the letter dated October 17, 1984, also from Ms. Varricchio and yourself, GAP stated that the actions on the part of the staff in review-ing the allegations in the September 28, 1984 letter were hastily done and did not consider other available evidence. Additionally, GAP requested that it be given 14 days nctice prior to issuance of the full-power operating license.

At no time did the HRC treat the concerns in a hasty or haphazard manner. The staff oecision to issue the full-power license was based on a review of avail-able information. The information you submitted was not of sufficient speci-ficity to cause the staff to change its position. '

The staff was unable to give GAP the 14 days notice it requested since the full-power license was scheduled for issua'nce on October 18, 1984. The licensee had  ;

satisfied all of the restrictions prohibiting operation above 5% of rated power i and had satisfactorily completed its low-power test program; therefore, a 14 day delay in issuing the license vias not justified.

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I:s. Billie Garde November 7, 1984 As noted above, the staff is prepared to meet with the allegers to ensure that all avenues of information are explored. Ey permitting the NRC to discuss the concerns directly with the allegers, GAP will be assured that a thorough review of the allegations has been performed. Otherwise, the staff has no basis to change the conclusions drawn above. I suggest that a meeting be held with the NRC and GAP within the next week to discuss this propesal. The staff will con-tact you regarding such a meeting.

A copy of a notice being filed with the Office of the Federal Register for pub-lication is enclosed for your information.

Sincerely, P ,

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Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

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NUCl. EAR REGULATORY C0?'.f11SSION a

DOCKET NO. STN 50-483 UNION ELECTRIC COMPANY CALLAk'AY PLANT, UNIT 1 Request for Action Under 10 CFR 2.206 Notice is hereby given that by letter dated September 28, 1984, the Government Accountability Project, on behalf of Concerned Citizens About .

Callaway and others, has requested that the Commission suspend the low-power license for Callaway Unit I pending an investigation of the allegations set forth in the letter and the completion of any necessary reinspections of the plant as a result of problems identified during the investigation. -The alle-gations concern prin.arily improper construction practices and other improper conduct by plant workers such as a drug or alcohol abuse on the site.

The i letter is being treated as a request for action under 10 CFR 2.206 and, accordingly, the staff bill take appropriate action on the request within a reasonable time.

A ccpy of the petitioner's letter is available for public inspection in the Commission's Public Document Room at 1717 H Street, N. L'., Washington, D. C. 20555 and in the local public document room at Fulton City Library, 709 Market Street, Fulton, Missouri 65251 and at the Olin Library of L'ashington University, Skinker and Lindell Boulevards, St. Louis, Missouri 63130.

Dated in Bethesda, Maryland, this 7th day cf November 19S4 FOR THE UUCLEAR REGULATORY C0!NISSION G ,~

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i" G .lg UNION ELECTRIC COMPANY 1901 Grotiot Street. St. Louis November 15, 1984 Donald F. Schnell Vice President Mr. Richard C. DeYoung, Director Of fice of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. DeYoung:

ULNRC- 976 INSPECTION REPORT NO. 50-483/84-36 This reply is in response to your letter of October 19, 1984 which transmitted the report of the inspection conducted at Callaway Plant, Unit 1 during the period of July 30 through August 3 and August 13-17, 1984. Our responses to the items of noncompliance are presented below in the order listed within the body of inspection report number 50-483/84-36.

None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.

(50-483/84-36-01) SEVERITY LEVEL III VIOLATION (Civil Penalty)

Technical Specification .3.6.2.1 states, "Two independent Containment Spray Systems shall be OPERABLE with each Containment Spray System capable of taking suction from the RWST and trans-ferring suction to the containment sump." This requirement is applicable for operational Modes 1, 2, 3, and 4.

TechnicalSpecificatkon3.0.3 states, "When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ACTION shall be initiated to place the unit in a MODE in which the specification does not ap-ply by placing,it, as applicable, in:

a. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

b. At Aeast HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

c. Ac least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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A31 NOV 191984 24-Moang Address PO Box 149. St Louis MO 63166

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. Mr. Richard C. DeYoung

& Pag @ 2

' November 15, 1984 Contrary to the above, at 6: 30 a.m. (CDT) on August 10, 1984, the licensee entered operational Mode 4 (hot shutdown) with Containment Spray manual isolation valves EN-V014 and EN-V018 closed and, therefore, with both Containment Spray Systems inoperable. The plant remained in Mode 4 with both valves closed until the closed valves were subsequently identified by the licensee and opened at 10: 50 a.m (CDT) on August 14, 1984.

Response

1 Admission or Denial of the Alleged Violation Au previously noted in Licensee Event Report 84-029-00 transmit-ted to the NRC September 10, 1984, Union Electric 7tcknowledges the cited violations.

Reasons for the Violation If Admitted The reasons for the violation were failure to follca procedures ar.d orders and failure to recognize the interrelationships among administrative controls as listed below:

o On May 7, 1984 Containment Spray manual i. solation valves (EN-V014 and EN-V018) were closed, locked and tagged on Workman's Protection Assurance (WPA) 84-3252 to prevent inadvertent discharge into containment. At this time, the valves were not entered on the Equipment Out of Service Log (EOSL).

o On May 9, 1984 valves EN-V014, EN-V018 and EN-V097 were noted as exceptions upon completion of OTN-EN-00001, but their status was not entered in the EOSL as required by Standing Order 84-24. '

o On August 3, 1984 in preparation for entering Mode 4 a review was made of WPA. WPA 84-3252 for valves EN-V014 and EN-V018 was not identified as being required for Mode 4.

o On August 8, 1984 Temporary Change Notice (TCN)84-945 to ODP-ZZ-00014 was executed to delete the sign-off requirement for the review of the EOSL, the WPA log review, and the Temporary Modification log review.

o On August 10, 1984 Mode 4 was entered.

o On August 14, 1984 WPA 84-3252 showing valves EN-V014 and EN-V018 closed was found. These valves were subsequently opened, locked and independently verified.

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. Mr. Richard C..DeYoung Page 3

- November 15, 1984 Corrective Actions Taken And The Results Achieved On August 14, 1984 upon discovery of the Containment Spray Manual Isolation valves being locked closed, the valves were immediately opened, locked, and independently verified. Also when the EOSL was found to be out of date, immediate reviews of the Surveillance Master Tracking log, outstanding Work Requests, out-standing WPA, and outstanding Temporary Modifications were initi-ated against the EOSL to bring it up to date. These reviews were completed and the EOSL brought up to date on August 20, 1984.

The individuals responsible for not entering EN-V014 and EN-V018 in the EOSL were counseled by August 30, 1984.

The Plant Manager and/or the Assistant Plant Managers held a series of meetings with plant staff and support personnel. The purpose of these meetings was to re-emphasize management's deter-mination to ensure compliance with Callaway operating procedures and Technical Specifications to all levels of the work force, highlight the recent Callaway events, and stress the . necessity for improving individual performance, group performance, and communication. These meetings were completed September 7, 1984.

In addition, on August 20, 1984 the content of Standing Order 84-24 was incorporated into ODP-ZZ-00002, Equipment Status Control, and APA-ZZ-00310, Workman's Protection Assurance.

And finally, on August 15, 1984 TCN 84-945, which removed the requirement for review of EOSL, WPA, and Temporary Modifications, was eliminated by a revision to procedure ODP-ZZ-00014, Operational Mode Change Requirements. This revision also in-cluded the requirement to do the same reviews for all mode ascensions. It previously applied to the change from Mode 5 to Mode 4 only. The individuals who initiated TCN 84-945 were coun-seled on August 17, 1984 and August 19, 1984. They had been aware of the limitations imposed on temporary changes and had not intended the TCN to delete the reviews of the EOSL, WPA, and Temporary Modifications. They had intended only to delete what they believed to be redundant documentation' of the reviews. As an added precaution, a letter was issued on August 18, 1984 to Nuclear Operations personnel'and contractors emphasizing the lim-itations on the use of temporary changes.

Corrective Actions To Be Taken To Avoid Further violations No further corrective action is considered necessary.

Date When Full Compliance Will Be Achieved Union Electric achieved full compliance September 7, 1984.

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Mr. Richard C. DeYoung Page 4 November 15, 1984 Proposed Civil Penalty Union Electric acknowledges the cited violation and appreciates the reduction in the amount of civil pecalty from the base amount. However, we feel there are additional circumstances which may not have been considered and should result in complete mitigation of the penalty.

The subject Severity Level III Violation is the only Severity Level III Violation Union Electric has received. This incident regarding the containment spray valves is the first and only in-cident of that nature to have occurred at Callaway The Commission's General Policy and Procedures for Enforcement Actions provide that civil penalties "are considered for Severity Level III Violations." In contrast, the Policy is to impose civil penalties for Severity Level I Violations and to impose civil penalties " absent mitigating circumstances" for Severity Level II Violations (10 C.F.R. Part 2, Appendix C, Section V.B.).

More specifically, the Commission's Policy indicates that a civil penalty may be considered appropriate for the second and subse-quent Severity Level III Violations of a "similar" nature (10 C.F.R. Part 2, Appendix C, Section V.D., Table 2). In making the most recent change to Table 2, the Commission stated: " Table 2 has been changed to indicate that a civil penalty might not be imposed for the first Severity Level III Violation in an area of concern . . . ." 49 Fed. Reg. 8586 (March 8, 1984).

In addition, 10CFR2, Appendix C, V.B.1., 2. and 3. provide reduc-tions of civil penalties of 50%, 50% and 100% respectively for prompt identification and reporting, corrective action to prevent recurrence, and good prior performance. We feel that the Callaway Plant staff took timely action regarding identification, reporting and corrective action and has demonstrated good prior performance.

For these reasons, Union Electric Company believes that the proposed penalty should be reduced by 100% rather than only 50%

and we request your reconsideration of these factors.

Nevertheless, if your position is that these factors do not justify a further reduction in the penalty, the proposed penalty of $25,000 will be paid and we will not further contest it.

51 ease advise us of your decision.

350-483/84-36-03) SEVERITY LEVEL IV VIOLATION 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformance are promptly identified and corrected..."

Mr. Richard C. DeYoung

. Paga 5 November 15, 1984 ,

The Callaway Plant FSAR, Section 17.2.16, states in part,

" Measures shall be established to assure that conditions adverse to quality are promptly identified, reported, and corrected..."

Contrary to the above, adequate measures were not established to assure that conditions adverse to quality were promptly identi-fled and corrected in that a deficient Bechtel design drawing resulted in a card associated with bistable 456B being installed incorrectly. Although this condition existed since November 1983, it was not detected during preoperational testing and the licensee did not become aware of it until this condition caused an inadvertent safety injection which occurred on August 13, 1984 when bistable 456B was tripped during a loop calibration surveil-lance procedure. Additionally, the trip status of 456B was un-known because the indicator light for it on the Partial Trip Status Panel located in the Control Room was burned out. Work Request No. 30748 to relamp the Partial Trip Status Panel was authorized on July 28, 1984, with a requested completion date of August 1, 1984, although the work was not accomplished until August 13, 1984, after the inadvertent safety injection occurred.

Response

Corrective Action Taken And The Results Achieved The circumstances regarding this item were reported to the NRC by Licensee Event Report (LER) 50-483/84-028-00 transmitted to the NRC September 11, 1984.

As stated in the LER, three of the four instrument channels that monitor RCS pressure feed a permissive circuit (P-ll) which per-mits blocking of the Pressurizer Low Pressure /Steamline Low Pressure Safety Injection (SI) signals at low RCS pressures.

Prior to this event, P-ll was in the " BLOCK" mode as the plant was in Mode 4 and at low RCS pressure. Also, one of the three pressure loops (Loop 456) that make up the 2 out of 3 coincidence logic for P-ll was failed in the tripped state due to incorrect strapping on the associated bistable. This design error caused the bistable to provide a tripped output when plant conditions

~

did not require it. This trip went undetected due to failed lamps on the associated window of the Partial Trip Status Panel.

Also, the initial surveillance tests had not yet been performed on any of these pressure loops prior to this event. Thus, when the pressure loop (Loop 455) being calibrated was placed in test, the required 2 out of 3 coincidence for P-11 was satisfied, the block of the SI signal was automatically reset and the Pressurizer Low Pressure SI signal intiated. ,

Mr. Richard C. DeYoung Pcge 6

'. November 15, 1984 The failed lamps in the Partial Trip Status Panel have been replaced and the bistable that resets P-11 on Loop 456 has been corrected to prevent the false output. A step was added to procedure ISL-BB-0P455 on August 21, 1984 to require a lamp test on the Partial Trip Status Panel prior to putting an instrument channel in the test mode.

Corrective Action To Be Taken To Avoid Further Noncompliance A step similar to the one added to ISL-BB-0P455 is being added to other applicable Instrumentation and Control procedures.

Date When Full Compliance Will Be Achieved Procedure revisions are expected to be completed by December 7, 1984.

If you have any questions regarding this response or if addi-tional information is required, please let us know.

Very truly yours, Donald F. Schnell SEM/JRV/bjk cc: AJames G. Keppler, Regional Administrator, NRC Region III W. L. Forney, NRC Region III ,

NRC Resident Inspectors, Callaway Plant (2)

Missouri Public Service Commission l

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STATE OF MISSOURI )

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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an of ficer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief.

By M Donald F. Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this /8 day of 1984 lW~ . -h B.5R3ARAh.PFA v NOTARY PLBUC. STATE OF MISSOURI MY COMMISSION EXFiRES t.PRIL 22,1985 ST. LOUIS COUNTY I

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