IR 05000483/1987005

Insp Rept 50-483/87-05 on 870208-0404.Violations Noted: Failure to Perform Tech Spec Surveillances at Specified Intervals

ML20213A671
Person / Time
Site:	Callaway
Issue date:	04/20/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20213A666	List: IR 05000483/1987005 ML20213A665 ML20213A670
References
50-483-87-05, 50-483-87-5, NUDOCS 8704280158
Download: ML20213A671 (11)

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.U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/87005(DRP)

Docket No. 50-483 License No. NPF-30 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway Plant, Unit 1 Inspection at: Callaway Site, Steedman, M0 Inspection Conducted: February 8 through April 4, 1987 Inspectors: B. H. Little C. H. Brown Approved B3 d Jr Reactor Projects Section 1A (M/P7 Date'

Inspection Summary Inspection on February 8 through April 4, 1987 (Report No. 50-483/87005(DRP))

Areas inspected: A routine unannounced safety inspection by the resident inspectors of licensee actio,n on Part 21 Reports, Licensee Event Reports regional and headquarters requests, training and cualification effectiven,ess, anc ESF system walkdow operational Results: Ofsafety, the eightsurveillance, maintenance,lations areas inspected, no vio or deviations were identified in seven areas; one violation was identified in the remaining area (failuretoperformTechnicalSpecificationsSurveillancesatspecified intervals - Paragraph 3.). The violation was determined to not result in a significant plant safety conditio PDR ADOCK 05000483 PDR O

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DETAILS Persons Contacted D. F. Schnell, Vice President, Nuclear G. L. Randolph, General Manager, Callaway Plant

• J. D. Blosser, Manager, Callaway Plant C. D. Naslund, Manager, Operations Support Manager, Quality Assurance P.Peevy, J. Neuhalfen,istant Ass Manager, Technical Services

• P. T. Appleby, Assistant Manager, Support' Services W. F. Powell, Assistant Manager, Materials M. E. Taylor, Superintendent, Operations D. E. Young, Su W. R. Robinson,perintendent, Maintenance Superintendent, I&C R. R. Roselius, Superintendent, Health Physics V. J. Shanks, Superintendent, Chemistry J. A. Ridgel, Superintendent, Radwaste G. J. Czeschin, Superintendent, Planning & Scheduling W. H. Sheppard, Superintendent, Outages J. M. Price, Superintendent, Training G. R. Pendegraff, Superintendent, Security

• J. E. Davis, Superintendent, Compliance D. W. Capone, Manager, Nuclear Engineering R.Passwater, A. Campbell, Assistant Manager,icensingNuclear Superintendent, L Engineering

• J. V. Laux, Superintendent, Technical Support, Quality Assurance

• J. C. Gearhart, Superintendent, Operations Su) port, Quality Assurance G. A. Hughes, Supervisor, Independent Safety Engineer Group

• Denotes those present at one or more exit interview In addition, a number of equipment operators, reactor operators, senior reactor operators, and other members of the qualit control, operations, maintenance, health physics, y assurance,,

and engineering staffs quality-were contacte . Licensee Action on 10 CFR Part 21 Reports (92700) (Closed)10CFRPart 21(483/85003-PP): Undetectable Failure in Engineering Safety Features Actuation System (ESFAS). This issue was originally reported by Westinghouse on November 7, 1979, (NS-TMA-2150)andtestproceduresrecommendedtoverifythe interlock P-4 functional. Three other letters were issued reporting furtherdeficiencies(January 4,1980; February 15, 1980; and March 22,1985). The Callaway Plant has issued the following procedures or revisions to verify the operability of the P-4 permissiv (1) 0$P-SB-00001, Revision 1, dated September 26, 1984, " Reactor Trip Breaker P-4 Verification."

(2) 0SP-SB-00001, Revision 5, dated July 31,1985, " Reactor Trip Breakers - Trip Actuating."

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OSP-SB-00001 checks across trip breaker auxiliary contacts and the a'ssociated diode and wiring. These procedures appear to have eliminated the undetectable failure of this part of the ESFA This item is considered close (Closed) 10 CFR Part 21(483/84004-PP): General Electric-Ferro-Resonant Transformers Utilized in Westinghouse Vital 7.5 KVA Inverters. The 10 CFR Part 21 was issued by Westinghouse following the failure of several units shortly after the initial electrical loading of the GE Ferro-Resonant Transformer The problem was due to insufficient securing of the center leg and insulation breakdown apparently due to workmanship. A high potential test was recommended to verify the condition of the insulation on the transformer winding The high potential test was performed on these transformers installed at the was greater than 20 Megohm plant All the and resistance, transformers used inphase to ground the vital 7.5 KVA inverters were found to be satisfactory. This item is considered close (Closed) 10 CFR Part 21(483/85001-PP)andIEInformationNoticeN : Post-tensioned Containment Tendon Anchor Head Failur A

)otential Part 21 problem was found at the Farley Unit 2 Plant when aroken anchor heads and broken wires for a failed post-tensioned containment tendon were found during an inspection. The anchor heads and wires were found satisfactory at the Callaway Site during a licensee's inspection in this area. This matter is considered close No violations or deviations were identifie . Licensee Event Report (LER) Followup (90712 and 92700)

An inspection of LERs was performed to determine that the reporting requirements were fulfilled, immediate corrective action was accomplished, and that events were evaluated for root cause and received appropriate corrective action to prevent recurrence. In addition, each event was evaluated for previous events and generic applicability. The

. inspection included an in-office review, direct observations, the review of plant records, and interviews with licensee personnel.

l (Closed) LER 483/86023-00: Technical Specification Violation -

Open Containment Penetration While in Mode 4. On June 21, 1986 during an operations review of a valve line-up to drain the "C",

steam generator, a non-licensed operator questioned the

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appropriateness of the valve line-up while in Mode 4. Operations did not perform the valve line-up to drain the steam generator but

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the question prompted an engineering review of previous steam generator draining operations. The licensee's review determined that on two occasions; March 31, 1985 and May 19, 1986, the inner andoutercontainmentisolationvalves(BM-V-0045andBM-V-0046)

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were opened in Mode 4 to permit steam generator drainin Technical Specifications T/S 3/4.6.1.1 (Containment Integrity) and T/S 3/4. (Containment Isolation Valves) require that valves BM-V-0045 and BM-V-0046 be closed while in Modes 1, 2,.3, and The licensee's evaluation attributed the root cause of the events to management oversight. To prevent recurrence, special operatin procedure OTS-AE-00001 (Draining and Refilling Steam Generators) g was revised to reference Technical Specifications and to restrict performance to Modes 5 and As an interim measure, pending recei)t of metal tags, all manual containment penetration valves have )een " Red" tagge The inspector determined that procedural / tagging deficiencies were themajorcontributortothisevent. The deficiency was identified through the attentiveness of a non-licensed operator and subsequent licensee review. The event posed minimal risk to containment integrity as the portion of the steam generator drain line which is considered to be nonsafety-related is constructed and tested in accordance with ANSI B31.1 and is seismically supported. This piping is also protected from internally generated missiles since all of the piping in question is routed outside the secondary shield l wall inside containment. Additionally, the steam generator draining activities were performed with the reactor at temperatures less than 350 F (Mode 4), and at reduced pressures with the steam generator secondary temperature and pressure equal to or less than 210 and 10 psig respectivel Violations are identified in the above LER which meet the criteria for 10 CFR Part 2, Appendix C for which a notice of violation will not generally be issued. These violations are of lesser severity which were identified, reported, and satisfactorily corrected by the licensee, and are not violations that could reasonably be expected to have been prevented by the licensee's corrective action for a previous violation. Therefore, no notice of violation is being issued and this LER is considered close b. (Closed) LER 483/86042-00: Technical Specification Violation -

Failure to Meet Surveillance Requirement. On December 31, 1986, during a review of surveillance procedure OSP-AL-V0001 (Condensate Storage Tank to Motor Driven Auxiliary Feed Pump "B" Isolation Valve AL-HV-0034), the licensee determined that valve AL-HV-0034 had not been tested as required by Technical Specifications 4.0.5 which specifies surveillance intervals in accordance with ASME Section X Valve AL-HV-0034, (ASME Code Class 3) which had been tested on November 13, 1986, indicated an increase in stroke time, and in accordance with ASME Section XI, required that the surveillance frequency be reduced from quarterly to monthly. The surveillance extension provision of Technical Specification 4.0.2 established the latest allowable day to complete the surveillance as December 22, 198 The valve was tested on December 31, 198 The licensee's evaluation of the cause attributed the event to a procedural deficiency, relating to the Surveillance Test Request Form and cognitive personnel error by the reviewer.

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j The inspector reported, determined and promptly that the corrected by violation was identified, the license The surve illance I test of valve AL-HV-0034 performed on December 31, 1986, I demonstrated acceptable stroke time and that the valve would have l performed its specified function. However, the licensee's failure to perform the required surveillance at intervals specified by ANSI Section XI is a violation of Technical Specification 4. (483/87005-01a(DRP)).

c. (Closed) LER 483/87001-00: TechnicalSpecification(T/S) Violation

- Failure to Satisfy T/S Action Statements Required by Delinquent Fire Barrier Surveillances. On February 12 1987, during the licensee's evaluation of Incident Report (IR) No.87-016 relating toadeficientseal(13150530), the licensee determined that the specified 18 month visual inspections of fire barrier penetration seals (T/S 4.7.11.1.c) had not been performed by the late finish date of April 4, 1986, and upon exceeding the date failed to administrative 1y declare 3/4.7.11 (Fire Barrier the seals Penetrations inoperable Action and .fully)

Requirements The satisfy T/S licensee's evaluation showed that for approximately 99% of the seals T/S action reguirements were satisfied. For the remaining 2 seals, required continuous watches and hourly patrols had not been establishe The licensee attributed the cause to personnel errors made in the assumption that the seals were operable until determined otherwise by inspection and that the hourl maintained since March 3, 1986, met y firewatch the T/S actionpatrol established and requirement The licensee subseguently performed a 100% visual inspection of fire barrier seal This effort identified two defective seals for which the T/S required compensatory action had not been established; seal 13150530 did not have the required continuous firewatch and seal 13250699 did not have the required hourly firewatch patro On March 20, 1987, the inspector met with licensee's management and departmentrepresentativesofQualityAssurance, Compliance,and Safety. The inspector determined that although the event was of little safety significance, it did indicate past procedural and practice deficiencies. The inspector determined that the licensee put forth considerable effort to identify, evaluate, and correct the root cause; however, the Event Report, LER 87001-00 failed to address surveillance task scheduling and tracking deficiencies, anddid not take credit for corrective actions implemented which includedprocedurerevisionsmadetoQDP-22-04100(Compliance Surveillance Requirement Trackinc) which provides shift supervisor's notification. The revised procecure provides for progressive notifications upon approaching late finish dates and requires that an Incident Report be initiated when the date is exceeded. The licensee stated that root cause and corrective action sections of the pending supplemental report to the LER would address these point :

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Technical Specification 3/4.7.11, " Fire Barrier Penetration Surveillance Requirement 4.7.11.1.c," requires that at least once per 18 months the licensee perform a visual inspection of at least 10% of each type (mechanical and electrical) of sealed penetration erforming the surveillance, The specified including late finish the allowable date for extension (Tp/S 4.0.2), was April 4, 198 T/S 4.0.3 specifies that failure to perform a surveillance requirement within the specified time interval shall constitute a failure to meet the operability requirements for a Limiting ConditionforOperation(LC0).

The licensee's exceeding the late finish date for the surveillance required by T/S 4.7.11.1.c and subsequent failure to satisfy T/S i LC0 3.7.11 action requirements, is a second example of failure top (483 /87005-01b(DRP)).erform required surveillances at specified intervals d. (Closed) LER 483/85052-00, 483/86022-01, and 483/86037-00:

Feedwater Isolation / Auxiliary Feedwater Actuation Resulting From Circuit Card Failures. The LERs document events resulting from circuit card failures which resulted in reactor trips on l December 9, 1985, and June 21, 1986, and a Turbine Driven-Auxiliary i Feedwater Actuation on November 5,198 The licensee's investigation of this matter included a common mode failure analysis and the evaluation of reportability under 10 CFR Part 21. The valve control modules and input buffer cards were also sent to the vendor (Consolidated Controls Corp. (CCC)) for analysi The vendor determined that no failure trend existed and attributed the cause to random failures. Licensee's analysis determined the following:

Ceramic capacitors of this type are considered to be very reliabl The design appears to be conservative - 100 Volt (V) rated, used on a 48 V suppl Approximately 360 of these capacitors are installed on the Main Steam Feedwater Isolation System (MSFIS) input buffer cards (<1.0% failure rate).

No reported failure of these capacitors at the Wolf Creek Plan An analysis by CCC did not indicate a significant failure trend for these capacitor The licensee determined that no additional action was warrante , . . . - . .. -.. -. - -- ~ . - . . ._

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The inspector determine'd that there has been no reactor trips ,

resulting from related card failure during the past eight month l The licensee has-taken appropriate action in this matter. The '

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above LERs are considered close ! (Closed) LERs'.483/84004-01, 483/84004-02, and 483/84004-03:

Inadvertent Engineered Safety Feature Actuation Si An  ;

Engineered Safety Feature Actuation Signal wa (ESFAS)gnal. initiated

, by a radiation monitor causing a Containment Purge Isolatico Signal (CPIS) and a Control Room Ventilation Isolation Signal

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(CTVIS). The event was initially reported in LER 84-004-00, inspected,.and closed in NRC Inspection Report N0. 483/84048(DRP).

! Similar recurrences prompted additional licensee response and F

supplemental event reports. The licensee determined that the events l were not the result of actual radiation levels but of spurious '

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, electronic signal ,

The licensee's investigations into the cause for the spurious alarms revealed an incompatibility between the software and hardware in the

RM-80 microprocessing unit for the radiation monitors. Through continued discussions with GA Technologies Inc , it was discovered

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times overrun" software to accommodate scintillator pulse counter

, overflow.- However, the Callaway Plant does not require the use of this software and therefore the supporting hardware was not

installed. System interface problems were corrected through the

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hardware change processed by Callaway Modification Package CMP 85-0046B. The work was performed on Work Request (WR) Nos. 44852 through 44860 and completed March 21, 1986. There has been no l

recurrence of this proble This item is considered closed.

! Response to Regional and Headquarters Requests (25019) (92701)

Low Temperature Overpressure Protection System (LTOPS)

An inspection of the LTOPS was performed to verify implementation

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of the licensee's commitments, as described in the Callaway Plant Safety Evaluation Report NUREG-0830, relating to overpressure ,

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transient protection. Inspection requirements, defined in Temporary Instruction (TI) 2500/19, were addressed during this inspection.

4 The inspection included the review of system design / modification

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documents, administrative controls and procedures, and operator training.

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(1) System Design and Modifications

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The Callaway Plant LTOPS utilizes redundant Class 1E equipment  !

' andelectricalpowersupalies)whichincludestwopowerand operated relief valves ()0RVs two spring loa

, valves located on the suction side of each residual heat removal (RHR) system train. The initial LTOPS design provided l

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lthe PORV Subsequent equipment modifications were made to-the RHR system to permit additional use of the RHR suction:

. relief valves. The LTOPS design,-including the modification

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was included in NRR review and approval (SER Sup Section5.2.2)aspartofthelicensingprocess.plementNo.5,.

.Callaway Plant Operating License NPF-30, Condition C. (12), required that equipment modifications be made to the RHR s Inspection and closeout of license Condition C. (ystem.12)is documented in NRC Inspection Report No. 483/86016(DRP).

(2). Administrative Controls and Procedures The licensee has implemented appropriate ~ administrative controls and procedures pertaining to low temperature pressure transient protection. The procedures provide instructions and precautions -relating to water-solid conditions, and specify required tests and surveillances following maintenance-and modifications. Additionally ConditionForOperation3.4.$.TechnicalSpecificationsLimiting 3 provides operability require-ments for the overpressure protection systems and includes periodic surveillance and test requirement The inspector determined that the licensee's LTOPS program satisfies Technical Specifications and that tests and surveillances are curren (3) Training ColdOverpressureProtectionSystem(COPS)trainingisincluded in licensee's training program for licensed operators. COPS is administered as part of the course titled, " Control Board Certification." This course is included in the initial

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qualification and requalification programs. The lesson plan covers applicable procedures and Technical Specifications and provides instruction on prevention recognition and mitigation of cold overpressure transients. il2500/19 is, considered close b. Degraded Motor Leads in Limitorque D_C_ Motor Operators

- A request was received from IE as to he actions and findings by the L licensee on Information Notice 0.4) R 008, dated February 4,1987.

L The IN addressed problems ocy ng s th Limitorque valve operators with DC motors having leads insulated with Nomex-Kapton materia Inspection in this matter included the review of IN No. 87008, interviews with licensee engineering and quality assurance personnel and tk review of quality records. The inspection determined that motors, with problems as described in the notice, had not been installed at Callaway; however, one was found in spare parts storage. The motor has been tagged, restricting its use, pending further dispositio .. . . .

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The inspector determined that the licensee was responsive and has taken appropriate action. This matter is considered close No violations or deviations were identifie . Training and Qualification Effectiveness (41400 and 41701)

An evaluation of training and qualification effectiveness was made during the inspection period. The evaluation included discussions with personnel, observations of plant evolutions in progress, and the review of personnel performance during plant event Radiological controls established for the maintenance outage included special ALARA training, thorough surveys, posting and barrier Inspector's observations of Health Physics (HP) procedures and practices employed by HP, craft personnel, and operators demonstrated effective training in this are On several occasions control room operations have been observed during unplanned occurrences. 0]erating crews' performance during such events demonstrated operators' a)ility to promptly identify and correct off-normal conditions, and is indicative of effective trainin Events at the plant and applicable events occurring at other sites are factored into the requalification program. The operators appear to be knowledgeable of events in the industry and how they may be affecte Ne violations or deviations were identifie . Operational Safety Verification (71707)

The inspectors observed control room operations, reviewed applicable logs and conducted discussions with control room operators throughout the inspection period. The inspector verified the operability of selected safety related systems, reviewed tagout records, and verified proper return to service of affected components. Tours of the reactor, auxiliary, and turbine buildings were conducted. During these tours, observations were made relative to plant equipment conditions, fire hazards, fire protection, adherence to procedures, radiological control and conditions, housekeeping, security, tagging of equipment, ongoing maintenance and surveillance, containment integrity, and availability of safety related equipmen The inspectors observed licensee's maintenance of good a terial conditions within the plant, housekeeping, component tags and locks maintained. Radiological controls have been effectively implemented for the current maintenance outages, these include; personnel staffing, training, surveys, posting, and barrier No violations or deviations were identifie _:

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. Monthly Surveillance (61726)

The inspectors reviewed or observed selected portions of the Technical Specifications required surveillance testing during power operation Items which were considered during the ins)ection included whether adequate procedures were used to perform t1e testing, test instrumentation was calibrated, test results conformed with Technical Specifications and procedural requirements, and the test was performed within the required time limits. The. inspector determined that the test results were reviewed by someone other than the personnel involved with the performance of the test, and that any deficiencies identified during the testin personnel.g were reviewed and resolved by appropriate management The inspector's overview of the licensee's surveillance )rogram showed that the licensee had developed and implemented a com)reiensive and effective program. However, a few deficiencies have 3een identified

.during licensee's review process. These appear to be isolated omissions made during the initial listing of required valve surveillanc The licensee is conducting evaluations to ensure program completeness and has dccumented personnel and administrative oversights regarding the surveillance program in Licensee Event Report No violations or deviations were identifie . Monthly Maintenance (62703)

Selected portions of the plant maintenance activities on safety-related systems and components were observed or reviewed to ascertain that the activities were performed in accordance with approved )rocedures, regulatory, guides, industry codes and standards, and t1at the performance of the activities conformed to the Technical Specifications. The following items were considered during these inspections: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using, approved procedures and were inspected as applicable; functional testing and/or calibration was performed prior to returning the components or systems to service; parts and materials that were used were properly certified; radiological controls were implemented as necessary; and, fire prevention controls i were implemente Work Request N Activity Multiple WRAs and "A" diesel generator outage PM packages Multiple WRAs and "B" diesel generator outage PM packages Generic WRA "A" diesel generator

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No violations or deviations were identifie . ESF System Walkdown (71710)

The operability of selected engineered safety features (ESF) was confirmed by the inspectors during a walkdown of the accessible portions of the system. The following items were included: procedures match the plant drawings, equipment conditions, housekeeping, instrumentation and valveandelectricalbreakerlineupstatus(perprocedurechecklist);

locks, tags, jumpers, etc. are properly attached and identifiable. The following systems were walked down during this inspection period:

"A" Emergency Diesel Generator Emergency Core Cooling System (ECCS) - Accumulators ECCS - Subsystems Residual Heat Removal (RHR)

SafetyInjection(SI)

CentrifugalChargingPump(CCP)

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Off-site Power - Shutdown No violations or deviations were identifie . Exit Interviews (30703)

Theinspectormetwithlicenseerepresentatives(denotedunderPersons Contacted) at intervals during the ins)ection period. The inspector summarized the scope and findings of t1e inspection. The licensee representative acknowledged the findings as reported herein. The inspector also discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspector during the inspection. The licensee did not identify any such documents / processes as proprietar . .. .

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