IR 05000483/1983002

IE Insp Rept 50-483/83-02 on 830223-24 to 0314-17. Noncompliance Noted:Failure to Include Design Document Limits & Precautions in Safety Injection Accumulator Preoperational Test Procedure CS-03EP01

ML20204G102
Person / Time
Site:	Callaway
Issue date:	04/18/1983
From:	Reyes L, Ring M, Wohld P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20204G057	List: IR 05000483/1983002 ML20204G053 ML20204G081
References
50-483-83-02, 50-483-83-2, NUDOCS 8305020357
Download: ML20204G102 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/83-02(DE)

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Docket No. 50-483 License No. CPPR-139 Licensee: The Union Electric Company Post Office Box 149 St. Louis, MO 63166 Facility Name: Callaway, Unit 1 Inspection At: Callaway Site, Callaway County, MO Inspection Conducted: February 23-24 and March 14-17, 1983 9.4. Mddd Inspectors: P. R. Wohld /$ 3

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M. A. Ring 4//S[ff 3 f)&rf &

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Approved By: A ef MD Test Program Section Inspection Summary Inspection during the period of February 23-24 and March 14-17, 1983 (Report No. 50-483/83-02(DE))

Areas Inspected: Routine announced inspection to observe preoperational testing, review and discuss the preoperational test program and test pro-cedures, inspect and update the status of open items, int.pect the plant for general readiness for testing, equipment protection and cleanlines The inspection involved 82 inspector-hours onsite and 43 inspector-hours offsite by three NRC inspectors, including no inspector-hours onsite during

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off-shift Results: One item of noncompliant.e was identified. Of the four areas inspected, no items of noncompliance or deviations were identified in three areas; one item of noncompliance was identified in the other area (failure to include design document limits and precautions in test procedure -

Paragraph 4).

8305020357 830418 PDR ADOCK 05000483 0 PDR

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DETAILS 1. Persons Contacted

• J. F. McLaughlin, Assistant to Vice President - Nuclear

• J. N. Kaelin, Superintendent of Startup

• D. Brady, Startup Program Coordinator

• R. L. Powers, Superintendent of Site QA

• M. J. Pechar, QA Consultant

• Q. B. DuBois, QA Consultant

• R. L. Huston, Test Program Coordinator

• J. L. Harden, Assistant Startup Program Coordinator

• W. F. Minerich, Startup Group Supervisor J. V. Laux, Supervisor Engineer, QA Startup

• Denotes those attending the exit intervie Additional plant technical and administrative personnel were contacted by the inspectors during the course of the inspectio . Licensee Action on Previous Items (CLOSED) Open Item (483/82-11-01): This item dealt with temporary alterations performed per test procedures being exempted from the requirements of SAI-11 (temporary alterations procedure) without invoking the applicable requirements of SAI-11. The inspector reviewed Revision 5 to SAI-11 which now requires independent verification and contrasting length and color for jumpers and lifted leads even if performed pec test procedure. The inspector also reviewed SAI-5, Revision 5, December 12, 1982, "Preoperational Test Procedure Develop-ment, Test Conduct and Results Approv ]", paragraph 3.4.1.K which requires that temporary alterations not specifically controlled by the preoperational test procedure be documented and controlled by SAI-1 Additionally, the licensee committed to ensuring that documentation of the independent verification requirements will be available in the test procedures. Based on the above discussion, the inspector considers the item close (CLOSED) Open Item (483/82-11-02): This item dealt with development of instructions for coordinating Startup and Operations. The inspector reviewed Revision 5 of SAI-5 dated December 2, 1982, which makes the System Startup Engineer responsible for adequate briefing and coordina-tion of all test participants as necessary to ensure safe operation of equipment. Additionally, the inspector reviewed Revision 1 of SAI-18,

" Release for Operations", dated December 10, 1982, and Revision 0 of Operations Procedure APA-ZZ-00380, " Temporary System Modifications,"

dated January 29, 1983. On review of specific tests, the inspector noted that on a case basis the test procedures require notification or opera-tion via the control room. Based on the above discussion, the inspector considers the item close *

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(CLOSED) Open Item (483/82-11-03): This item dealt with a lack of programmatic instructions for ensuring calibration and periodic recali-bration for permanent plant instruments used during testing. The inspector reviewed SAI-5, Revision 5, paragraph 3.4.1.I, which requires the System Startup Engineer to ensure that any installed instrumentation used to obtain test data is in current calibration. Additionally, cali-bration should be performed within 90 days prior to the test start date or as specified by the Engineering Coordinator or the JTG. These re-quirements meet or exceed recognized standards on instrument calibratio Therefore, the inspector considers the item close (CLOSED) Open Item (483/82-11-04): This item dealt with administrative controls for verifying instrument calibration status, specifically, the use of a calibration sticker program. The inspector reviewed Revision 6 of SAI-16, " Electrical and Instrument Component Test Program Management",

which in paragraph 3.3.2.G requires affixing of a tested / calibration sticker with data of calibration on instruments. Since the Startup Program now intends to use calibration stickers, this item is considered closed. Review of the operations program verifying instrument calibra-tion will be conducted at a later time by the Resident Inspector's offic (OPEN) Open Item (483/82-11-11): During the inspection, the inspector was given a copy of Generic Test Procedure, Steady State Vibration Measurement, C-06SS01, Revision 0, dated March 7, 1983, which was written to resolve the pipe vibration program question raised by this open ite Subsequent to the inspection, the procedure was reviewed briefly, and concerns relative to applicable requirements, acceptance criteria, and practical program considerations were relayed to the applicant's Mr. John Marden. This item remains ope . Timeliness of Test Procedure Submittal to Region III The submittal of test procedures for NRC review sixty days prior to test performance was discussed at length with the Union Electric staf The sixty days is a commitment in the FSAR and required by Regulatory Guide 1.68. Region III has waived the requirement on individual tests when it was reasonable to do so. However, this has caused increasing problems with the timeliness of Region III procedure reviews. As dis-cussed with the staff, Region III will consider an occasional waiver of the sixty day requirement based on our review requirements. This must be done through the Region III Test Program Section Chief (currently Mr. L. A. Reyes) or his designee. To avoid unnecessary delay, it was agreed that a waiver could be granted via phone and that Union Electric would document the call, sending a copy to the Test Program Section shortly thereafte I  ;

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No items of noncompliance or deviations were identifie . SI Accumulator Preoperational Test Procedure Review (CS-03EP01)

The inspector reviewed the SI Accumulator test' procedure CS-03EP01 and determined that the test procedure generally meets the test objectives outlined in Chapter 14 of the FSAR and applicable portions of Regulatory Guides 1.68 and 1.7 The inspector noted that the test procedure is more comprehensive than the FSAR Chapter 14 abstract indicates it would need to be. This is necessary, however, for the test to meet applicable Regulatory Guides, et The adequacy of Chapter 14 and the identification of criteria sources in response to Chapter 14 FSAR Question 640.10 were discusse The applicant noted the inspector's comments in these area One test procedure deficiency was identified in that SI Accumulator temperature control was not included to protect the accumulators when pressurized as indicated _necessary by the. Westinghouse " Precautions, Limitations and Setpoints for Nuclear Steam Supply Systems," Revision 1, April 1981. 'This was identified after the accumulators were pressurized in possible violation of the tank temperature / pressure limit The omission of proper precaution in the test procedure and subsequent pressurization of the accumulators without adequate temperature control-is an item of noncompliance (483/83-02-01).

No other items of noncompliance or deviations were-identifie . SI Accumulator Preoperational Test Witnessing (CS-03EP01)

- The inspector observed a portion of the preoperational test in progress and. verified that approved procedures were in use, that the test engineer was knowledgeable and capable of performing the test, and that test .

support personnel were aware of their responsibilities. ~The test was properly terminated when difficulties were identified with the installed level instrument While observing testing, the inspector questioned the possibility of

a piping system water hammer occuring in unfilled accumulator injection lines during an accumulator blowdown. The test engineer agreed to filling the lines as much as possible prior to the blowdown as a precau-i tion and to observe the lines during blowdown. Because of testing delays i and a change in test personnel, the inspector called the applicant l

(Mr. R. L. Huston) on March 25, 1983 and requested that such line filling j be considered for addition to the test prerequisite sectio Mr. Huston

agreed that this would be considered.

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No items of noncompliance or deviations were identified.

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, ' V-(Class IE) System Preoperational Test Procedure Review (CS-03NB01)

The inspector reviewed the test procedure and determined _that there is a design change, DCP E16, outstanding against the system that needs to be completed to satisfy-the " degraded voltage" concern expressed in the NRC Safety Evaluation Report, October 1981, Item 8.3.1.2, pages 8-09 to'8-13. The applicant indicated that_ retesting will be done when the

, design is implemented. For tracking purposes only, this retesting will be tracked as Open Item (483/83-02-02). ,

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The inspector noted'that the test appeared to meet all applicable test-requirements for the design as is but with a.somewhat heavy dependence

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on component testing. Test engineering personnel indicated that testing completeness was carefully considered in reviewing the component tests used in support of the preoperational tes The FSAR Chapter 14 test. abstract indicates that system instrumentation is to be verified. However, no criteria is given in the abstract or'in-the criteria section of the test procedure for instrumentation. Inspec-tion of instrumentation criteria important to system operation, particu-larly the setpoint. curves for the_ under _ voltage alarm and load shed

. relays, is needed on whatever design is in use at fuel loading. This I will be_ tracked as Open Item (483/83-02-03).

No. items of noncompliance or deviations were identifie . Exit Interview The inspector met with applicant representatives (denoted in Paragraph 1) on March 17, 1983. The inspectors summarized the' scope and findings of the inspection. The licensee acknowledged.the statements made by the inspectors with respect to items discussed in the repor ,

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