IR 05000483/1987033

Safety Insp Rept 50-483/87-33 on 871007-17.Violations Noted: Failure to Perform Adequate Preoperational Test & Failure to Promptly Rept Condition Adverse to Quality.Major Areas Inspected:Mispositioned Balancing Damper

ML20236K606
Person / Time
Site:	Callaway
Issue date:	11/04/1987
From:	Hinds J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236K586	List: IR 05000483/1987033 ML20236K584
References
50-483-87-33, NUDOCS 8711090285
Download: ML20236K606 (8)

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I U.S. NUCLEAR-REGULATORY COMMISSION REGION III .

Report No. 50-483/87033(DRP) f Docket No. 50-483 License No. NPF-30 i

Licensee: Union Electric Company-  !

Post Office Box 149 - Mail Code 400 i St. Louis, MO 63166 i Facility Name: Callaway Plant, Unit 1 Inspection At: Callaway Site, Steedman, Missouri'

Inspection Conducted: October 7-17, 1987 Inspector: B. H. Little k/Y J

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// 87 Approved By:d pir> Re.actor M. Hinds, Projects Chief Section 1A Date

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l Inspection Summary

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Inspection on October 7-17, 1987 (Report No. 50-483/87033(DRP))

Areas Inspected: A special unannounced safety. inspection by the Senior -l Resident Inspector regarding mispositioned balancing damper No.'GKD 0324 of  ;

Control Room Emergency Ventilation System (CREVS) Train "B." l Results: Two apparent violations were. identified (failure to perform an 1 adequate preoperational test and failure to'promptly correct, document, and report a condition adverse to quality - Paragraph'2.b(2)). The appropriate enforcement action for these violations will be determined and communicated to i the licensee by separate correspondenc )

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DETAILS -

q 1. Persons Contacted

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R. Affolter, Superintendent, Systems Engineering

• J. Blosser, Plant Manager

• W. Campbell, Manager, Nuclear Engineering D. Hollabaugh, Supervising Engineer, Systems Engineering L. Kanuckel, Quality Assurance (QA) Supervising Engineer J. Laux, Superintendent, QA Technical Support ,

K. Schweiss, System Engineer 1 T. Sharkey, Supervisor, Compliance B. Standfield, QA Engineer i

• Denotes those present at one or more exit interview In addition, other members of.the operations, compliance, and engineering staffs were contacte . Inspection of Control Room Emergency Ventilation System Operability Background

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During a special safety inspection from September 8-11, 1987, of a Licensee Event (LER 87-013-00) relating to inoperability of the ,

CREVS, additional regulatory concerns were identified with regard :

to the position of CREVS Train B balancing damper No. GKD 032 While performing system flow checks to evaluate Control. Room (CR)

pressure, the licensee found that damper GKD 0324 had been positioned so that the flow to Control Room Air Conditioning Unit Equipment Room (CRACUER) B was approximately 160 CF The licensee left the damper in the as-found condition upon completion _of the flow check !

By design, the flow balancing damper provides manual regulation of supply air to the CRACUER (CREVS Train B). The CREVS, when balanced in accordance with design (Bechtel Drawing'No. M2H15210),

draws 300 CFM from the room and supplies a flow of 350 CFM through GKD 0324. This balance maintains a positive pressure in the room { i and thereby precludes inleakage from the Auxiliary Building in the j event of a design basis accident, and subsequent increased doses !

to Control Room personne l The inspector's concern relating to the position of the damper was discussed with the licensee at the close of the September 8-11 l inspection and documented as Unresolved It' ems in,NRC Inspection ~ l Report No. 50-483/87023(DRSS).

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On October 5, 1987, the licensee determined (based on a preliminary d engineering evaluation of GDC-19 calculations) that the mispositioning of damper GKD 0324 adversely affected CREVS Train B functionalit l The licensee documented this matter in Incident Report (IR) No.87-204 I and notified the NRC using the Emergency Notification System (Four Hour Notification).

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i A special safety inspection was performed to assess the licensee -

activities associated with the mispositioning of CREVS Train B i balancing damper GKD 032 The inspection included the following:

• Review of documentation: Request for Resolution (RFR) j No. 4210, irs87-173 and 87-204, Work Requests (WRs) >

No. 104769 and No. 105377, Surveillance Procedure No. ESP-GK-03009, Preoperational Test Package No. CS-03-GK01, and Bechtel Drawing No. M2H1521 * Interviews with licensee personnel from the following departments: Compliance, Engineering, Operations and Quality Assuranc b. Inspection Findings (1) Event Chronatogy May 25, 1984 The CREVS preoperational test (CS-03-GK01)

was completed. Train A developed a Control Room positive pressure of 0.48 inches H2 O relative to the outside atmosphere. Train B developed '

a Control Room positive pressure of O.26 inches H2 March 4, 1986 The 18-month Inservice Inspection was completed. Train A developed a CR positive pressure of 0.36 inches H )

Train 8 developed a CR positive pressure I of 0.62 inches H2 July 9, 1987 A CREVS surveillance test was performe Train A failed to develop a positive '

pressure > 0.25 inches H 2O due to

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,j breached electrical penetrations j (IR No.87-122). j l

August 10, 1987 The licensee issued LER No. 87-013-00, which reported the inoperability of the CREVS and T/S 3.0.3 entry due to breached electrical penetration _ - _ _ _

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August 14, 1987 While performing flow measurements (WR No. 104769).of CREVS Train B, utility personnel found damper GKD 0324 in a nearly closed position. ' The damper was left in this position, resulting in a flew of approximately 160 CFM to the ,

CRACUE No IR was issue August 19, 1987 The-licensee's Engineering Department ,

initiated RFR 04210, which documented the concern of how CRACUER supply and exhaust flows affect Control Room pressure. A resolution need date of October 25, 1987, was indicated.on the RF I September 8-11, 1987 The NRC Region III inspection of l

LER 87-013-00 identified unresolved items relating to the position of damper GKD 0324.

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September 10, 1987 The licensee issued IR No. 87-73, documenting the event of August 14, 1987 relating to the GK0'0324 damper

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l September 12, 1987 The plant entered Mode 5 (Cold Shutdown).  ;

October 5, 1987 The licensee issued IR No.87-204, I based on the results of a preliminary engineering evaluation which determined that the mispositioned ,

damper functionally degraded CREVS 1 Train B and that Control. Room operators f would receive doses exceeding GDC-19 !

criteri The.NRC was notified of the event via the ENS (Four Hour Report). j October 8, 1987 The balancing damper was correctly positioned during performance of a .

CREVS Train B flow balance per WR No. 10537 (2) Document Review and Evaluation of Events Chapter 9 of the SNUPPS Final Safety Analysis Report (FSAR)

provides a description of the CREVS. The system is designed to meet GDC-19' criteria. The FSAR does not describe the i

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CRACUER flow / pressure requirement However,.Bechtell Drawing ;

No. M2H15210 specifies. a supply flow (controlled by damper .

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GKD 0324)'of 350 CFM with a room exhaust' flow of 300 CFM;,

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therefore, the system is designed to maintain the room unde a_ positive pressur ,

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Preoperational Test Package CS-03-GK01 does'not provide acceptance. criteria pertaining to the CRACUER air flow; governed by the GKD1 0324 damper positio .

The damper was not: included on the sketches or_ damper lists which were used in performance of the tes Air flows to and from the room were not documented in.the Preoperational Test Package. 10.CFR.Part 50, Appendix B,-

Criterion XI (Test Control) requires that. test. procedures?

incorporate the requirements and. acceptance _ limits contained in applicable design documents. .The-licensee's failure to incorporate into test procedures the design-flows 'for:the CRACUER as specified in Bechtel Drawing No. M2H15210 is.an apparent _ violation of 10 CFR 50, Appendix B, Criterion XI (483/87033-01(DRP)).

The surveillance requirements specified for Limiting Condition .

for Operation 3.7.6 (which requires operability of both CREVS trains in all modes) do not require. initial or. periodic verification of CRACUER pressure or, air flow. Periodic (once per 18 months) verification of CR. pressure is' required by Technical Specification (T/S) 4.7.'6.e and is obtained during the performance'of Surveillance Procedure ESP-GK-03009. The test was performed in' March 1986. The. test' data showed that CREVS Train B developed a CR positive pressure of.0.62 inches-H2 0, which was a significant increase from the value (0.26 inches H2 O) obtained during the preoperational= test performed in May 1984. The CR pressure'obtained.during the 1986 surveillance satisfied.T/S requirements, and apparently no:

additional evaluation was performed. However, the incre~ase in CR pressure indicated that_a' change had occurred in CREVS Train B, possibly the result of the closing of. damper-.

GKD 032 The change occurred sometime following the 1984:

preoperational test and prior.to the 1986 surveillanc Through the review.of plant records and personne1~ interview, '

the inspector was unable to determine when the' balancing damper was mispositioned. The licensee's review'of work documents found that no work-authorizing documents had been issued for GKD 032 The location of the damper (approximately 20Lfeet'aboveLthe !

floor) makes it unlikely that it had been inadvertentl ;

mispositioned. _The inspector.could not rule out a dampe i position change due to air flow or vibration, as the damper could be moved by hand without loosening _the wing nut, but .

it was found to be snu I

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On August 14, 1987, while performing CREVS flow measurements, utility personnel found Damper GKD 0324 in a nearly closed position. (The flow measurements were in response to the CREVS event involving breached electrical penetrations [LER No. 87-013-00] and the observed difference in CR pressure during Train A and Train B tests.) The system engineer was involved in obtaining the flow measurements and was aware that the design supply flow specified for the CRACUER was 350 CFM (Bechtel Drawing No. M2H15210). Attempts made to increase the flow to the room caused pressure to decrease in the Control Room. The damper was left in the as-found position, providing a flow of approximately 160 CFM to the J CRACUE The action was taken based on a recognized need to '

maintain the T/S specified CR pressure. Based on the informal phone discussions between plant and corporate engineering staff members, the determination was made that the reduced flow to {

the CRACUER did not present an " operability" issue with regard ]

to the CREVS. The shift supervisor placed a " hold" on per- i formance of flow balancing (WR No. W104769). On August 19, l

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1987, the plant engineering staff issued RFR No. 04210 to obtain formal resolution of this matte The RFR specified a need date of October 25, 1987. The mispositioned damper j was not documented in an incident repor i

'f The inspector interviewed engineering personnel to assess the {

basis for the initial engineering judgement (August 14, 1987) I that less than design flow to the CRACUER did not render the !

CREVS Train B inoperable. It appears that the judgement was based on the following considerations:

• The FSAR does not address CRACUER Room pressure or air flow * T/S surveillance requirements do not specify periodic verification of CRACUER pressure or air flow l

• Preoperational Test CS-03-GK01 did not provide acceptance criteria relating to damper position, room pressure, or air flo i

• CRACUER conditions were not included in the CR dose i calculations (GDC-19 criteria).

A review of the event chronology points out the licensee errors l made following identification of the mispositioned damper. On August 14, 1987, while performing CREVS Train 8 flow measurements, utility personnel found balancing damper GKD 0324 mispositioned, )

resulting in reduced flow to the CRACUER. The as-fnund air flow was approximately 160 CFM. Bechtel drawing M1H15210 specifies a design flow of 350 CFM. Although damper adjust-ments were attempted, the damper was lef t in approximately the as-found condition. The reduced flow through the damper-l 6 l

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represented a deviation from a design document and a condition adverse to quality. The licensee's initial assessment of the degraded flow condition failed to adquately ascertain system functionality and therefore resulted.in untimely corrective action. Additionally, utility personnel failed to document the mispositioned damper on an incident report, contrary to administrative procedure APA-ZZ-00500, " Nonconforming Operations Reporting and Corrective Actions." This matter w's subsequently documented in IR 87-173 on September 10, 1987, after the mispositioned damper was considered to be an Unresolved Item by an NRC Region III inspecto J 10 CFR 50, Appendix B, Criterion XVI.(Corrective Action) requires )

that conditi.ons adverse to quality be promptly identified and j corrected, and that the conditions and associated corrective :

actions be documented and reported to appropriate levels of !

management. The licensee's failure to promptly correct, 1 document, and report the degraded flow condition resulting from j the mispositioned damper is an apparent violation of 10 CFR 50, j Appendix B, Criterion XVI (483/87033-02(DRP)). j On October 5, 1987, based on the results of a preliminary i engineering evaluation (RFR 04210 and IR No.87-173), the licensee determined that Train B of the CREV5 b d been .

functionally degraded due to the incorrect position of i balancing damper GKD 0324. The licensee determined that i this condition may have existed since the issuance of the .!

operating license. Preliminary calculations showed that the dose to Cnntrol Room operators would exceed G0C-19 dose guideline Based on the findings of this inspection, Unresolved Items j 483/87023-03 and 483/87023-04 are considered closed and will be {

tracked as the above cited violation '

3. Licensee Corrective Action  :

i Balancing damper GKD 0324 was correctly positioned during performance of a complete CREVS Train B flow balance on October 8',1987 (WR No.105377). 1 A complete flow balance of Train A was al'so performed. No deficiencies ;

were note ]

The system engineer, engineering supervisor, and involved operations personnel have been counseled on the need for timely identification and j resolution of significant changes to safety-related system The event will be included in the required reading lis <

The event will undergo a review by the licensee's event evaluation team for evaluation of the root cause and corrective actio ,

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' . Safety Significance The Basis -for Technical Specification 3.7 6 states,' int part, thatzthe . .)

operability of the Control Room Emergency Ventilation System ensures.that  ;

the Control Room will remain habitable- for operationsipersonnel durin 'j and following all credible accident condition l

>j The licensee is obtaining a detailed. safety evaluation from Bechtel' ;

i Co.rporation to ascertain CREVS acceptability relative to GDC-19: criteri 'i CREVS Train Alwas. fully operable during the period'that the Train B- .

damper was mispositioned and would have provided as'sociated protection .{

to CR personnel, excepting periods when the CREVS was. degraded due t O bre. ached electrical penetrations (June through July 1987) as reporte y in LER 87-013-00 and when Train A was' removed'from service.for. testing or maintenance. .CREVS Train B was functional in all other respect )

The event posed no significant threat to"public or plant safety basedl )

on the operability and capabilities of the redundant CREVS trains and'the' j

. low probability of a-design basis accident occurring. atla time when both' O CREVS trains were in a degraded. conditio However, the event increased q the potential for unfiltered inleakage and an increase in dose to-CR ,1 personnel, = and is considered significant based on initial . test!per.formance 9 deficiencies and untimely corrective action following. deficiency,. H identificatio , Exit Interview j q

The inspector met with licensee representatives' (denoted .under Persons ' d Contacted) at intervals' during the inspection period. The inspector ]

summarized the scope and findings of.the. inspection. The licensee j representatives acknowledged the~ findings as' reported herein. The inspector also discussed the likely informational content of the' D

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inspection report with regard-to documents or processesLreviewe by the inspector duri.ng the inspectior.. The licensee did not. identify  !

any such documents / processes as proprietar I i

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