IR 05000483/1989014

Insp Rept 50-483/89-14 on 890717-0803.No Violations or Deviations Noted.Major Areas Inspected:Design Changes & Mod & Dedication of Commercial Grade Equipment for safety- Related Applications

ML20246K722
Person / Time
Site:	Callaway
Issue date:	08/28/1989
From:	Lougheed V, Merholz M, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246K718	List: IR 05000483/1989014 ML20246K714
References
50-483-89-14, NUDOCS 8909060056
Download: ML20246K722 (7)

Text

A w

}

..

' '

-

,

11 .

,

'U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/89014

-

' Docket No. 50-48 ' License NO. NPF-30

-.

' Licensee: Union Electric Company Post Office Box 149 - Mail Code 400:

'

St. Louis, M0 63166 Facility Name: Callaway Nuclear Plan Inspection At: Steedman, MO 65077 Inspection conducted: July 17.through August 3, 1989

. Inspectors: 2g/g-w,sp/

. R. Merholz Date P/19,/p,9

'Datt /.

Also Inspe g: T. A. p jon Approved B

'

M. P. Ylips, Chief Mff

Operational Programs-Sectio Date Inspection Summary Inspection on July 17 through August 3, 1989 (Report No. 50-483/89014(DRS))

Areas Inspected: Rot' tine announced inspection of design changes and-modifications and the dedication of commercial grade equipment for

-

safety-related applications. This inspection was conducted in accordance with Inspection Modules 37700, 38703, and 3782 Results: No violations, deviations, or open items were identified during this inspection. The licensee had a solid program in regards to both Engineering and Commercial Grade Procurement. The licensee's QA organization was effective in monitoring engineering and procurement activities and in g obtaining prompt resolution of issue r s

,

Q

-- _ . _ _ _

_ - _ - _ _ - _ _ _ _ - - - _ ___ - - . _ _ _ _ - _ _ _ - _ _ - _ _ . -- - _ _ _ _ _ _ _ .

.

. 1,

[".

-4

!: ,

l DETAILS

l'

' Persons contacted

'

Union Electric J. Blosser, Manager Callaway Plant W. Campbell,-Manager Nuclear Engineering

• R. Carlson, Supervising Engineer - Materials F. Dunn, Design Engineer .

• J. Gearhart. Superintendent - Q .

i

• R. Hamblen, Supervising Engineer _- Electrical / Controls

• T. Hermann, Supervising Engineer

• Klein, Materials Engineer K. Kuechenmeister, Assistant Manager - Materials

'

• M. Lane, Supervising Engineer'- Projects

+R. Lutz, Materials Engineer

• T. McFarland, Superintendent.- Projects Engineering

• J. McGraw,. Superintendent - Design Control W. Norton, QA Engineer

.

• S. Petzel, QA Engineer-

• C..Slizewski, Supervising Engineer - QA

• D. Wingbermuehle, Supervising Engineer - EQ/ Materials Support

,

U.S. Nuclear Regulatory Commission

• C. Brown, Resident Inspector

.B. Little, Senior Resident Inspector Other personnel were contacted as a matter of routine during the inspectio * Indicates those attending the exit interview held on-August 3, 198 . Design Changes and Modifications The inspectors reviewed eight permanent plant modifications and a selection of temporary modifications to determine if they had been conducted in accordance with regulatory and programmatic requirements, as expressed in the Callaway Administrative Procedure Description of Modifications (1) Modification 84-0523 " Addition of Check Valves in the Chemical and Volume Control System (CVCS)": This modification added check valves downstream of the Centrifugal Charging Pumps (CCPs) discharge lines to seal injection. The modification provided the operators with the ability to use either CCP to

_ - _ _ _ _ _ _ _ _ --

_ _ _ _ -

- _ _ -

7 ;

,

. .

supply seal injection. The modification was worked during the first refueling outage. During the last refueling outage, drain and vent lines were added to facilitate maintenance and testing of the check valve (2) Modification 86-0053 " Install Vent Path Between Diesel Generator Air Compressor and Aftercooler": This modification installed vent valves between the standby diesel generator starting air compressor and its downstream aftercooler. The vent valves were added to provide the ability to vent high-pressure air from the system during periodic maintenanc <

This lessened the safety hazard for maintenance personna (3) Modification 87-1032 " Steam Generator Level Reactor Trip-Modification": This modification revised the steam generator low-level trip logic by adding an environmental modifier, for situations where an adverse containment atmosphere existed; and a time delay during low power operation, to allow the operators time to regain control over the feedwater system. These changes necessitated a change to the Technical Specifications, which required NRC approval prior to implementatio (4) Modification 87-1115 " Core Exit Thermocouple Nozzle Upgrade":

This modification replaced the core exit thermocouple nozzle assemblies (CETNAs). The old CETNA design required approximately two hours each (for four assemblies to assemble, while the new design required 15 minute The new design allowed the lower conoseal to be left assembled during head removal and reinsta11ation. The new design also used Grafoil packing at the upper joint which sealed over a much larger surface ares and was seated using a single large drive nut, in comparison to the old design, which required sequential torquing of six seat screw (5) Modification 88-1004 " Emergency Fuel Oil Transfer Pumps": This modification revised the logic of the fuel oil transfer pumps such that they run continuously when the diesel is runnin The modification also added a vent line to the fuel oil day tan (6) Modification 88-1020 " Rewire Bypass Limit Switches on Motor Operated Valves (MOVs)": This modification moved the torque bypass limit switch to a separate rotor from the rotor where

' the close limit switch was terminated. This allowed the two I

limit switches to be adjusted separately, resolving one of-the concerns of IEB 85-03 and IN 86-2 (7) Modification 89-1001 " Removal of Autoclosure Interlock on Residual Heat Removal (RHR) Valves: This modification (a) Removed the automatic closure signal from the four RHR shutdown cooling suction valves, (b) Added main control room

L- - - - - _ _ __ _ - - . - _ - - - - - - - - - - - - - - - - - - - - - - - - _ _ _ _ _ _ _

- _ _ - . _ _ - _ _ _ - - .

,

l

~

,, .

.

alarms if two of these valves are open and RCS pressure is above a specified pressure, (c) Lowered the alarm setpoints for the other two-valves, and (d) Lowered the'setpoint for the RHR low flow alarm during Mode 6. Since these changes affected the Technical Specifications, NRC approval was required prior to implementing the chang (8) Modification 89-1013 " Increase Size of Steam Generator (S/G)

Manway Insert Screws": This modification increased the size of the 5/G manway insert screws from 1/4" to 5/16" diameter. This was necessary since the 1/4" screws were of marginal size and susceptible to breakage during manway removal or installatio The manway insert held a pasket in place during manway removal or installation, and ensured that only corrosion-resistant material contacted the primary coolant. (The insert was stainless steel while the manway cover was carbon steel). The manway cover is secured over the insert during installation, therefore, the insert screws performed their function only during assembly or disassembly of the manwa (9) Temporary Modifications: The twenty installed temporary modifications were reviewed for compliance to Callaway Administrative Procedure APA-ZZ-00605, and as to acceptability of their safety evaluation Inypection Result The inspectors reviewed the safety evaluations, design support documentation, procedural and documentation changes, training, and post-modification testing for the above modification ~

(1) Safety Evaluation: The safety evaluations were technically adequate and answered the questions of 10 CFR 50.59. One modification (88-1020) did not explicitly address the 50.59 questions in the safety evaluation, however the accompanying design input record (DIR) documented that they had been properly considered. Two of the modifications (87-1032 and 89-1001) required prior NRC approval: for these cases, the inspectors verified that such approval was obtained prior to the modification being implemented. The safety evaluations for the temporary modifications were extremely thorough and well-researched and indicated proper understanding of the requirements of 10 CFR 50.5 (2) Design Support: The inspectors reviewed the design support packages and supporting calculations, and held discussions with engineers and management of the Nuclear Engineering Department l

L- _ -- - - - - - - - - - - - - - - - _ - - - - - - _ - - - - _ _ - - _

- -

l .

.

. .

concerning the control of changes to the design process. The licensee had adequate procedures to control their design proces Adequate calculations were performed to. support the modification Additionally, the licensee had a definitive action plan for-capturing and documenting their original plant design basis,

' '

and were proceeding with this plan on schedul (3) Procedure and Documentation Changes: The inspectors reviewed the procedures and drawings affected by the modifications to ensure that they had been properly updated in accordance with Callaway Engineering Procedure EDP-ZZ-04004 " Implementation and Closure of Plant Modifications." Although the design package for modification 89-1001 indicated that a new preventative maintenance procedure was required, the inspectors verified that preventative maintenance requirements for the modification were covered in an existing procedure. Discussions were held with the responsible I&C engineer and system engineer, and the licensee corrected the original package to show the proper procedure numbe (4) Training: The inspectors verified that appropriate training was specified in the modification packages, that training required prior to operability had been performed, and that any remaining training was scheduled. A general discussion was held with training personnel as to the methodology used by the licensee to ensure proper training. Training for all the modifications reviewed was adequate and in compliance with the licensee's program, as described in Training Procedures TDP-ZZ-00009 and TDP-ZZ-00013.

l (5) Post-modification Testing (Note: Post-modification testing l was called " Retests" by the licensee). The inspectors reviewed the modification packages to ensure that adequate post-modification testing was required by the modification package. The inspectors also reviewed a number of the post-modification test package (a) One retest, associated with modification 89-1001, l identified a problem in the computer points associated l

with the modification. The test was found to be adequate, I by the licensee, based on information that was redundant with the malfunctioning computer points. The test engineer originally wrote work requests to fix the problems, but immediately voided them. This was documented in the test log along with a note that the concern had been discussed with the I&C computer people. The inspectors determined that no actions had been implemented to correct the original malfunctions. The licensee took immediate action to track down the problem and ensure that it was properly logged into i

'

l I 5

- - - _ - - - - - - - - - - -

_ - - - - - -

[ :

-

.

. .

.

the system. The inspectors had no concerns over the adequacy of the test, and were satisfied with the actions taken by the license (b) One retest, associated with modification 87-1032, required ~

calculations to be performed regarding the "as-found" and

"as-left" limit switch settings for the four limit switches on a motor-operated valve. Two of the four "as-found" calculations were performed incorrectly, while.the other two "as-found" and the "as-laft" calculations were correc The inspectors reviewed a sampling of other tests which used this procedure, including some which were not on the reviewed modifications. This retest was the only example where any problems with doing the calculations was foun The-inspectors were satisfied that the final "as-left" position for this retest was correct, and that the problem was an isolated cas No violations were identified in this are . Commercial Grade Procurement: The licensee had a separate Materials Engineering Group which handled all procurement for the plant. The

. inspectors held discussions with engineers and management of this department, Quality Control (QC), and Quality Assurance (QA) personnel involved with procurement. The majority of the licensee's modifications used either qualified spara parts (left over from construction) or parts purchased from a Part 21 supplier. Very few were purchased as commercial grade items. None of the modifications reviewed had any parts procured as commercial grad Commercial grade items were mainly used as rep 15 cement items for normal maintenance. The licensee had implemented a sophisticated "on-line" computer tracking system which tracked the replacement part from the time it was first requested by maintenance to when it was received by QC. The Materials Engineering Department determined the critical characteristics of the replacement part and provided input for the purchase order such as acceptable manufacturers and catalog numbers. They also provided instructions for the QC receiving personnel as to the critical characteristics to be verified during receipt inspectio The Materials Engineering Department only handled "like-for-like" replacements. If there were any changes to the item, then the Nuclear Engineering Department was requested to evaluate the acceptability of the change. This was done through the licensee's " Request for Resolution" process. The EQ/ Materia h Support group within Nuclear Engineering did the evaluation The licensee did not normally rely on commercial grade vendor paperwork as the basis for acceptability. They sample tested many items to ensure that they met the required critical characteristics. At the time of the

. _ . . _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ -

_ - ,

,

-.

. #

"t -

.

S*

. . . -v inspection, this was done through.a contract'with a commercial. testing lab. .However, the licensee intended ~to have the ability to do on-site

'

.

testing. -Test equipment-had been budgeted and was on order in order to accomplish this goa The licensee was a participating member in the recent EPRI study on

-

'

commercial grade procurement and was revising their materials procedures to reflect.the results of this stud ' Quality Verification Effectiveness-The inspectors reviewed several QA audits and surveillance, and held discussions with QA personnel. The licensee appeared to have a' strong, proactive QA organization. The QA organization.used both formal audits L

and unscheduled, unannounced surveillance of work activities (including l . work performed on back shifts and/ or weekends, as appropriate). The-QA organization had an excellent working relationship with Nuclear Engineering and.other site organizations. . Prompt' corrective action, often by the.end of the surveillance period, was taken in response to their findings. The licensee stated that the Nuclear Engineering Department regarded QA as a-resource tool to be used to help Engineering improve its performanc . Exit Intervie The inspectors met with licensee representatives (as denoted in Paragraph 1)

at the conclusion of the inspection on August 3, 1989, and summarized the

'

purpose, scope, and findings of the' inspection. .The inspectors also discussed the likely informational content of the inspection report with L regard to documents or processes reviewed by the inspectors during th inspection. The licensee did not identify any such documents / processes as proprietary.

I

,

--

_ _ . _ _ . _ . _ _