ML20077M394
| ML20077M394 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/30/1991 |
| From: | Naslund C UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2454, NUDOCS 9108130326 | |
| Download: ML20077M394 (3) | |
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July 30, 1991
, Uvrox ILLECTRIC EE U. S. Nuclear Regulatory Cormaission Attn: Doctunent Control Desk Mail Station F1-137 Washington, D.C.
20555 ULNRC 2454 Centlemen:
CALLAWAY PLANT DOCKET NUMBER 50-483 INCOMPLETE INTERVAL 1 PERIOD 1 ASME XI VT-2 VISUAL EXAMINATIONS
References:
- 1) SOS 90 0157
- 2) ASME Section XI, 1980 Edition, Winter 1981 Addenda SOS 90 0157 (reference 1) documents a nonconformance to the pressure test and VT 2 visual examination requirements of ASME Section XI (reference 2), paragraphs IWC-5210(a) and IWD 5210(a). This letter provides a brief description of the nonconformance, cause, operability irnpact,.and corrective action taken to prevent recurrence, SOS 90 0157 is on file at tbc C.11away Plant.
On May 25, 1990 Union Electric reported, per the Callaway Corrective Action Program, a possible lack of documentation for a number of ASME Section XI VT-2 visual examinations. Subsequent investigation revealed that VT 2 visual examinations had not been performed on portions of fourteen Class 2 and Class 3 systems prior to the end of Callaway's Feriod 1 of Interval-1 (first 40-month inspection period) as required by ASME Section XI.
Root cause of the missed VT 2 visual examinations on Class 2 systems was due to an interpretation of paragraph IWC-1220 of reference 2.-This interpretation was extended, in error, to Class 3 systems as well. Specifically, paragraph IWC-1220 delinectes exemptions from the inservice examination (i.e., visual, surface, and volumetric) requirements of IWC-2500. Union Electric held the position that this exemption applied to VT-2 visual examit.ations. Moreover, this position was substantiated by.he opinicn of a reputable code consultant. Based on clarifications in later editions-of the code that Cc11away is not committed to however,-the exemptions of IWC 1220 apply to surface and volumetric examinations only, Immediate corrective action was to evaluate operability and structural integrity of the piping and cornponents where VT-2 visual l
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examinations were not performed, An engineering evaluation successfully demonstrated operability and structural integrity of the subject systems during tho first 40-month inspection period by identifying Callaway leak detection programs, other than the VT-2 Visual Examination program, which "erified leak tight integrity. Moreover, system operability and structural integrity has recently been verified by completing the VT-2 visual examinations for the second 40-month inspection period that were missed in the first 40-month inspection period.
To prevent recurrer.ce of this incident, the Callaway Surveillance Program will be utilized to schedule, track, and document completion of all 40 ttonth VT 2 visual examinations. This program is used to track repetitive regulatory work to ensure co npliance, These VT-2 visual examinations will be incorporated in eht Surveillance Program prior to the start of Refuel 5 scheduled in the spring of 1992,
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tw C.,D. Naslund Manager, Union Electric Nucicar Engineering rf,/!Z' 4'. ?,fk ys xl A CDN/ MET /RDA/TLS/JMG/Sil4/ crc Attachment cc:
Distribution attached
cc:
A. Bert Davis, Regional Administrator U.S. Nuclear Regulatory Comrnission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 R. L. Mague chief, Project Section 3C U.S. Nuclear Regulatory Cotunission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 M. D. Lynch (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conanission Mail Stop 13-E 21 Washington, D.C.
20555 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102 T. A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W.
Washington, D.C.
20037 B. L. Bartlett Senior Resident NRC Inspector, Callaway Plant Callaway Resident Office U.S. Nuclear Regulatory Conanission RR #1 Steedman, MO 65077
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