ML20084F542
| ML20084F542 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/19/1984 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Knop R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20084F532 | List: |
| References | |
| ULNRC-805, NUDOCS 8405040224 | |
| Download: ML20084F542 (4) | |
Text
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UNION ELECTRIC COM PANY 1908 GRATIOT STREET ST. LoulS, MISSOURI DON ALD F. SCHesELL O. SOX 149 ST. LOUIS. MISSOURI 63 3 66 vece peerosogast Mr.
R.
C. Knop, Chief Project Branch 1 U.S.
Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-805
Dear Mr. Knop:
INSPECTION REPORT NO. 50-4 8 3/83-32 (D.)RP)
This reply is in responce to your letter of March 21, 1984 which transmitted the report of the inspection conducted at Callaway Plant, Unit 1 during the period of December 1, 1983 to February 15, 1984.
Our response to the item of noncompliance is presented below.
None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.
(50-483/83-32-01) SEVERITY LEVEL IV VIOLATION 10CFR 50, Appendix B, Criterion XI, Test Control, states in part, "A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents....
Test procedures shall include provisions for assuring that all prerequisites for the given test have been met...and that the test is performed under suitable environmental conditions.
Test results shall be documented and evaluated to assure that test requirements have been satisfied."
Union Electric Company's Quality Assurance Manual Section 17.1.11 states in part, "The SNUPPS utilities will accomplish tests in accordance with written test procedures....
Test procedures, developed to control tests, will incorporate or reference the requirements and acceptance limits specified in applicable design and procurement documents.
These test procedures, as appropriate, will also include test objectives; test.
prerequisites; instructions for performing each test; operating instructions for test equipment and instrumentation, or reference 8405040224 840427 PDR ADOCK 05000483 PDR ggg 0
..Mr.
R. C. Knop April '19, 1984 thereto; and documentation and evaluation of test results to.
assure satisfaction of test requirements...."
Contrary to the above the inspector found:
a.
On December 8, 1983, during the performance of the auxiliary feedwater pumps endurance preoperational test (CS-03 ALO 3 ),
the environmental conditions to meet acceptance criteria for the PALO2 pump test had not been established.
Test prerequisites for establishing environmental conditions were not provided in the test procedure.
b.
On January 30, 1984, during the performance of the LOCA Sequencer preoperational test (CS-03NF02), the emergency diesel generator was operated without cooling water for approximately six minutes, resulting in the overheating of the diesel generator.
The test procedure was deficient in that the required backup cooling water was not specified as a prerequisite, and the procedure failed to specify establishing backup cooling prior to securing the essential cooling water pump.
c.
A Startup Field Report (SFR) SFR-2-EJ-068A dated February 14, 1984, documented a nonconforming condition which was identified during the performance of an Emergency Cooling Water Sump Test on October 7, 1983.
The test was performed without an approved procedure.
Test results including test deficiencies were neither formally documented nor evaluated.
Corrective Action Taken And The Results Achieved:
a.
In order to assure that testing was adequate and in accordance with a prescribed test method which satisfied the intent of the acceptance criteria, Procedure CS-03ALO3 was changed via Minor Change Notice, to include pump room prerequisites.
The test was performed using the revised procedure and the results were satisfactory.
b.
An examination of Procedure CS-03NF02 shows that consideration for the loss of cooling water and resultant engine heating was made.
The Notes and Precaution Section
(.5. 0 ) included the following:
5.6 If at anytime during the DG short-time or Continuous Rated Load Test, the engine jacket water temperature rises above 185 degrees F, the lube oil temperature exceeds 160 degrees F or the valve rocker lube oil temperature exceeds 165 degrees F, unload the generator, open the feeder breaker to the bus under test and shut down the engine.
After correcting the problem, the test can be re, started.
Mr.
R. C. Knop April 19, 1984 5.10 Essential service water and component cooling water supplies will be interrunted during phases of this pre-operational test.
Equipment requiring a continuous cooling water for normal operation should be aligned to an alternate source or placed out of service.
These entries in the Procedure as precautions (which apply throughout the procedura) provide adequate nrocedural coverage.
The events which were observed relating to loss of cooling water and resultant overheating resulted from personnel error.
Corrective actions taken in regard to this matter were as follows:
Partial disassembly and visual inspection of the o
diesel generator bv a vendor representative with no damage noted.
Onerational testina of the diesel cenerator subsequent to inspection with no evidence of adverse conditions.
Re-training of Startuo personnel in conduct of preonerational testing with emphasis on procedural requirements including adherence to nrecautions and limitations.
- c. Testing of the Emergency Core Cooling System (ECCS) sump which was initially performed was felt to be of a general performance evaluation and developmental nature.
In addition, the testing was not a defined FSAR requirement and thus, was not performed as a preoperational test.
Subsequent evaluation of the testing and documentation requirenents resulted in preparation of Preoperational Test Procedure C-03EJ04 (annroved March 9, 1984) and field performance testing (successfully completed March 13, 1984).
Documentation of evaluation and corrective action was made on Request for Corrective Action (RCA) S8402-014, Rev.
O, initiated March 1, 1984 and closed out on '4 arch 20, 1984.
Corrective Action To Be Taken To Avoid Further Noncomoliance:
Actions as noted above have been comoleted.
These findings are of an individual nature and are not expected to recur.
Corrective action in the form of retraining of nersonnel has been conducted.
The Date When Full Conoliance Will Be Achieved:
Preoperational Test Procedure CS-03ALO3 testing activities were completed on February 21, 1984.
"
- Mr. R. C. Knop April 19, 1984 -
Field performance of Preoperational Test Procedure CS-03NF02, including actions to correct the problems noted was completed and results approved March 6, 1984.
Preoperational Test Procedure C-03EJ04 was appproved on March 9, 1984 and testing was successfully completed on March 13, 1984.
Startup training on the Preoperational Test Procedure program was completed on March 7, 1984.
If you have any questions regarding this response or if additional information is required, please let me know.
Very truly yours,-
m Donald F.
Schnell NRI/glp cc:
W. L.
Forney, NRC Region III NRC Resident Inspectors, Callaway Plant (2)
Missouri Public Service Commission
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