ML20094J642
| ML20094J642 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/24/1984 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20094J637 | List: |
| References | |
| ULNRC-881, NUDOCS 8408140404 | |
| Download: ML20094J642 (5) | |
Text
__
l UNION ELECTRIC COM PANY 1901 GRATIOT STREET ST. Louis, MISSOURI M AILING ADDRESS:
July 24, 1984
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Mr. R. L.
Spessard, Director Division of Engineering U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-881
Dear Mr. Spessard:
INSPECTION REPORT NO. 50-483/84-23 This reply is in response to your letter of June 25, 1984 which transmitted the report of the inspection conducted at Callaway Plant, Unit 1 during the period of April 23 through June 1, 1984.
Our responses to the items of noncompliance are presented below in the order listed within the body of inspection report number 50-483/84-23.
None of the material in the inspection report or in this response is considered proprietary by Union Electric Company.
(50-483/84-23-01) SEVERITY LEVEL V VIOLATION 10 CFR 50, Appendix B, Criterion V, as implemented by SNUPPS Quality Assurance Programs for Design and Construction, Section 17.1.5; Westinghouse site instruction, " Processing and Control of Nonconformance Reports-NSSS Equipment"; and Bechtel site instruc-tion, EDPI 4.70-01, requires that activities affecting quality be performed in accordance with documented instructions of a type appropriate to the circumstances, specifically, that documenta-tion be provided for disposition of nonconformance conditions.
Contrary to the above, Bechtel and Westinghouse site instructionc for the processing and control of nonconformance reports were not followed in the processing of eight Startup Field Reports (SFRs) dispositioned "use-as-is" in that sufficient information explain-ing the rationale for the recommendation was not provided and records documenting the disposition of six of the nonconformances were not generated as required by procedures.
8408140404 G40810 JUL 261984 PDR ADOCK 05000483 G
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-July-24, 1984
Response
Corrective Action Taken And The Results Achieved
~Unica Electric performed a review of a random sample of one hun-dred Bechtel SFRs dispositioned "use-as-is."
Of the one hundred selected, six were found to have inadequate explanations of the
' basis for "use-as-is."
Union Electric Quality Assurance issued
' Request for Corrective Action (RCA) #G8406-039 for these six SFRs to have;the bases for their-disposition documented.
The response from Bechtel to the RCA included additional technical bases for "use-as-is" dispositions for each of the SFRs identified.
No l revised dispositions resulted from the review of the SFRs by Union Electric or Bechtel.
Union Electric and Westinghouse are performing a review of Westinghouse SFRs with-"use-as-is" dispositions.
Union Electric and Westinghouse have reviewed the entire file of Westinghouse SFRs and found twenty-two having insufficient documentation to substantiate ~the "use-as-is" disposition.
These SFRs were referred to-the appropriate Westinghouse engineering shops to substantiate the existing dispositions.
Of-the twenty-two SFRs, sixteen have beenTcompleted, two require' additional information ifrom Union Electric and four are still being' reviewed.
The ini-tial transmittal!from Westinghouse containing the backup documen-tation for the completed "use-as-is" SFRs was transmitted to
-Union. Electric'onIJuly 23,_1984 and is being reviewed by the r
Union Electric Nuclear Engineering Department.
The. backup'docu-
- mentation for1the outstanding SFRs and the responses.to Union Electric comments on the-first transmittal is_ scheduled for
-transmitte.1 to Union Electric.the week of July 30,1984.
To date, this-review has resulted in'no changes to the existing i-Ldispositions.s
~ Corrective' Action'To'Be Teken To' Avoid Further Noncompliance
'NoLfurther corrective. action beyond the actions identified _above.
are' considered necessary.
Date When Full Compliance Will Be Achieved 4
~ Union' Electric should achieve full compliance by August 3,;1984.
Q (50-483/84-23-02) SEVERITY LEVEL V VIOLATION 10 CFR-50, _ Appendix'B,- Critericn.XI, as. implemented by SNUPPSi
' Quality Assurance; Programs /for. Design and Construction,' 17.1.11, requires that test'results be documented and evaluated.to assure thatitheitest requirements have'been satisfied.
' Contrary.to the above, theLtest results' packages-for preopera-jtional tests.CS-03BG05,; Boric: Acid Blending, and CS-03BG06,'CVCS
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-Mr'.
R. L. Spessard Page 3-
. July 24,;1984 System Hot Preoperational. Test, did not receive adequate evalua-t tion and/or. documentation.of the acceptability of the test I
results'in that'they.were reviewed and' approved withLacceptance.
criteriaLwhich were obtained with unreliable gauges and test data which exceeded their expected values.
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Response
Corrective Action Taken And The Results Achieved
- An-additional review and evaluation was made of test results
. packages.CS-03BG05 and CS-03BG06.
The results of the evaluation are documented on letter UOTE-207.
This letter has been added to
- the packages and the results are outlined below.
'CS 03BG05 documents emergency boration flows as recorded by BG-FI-183A and.-183B.as more than 150 gpm.. An evaluation of the
' calibration of the: instrument was not included in the test
- package.
SFR-BG-122A was issued to identify the indeterminate flows'above 150 gpm and was dispositioned "use-as-is" based on-SNP-SU-2.2.2 Acceptance Criteria which require emergency flow to be greater than 85.gpm.. Subsequent-to the'SFR resolution, and as.
part-of the pre-op post-calibration program, BG-FI-184A-and -184B were recalibrated and documented on CS-06CS12A.
- Both instruments
~
Twere :found to be within tolerance from the 120 gpm 'to 150 gpm range.
' CS-03BG06 requires letdown flow through SBG04A to be 45 + 3 gpm
- as measured by FI-132.which.is ungraduated from 0 to 50 gpm.
During t21e conduct of the test to measure flow through this.orif--
ice,;the test ~ engineer recorded "approximately-48 gpm." -. No. eval-uation was made as to the acc'eptability'of the:"best estimate" of pg this flow rate.
DuringLoperations the 45 gpm orifice is.never.
utilized singularly.
A 75 gpm orifice (SBG04B or C) is always utilized during letdown.
.The'45 gpm orifice is opened to supple-ment aL75 gpm orifice already.in service providing approximately 120 gpm flow.. As documented in the test package, FI-132 success-fully demonstrated letdown flows of approximately 75 gpm and 120 gpmTwhen SEG04A, B,.and C'were utilized in various combinations.
. CS-03BG06 also specified an allowable range of 7.5 to 8.5 gpm
. seal ater flow to the No. 1 RCP seals.
During the test ~the No.
' l seal flow to all four RCPs exceeded the maximum allowable,.
ranging from 9.1 to 9.5 gpm.
No evaluation of exceeding the max-
-imum was' identified in the test results package.
Manual M-712-0068, section 6.1.1~" Injection Water", specified a normal operating range. of' 8 gpm to 13 gpm,.with absolute minimum and maximum flows.of'6 gpm and 20 gpm, respectively.
Therefore, the allowable range-of 7.5.to 8.5 gpm is'more conservative than al-lowed by the manufacturer.'
Although the allowable ranges speci-fied insthe test were not met, they are considered acceptable based onsthefmanufacturer's specifications.
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.Page-4 July 24, 1984 The results of the additional review and evaluation confirmed the acceptance of pre-operational tests CS-03BG05 and CS-03BG06.
Corrective Action To'Be Taken To Avoid Further Noncompliance The Pre-operational Test Program was completed with issuance of the License to load fuel.
Letter UOTE 84-207 has been added to the record copies of CS-03BG05 and CS-03BG06-to clarify any questions related to-these concerns.
No other corrective action is_ considered necessary.
Date When Full Compliance Will Be Achieved Union Electric achieved full compliance July 10, 1984.
(50-483/84-23-05) SEVERITY LEVEL IV VIOLATION 10 CFR 50, Appendix B, Criterion II, as implemented by commitment in_SNUPPS-C'FSAR, Appendix 3A, to Regulatory Guide 1.33 (endorsing /American National Standards Institute N18.7-1976)-
requires that activities affecting quality be accomplished under
' suitably controlled conditions.
-contrary.to the above, engineered safety feature pump:and fan motor start-limitations were not found-in: applicable system or plant' operating procedures in.the control room.
Personnel con-tacted_in the control room were not' cognizant of the limits by training or experience and on one occasion the safety. injection pump was started from-the' control room in violati'on of the manufacturer's recommended limitations for the motor.
' Response-l-
Corrective' Action Taken'And The Results' Achieved
- Motor nameplates and operating manuals for. plant pumpsi and motors E
were reviewed to determine' motor start limitations.
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lTheLappropriate operating procedures.have been. revised or
--Temporary Change Notices-to procedures have been' issued to add the pump and, fan motor start limitations. -
L 1m Operations: Department Night Order has been issued to ensure that all_ personnel,. including back shift,-are aware of'these s
- limitations.
Corrective Action To Be 'Taken To Avoid Further Nor4 compliance
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No' further corrective action is considered necessary.
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i Mr. R.
L. Spes'sard
.Page-5 Date When Full Compliance Will Be Achieved Full compliance was achieved July 10, 1984.
If you have any quections regarding this response or.if addi-tional.information is required, please let me know.
Very.truly yours, s
Donald F.
Schnell SEM/THM/JRV/lw cc: 11.
L.
Eorney,-NRC Region III NRC Resident Inspectors, Callaway Plant (2)
Missouri Public Service Commission e re w w
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