ML20108B352

Responds to NRC Re Noncompliance Noted in Insp Rept 50-483/84-34.Corrective actions:WR-025113 Issued on 840607 to Disassemble,Inspect & Rework Valve Seats of Check Valves V-001 & V-004.No Valve Damage Present

ML20108B352
Person / Time
Site:	Callaway
Issue date:	10/26/1984
From:	Schnell D UNION ELECTRIC CO.
To:	Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20108B325	List: ML20108B352
References
ULNRC-959, NUDOCS 8411160037
Download: ML20108B352 (4)

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1901Grotiot Street St Louis Donoid F.SchneN vbe hudat  !

l October 26, 1984

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! Mr. R.'L. Spessard, Director

_. Division of Reactor Safety .

U.S. Nuclear Regulatory Commission Region III

!- 799 Roosevelt Road

. Glen Ellyn, IL 60137

Dear Mr. Spessard:

ULNRC- 959 INSPECTION REPORT NO. 50-483/84-34 i

This reply is in response to your letter of September 28, 1984 which transmitted the report of the inspection conducted at callaway Plant, Unit 1 during the period of July 16 through August.30, 1984. Our response to the individual segments of the item of noncompliance is presented below in the order listed within the body of inspection report number 50-483/84-34.

, None.of the material in the inspection report or in this response is considered proprietary by Union Electric Company.

. (50-483/84-34-01) SEVERITY LEVEL IV VIOLATION 10 CFR 50, Appendix B, Criterion V, as implemented by SNUPPS l

Quality Assurance Programs for Design and Construction, Section 17.1.5, and Startup Administration Instruction, SAI-5, requires that activities affecting quality be performed in accordance with documented instructions and procedures of a type appropriate to the circumstances. Contrary to the above:

! 1. A suspect deficient condition was identified and documented L in the test log for CS-03NF02 Rev. O "LOCA Sequencer" for which no Startup Field Report (SFR) was initiated as

! required by SAI-12, " Test Program Problem Resolution",

j Further, the Joint Test Group (JTG) evaluated and approved the results package without requesting that an SFR be initi-ated to resolve the possible deficient condition.

8411160037 841109 PDR ADOCK 05000483 PDR g - OCT 291984 Moong Addren: P.O Box 149. St Lout MO 63166

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. Mr'.iR. L. ' Spe2 GEED ! )

. Paga 2,

- October. 26, 1984.. .

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. Response

' Corrective Action Taken-And The Results Achieved

-The test log. entry states that'there was a substantial water ham-mer or check valve " slam" when service water-was restored.

Because of leakage of service water.to the URS,..WR-025113 was is-sued June 7, 1984, to disassemble, inspect, and rework

the. valve-seats of check valves V-001 and V-004. The valves were: tested in accordance with the vendor instruction manual to determine.if' cracking had' occurred.

1 The results of'the examination showed-that-no valve damage was present._ Some rough areas lwere noted on the valve seat and. disc surface of V-001,' but these were determined to have no effect on the ability of-the valve to-perform-its designed function.

' Operational Surveillance Procedures OSP-EF-P001A and OSP-EF-P001B were successfully completed during ESFAS testing which verified the valves' operability after internal inspection.

It should be noted that valve slamming is normal for these valves

, by design. Slamming occurs due to the sudden surge of essential  ;

service water against piping which is not completely filled down-

stream of the check valves in question.

A copy of this response has been included in the CS-03NF02 i Pre-operational Test Results Package as a supplemental. record for i

. future reference.

! Corrective Action Taken To Avoid Further Noncompliance The JTG is no longer a functional body at Callaway. Although the 4

above identified problem should have been addressed by the JTG in

! accordance with the Pre-operational Start-up Program, corrective action was.taken by Plant Operations and Maintenance based on service water leakage past the check valves back to the UHS.

l Should significant leakage occur.in the future which would be in-l dicative of valve loss of passive integrity, inspections includ--

L ing the disassemblage of the valve (s) will be undertaken by Plant Operations and Maintenance.

Date When Full. Compliance Will Be Achieved

[

Disassembly and inspection of V-001 and V-004 were completed on

. June 12, 1984. Results were satisfactory. ESFAS testing was performed in July 1984, which provided evidence that the valves in question were functioning as designed.

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. Mr IR. LAiSpengard

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• Pcg3 ! 3 -

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• October: 26,1 1984~

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:2. Normal operating procedures for the Residual Heat Removal System,.OTN-EJ-00001, R1, and Containment Spray System,

-OTN-EN-00001, RO,.were written and approved without adequate instructions forLfilling and vaating to' assure their opera-x

, =bility in the post Loss of Coolant Accident (LOCA) recircu-j' lation mode of operation.

Response' Corrective Action Taken And The Results Achieved The normal operating procedure for the Residual' Heat Removal

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System and-the Containment Spray System was revised to reflect comments addressed'by Inspection Report 50-483/84-34. The neces-sity of-venting this piping is still in question. The venting is being tracked with Surveillance Task numbers ST-00136 and-

.ST-00137 which cover EN and EJ systems.

I Corrective Action 1N) Be Taken To Avoid Further Noncompliance Evaluation of the continued need for these tasks will be made at some future date by Nuclear Engineering. To prevent. future non-compliances, Plant Engineering will review all operational' tech-nical procedures.

. Date When Full Compliance Will Be Achieved Union Electric achieved full compliance August 5, 1984.

3. The surveillance procedure for determining Reactor Coolant System (RCS) leakage as required by Technical Specifications 3.4.6.2.d and f (procedure No. OSP-BB-00009,- R0, "RCS Inventory Balance") was written'and approved with technical errors that made the procedure invalid for the purpose intended.

Response

Corrective Action Taken And The Results Achieved As part of Union Electric's Procedure Development Program,

- OSP-BB-00009 was issued as Revision 0 approximately one year prior to issuance of the final Technical Specifications. The procedure was in review for Revision 1 at the time of the.NRC in-

. Lspection and was issued during the NRC visit. Revision 1 cor-rected the NRC identified deficiency and was issued concurrent with the initial performance of the procedure. Subsequent review i indicated the need for Revision 2, which was issued August 31, 1984.

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Corrective Action To Be Taken To Avoid Further Noncompliance Minor: parameter differences may become apparent when the Tank Data Book is issued in final approved form. This is scheduled to be completed by November 30, 1984. A Revision 3 may be written and issued as a result of these minor changes.

Date When Full Compliance Will Be Achieved Full compliance was achieved August 31, 1984.

If you have-any questions regarding this response or if addi-tional information is required, please let me know.

~Very truly yours, w D chnell

[b(Donald SEM/JRV/le cc: W. L. Forney, NRC Region III NRC Resident Inspectors, Callaway Plant (2)

Missouri Public Service Commission 3

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