ML20129J597
| ML20129J597 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/31/1985 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Harrison J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| ULNRC-1104, NUDOCS 8506100133 | |
| Download: ML20129J597 (3) | |
Text
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a s_ s LMION ELECTRIC COM%NY 1901 Grotiot Street, St Louis Donald F.Schrell Vce President May 31, 1985 Mr. J. J. Harrison Engineering Branch U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 ULNRC-1104
Dear Mr. Harrison:
INSPECTION REPORT NO. 50-483/85004 This reply is in response to your letter of April 29, 1985 which transmitted the report of the inspection conducted at Callaway Plant during'the period of March 4 through April 5, 1985.
Our response to the item of noncompliance is presented below.
None of the material in the inspection report or in this respanse is considered proprietary by Union Electric Company.
(50-483/85-04-01)
SEVERITY LEVEL V VIOLATION 10CFR50, Appendix B, Criterien XI, as implemented by the Union Electric Quality Assurance Program, requires that test results be evaluated and documented to assure that test requirements have been satisfied.
Contrary to the above, test results packages were reviewed and approved by the On-Site Review Committee with the following existing discrepancies:
1.
In ETT-SF-07033, Revision 2,
" Rod Drop Time Measurements (Hot, Full-Flow) ", re-evaluation of rod drop times resulted in changing the drop times for approximately 40%
of the rods.
Average rod drop time and the standard deviation were not subsequently recalculated in order to verify the design criterion that rod drop time for any rod should not vary from the average by more than +/- 2 standard deviations.
2.
In ETT-BB-07030, Revision 2,
" Reactor Coolant System Flow Measurements",_ superseded RTD calibration curves were inadvertently used to convert resistance to temperature.
8506100133 850531 PDR ADOCK 05000483 G
PDR Mailing Address RO Box 149 St. Louis, MO 63166 JdljN 41985 10 V6of
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Mr. J. J. Harricon Page 2 May 31, 1985 3.
In the Thermal Power Measurement and Statepoint Data Collection series of tests (ETT-SC-07031, 07032, 07033, 07034, and 07035), incorrect test instrumentation was used and the test pressure gauges used for measuring main steam pressure lacked documentation to substantiate their acceptability.
In fact, documentation was included in the package for ETT-SC-07035 which indicated that the test gauges had been rejected for calibration prior to performing the test.
Response
Corrective Action Taken and the Results Achieved As noted in the details of Inspection Report 50-483/85004, the deficiencies were evaluated and corrected by the licensee.
Where required, corrected test results or additional documentation necessary to support evaluations performed were added to the test results packages.
In no instance did the errors discovered in the test r,sults packages result in operation of the Callaway Plant with reduced margins of safety
[
as defined in the bases of the Technical Specifications or the Final Safety Analysis Report.
Based on the review of the Callaway Initial Startup Test Program results by the licensee and the NRC, reasonable assurance has been provided that no errors exist in the Initial Startup Test results packages which would result in a reduced margin of safety as defined in the bases of the Technical Specifications or the Final Safety Analysis Report.
No additional corrective action is required to validate these test results packages.
Corrective Action Taken to Prevent Further Noncompliance The deficiencies noted in the Notice of Violation indicate that the independent review of test results packages requires improvement.
The.On-Site Review Committee (ORC) was chartered with the independent review responsibility for the initial startup test program.
The Committee's failure to identify the deficiencies noted in the Notice of Violation is not indicative of a general weakness in the quality of ORC reviews.
The GRC members have been made aware of the specific deficiencies and will augment their review process with ad hoc committees tasked to provide additional detailed review as deemed appropriate.
Performance of such reviews would augment, not replace, the existing reviews performed by ORC members.
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Mr. J.JJ.:Herrison Page 3 May 31, 1985 Date When Full' Compliance Will Be Achieved Full compliance will be achieved by May 31, 1985.
.Please contact us if you have any questions regarding this response or if additional'information is required.
Very truly yours,-
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'a Donald F.
Schnell DFS/SEM/JRV/bjp cc:
G.~C. Wright, NRC Region III
.NRC Resident Inspectors, Callaway~ Plant.(2)
- Missouri Public Service Commission