ML20214E424
| ML20214E424 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 05/18/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| ULNRC-1516, NUDOCS 8705220082 | |
| Download: ML20214E424 (5) | |
Text
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1901 Gratiot Street, St. Loum Donald F. Schnell Vbe President i
May 18, 1987 Mr. A. B. Davis, Regional Administrator U. S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 ULNRC-1516
Dear Mr. Davis:
INSPECTION REPORT NO. 50-483/87005 This responds to Mr.
R. F. Warnick's letter dated April'20, 1987 which transmitted the report of the inspection conducted at Callaway Plant during the period February 8 through April 4, 1987.
Our response to the violation is presented below.
None of the material in this response is considered proprietary by Union Electric Company.
(50-483/87005-01) SEVERITY LEVEL IV VIOLATION Collectively the following incidents comprise the violation.
A.
Technical Specification 4.0.5, Surveillance Requirements specifies that inservice inspection and testing of ASME Code Class 1, 2, and'3 components shall be applicable as follows:
" Inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code."
OhkohjokB3 PDR gof I
Mading Address: P.O. Box 149 St. Louis, MO 63166
_ _ _ _ i Contrary to the above, the surveillance requirement for the stroke testing of an ASME Code Class-3 valve (AL-HV-0034 Auxiliary Feed Pump "B" Isolation Valve) was not performed in accordance with Section XI of the ASME Boiler and Pressure Vessel Code; in that, the specified interval in Section XI required that the stroke testing be performed on or before December 22, 1986.
The test was not performed until December 31, 1986.
B.
Technical Specification 3.7.11, Limiting conditions for Operation requires that fire barrier penetrations including penetration seals be operable at all times.
Technical Specification 3.7.ll.a requires the following:
"With one or more of the above required fire barrier penetrations inoperable, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> establish a continuous fire watch on at least one side of the affected per-tration, or verify the OPERABILITY of fire detectors on at least one side of the inoperable fire barrier and establish an hourly fire watch patrol."
Technical Specification 4.7.ll.l.c Surveillance Requirement, requires that at least once per 18 months the above required fire rated assemblics and penetration scaling devices shall be verified OPERABLE by performing a visual inspection of at least 10% of each type (electrical and mechanical) of sealed penetration.
l Contrary to the above on April 4, 1986, continuous and/or hourly fire watch patrols were not established as required for inoperable fire seal penetrations which resulted from exceeding the allowable date for performing the 18 month surveillance.
Responso Root Cause The following root cause was determined for part A of the violation:
A surveillance task sheet was not revised to reflect an increased frequency as required by ASME Section XI.
There was cognitive personnel error by the reviewer of the Surveillance Test Request Form failing to recognize this error.
The following root cause was determined for part B of the violation:
The failure to declare the seals and the fire rated assemblics inoperable and properly enter the Technical Specification Action Statement after execeding the late finish date was due to personnel error in the determination that the seals were operable until proven inoperable by the inspection.
Corrective Actions Taken and Results Achieved The following corrective actions were taken for part A of the violation:
The appropriate action statement was immediately entered and the surveillance on AL-HV-00034 was performed and completed satisfactorily.
As a result of the failure to comply with the increased surveil-lance frequency, a review of other Section XI components which have increased surveillance frequency requirements was completed with no other deficiencies noted.
The surveillance tracking engineer has been counseled to review Surveillance Test Request Forms more closely to ensure completeness.
The following corrective actions were taken for part B of the violation:
Upon discovery of the violation the action state. ment was entered, appropriate fire watches were established, and menagement directed a 100% inspection of the fire seals.
As a precautionary measure, hourly firewatch patrols were maintained throughout the plant during the inspection period.
When an inoperable seal was identified, appropriate fire watches were posted or verified in place and work requests were initiated.
Appropriate plant personnel have been counseled that, regardless of the reason for inoperability, the Technical Specification action statement requirements must be imposed in accordance with plant administrative controls when Technical Specification equipment is inoperable.
A review was conducted of other surveillances requiring long-term i.nspection of a large population of passive equipme nt.
A 100%
inspection of all fire rated assemblies was performed and appropriate action statements were met.
The surveillance program administrative procedure has been revised to provide guidance to ensure proper declaration of inoperable status is made if the late date for a surveillance is exceeded.
The Compliance Department surveillance tracking procedure has also been revised to require Compliance Group personnel to generate an Incident Report if the late finish date is not satisfied.
This is in addition to the progressive notifications already outlined in this compliance Department procedure.
Corrective Action To Be Taken To Avoid Further Violations The corrective actions to be taken to prevent recurrence for part A of the violation are:
The Surveillance Test Request Form will be revised to improve tracking of surveillances.
The ISI Engineer will perform a review of the surveillance program for Pumps and Valves.
The review will determine if there is documentation available to show that the appropriate acceptance criteria have been met.
The review will consist of those Surveillance Task Sheets initiated for the Pump and Valve program since January 1, 1986.
Quality Assurance will provide an independent assessment of the review performed by the Inservice Inspection Engineer.
The corrective actions to be taken to prevent recurrence for part B of the violation are:
Due to the concerns and deficiencies identified in LERs86-042 and 87-001 an informal Management assessment of the overall surveillance program compliance was initiated.
During the assessment period, LER 87-005 was identified concerning three valves missing from a Fire Protection surveillance procedure.
The results of the assessment indicated need for improvements in the Fire Protection, Health Physics, and the pump and valve areas.
Corrective action is complete for the HP area; actions indicated above will be taken for the pump and valve area.
To address the potential problem in the Fire Protection area, the On-Site Review Committee established a Subcommittee, including Nuclear Operations, Nuclear Engineering and QA personnel, to review the Fire Protection surveillance procedures.
The completion of the subcommittee review and the correction of any deficiencies identified should provide assurance that deficien-cies similar to the subject violation and the violation identified on LER 87-005 will not recur.
The Date When Full Compliance Will Be Achieved Union Electric is in compliance with all License conditions and Technical Specifications.
The reviews of the surveillance program for pumps and valves and for fire protection will be completed by December 31, 1987.
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5-If you have any questions regarding thisLresponse or if-
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additional information is required, please let me know.
Very_truly yours,-
Donald F. Schnell cc U.S. Nuclear Regulatory Commission Document Control Desk (Original).
R. F. Warnick - Chief, Reactor Projects, Branch I W. L. Forney - Chief, Reactor Projects, Section lA'
' Paul O' Conner - Licensing Project Manager (2 '. copies)
B. H. Little - NRC Senior Resident Inspector Manager, Electrical Department, Missouri Public Service Commission i
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