ML20235X034

Responds to NRC Re Violations Noted in Insp Rept 50-483/87-26.Corrective Actions:Preventive Maint on EJ-HV-8804A & B Rescheduled to Occur During Mode 5 & Quarterly Pump Surveillance Procedures Changed

ML20235X034
Person / Time
Site:	Callaway
Issue date:	10/14/1987
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
ULNRC-1653, NUDOCS 8710190175
Download: ML20235X034 (3)

Text

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' [Jgjog Etscruic usnac.os 1901 Gratiot Street, St. Lows 1981001 R A D 02 Donald F. Schnell October 14, 1987 Vice President U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555 ULNRC-1653 Gentlemen:

INSPECTION REPORT NO. 50-483/87026 This responds to W. L. Forney's letter dated September 17, 1987 which transmitted the report of the inspection conducted at Callaway Plant during the period of August 12 through August 21, 1987. Our response to the violation is presented below.

None of the material in this response is considered proprie-tary by Union Electric Company.

(50-483/87026-01) SEVERITY LEVEL IV VIOLATION 10CFR50. 59 (a) (1) (iii) states that the holder of a license authorizing _ operation of a utilization facility may conduct tests not described in the safety analysis report without prior Commission approval unless the proposed test involves an unreviewed safety question. 10CFR50. 59 (a) (2) (iii) states that a proposed change involves an unreviewed safety ques-tion if the margin of safety as defined in the basis for any technical specification is reduced. 10CFR5 0. 59 (b) (1) states that a safety evaluation shall be performed to determine if any unreviewed safety question exists.

Technical Specification 3.5.2 requires that two independent g

ev Emergency Core Cooling System (ECCS) subsystems be operable (each subsystem includes one operable Safety Injection Pump) o8'o while operating in Mode 1 (power operation). The basis for Q

mo Technical Specification 3.5.2 states that the OF':RABILITY of two independent subsystems ensures that sufficient emergency or core cooling capability will be available in the event of an D8 accident while assuming the loss of one subsystem.

oQ U Contrary to the above, while the unit was in Mode 1, the licensee conducted tests not described in the safety analy-g$

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"* sis report without prior Commission approval on Jur.e 29 and July 15, 1987, and on prior occasions during 1985 through 1987, which involved an unreviewed safety question.

Maihng Address: P.O Box 149, St. Laws, MO 63166 M\

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- j. s ULNRC-1653-Page_2 of 3 Those tests,' Operations. Surveillance Procedure OSP-EM-P001A and B and maintenance retest instructions following work under WR No. W-414651'and PM 49488, required. manual closure of valve BN-HV-8813, the safety injection combined recircu-lation to the Refueling Water Storage Tank isolation' valve,

. rendering both ECCS safety injection subsystems inoperable reducing the margin of safety defined in the bases of

%) Technical Specification 3.5.2.

Response

Corrective Actions Taken and Results Achieved The preventive maintenance on EJ-HV-8804A and B has beer rescheduled to occur during Mode 5 (Cold Shutdown) or Mode 6 (Refueling). This will preclude closure of BN-HV-8813 dor retests of the two EJ valves in modes when BN-HV-8813 is required to be operable.

A letter'was issued to the Shift Supervisors to emphasize the necessity for adequate evaluation of all activities prior to performance.

The quarterly pump surveillance procedures were changed to

,  : delete the requirement.for cycling BN-HV-8813. In addition, other' surveillance procedures which cycle the valves refer-enced in Technical Specification 4.5.2 were reviewed to ensure they are not cycled during power operations, startup or hot standby by any other procedure. No other problems were identified.

Corrective Actions to be Taken to Prevent Recurrence In addition to the corrective actions above, Management is reviewing the procedure revision process and the work l planning process to identify deficiencies which may have caused the noted events.

Special notations are being added to the computerized Master Equipment List to identify the appropriate precautions and Mode restraints necessary for maintenance of the valves listed in Technical Specification 4.5.2. These special notations should be completed by October 9, 1987.

The Date When Full Compliance Will Be Achieved Union Electric is in compliance with our License conditions and Technical Specifications. The corrective actions to oe taken will be completed by December 31, 1987.

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If you:have:.any. quest' ions regarding thiszresponse oriif

,- ' additional informationiis. required,1please-let-me.know..

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.'Very truly yours,

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iDonald F. Schnell cc:- A. B. . Davis--. Reg'ional> Administrator,.USNRC Region III

' J .1 M . Hinds.- Chief,> Reactor Protects, . Section' '1 A, -

USNRC Region.III n6 . Tom Alexion - USNRC.-Licensing Project Manager

-(2. Copies)

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B.~H'.Little'- USNRC Senior. Resident Inspector.

, Manager,s Electrid Department, Missouri Public-. Service-

-Commission  !

' Shaw,.Pittman,'Potts & Trowbridge m

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