ML20237A407
| ML20237A407 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/08/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| ULNRC-1691, NUDOCS 8712140456 | |
| Download: ML20237A407 (8) | |
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~ Etscraic iWEB 1901 Gratiot Street. St. Louis
. Donald F. Schnell.
Vice President December 8, 1987
-Mr. James Lieberman, Director Office of Enforcement j
U. S. Nuclear Regulatory Commission i
ATTN:
Document Control Desk Washington', D. C.
20555 ULNRC-1691
Dear Mr. Lieberman:
REPLY TO NOTICE OF. VIOLATION FOR INSPECTION REPORT NOs. 50-483/87023 and 50-483/87028 This responds to Mr. A. Dert Davis's letter dated November 9, 1987, which transmitted a Notice of Violation and Proposed Imposition.of Civil Penalties for violations identified by inspections conducted at Callaway Plant during the period August 24 through September 11, 1987.
Our_ responses to the violations are presented below in the order listed within the body of the Notice.
Also included is our decision'with respect to the proposed Civil Penalty.
None of'the material in this response is considered proprietary by Union Electric Company.
(50-483/87023-02) SEVERITY LEVEL III: VIOLATION I.A Technical Specification Limiting Condition for Cperation (LCO) 3.7.6 requires two independent Control Room Emergency Ventilation Systems (CREVS) to be operable during all modes.
Technical Specification Surveillance Requirement 4.7.6.e.3 states, in part, that each of the CREVS shall be demonstrated operable by verifying that the system maintains the control room at-a positive pressure greater than or equal to 0.25 inch water
. gauge (w.g.) relative to the outside atmosphere during system operation.
Technical Specification LCO 3.0.3 requires that when an LCO is not met, except as provided its the associated ACTION requirements, action shall be initiated within one hour to place the unit in hot standby within the next six hours, hot shutdown within the following six hours, and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
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PDR it e ao tv o d li Maihng Address: P.O. Box 149, St. Lows. MO 63166
ULNRC-1691 Page 2 l
l Contrary to the above, from approximately June 8 to July 9,
- 1987, while the unit operated in Mode 1, both independent CREVS were inoperable in that each could not maintain the control roore at a pressure equal to or greater than 0.25 inch w.g. due to the breaching of electrical penetration seals, and action was not initiated within one hour to place the unit in hot standby within the next six hours, hot shutdown within the following six hours, and cold shutdown within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Response
Admission or Denial of the Alleged Violation As previously noted in Licensee Event Report 87-013-01 transmitted to the NRC on November 4, 1987, Union Electric acknowledges the cited violation.
We believe, however, that a clarification is in order for the Commission's description of the violation which states "...both independent CREVS were inoperable in that each could not maintain the control room at a pressure equal to or greater than 0.25 inch w.g. due to the breaching of electrical penetration seals, and action was nec initiated within one hour...".
Our clarification is that once the inoperable condition of the CREVS was identified, appropriate action was taken in accordance with the Technical Specifications.
There was no deliberate disregard of the Technical Specifications as might be implied from the wording of the violation.
Reason _for the Violation if Admitted The reason for this violation was attributed to utility personnel oversight during the work planning for implementation of a design change which breached the control room electrical penetrations.
Personnel failed to recognize that breaching the electrical penetrations would affect Technical Specification (T/S) 3/4.7.6 requirements.
Programmatically breaching the penetrations was only considered from a fire protection standpoint.
l Corrective Steps That Have Been Taken and the Results Achieved 1
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All five breached CR electrical penetration seals discovered after the failure of the control building pressure test were plugged with a temporary sealing compound.
These temporary seals were replaced with permanent seals during the Refuel II outage, j
i An Operations Night Order was issued to prohibit breaching of the l
CR pressure boundary.
This Operations Night Order will remain in j
effect until procedural guidance is provided for evaluating the impact of breachina any barrier which is a portion of the CR pressure boundary.
An engineering evaluation has been completed which describes the criteria and restrictions for breaching the l
CR pressure boundary.
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ULNRC-1691 Page 3 Management has discussed this event with personnel j.nvolved and i
has directed personnel involved in work planning for design I
changes and corrective maintenance activities to be aware of the
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effects of performing work which might impact Technical e
Specification LCO's.
The Callaway Civil Structural Manual (CSM) Rev.
3, was issued
.with a revised post-pour installation form (PPIF) which includes Systems Engineering review and sign-off for penetrations through
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contro' room, auxiliary building, and fuel building pressure i
boundaries.
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Corrective Steps Which Will be Taken to Avoid Further Violations In addition to the corrective actions taken above which will avoid further violations, the controlling administrative procedure will be revised to prcvide guidance for evaluating the J
impact of breaching any barrier which is a portion of the pressure boundary, j
Date When Full Compliance Will Be Achieved
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Union E"ectric is in compliance with License Conditions and Technical Specifications.
The final element of corrective action will be in place by January 31, 1988.
(50-483/87023-01) SEVERITY LEVEL'III: VIOLATION I.B 10 CFR 50.59 states, in part, that the holder of a license may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the change involves a change in the technical specifications incorporated in the license or an unreviewed safety question.
The change shall be deemed to involve an unreviewed safety question if the consequences of an accident previously evaluated in the safety analysis report may be increased.
The licensee shall maintain records of changes to the facility which include a written safety evaluation providing the bases for the determination that the change does not involve an unreviewed safety question.
Callaway Final Safety Analysis Report (FSAR) Section 6.4.2.3 requires in part, that, during the emergency mode of operation, the control room is maintained at a positive pressure of 0.25 inch w.g.
(minimum) to prevent infiltration from surrounding areac of unfiltered air.
Contrary to the above, as of July 9, 1987, the licensee failed to prepare an adequate safety evaluation to support a change which was made to the area radiation monitoring system annunciators that affected the capability of the control room to maintain positive pressure.
The safety evaluation should have considered work actions to be taken to accomplish the modification wherein the electriccl penetration seals were breached, creating a I
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situation in which the minimum positive pressure in the control room could not be established.
This increased the potential for airborne activity in-leakage and thus created an unreviewed safety question by increasing the consequences of a Loss of Coolant Accident.
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Response
Admission or Denial of the Alleged Violation Union Electric acknowledges that the breaching of the control room electrical penetration seals created an unreviewed safety question under 10 CFR 50,59 as stated above.
However, our investigation of this violation confirms our belief that the Technical Specification violation cited in Violation I.A and the safety evaluation deficiency noted above were caused by the same failure to recognize the adverse condition in which the plant was being placed.
If it had been recognized that breaching the penetration seals in this manner would create a situation in which the minimum positive pressure in the control room could not be established, different modification methods would have been utilized or the work would have been deferred to avoid such a situation.
Under the Union Electric modification program, the designer is responsible for performing safety evaluations which consider the impact of the installed modifications.
We depend on the cognizance of work planners and operating personnel to identify in-process installation activities which may result in an unreviewed safety question situation.
As indicated above, if a potential unreviewed safety question situation had been recog-nized, work activities would not have taken place until the ques-tion was resolved.
This would typically involve the generation of a Request for Resolution to engineering defining the situation.
Engineering would evaluate the request, provide a disposition, and generate a safety evaluation covering the disposition, if appropriate.
This did not occur for the penetration seal breaching activities because no one involved with the installation recognized the problem.
Union Electric's position is that this occurrence does not represent a deficiency in the Callaway Plant safety evaluation program.
The corrective actions taken and to be taken for Violation I.A are considered adequate to prevent this situation from recurring.
(50-483/87028-01) SEVERITY LEVEL III: VIOLATION II 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures be established to assure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified and corrected.
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ULNRC-1691
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Page 5 Contrary to the above, although in May 1984, valve EF-V-0117 of the train "B" Essential Service Water (ESW) system was identified l
as being partly closed, thereby possibly reducing available ESW flow and constituting a condition adverse to quality, measures were not taken to assure that this condition was promptly corrected.
The valve remained in the partly closed condition until August 15, 1987.
The ESW train "B" flow rate was determined to be 11,000 gpm with the valve partially closed while the design flow rate specified in the Callaway FSAR is 13,594 gpm.
Response
Admission or Denial of the Alleged Violation As previously noted in Licensee Event Report 87-018-00 transmitted to the NRC September 14, 1987, Union Electric acknowledges the cited violation with the following clarification to the " contrary to the above" statement in the violation.
In May 1984, valve EF-V 6117 was identified as having a position indication discrepancy, and a work request (WR) was written to correct this problem.
The valve was not actually identified as being partly closed, as indicated in the cited violation, until August 15, 1987 during a valve line-up verification to determine the cause of a low flow condition during a containment cooler surveillance.
This clarification as to when Union Electric knew the valve was mispositioned is the key to the determination of promptness of corrective action.
Union Electric did take prompt corrective action upon final determination that the valve was mispositioned, as indicated in Inspection Report No. 87028 on page 4.
Reason for the Violation if Admitted The primary cause of this violation was the failure of utility personnel to recognize the effect that the valve indication problem had on ESW system operability.
This resulted in a low work priority being placed on the initial WR.
When the Technical Specifications were approved and issued in June 1984, a review of open WR's failed to identify this WR as a mode or operability restraint.
This resulted in our failure to ensure the WR work was performed in a timely fashion.
A corollary reason for this violation was the improper voiding of the initial WR (WR#1) identifying the valve indication discrepancy and of a follow-up WR (WR#2) meant to replace WR#1.
WR#1 was voided on September 9, 1986 because it appeared to be covered by WR#2.
WR#2 (originated June 10, 1986) was initiated to perform an inspection of EF-V-0117 to assist in determining the root cause of an actuator whaft failure in a similar valve.
Completion of the inspection would require a retest involving verification of position indication and thus it was likely
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Page 6 concluded that' performance of WR#2 would also correct the problem in WR#1.
The description of WR#2 had not been modified to specifically embody the work scope of WR#1.
When a later decision was made not to inspect EF-V-0117 due to vendor involvement in th root cause evaluation of the similar valve actuator shaft failure, WR#2 was voided on September 10, 1986.
The review by planning and engineering personnel failed to note that the work scope of WR#2 did not cover WR#1.
Consequently, the problem noted on WR#1 went unresolved.
The following addresces the reason this event was not detected until August 1987.
Since the ASME Section XI baseline was established in very close proximity to the completion of the system pre-op test, results of the baseline total flow value for the ASME XI pump and valve test were not compared to total flow established during the pre-op.
Although methods used to establish this baseline were correct per the ASME code, a l
comparison would have discovered the reduced flow.
When the ESW pump was re-baselined in February 1987 to evaluate suspected pump degradation per ASME XI, only the pump performance was evaluated (no pump degradation had occurred).
If total system performance had been evaluated and compared to system design, the deviation would have been discovered.
Corrective Steps That Have Been Taken and the Results Achieved A caution tag was placed on the valve actuator for EF-V-Oll7 to alert operators to the problem and to ensure that the local indicator on the valve stem was used for position indication until the actuator was repaired during Refuel II to provide accurate position indication.
The failure of personnel to properly prioritize work on the valve indicator and to properly investigate the circumstances created by voiding WR#1 is considered an isolated case.
To provide addi-tional assurance that this was an isolated occurrence, a review of voided and open WR's on selected systems was performed.
This review ensured that operability concerns were properly identified and prioritized.
In addition, this review ensured that WR's were not voided without work completion or appropriate follow-up i
action.
The current WR control procedures, APA-ZZ-00320 " Initiating and Processing Work Requests" and PDP-ZZ-00003 " Work Request Process-ing", require specific definition of the reason for voiding WRs, including the name of the person who initiates such action.
In addition, PDP-ZZ-00003 was revised to specifically require the work planner to ensure that the entire scope of work for a WR being voided is covered by another work document if the WR is being voided because of redundant work documents.
Engineering and work planning personnel involted in voiding the WR's have been counseled.
It was re-emphasized that a thorough I
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l ULNRC-1691 Page 7 review must be accomplished prior to authorizing the voiding of l
any WR.
Using this event as an example, management has directed planning and engineering personnel to fully consider the impact of their activities on.the operability of plant systems.
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An ESW System Total Flow Verification test was performed during i
Refuel II which confirmed that total ESW system flow for trains "A"
and "B" satisfies LOCA requirements.
Corrective Steps Which Will be Taken to Avoid Further Violations i
No further correctivo action is considered necessary.
Date When Full Compliance Will Be Achieved Union Electric is in full compliance and has accomplished all corrective actions necessary to prevent recurrence.
Proposed Civil Penalty Union Electric does not contest the proposed Civil Penalty.
Enclosed is a check in the amount of fifty thousand dollars
($50,000) payable to the Treasurer of the United States.
Please favor us with an acknowledgement of your receipt of this payment.
If you have any questions regarding this response or if additional information is required, please let us know.
Very truly
- ours, e-5 Donald F.
Schnell DFS/APN/bjp Enclosure - Check cc:
A.
B.
Davis - Regional Administrator, Region III W.
D.
Shafer - Chief Emergency Preparedness and Radiological Protection Branch W.
L. Forney - Chief, Reactor Projects, Section 1A Tom Alexion - Licensing Project Manager (2 Copies)
B.
H.
Little - NRC Senior Resident Inspector B.
J. Washburn - Manager, Utility operations, Missouri Public Service Commission
N STATE OF MISSOURI )
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Donald F. Schnell, of lawful age, being first duly sworn upon oath says that he is Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full power and authority to do so; and that the factt, therein stated are true and correct to the best of his knowledgu, information and belief.
By /
f4 2%/
' Donald F.
Schnell Vice President Nuclear SUBSCRIBED and sworn to before me this day of dut*/w,1987'
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BAH AR J,
FA F NOTARY PUBUC, STATE OF MISSOURI MY COMMISSION EXPlRES APRIL 22,198S ST. LOUIS COUNTY.
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