ML20237E617
| ML20237E617 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 12/21/1987 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| ULNRC-1701, NUDOCS 8712290087 | |
| Download: ML20237E617 (4) | |
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Donald F. Schnell,
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U.S. Nuclear Regulatory Commission
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L Document Control Desk Washington, D.C.
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ULNRC-1701 lp Gentlemen:
p INSPECTION REPORT NO'S. 50-483/8'1033 L 87035 ThisrespondstcIC.E.-Norelius'sletter;datedNovember24, 1987 which transmitted the NRC's evaluation of'.the inspec-T, tien conducted at Cal $ vay Plant during the' period.of
_ October 7-17, 1987.. Our responses to the violatiorfs are presented below.
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. N None of the material in these. responses is consiper'ed i
proprietary by Union Electric Company, f ) (, yj
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' k.. g (50-483/87033-01) SEVERITY LEVEL IV: VIOLATION 1 10CFR50, Appendix B, Criterion XI (Test' Control). requires, in part, that a test I.rogram be established to apare that 3
all testing required to demonstrate that: structurett sys-tems, and components will perform satisfactorily in'serd,1ce is identified and performed in accordance:with written t(st procedures which incorporate the requirements and acceptance lithits contained in applicable design documents.
Test.
't rescits shall be documented and evaluated to assure that test requirements'have b4tn satisfied.
Bechtel Drawing No. M2H15210, an applicable d.esign document for the Conrrol Room Emergency Ventilation System (CREVS),
specifies a supply flow -(controlled. by damper GKD. 0324) 4of",
350 cfm for the Contrcl Room Air Conditioning Unit Equipment j4 Room (CRACUER);-
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Contrary to the above, Preoperational Test Packaga No.L
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CS-03-GK01 did.not include the requirements and acceptangp limits for the CRACUER/ supply air flow as specified on
'i Bechtel' Drawing No. M2H15210.. Inadd,ition,~theairflow'to*h'
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3 the CRACUER was neither documented'nor avy utted to assure J
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that test requirements had been satisfibd.
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B712290087 8712E1 0
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Mailing Address: P.O. Box 149, St. Louis M63166 L
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ULNRC-17011 Page 2.of d '
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Response
Corrective Action Taken'and the Results Achieved The preoperational test packages associated with both trains of the Control Room Emergency Ventilation System (CREVS) and the Fuel Building Emergency Ventilation System (FBEVS) were
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reviewed to ensure that no other similar omissions of t'
verification'had occurred.
No other deficiencies were found.
A system flow balance was also performed for each' train of the CREVS.
The results.of those. flow balances did not indicate any' deviations "from. design values which affected i
system operability.
Manually positioned flow balancing dampers on the CREVS and FBbVS have been equipped with-locking devices and will be administratively controlled in accordance with the Callaway locked valve program.
The. correct balanced position is now indicated on each manual flow balancing damper on'the CREVS and the FBEVS.
Union Electric has initiated preventive maintenance task' sheets to periodically verify the flow rates required for system operability of both the CREVS and FBEVS.
Corrective Action to be Taken to Avoid Further Violations Union Electric is initiating a formal review of the objec-tives.of the predictive maintenance, preventive maintenance, l
and surveillance testing programs for safety related sys-tems.
This review will compare existing programs with the performance reqtisements of safety related systems to assure those requirements ce verified to be satisfied periodical-ly.
When system safety related performance requirements are not currently being periodically verified by an existing operational program, an evaluation will be performed.
This evaluation will address factors such as detectability of.
performance degradation during operation, the pctential mechanisms for performance degradation, and the operational impact of additional testing or monitoring.
This review will identify recommended additions to the predictive or preventive maintenance programs.
Implementation of the 3
predictive and preventive maintenance requirements resulting-1 from this review will identify inservice. degradation or preoperational test program omissions affecting system operability.
The Date When Full Compliance Will be Achieved Union Electric is in compliance with license conditions and Technical Specifications.
The above stated comprehensive review will be completed by May 1, 1988.
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ULNRC-1701 4
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(50-483/87033-02) SEVERITY LEVEL IV: VIOLATION 2 4
3 10CFR50, Appendix B, Criterion XVI (Corrective Action)-
l requires that measures be-established to assure that condi-tions adverse to quality and nonconformances are promptly 4
identified and corrected.
In the case of'a significant condition adverse to quality, the measures shall assure that the cause of the condition is determined and corrective i
action.taken to preclude repetition.
Contrary to the above, measures were not taken to assure that conditions adverse to quality were promptly corrected in that on August 14, 1987, while performing CREVS flow i
measurements, utility personnel found damper GKD 0324 in a nearly closed position.
This resulted in a flow of 160 cfm to the CRACUER.
Although the system engineer was aware that the design air flow, as specified on Bechtel Drawing No.
M2H15210,.was 350 cfm, the damper was left in the as-found position.
Plant engineering issued a Request for Resolution of thjs matter on August 19, 1987;-however, the damper was I
not correctly positioned until October 8, 1987.
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Response
Corrective Action Taken and the Results Achieved
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Management has counseled the engineering personnel involved j
with the determination of system operability on their i
failure to initiate an appropriate corrective action docu-ment (Incident Report) to address the discovered condition.
Involved personnel have been counseled on the importance of resolution of significant deviations from safety related parameters, Additional guidance was issued to engineering personnel to clarify the conditions which require the initiation of an Incident Report.
As described in the response to Violation 1, the CREVS was l
subsequently flow balanced and CRACUER flows'wcre'estab-lished within acceptable ranges.
It was determined that damper GKD 0324 required an adjustment of one-half inch from the as-found condition to meet the design air flow.
Corrective Action to be Taken to Avoid Further Violations l
The guidance given to engineering personnel regarding initiation of an Incident Report will be incorporated into applicable procedures.
The Date Wh,en rull Compliance Will be Achieved Union Electric is in compliance with license conditions and l
Technical Specifications.
The guidance on the initiation of Incident Reports:will be incorporated into procedures by May I.y;1988.
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ULNRC-1701 Page 4 of 4 l
If you have any questions regarding this response or-if additional information is required, please let me know.
Very truly yours,
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Donald F. Schnell cc:
A. B. Davis - Regional Administrator, Region III
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J. M. Hinds - 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 l
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