ULNRC-05374, Special Report 07-001 Re Historical Inoperability of Seismic Instrument SGAR0008

Special Report 07-001 Re Historical Inoperability of Seismic Instrument SGAR0008

ML070890296
Person / Time
Site:	Callaway
Issue date:	03/08/2007
From:	Diya F AmerenUE
To:	Document Control Desk, NRC/NRR/ADRO
References
SGAR0008, ULNRC-05374 07-001
Download: ML070890296 (6)

Text

AmerenUE P0 Box 620 Cal/awayPlant Fulton, MO 65251 March 8, 2007 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC-05374 n Ladies and Gentlemen:

• "'Ame U/E DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30 SPECIAL REPORT 07-01 Historical Inoperability of Seismic Instrument SGAR0008 Enclosed is a voluntary Special Report documenting three historical occurrences of seismic instrument SGAR0008, 'C' Steam Generator Support Peak Recording Accelerometer, inoperability for which a report in accordance with Final Safety Analysis Report Section 16.3.3.2 Action 'a' was not submitted.

No new commitments are identified in this correspondence. None of the material in this report is considered proprietary by Union Electric.

If you have any questions or require additional information, please contact Mr. Keith Mills, Supervisor, Regulatory Affairs Regional/Safety Analysis at 573/676-4317.

Sincerely, F. M. Diya Director Plant Operations Enclosure 1) Special Report a subsidiaryof Ameren Corporation

ULNRC-05374 March 8, 2007 Page 2 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Conr2-nission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Cailaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

bcc: C. D. Naslund A. C. Heflin F. M. Diya D. T. Fitzgerald G. A. Hughes D. E. Shafer S. L. Gallagher (100)

L. M. Belsky (NSRB)

K. A. Mills P. M. Bell J. W. Hiller A160.0761 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrecreceives ALL attachments as long as they are non-safeguards and public disclosed).

Send the following without attachments:

Ms. Diane M. Hooper Mr. Dennis Buschbaum Supervisor, Licensing TXU Power WCNOC Comanche Peak SES P.O. Box 411 P.O. Box 1002 Burlington, KS 66839 Glen Rose, TX 76043 Mr. Scott Bauer Mr. Stan Ketelsen Regulatory Affairs Manager, Regulatory Services Pao Verde NGS Pacific Gas & Electric P.O. Box 52034, Mail Stop 104/5/536 Mail Station 7636 P.O. Box 56 Phoenix, AZ 85072-2034 Avila Beach, CA 93424 Mr. Scott Head Mr. John O'Neill Supervisor, Licensing Pillsbury Winthrop Shaw Pittman LLP South Texas Project NOC 2300 N. Street N.W.

Mail Code N5014 Washington, DC 20037 P.O. Box 289 Wadsworth, TX 77483

ULNRC-05374 March 8, 2007 Page 1 of 3 ENCLOSURE Special Report The Seismic Instrumentation Limiting Condition For Operation (LCO), Section 16.3.3.2 of the Final Safety Analysis Report (FSAR), requires seismic monitoring instrumentation to be Operable at all times. With one or more of the required seismic monitoring instruments inoperable for more than 30 days, LCO Action 'a' requires a Special Report to be prepared and submitted to the Commission within the next 10 days outlining the cause of the malfunction and the plans for restoring the instrument(s) to Operable status.

There is no current inoperability of seismic instrumentation requiring the submittal of a Special Report. However, a practice associated with surveillance testing of required seismic instrument SGAR0008, 'C' Steam Generator Support Peak Recording Accelerometer, was identified to have the potential for challenging the requirements of LCO 16.3.3.2. The practice of removing SCAR0008 from service during refueling outages was initiated in 1999 without establishing a consistent method to ensure that associated LCO actions were tracked. This issue was documented in the Callaway corrective action program as CAR 200700754 on 1/26/2007. The evaluation under CAR 200700754 revealed previous instances where Special Reports for SGAR0008 inoperability were required but not submitted.

There is no specific reporting requirement addressing historical seismic instrument inoperability or the failure to report as required under FSAR 16.3.3.2 Action 'a'.

However, a voluntary submittal is being made to document three failures to report and to address the cause and associated corrective actions.

Background

As part of the evaluation under the corrective action program, the electronically available work history for SGAR0008 was reviewed back through 1992. The review initially revealed four potential occurrences of seismic instrumentation inoperability lasting longer than 30 days (720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />) for which no Special Report was issued.

Further investigation of the surveillance testing documentation on SGAR0008 revealed that a suggestion documented in CAR 199301604 was written to evaluate potential false recordings due to heavy work performed near the seismic instrumentation (SGAR0008 is located in the containment building near the equipment hatch). One of the specified actions was to create an auxiliary work document in addition to the required surveillance testing. The purpose of the auxiliary work document was to read and restore, as necessary, the scratch plates for SGAR0008 at the end of each outage and to trend the results to determine any further necessary actions. As surveillance testing was performed from 1993 through 1998, testing was completed at the beginning of each outage with the instrument restored

ULNRC-05374 March 8, 2007 Page 2 of 3 during the surveillance procedure. The auxiliary work document was then performed at the end of each outage.

The 1995 performance of this surveillance was originally identified as exceeding 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> based on the work history review; however, the surveillance record shows that the seismic monitor was restored within one day of beginning the surveillance. The auxiliary document was then performed at the end of the outage as discussed above.

Sometime between the 1998 and 1999 surveillance testing, the decision was made to physically remove the instrument following the surveillance at the beginning of an outage and to replace it under the auxiliarywork document at the end. Beginning with the 1999 surveillance, guidance was added to the task instructions stating: "Store SGAR0008 in a protected location and note where located". Further review ultimately identified three occurrences where this practice resulted in SGAR0008 being removed from service for greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />.. A Special Report was net submitted in accordance with requirements of FSAR 16.3.3.2 Action 'a' for the removal of SGAR008 as follows:

Surveillance Removal Re.storation Awprox. Duration [Hours]

S619859 10/2/1999 1/1/1999 733 S647679 4/7/2001 5/12/2001 849 S701110 4/10/2004 5/26/2004 1119 Cause of the Failure to Submit a Special Report Callaway Plant's evaluation determined there were inadequate administrative controls established to ensure that time tracking under FSAR 16.3.3.2 was performed when the practice of removing SGAR0008 was implemented. In addition, the controls established through surveillance procedure and work document notes to initiate time tracking were not consistently implemented.

Extent of Corlition The work practices and history of the remaining eight required seismic instruments were reviewed to determine the extent of condition. The practice of instrument removal for protection against potential false recordings during heavy work activities was not implemented for these instruments. Consequently, the unavailability of these instruments has been significantly less than the 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> allowed under LCO 16.3.3.2 Action 'a'. The electronic surveillance history of all eight instruments was reviewed back through 1992. No additional reporting failures were identified.

ULNRC-05374 March 8, 2007 Page 3 of 3 Corrective Action The remedial action of adding a step to the core work document, which generates the surveillance documents for SGAR0008, has been completed. The added step requires a sign-off and causes notification to the Control Room staff to track the inoperability of SGAR0008 during surveillance testing and removal from service.

Final corrective action is to incorporate a similar step into the specific surveillance procedure associated with each required seismic instrument. These corrective actions were completed on March 1, 2007.