IR 05000483/1987023
| ML20236V106 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/09/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Schnell D UNION ELECTRIC CO. |
| Shared Package | |
| ML20236V108 | List: |
| References | |
| NUDOCS 8712040089 | |
| Download: ML20236V106 (4) | |
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November 9, 1987 Docket No. 50-483 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORTS N0. 50-483/87023(DRSS) AND N0. 50-483/87028(DRP))
This refers to NRC inspections conducted during the period August 24 thrcugh September 11, 1987 of activities authorized by NRC Operating License No. NPF-30 at the Callaway County Nuclear Station. These inspections reviewed the events reported by the licensee involving the Control Room Emergency Ventilation System (CREVS) and the Essential Service Water (ESW) system. The details of these events are presented in the subject inspection reports which were sent to you by letters dated September 25 and 28, 1987.
On October 2, 1987, an enforcement conference was held with you and members of your staff during which the viola-tions, root causes, and your corrective actions were discussed.
Violation I occurred while the plant operated in Mode 1, when both independent CREVS systems were inoperable for approximately one month. Modifications were being performed during this period which caused the breaching of the control room electrical penetration seals. This degraded the capability of the CREVS to provide the required positive pressure in the control room and corrective action was not initiated within the time specified in the technical specifica-tions (TS). A safety evaluation report performed to support this modification did not evaluate the work sequence and actions needed to accomplish the modifi-cation.
Thus, during the period of work, when the control room boundary was breached in order to accomplish the modification, an unreviewed safety question arose in that the consequences of a Loss of Coolant Accident (LOCA) were increased in that the postulated radiation doses to the control room staff would have risen.
Violation II occurred during the period May 1984 through August 15, 1987 when a partially closed valve in the ESW system reduced.the flow capability of the ESW "B" train. While the problem with the valve position was identified by the licensee, prompt corrective action was not taken to restore the system to proper operation. This deficiency was initially to be corrected in a maintenance work request.
However, the work request was erroneously cancelled by the licensee without performing the work. The effect of the valve position on the operability of the system was not evaluated at the time that the deficiency was found nor at the time that the work request was cancelled.
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November 9, 1987
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i To emphasize the need for disciplined control of modification, maintenance and corrective action activities'affecting the operability of safety systems, I have
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been authorized, after consultation'with the Director, Office of Enforcement,
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and the Deputy Executive Director for Regional Operations, to issue the enclosed Notice of Violation and Proposed imposition of Civil Penalties in the amount of Fifty Thousand Dollars ($50,000) for the violations described in the enclosed
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. Notice.
In accordance with the " General. Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1987) (Enforcement Policy),
Violations I.A and I.B and Violation II described in the enclosed Notice have.
been categorized as a Severity Level III problem. The base value of a civil penalty for a Severity Level III violation or problem-is $50,000. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circum-stances.
For Violations I and II, the civil penalty has been reduced by 50 per-cent because of your prior good performance in the area of maintenance that-resulted in a Category 1 SALP and because these violations appear to be isolated events. Whi_le the violations were identified and reported by the licensee, further mitigation _of the civil penalty was not deemed warranted because of the duration that the violations existed and the~ corrective actions were neither unusually prompt nor extensive.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including.your proposed corrective actions, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC'
regulatory requirements.
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In accordance with Section 2.790 of the NRC's " Rules of Practice,i' Part 2,.
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The responses directed by this letter and the enclosed Notice are:not subject to the clearance procedure of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, Pub. L. No.96-511.
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Sincerely,
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Y A. Ber Davi Regional Administrator Enclosures:
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Notice of Violation and Proposed Imposition of Civil Penalty 2.
NRC Inspection Reports No. 50-483/87023 DRSS)
No. 50-483/87028 DRP)
RII RI4 RIII RII
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Union Electric Company-3-November 9, 1987 l
l cc w/ enclosure:
A. P. Neuhalfen, Manager Quality Assurance Tom P. Sharkey, Supervisor, Compliance DCD/DCB(RIDS)
l Licensing Fee Management Branch Resident Inspector, RIII l
Region IV Resident Inspector, Wolf Creek K. Drey Chris R. Rogers, P.E.
Utility Division, Missouri Public Service Commission CFA, Inc.
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Union Electric Company-4-November 9, 1987 DISTRIBUTION:
PDR SECY CA ACRS J. Taylor, DED0 A. B. Davis, RIII J. Lieberman, OE L. Chandler, 0GC P. Milano, OE Enforcement Coordinators RI, RII, RIII, RIV, RV T. Aurley, NRR B. Hayes, 01 S. Connelly, OIA E. Jordan, AE0D F. Ingram, PA G. Johnson, RM DCS
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