IR 05000483/1996009

Ack Receipt of Informing NRC of Steps Taken to Correct Violation Noted in Insp Rept 50-483/96-09 on 960901-1012

ML20133A360
Person / Time
Site:	Callaway
Issue date:	12/27/1996
From:	Dyer J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Schnell D UNION ELECTRIC CO.
References
NUDOCS 9612310062
Download: ML20133A360 (5)

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DEC 271996 i

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Donald F. Schnell, Senior Vice '

President - Nuclear  !

Union Electric Company i P.O. Box 149  !

i St. Louis, Missoun 65166 l .

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SUBJECT: NRC INSP.ECTION REPORT 50-483/9609 i

Dear Mr. Schnell:

Thank you for your letter of November 25,1996,in response to our letter and

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f Notice of Violation dated October 31,196. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. Our identification'of this t minor example was .. 6 ended to heighten plant staff sensitivity to the importance of a ,

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thorough review of procedures which are potentially impacted by minor design changes. l

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We will review the implementation cf your corrective actions during a future inspection to i determine that full compliance has been achieved and will be maintained.

Sincerely, W '

J. E. Dyer, Director .

Division of Reactor Projects Docket No.: 50-483 License No.: NPF-30

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cc w/ enclosure:

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, Maryland 20855 i

Gerald Charnoff, Esq.

Thomas A. Baxter, Esq.

. Shaw, Pittman, Potts & TrowtHdge 2300 N. Street, N.W.

Washington, D.C. 20037 l

9612310062 961227 PDR ADOCK 05000483 e PM

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l Union Electric Company -2-H. D. Bono, Supervising Engineer Site Licensing  !

Union Electric Company P.O. Box 620 Fulton, Missouri 65251 -

G. L. Randolph, Vice President .

Nuclear Operations j

Union Electric Company .

P.O. Box 620 I Fulton, Missouri 65251 Manager - Electric Department Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, Missouri 65102 Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 I Jefferson City, Missouri 65102 Neil S. Carns, President and Chief Executive Officer  !

Wolf Creek Nuclear Operating Corporation P.O. Box 411 i Burlington, Kansas 66839  ;

Dan 1. Bolef, President Kay Drey, Representative Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 Lee Fritz, Presiding Commissioner l Callaway County Court House 10 East Fifth Street Fulton, Missouri 65151

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Union Electric Company -3- -

Alan C. Passwater, Manager Licensing and Fuels Union Electric Company P.O. Box 149 St. Louis, Missouri 63166 J. V. Laux, Manager Quality Assurance Union Electric Company P.O. Box 620 Fulton, Missouri 65251 j l

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DEC 2 71996 Union Electric Company -4-

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bec to DMB (IE01)

bec distrib. by RIV:

L. J. Callan Resident inspector DRP Director DRS-PSB ,

Branch Chief (DRP/B) MIS System l Project Engineer (DRP/B) RIV File j Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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1 310020 DOCUMENT NAME: R:\_CW\CW609AK.DP To receive copy of document, Indicate in box: "C" = Copy weout enclosures "E" = Copy with enclosures "N" = No copy RIV:C:DRP/B * D:DRP l l WDJohnson;df JEDyer GWP 12/20/96 12ff?/96 OFFICIAL RECORD COPY

• PREVIOUSLY CONCURRED f

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DEC 271996 Union Electric Company -4- l bec to DMB (IE01)

bec distrib, by RIV:

L. J. Callan Resident inspector DRP Director DRS-PSB <

Branch Chief (DRP/B) MIS System Project Engineer (DRP/B) RIV File

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j Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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i DOCUMENT NAME: R:\_CW\CW609AK.DP To receivo copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:C:DRP/B * D:DRP l l WDJohnson;df JEDyer GWP 12/20/96 12/l7/96 l OFFICIAL RECORD COPY

• PREVIOUSLY CONCURRED

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/ 1901 Chouteau Avenue ,

Post Office Box 149

, St. lavis. Missoun 63166 314 554 2650

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'g November 25,1996 i

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U. S. Nuclear Regulatory Commission Atta: Document ControlDesk i Mail Stop P1-137 I Washington, DC 20555-0001 ULNRC-3495 ,

Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/96009 CALLAWAY PLANT i I

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This responds to Mr. J. E. Dyer's letter dated October 31,1996, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96009. Our response to the violation is presented in the attachment.

None of the materialin the response is considered proprietag by Union Electric.

If you have any questions regarding this response, or if additional information is l required, please let me know.  !

Very truly yours,

• l Donald ,

DFS/tmw Attachment: 1) Response to Violation

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'k ULNRC-3495

November 25,1996 .

Page 2 3

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i cc: Mr. L. Joe Callan f Regional Administrator ,

U.S. Nuclear Regulatory Commission  !

Region IV  ;

611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector Callaway Resident Office  !

U.S. Nuclear Regulatory Commission  ;

8201 NRC Road Steedman,MO 65077 Ms. Kristine M. Thomas (2 copies) l Licensing Project Manager, Callaway Plant i Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission

- Mail Stop 13E16 l Washington, DC 20555-2738  ;

i Manager, Electric Department i Missouri Public Service Commission {

PO Box 360 Jefferson City, MO 65102

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Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.  !

Washington,DC 20037 ,

Manager, Plant Support Wolf Creek Nuclear Operating Corporation l

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PO Box 411 -

Burlington, KS 66839

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Attachment to ULNRC-3495 November 25,1996 Page1 Statement of Violation During an NRC inspection conducted on September 1 through October 12,1996, one violation of NRC requirements was identified. In accordance with the " General Statement

, ofPolicy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Callaway Plant Technical Specification 6.8'.1.a states that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A, of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A, paragraph 6.1. lists procedures for combating loss of l primary coolant.

Section 18 of Emergency Operating Procedure E-1, " Loss of Reactor or Secondary Coolant", Rev.1B2, describes the steps required to energize hydrogen recombiners following a loss of coolant accident. This procedure instructs that hydrogen recombiners be energized according to Procedure OTN-GS-00001, " Containment Hydiogen Control

' System", Rev. 5 Contrary to the above, on September 19,1996, the inspectors identified that Procedure OTN-OS-00001 was not properly maintained because a modification made to a hydrogen recombiner temperature indicator was not translated into Procedure OTN-GS-00001.

This is a Severity Level IV violation (Supplement 1).

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Reason for the Violation

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The Callaway Plant Design Change Program utilizes a tiered approach determined by the -

significance of the change. Equivalent Material-Request for Resolution (RFRs) may be used to make design changes to material, components or parts which are considered a like-kind replacement. Replacement of the analog instrument GSTI0029 with a digital instmment was accomplished using the Equivalent Material RFR process since the instrument was non-safety related, had no control function, and provided indication only.

Procedure OTN-GS-00001 " Containment Hydrogen Control System", Revision 5, Step 4.4.9.2 requires taking temperature readings from GSTI0029. This indicating function was not affected by the change made under the Material Equivalent RFR, even though the instmment was physically changed.

The physical change to the instrument did not adversely affect the operator's ability to take the required temperature reading per the procedure. Operations is notified of all RFR approvals so that they may be screened for potential impact. No changes were deemed

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ULNRC-3495 November 25,1996 Y]i Page 2 necessary during the screening review of this Material Equivalency RER. OTN-GS-00001 was not revised to remove the infonnational note which pertained to the analog instrument and did not apply to the replacement digital temperature indicator. (The note described tapping the analog gauge when changing thermocouples to ensure a true reading.)

2 Procedure OTN-GS-00001 is a Reference Use procedure, and the informational note is not a procedure step. Therefore, there was no impact on the procedure results.

Corrective Steps Taken and Results Achieved:

Procedure OTN-GS-00001, Rev 5, was revised by Temporary Change Notice 96-248 and issued October 3,1996. Further reviews determined that the analog-to-digital change to i the temperature indicator similarly affected OSP-GS-00001, Rev. 6, " Containment H2 l Recombiner Functional Test" Revision 7 was issued October 4,1996.

l Corrective Steps to Avoid Further Violations:

There is no safety signi6cance or operationalimpact described in this violation. The

, procedure change process would likely have addressed deletion of the informational note

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as a future enhancement. Therefore, no further actions are necessary and the current tiered design change program will be retained.

I Date when Full Compliance will be Achieved: .

Full compliance was achieved on October 4,1996.

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