ML021000056
| ML021000056 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/09/2002 |
| From: | Merschoff E NRC Region 4 |
| To: | Randolph G Union Electric Co |
| References | |
| EA-02-046 IR-02-007 | |
| Download: ML021000056 (8) | |
See also: IR 05000483/2002007
Text
April 9, 2002
Garry L. Randolph, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT: FINAL SIGNIFICANCE DETERMINATION FOR A WHITE FINDING AND
NOTICE OF VIOLATION - NRC INSPECTION REPORT 50-483/02-07 -
CALLAWAY PLANT
Dear Mr. Randolph:
The purpose of this letter is to provide you with the final results of our significance
determination of the preliminary White finding identified in the subject inspection report, which
was forwarded to you by our letter of March 21, 2002. The inspection finding was assessed
using the significance determination process (SDP) and was preliminarily characterized as
White, i.e., an issue with low to moderate increased importance to safety, which may require
additional NRC inspections. This White finding involved the degradation of the condensate
storage tank diaphragm seal and subsequent failure of an auxiliary feedwater pump on
December 3, 2001, due to the entrainment of polyurethane foam in the pump suction.
In a telephone conversation with Dr. Dale Powers of my staff on March 26, 2002,
Mr. Mark Reidmeyer of your staff indicated that Union Electric Company did not contest the
characterization of the risk significance of this finding and that you declined your opportunity to
discuss this issue in a Regulatory Conference.
After considering the information developed during the inspection, the NRC has concluded that
the inspection finding is appropriately characterized as White. The finding has a low to
moderate safety significance under the SDP because it involved an increase in the core
damage frequency of between 1E-6/year and 1E-5/year. The finding may require additional
NRC inspections.
You have 10 business days from the date of this letter to appeal the staffs determination of
significance for the identified White finding. Such appeals will be considered to have merit only
if they meet the criteria given in NRC Inspection Manual Chapter 0609, Attachment 2.
The NRC has also determined that the multiple failures to promptly identify and correct the
degraded condensate storage tank diaphragm seal are a violation of 10 CFR Part 50,
Appendix B, Criterion XVI, as cited in the attached Notice of Violation (Notice). The
Union Electric Company -2-
circumstances surrounding the violation were described in detail in the subject inspection
report. In accordance with the NRC Enforcement Policy, NUREG-1600, the Notice of Violation
is considered an escalated enforcement action because it is associated with a White finding.
You are required to respond to this letter and should follow the instructions specified in the
enclosed Notice when preparing your response. The NRC will use your response, in part, to
determine whether further enforcement action is necessary to ensure compliance with
regulatory requirements.
As a result of this finding, as well as a finding of similar significance involving the failure of an
essential service water pump in February 2001, the Callaway Plant performance is in the
degraded cornerstone column of the NRC Action Matrix. Consequently, NRC will use the
degraded cornerstone column of the NRC Action Matrix to determine the most appropriate NRC
response for this event.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its
enclosures will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room).
Sincerely,
Thomas P. Gwynn for
Ellis W. Merschoff
Regional Administrator
Docket: 50-483
License: NPF-30
Enclosure:
Notice of Violation
cc w/enclosure:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855
John ONeill, Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, N.W.
Washington, D.C. 20037
Union Electric Company -3-
Mark A. Reidmeyer, Regional
Regulatory Affairs Supervisor
Regulatory Affairs
AmerenUE
P.O. Box 620
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
for Public Policy
Department of Natural Resources
205 Jefferson Street
Jefferson City, Missouri 65101
Otto L. Maynard, President and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
Dan I. Bolef, President
Kay Drey, Representative
Board of Directors Coalition
for the Environment
6267 Delmar Boulevard
University City, Missouri 63130
Lee Fritz, Presiding Commissioner
Callaway County Courthouse
10 East Fifth Street
Fulton, Missouri 65251
J. V. Laux, Manager
Quality Assurance
AmerenUE
P.O. Box 620
Fulton, Missouri 65251
Jerry Uhlmann, Director
State Emergency Management Agency
P.O. Box 116
Jefferson City, Missouri 65101
Union Electric Company -4-
Gary McNutt, Director
Section for Environmental Public Health
P.O. Box 570
Jefferson City, Missouri 65102-0570
John D. Blosser, Manager
Regulatory Affairs
AmerenUE
P.O. Box 620
Fulton, Missouri 65251
Union Electric Company -5-
Electronic distribution from ADAMS by RIV:
J. Donohew, Project Manager (JND)
T. Frye, NRR (TJF)
Regional Administrator (EWM)
DRP Director (KEB)
DRS Director (ATH)
DRS/STA (DAP)
G. Sanborn, (GFS)
Senior Resident Inspector (VGG)
Branch Chief, DRP/B (DNG)
Senior Project Engineer, DRP/B (RAK1)
DRP/TSS (PHH)
RITS Coordinator (NBH)
CWY Site Secretary (DVY)
R. Wise (RXW)
H. Freeman (HAF)
K. Smith (KDS1)
B. Maier (WAM)
B. Henderson (BWH)
C. Nolan - (CMN)
M. Johnson - (MRJ1)
Reactor Distribution w/RIDS codes
DISTRIBUTION:
RIDSSECYMAILCENTER
RIDSOCAMAILCENTER
RIDSEDOMAILCENTER
RIDSOEMAILCENTER
RIDSOGCMAILCENTER
RIDSNRROD
RIDSNRRADIP
RIDSOPAMAIL
RIDSOIMAILCENTER
RIDSOIGMAILCENTER
RIDSOCFOMAILCENTER
RIDSRGN1MAILCENTER
RIDSRGN2MAILCENTER
RIDSRGN3MAILCENTER
OEWEB
R4ALLEGE
Hard Copy:
Union Electric Company -6-
Records Center, INPO
DOCUMENT NAME: R:\_CW\CW2002-07 FINAL LETTER AND NOV.WPD
RIV:DRS\SRA NRR/PM SRI RI D:ACES
TWPruett:nlh JNDonohew TLHoeg TWJackson GFSanborn
/RA/ E E E /RA/
03/22/02 03 /25 /02 03/22/02 03/25/02 03/28/02
KEBrockman DAPowers ATHowell lll TPGwynn EWMerschoff
/RA/ /RA/ DAPowers for /RA/ TPGwynn for
03/27/02 03/27/02 03/28/02 04/03/02 04/09/02
OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax
NOTICE OF VIOLATION
Union Electric Company Docket: 50-483
Callaway Plant License: NPF-30
During an NRC inspection conducted between January 28 and February 27, 2002, a violation of
NRC requirements was identified. In accordance with the "General Statement of Policy and
Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:
10 CFR Part 50, Appendix B, Criterion XVI, requires, in part, that measures shall be
established to assure that conditions adverse to quality, such as failures, malfunctions,
deficiencies, deviations, defective material and equipment, and nonconformances are
promptly identified and corrected. For significant conditions adverse to quality, the
measures shall assure that the cause of the condition is determined and corrective
actions taken to preclude recurrence. The identification of significant conditions adverse
to quality shall be documented and reported to appropriate levels of management.
Contrary to the above, between January 1992 and January 31, 2002, the licensee failed
to promptly identify and correct a significant condition adverse to quality involving the
potential for foreign material to be in the auxiliary feedwater system and condensate
storage tank. In addition, between January 25 and 29, 2002, the identification of a
significant condition adverse to quality was not reported to the appropriate levels of
management. Specifically, there were several missed opportunities to identify and
correct the degraded condensate storage tank diaphragm seal, including the following
examples:
(1) In 1992, Corrective Action Tracking System Item 31040, which had been initiated
to generate an inspection of the condensate storage tank diaphragm seal, was
closed without having completed the inspection. The inspection was to have
been completed in response to NRC Information Notice 91-82, Problems With
Diaphragms in Safety Related Tanks.
(2) During the Spring and Summer of 2000, the inspection of the condensate
storage tank diaphragm was deferred on two occasions without adequate
justification. The deferrals were based on the chemistry specifications of the
condensate storage tank water and did not consider the potential for degradation
of the diaphragm seal.
(3) On October 17, 2000, an inadequate inspection of the condensate storage tank
diaphragm seal was performed. The inspection did not identify the degraded
condition of the diaphragm seal.
(4) On January 15, 2002, foreign material was not considered a credible failure
mechanism even though polyurethane foam was discovered in the seal water
cooling line for auxiliary feedwater Pump A.
(5) Between January 25 and 30, 2002, a significant condition adverse
to quality was not reported to appropriate levels of management in a timely
-2-
manner. Information regarding the as-found condition of the condensate storage
tank diaphragm seal was incorrectly reported. Consequently, broad corrective
actions to assess the extent of condition associated with the failure of the
diaphragm seal were delayed.
This violation is associated with a White Significance Determination Process finding.
Pursuant to the provisions of 10 CFR 2.201, Union Electric Company is hereby required to
submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Regional Administrator,
U.S. Nuclear Regulatory Commission, Region IV, 611 Ryan Plaza Drive, Suite 400, Arlington,
Texas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this
Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This
reply should be clearly marked as a "Reply to a Notice of Violation" and should include for each
violation: (1) the reason for the violation or, if contested, the basis for disputing the violation or
severity level, (2) the corrective steps that have been taken and the results achieved, (3) the
corrective steps that will be taken to avoid further violations, and (4) the date when full
compliance will be achieved. Your response may reference or include previous docketed
correspondence, if the correspondence adequately addresses the required response. If an
adequate reply is not received within the time specified in this Notice, an order or a Demand for
Information may be issued as to why the license should not be modified, suspended, or
revoked, or why such other action as may be proper should not be taken. Where good cause is
shown, consideration will be given to extending the response time.
If you contest this enforcement action, you should also provide a copy of your response, with
the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory
Commission, Washington, DC 20555-0001.
Because your response will be made available electronically for public inspection in the NRC
Public Document Room or from the Publicly Available Records (PARS) component of NRCs
document system (ADAMS), to the extent possible, it should not include any personal privacy,
proprietary, or safeguards information so that it can be made available to the public without
redaction. ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html (the Public Electronic Reading Room). If personal privacy or proprietary
information is necessary to provide an acceptable response, then please provide a bracketed
copy of your response that identifies the information that should be protected and a redacted
copy of your response that deletes such information. If you request withholding of such
material, you must specifically identify the portions of your response that you seek to have
withheld and provide in detail the bases for your claim of withholding (e.g., explain why the
disclosure of information will create an unwarranted invasion of personal privacy or provide the
information required by 10 CFR 2.790(b) to support a request for withholding confidential
commercial or financial information). If safeguards information is necessary to provide an
acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated this 9th day of April 2002