ML062570547

Response to Comments Relating to a Noncited Violation in NRC Inspection Report 05000483-06-011

ML062570547
Person / Time
Site:	Callaway
Issue date:	09/14/2006
From:	Howell A Division Reactor Projects I, Zordan Associates
To:	Naslund C Union Electric Co
References
EA-06-217
Download: ML062570547 (5)

See also: IR 05000483/2006011

Text

September 14, 2006

EA-06-217

Charles D. Naslund, Senior Vice

President and Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, MO 65251

SUBJECT: RESPONSE TO COMMENTS RELATING TO A NONCITED VIOLATION

IN NRC INSPECTION REPORT 05000483/2006011

Dear Mr. Naslund:

This is in response to a letter from Mr. Keith D. Young, Manager, Regulatory Affairs, dated

August 10, 2006, regarding AmerenUEs comments to the Callaway Plant Special NRC

Inspection Report 05000483/2006011, dated July 14, 2006. In the letter, AmerenUE requests

that the NRC re-evaluate Noncited Violation 5000483/2006011-01, Failure to Recognize and

Correct Inadequate Emergency Procedures, and change the characterization of this finding

from an NRC-identified to a licensee-identified inspection finding.

As stated in your letter, and discussed in the NRCs cover letter to the inspection report, on

March 27, 2006, Callaway Plant personnel identified a procedural deficiency related to the

amount of time required for Control Room crews to establish component cooling water flow to

the residual heat removal heat exchangers, as demonstrated in licensed operator simulator

training. The inspectors reviewed AmerenUEs actions to evaluate emergency operating

procedure (EOP) deficiencies prior to identifying the concern with the timing of component

cooling water initiation during emergency core cooling system containment recirculation.

AmerenUEs short-term actions associated with the finding included that a Safety Analysis

Engineer researched the issue and a corrective action document was initiated regarding the

deficiency in the procedure. The NRC recognizes that an AmerenUE root cause analysis team

was formed to investigate the issue, its extent of condition, and any generic related issues.

The NRC inspection team interacted with AmerenUEs root cause analysis team and there was

a sharing of information as the root cause investigation team performed its investigation.

However, in assessing whether the finding was NRC identified, self-revealing or licensee-

identified, the NRC considered the definition of NRC-identified offered in Manual

Chapter 0612, Power Reactor Inspection Reports, issued on June 22, 2006. That definition

states that NRC-identified findings also include previously documented licensee findings to

which the inspector has significantly added value. Added value means that the inspector has

identified previously unknown weakness(es) in the licensees classification, evaluation, or

corrective actions associated with the licensees correction of a finding.

Union Electric Company -2-

As stated earlier, the NRC did give Callaway Plant personal credit for identifying the procedural

deficiency, as reflected in the licensee-identified violation documented in the subject special

inspection report. However, for the performance deficiency associated with previous

opportunities to identify this issue and the associated Green noncited violation of 10 CFR Part 50, Appendix B, Criterion XVI, the NRC believes that its inspectors added significant value

to the deficiencies already identified by AmerenUE. Specifically, the NRC inspectors identified

significant additional information to be included in AmerenUEs evaluation by identifying

problems associated with AmerenUEs previous corrective actions. AmerenUE had previous

opportunities to identify and correct the emergency procedure deficiencies during

implementation of corrective actions in response to a previous NRC finding

(05000483/2003006-02), Callaway Action Request 200500564, and other identified conditions

adverse to quality as articulated in NRC Inspection Report 05000483/2006011. Therefore, the

NRC finds that Noncited Violation 5000483/2006011-01 was properly characterized as

NRC-identified for the violation that involved the failure to identify and correct the issues

associated with the previous NRC-identified EOP deficiencies.

In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter will be

made available electronically for public inspection in the NRC Public Document Room or from

the Publicly Available Records 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,

/RA/ by Anton Vegel for

Arthur T. Howell III, Director

Division of Reactor Projects

Docket: 50-483

License: NPF-30

cc:

Professional Nuclear Consulting, Inc.

19041 Raines Drive

Derwood, MD 20855

John ONeill, Esq.

Pillsbury Winthrop Shaw Pittman LLP

2300 N. Street, N.W.

Washington, DC 20037

Union Electric Company -3-

Keith A. Mills, Supervising Engineer,

Regional Regulatory Affairs/

Safety Analysis

AmerenUE

P.O. Box 620

Fulton, MO 65251

Missouri Public Service Commission

Governors Office Building

200 Madison Street

P.O. Box 360

Jefferson City, MO 65102

H. Floyd Gilzow

Deputy Director for Policy

Missouri Department of Natural Resources

P. O. Box 176

Jefferson City, MO 65102-0176

Rick A. Muench, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, KS 66839

Dan I. Bolef, President

Kay Drey, Representative

Board of Directors Coalition

for the Environment

6267 Delmar Boulevard

University City, MO 63130

Les H. Kanuckel, Manager

Quality Assurance

AmerenUE

P.O. Box 620

Fulton, MO 65251

Director, Missouri State Emergency

Management Agency

P.O. Box 116

Jefferson City, MO 65102-0116

Union Electric Company -4-

Keith D. Young, Manager

Regulatory Affairs

AmerenUE

P.O. Box 620

Fulton, MO 65251

David E. Shafer

Superintendent, Licensing

Regulatory Affairs

AmerenUE

P.O. Box 66149, MC 470

St. Louis, MO 63166-6149

Certrec Corporation

4200 South Hulen, Suite 630

Fort Worth, TX 76109

Keith G. Henke, Planner

Division of Community and Public Health

Office of Emergency Coordination

930 Wildwood, P.O. Box 570

Jefferson City, MO 65102

Union Electric Company -5-

Electronic distribution by RIV:

Regional Administrator (BSM1)

DRP Director (ATH)

DRS Director (DDC)

DRS Deputy Director (RJC1)

Senior Resident Inspector (MSP)

Branch Chief, DRP/B (GEW)

Senior Project Engineer, DRP/B (FLB2)

Team Leader, DRP/TSS (RLN1)

RITS Coordinator (KEG)

K. S. Fuller, RC/ACES (KSF)

C. A. Carpenter, D:OE (CAC)

OE:EA File (RidsOeMailCenter)

SUNSI Review Completed: __yes_ ADAMS: : Yes G No Initials: __gew_

Publicly Available G Non-Publicly Available G Sensitive  : Non-Sensitive

R:\_REACTORS\_CW\2006\CW2006-11 NCV Response Letter.wpd

RIV:C:DRP/B RI:DRP/B SRI:DRP/B ACES RC/ACES D:DRP

GEWerner;df DEDumbacher MSPeck MSHaire KSFuller ATHowell III

/RA/ E - GEWerner E - GEWerner /RA/ /RA/ AVegel for

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