ML062570547
| 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
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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