ML20034A334

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Responds to NRC Re Open Items Noted in Emergency Operating Procedures Insp Rept 50-483/89-24.Corrective Actions:Emergency Operating Procedures Have Been Reviewed to Identify Local Valve Operations Performed at Plant
ML20034A334
Person / Time
Site: Callaway 
Issue date: 04/09/1990
From: Schnell D
UNION ELECTRIC CO.
To: Miller H
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
ULNRC-2188, NUDOCS 9004230079
Download: ML20034A334 (3)


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m 09away Plat April 9, 1990 Mr. H.

J.--l Miller, Director Division of Reactor Safety-.

United States Nuclear RegulatoryECommission.

Region III 799 Roosevelt Rd.x Glen Ellyn, IL 60137,

ULNRC-2188

Dear Sir:

1 DOCKET NUMBER-50-483<

CALLAWAY-PLANT UNIT 1^

j FACILITY OPERATING LICENSE NPF-30:

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RESPONSE TO INSPECTION REPORT <50-483/89024-I

-This responds to your letter dated MarchL 14,-1990 which transmit-1 ted the results of the NRCcEmergency. Operating ProceduresLInspec-tion conducted at Callaway Plant.during the period'of= January 22-through February 2, 1990.' Our--responsecto the open;itemsMcon--

tained in t.he report is. presented-in the: attachment.

Union Electric has addressed the inspection team'sLconcernsLand-V will continue to enhance our. capabilities:related:to; Emergency._:

Operating-Procedures.

If you have any questions regarding the; response, or if. additional information is' required,.please let me 3

know.

-i Very truly;yours, j

Donald F. Schnell LHK/ CSP / pas Attachment cc:

A. B. Davis - Regional Administrator, USNRC Region III R. L. Hague - Chief, Reactor Projects Section 3A,-USNRC Region III q

l A..T.~Gody., Jr. - USNRC Licensing Project Manager (2 cop'ies)

USNRC Document Control Desk (original)

Manager - Electric Department, Missouri Public Service Commission B. H. Little - USNRC Senior Resident Inspector Shaw, Pittman, Potts, & Trowbridge L

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1 9004230079 900409

~PDR ADOCK 05000483 i

O PNU y

3 Mahng Aditess' P.O Box 62Q Flecn MO 652S1

L Attachm3nt to ULNRC-2188 Page 1 of 2 RLSPONSE TO OPEN ITEMS IN INSPECTION REPORT 50-483/89024 1.

Open-Item 50-483/89024-01

"...the licensee has started a valve relabelling program with larger, more visible labels.

Completion of this labelling program will be tracked as an open item." -

Response

The Emergency Operating Procedures (EOPs) have been reviewed to identify local valve operations performed in the plant.

The labelling team will walkdown this listing of local valves-by July 1, 1990 to ensure accuracy of information-and identify-the potential need for additional lighting and

-access platforms.-

Potential lighting and platform problems will be. submitted to Nuclear--Engineering for evaluation of design adequacy.

Larger, more visible labels will be ordered and installed on the valves.

Installation of these labels will be completed by July 1, 1991.

0 2.

Open Item 50-483/89024-02

" Issuance of the PGP as a controlled docknent addressing these concerns [as identified in the inspection reportl will:

be tracked as an open item."

Response

The Procedure Generation Package (PGP) has-been drafted as a a

new plant administrative procedure.

It~is presently in-the' i

review process and will be issued as an approved procedure by June 30, 1990.

Walkdowns of EOP revisions will: be required in accordance=with the Verification and Validation 3

c (V and V) process.specified in the PGP.

V and V will be

'j required on procedures referenced in-the EOPs.

Table-top.

reviews will only be used as-an enhancement to the valida-tion process in conjunction.with other validation tech l

niques.

APA-ZZ-00101, " Preparation, Review,=and Control of 1

Procedures", and APA-ZZ-00102, " Emergency Operating.Proce-.

6 dures Writer's Guide",'will be reviewed in= conjunction with j

the review process for the.PGP.to ensure cross-referencing-J is provided as necessary and conflicting guidance is'not provided.

The PGP will contain a responsibilities-section outlining the responsibilities of the key personnel involved-in the preparation, review, and approval process.

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'Attcchm:nt to'

- c ULNRC-2188-Page 2 of 2 l

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3.

Open Item 50-483/89024-03 "In summary,-the inspectors identified a need for upgraded ~

training for licensed operators in the use of EOPs and more n

training of equipment operators'in those tcsks they may be required to-perform during EOP impleme'.;tation...Tho resolu-tion of the' training issues will-be1 tracked as an open' item."-

Response.

EOP training is continually conducted as identified in'the performance based Licensed Operator Requalification-Program; The weaknesses' identified during the EOP-inspectioniwillLbei included in the Licensed-Operator Requalification' Training j

schaduled to be completed by August 31, 1990,. Specific q

areas to be included in the training-are:

a)

ES-0.0. entry requirements b)

DBA LOCA symptomo c)

Emphasia-on t melyLcompletion of COP' steps, f'

including rules of usage The affected lesson materials for the initial Licensed-Operator Course will also be1reviewedsand-revised as necessary to include these items.

This revision will' I

be completed-by June 30, 19S3,

'll The EOPs have been reviewed to' identify local operations: to be performed by equipment operators during-implementation.

Each crew will be required to walkdown.the requiredElocal operations and attest to these walkdowns by JanuaryL1., 1991,-

The local operator actions will be evaluated for inclusion in initial and requalification training programs.. This-evaluation will be completed by July 1, 1991.

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