ML20059M926
| ML20059M926 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/15/1993 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2909, NUDOCS 9311300003 | |
| Download: ML20059M926 (7) | |
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33 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 ULNRC-2909 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/93012 CALLAWAY PLANT This responds to Mr. L. Robert Greger's letter dated October 15,1993, which transmitted a Notice of Violation for events discussed in Inspection Report 50-183/93012. Our response to the violation is presented in the attachment.
None of the material in the response is considered proprietary by Union Electric Company.
If you have any questions regarding this response, or if additional information is required, please let me know.
Very truly yours,
+>sl Donald F. Schnell DFS/tmw
Attachment:
- 1) Response to Violatha f
cc: L B. Martin - Regional Administrator, USNRC Region III T. M. Tongue - Acting Chief, Reactor Projects Section 3" USNRC Region III L. R. Wharton - USNRC Licensing Project Manager (2 copies)
USNRC Document Control Desk (Original)
Manager - Electric Department, Missouri Public Service Commission B. L. Bartlett - USNRC Senior Resident Inspector T. A. Baxter - Shaw, Pittman, Potts, and Trowbridge 9311300003.931115I*
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Attachment to ULNRC-2909 Page1 of 6 Statement of Violation' During NRC inspections conducted between August 1 and September 18,1993, a violation of NRC requirements was identified, in accordance with the " General Statement of Policy and Procedure for NRC rinforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below; Callaway Plant Technical Specification 6.8.1.a states, in part, that written procedures shMI 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,1.d., recommends administrative procedures be established for procedure adherence and temporary changes.
1.
Procedure OTN-BG-00002, Revision 7, " Reactor Makeup Control and Boron Thermal Regeneration Systems," in part, implements Appendix A of Regulatory Guide 1.33 by specifying procedure adherence during plant activities. Procedural step 4.4.8 directs the unit reactor operator to adjust the reactor makeup system as required by plant conditions.
Contrary to the above, on August 31,1993, the unit reactor operator failed to reset the boric acid flow controller to zero to satisfy the existing plant condition (483/9301-01a).
2.
Procedure ODP-ZZ-00310, Revision 0, "WPA Tagging", in part, implements Appendix A of Regulatory Guide 1.33 by specifying procedure adherence during plant activities. Procedural step 4.1.1.6.2 specifies that the Shift Supervisor must verify that the tagout control sheet is properly filled out by ensuring that appropriate notes, cautions, and equipment out of service log (EOSL) numbers are indicated, if applicable.
Contrary to the above, on August 25,1993, the tagout control sheet for WPA
- 8258 was approved without' ensuring that special instructions were provided to properly tag containment isolation valve LF FV-0095 out of service (483/93012-Olb).
3.
Procedure MDP-ZZ-S0001, Revision 6, " Scaffolding Installation and Evaluation," in part, implements Appendix A of Regulatory Guide 1.33 by specifying procedure adherence during plant activities. Procedural step 7.2.2.2 specifies that the supervisor evaluate the scaffold against the criteria established in
r Attachment to '
ULNRC-2909 Page 2 of 6 section 5.0 (specific guidance for the installation of scaffolding to meet seismic requirements).
Contrary to the above, on August 24,1993 " anti-tipping" restraints were not installed next to main steam isolation valve "A" in the top 1/3 of the scaffold (483/93012-01c).
4.
Procedure APA-ZZ-00405, Revision 7, "Special Nuclear Material Control and Accounting Procedures," in part, implements Appendix A of Regulatory Guide 1.33 by specifying procedure adherence during plant activities. Procedural step 4.2.2 specifies that spent fuel assembly transfers shall be performed pursuant to instructions delineated in the fuel assembly transfer record; Contrary to the above, on August 4,1993, spent fuel assemblies F85 and F44 were positioned in locations contrary to the fuel assembly transfer record (483/93012-Old).
Brason for Violation - Item _J.
On August 30,1993, a Reactor Operator (RO) was borating the reactor coolant system in order to step out control rods for a flux map. The rod movement evolution was still in progress at shift turnover. The RO did not reset the controller to 0.0 at the end of the shift or note in the turnover to the next shift that the controller was not at its normal setpoint. The root cause was inattention to detail in the direction and performance of the evolution by operations personnel.
Corrective Steps taken and results achieved:
On August 31,1993, during an automatic makeup of water to the volume control tank,-
an RO noted that the boration valve was open when it should have been closed. The RO closed the valve and reset the Boric Acid Flow Controller The reactor coolant system temperature was maintained by manually stepping out the control' rods and reducing turbine load.
Attachment to ULNRC-2909 Page 3 of 6 A Human Performance Enhancement System (HPES) evaluation was performed. The RO specifically involved with this event was counseled concerning the importance of procedure compliance and attention to detail. The Plant Manager and Superintendent Operations met with Operations personnel prior to Refuel VI to discuss this occurrence and emphasize plant management's expectations for procedure compliance, self-checking, and attention to detail.
Corrective stens to avoid further violations:
This occurrence will be reviewed in detail with Operations personnel during the first cycle of 1994 requalification training. Plant management will continue to teach and stress use of the STAR (Stop, Think, Act, Review) methodology.
Date when full comoliance will be achieved:
Full compliance was achieved on August 31,1993. Corrective actions will be completed by April 1,1994.
Reason far Violation - Item 2 Workman's Protection Assurance (WPA) tagout 8258 was written to replace the circuit breaker for containment isolation valve (CIV) LFFV0095. The tagout directed that the breaker for valve LVV0095 be tagged open, which left the valve in its normal, open position. The valve should have been closed prior to tagging the breaker. An event review team (ERT) was initiated. In generating the WPA the author, a licensed reactor operator, did identify that the WPA would affect containment integrity, but failed to annotate the tagout. The reviewer of the WPA tagout, another licensed reactor operator, understood the concern with the valve but did not add this information to the WPA. This reactor operator assumed that appropriate compensatory measures would be taken to satisfy the technical specification action statement. During his review, the Shift Supervisor failed to identify that the valve was normally open and that tagging the breaker without first shutting the valve would affect containment integrity. The root
- cause for the violation is inattention to detailin the direction and performance of the WPA activities by operations personnel.
i
Attachment to ULNRC-2909 Page 4 of 6 Currective stens tak3n and results achieved:
After a shift turnover an oncoming RO noticed that valve LFFV0095 was de-energized.
The RO questioned the applicability of TS 3.6.1 (containment sump level t
measurements) for the valve configuration. Upon determining that LFFV0095 was open and de-energized, the affected penetration was isolated by de-energizing LFFV0096 (which is in series with LFFV0095) in its normal, closed position in time to comply with the applicable technical specification action statement.
An HPES evaluation was performed. This incident was discussed with the Shift Supervisor who authorized placement of the WPA tagout. A review of the affected components was performed prior to any further work under the modification.
The Plant Manager and Superintendent Operations met with Operations personnel prior to Refuel VI to discuss this occurrence and emphasize plant management's expectations for procedure compliance, self-checking, and attention to detail.
Corrective stens to nvoid further violations:
This occurrence will be reviewed in detail with Operations personnel during the first cycle of 1994 requalification training. Plant management will continue to teach and stress use of the STAR (Stop, Think, Act and Review) methodology.
Date when full compliance will be nchieved:
Full compliance was achieved on August 26,1993. Corrective actions v ill be completed by April 1,1994.
Reason for Violation - Item 3 The cause of this violation was poor communication between Maintenance Supervisors during shift turnover and misperception of procedure requirements. The Maintenance -
Supervisors involved did not adequately communicate the status of the erection of this scaffold and as a result it did not receive the required final inspection. The scaffold satisfied the procedural requirements for structural adequacy but did not meet the specific procedural requirement to be tied offin the upper third of the structure. The grocedure did not clearly define the specific configuration requirements of this scaffold.
P
t Attachment to ULNRC-2909 Page 5 of 6 Corrective stens taken and results achieved:
The scaffold was restrained in the upper one third section and toe boards were added as required by the procedure. Engineering inspected the scaffolding and concluded that the installed condition posed no seismic class II/I concerns to the adjacent safety related equipment. This occurrence was discussed with the supervisors responsible for construction of the scaffolding. The procedure governing scaffolding was revised to clarify expectations for inspection and acceptance of scaffolding. The procedure revision was issued September 8,1993. All Maintenance Supervisors have reviewed the revised procedure and are familiar with it's requirements.
Corrective steps to avoid further violations No other corrective action is required.
Date when full comoliance was achieved:
Full compliance was achieved on September 8,1993 and action to prevent recurrence was completed on September 16,1993.
Reason for Violation -Item 4 Union Electric personnel identified two instances of mispositioning spent fuel assemblies in the spent fuel pool. The mispositions were discovered by Equipment Operators when they attempted to place fuel assemblies in pool positions which were already occupied. It is believed that both errors were caused by misreading the fuel assembly transfer records.
The root cause of these errors is attributed to inattention to detail in the direction and '
performance of fuel movement activities by Operations personnel. A contributing factor was that new fuel assemblies were being placed in the spent fuel pool while spent fuel assemblies were being transferred between two regions of the pool.
Attachment to -
ULNRC-2909 Page 6 of 6 GrIcctive steps taken and results achieved; An event review team was initiated. Reactor Engineering video mapped both regions of the spent fuel pool to verify the locations of all new and spent fuel assemblies. No other assemblies were found to be mispositioned. There was no safety significance associated with either mispositioning event since each assembly was found within its correct region of the spent fuel pool. Positions within each region are arbitrarily assigned by Reactor Engineering.
An HPES evaluation was performed. The Senior Reactor Operator involved with the incorrect movements was counseled concerning procedure compliance and attention to detail.
The Plant Manager and Superintendent Operations met with Operations personnel prior to Refuel VI to discuss this occurrence and emphasize plant management's expectations for procedure compliance, self-checking, and attention to detail.
Corrective stens to avoid further violations:
In order to prevent recurrence of mispositioned spent fuel assemblies, briefings will be performed prior to fuel movements, and spent fuel and new fuel movements will be performed separately.
This occurrence will be reviewed in detail with Operations personnel during the first cycle of 1994 requalification training. Plant management will continue to teach and stress use of the STAR (Stop, Think, Act, Review) methodology.
Date when full compliance will be achieved:
Full compliance was achieved by September 27,1993. Corrective action a will be complete by April 1,1994.
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