ML20066E164
| ML20066E164 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/04/1991 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2346, NUDOCS 9101180120 | |
| Download: ML20066E164 (4) | |
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1901 Gratet Street Post Otfoce Bos I49
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St Lou:s.Mswuri63166 314 554 2650 f
!%nald F. Schnell Semot Yce President Nuclear 2
January 4, 1991 U.S. Nuclear Regulatory Commission Document Control Desk washington, DC 20555 ULNRC-2346 Gntlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-48A/90019 CALLAWAY PLANT y
This responds to Richard C. Knop's letter dated December 6, 1990, which transmitted a Notice of violation for events discussed in Inspection Report 50-48?/90019.
Our response to the violation is presented below.
None of the material in the response is considered proprietary by Union Electric Company.
Statement ct Violation As a result of the inspection conducted October i through November 15, 1990, one violation of NRC requirements was identified.
The violation involved a fallure to properly seal a conduit penetration as a fire barrier as described below.
Technical Specification 6.8.1 requires, in part, written procedures for the Firo Protection Program implementation.
APA-ZZ-00'103, Revision 1, " Fire Protection Operability Criteria and Surveillance Requirements," Attachment 6, page 1, requires, in part, that "all fire barriers... separating safety related fire areas...and all sealing devices in fire rated assembly penetrations...shall be operable at all times."
Bechtel Drawing M-0Y003, Revision 1,
" Conduit Fire Stop/Smoko and Gas Seal," item I.1.A, requires that "all conduits four inches diameter and smaller that penetrate a fire zone boundary wall or floor shall be sealed with a fire stop/ smoke and gas seal at the penetration or at both ends of the conduit."
contrary to the above, on November 1, 1990, an NRC inspector identified an open, uncapped one and one half inch conduit through the fire barrier separating safety related fire areas A.14 (Motor Driven Auxiliary Feedwater Pump "A") and A.15 (Turbine Driven Auxiliary Feedwater Pump).
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1 U. S. Nucicar R3gulctory Commiccion ULNRC-2346 Page 2 January 4, 1991 This is a Severity Level IV violation.
Response
Corrective Steps That Have Been Taken and the Results Achievod once the missing conduit seal was identified, immediate corrective action included verifying operable faro detection on both sides of the penetration.
An hourly fire watch wLc already established on one side of the penetration.
Work Request G482048-053 was generated to seal the conduit at both ends.
This work was completed on the same day the missing seal was discovered.
Corrective Steps That Will Be Taken to Avoid Furthex Violations on March 28, 1986, internal conduit seals were found missing and reported to the NRC as Licensee Event Roport 86-007.
As a result of this LER,-approximately 2000 conduit seals were inspected to ensure all internal-conduit seals were properly installed.
This inspection and final supplemental report to LER 86-007 were completed on April 8, 1988.
The subject missing conduit' seal has been the only internal conduit seal deficiency identified since that.date.
The subject missing conduit seal is believed to be an isolated oversight 4
of the conduit inspection program conducted as a result of LER 86-007.
No additional corrective actions are deemed necersary.
Date When Full Compliance Will Be Achieved, The subject noncompliance was corrected-on November 1, 1990.
J If you have any questions regarding this response, or if additional information-is required, please let me know.
Very truly yours,
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Donald F. Schnell PWG/lkr cci"%A. B. - Davis - Regional Administrator, USNRC Region III R. L. Hague --Chief, Reactor Projects Section 3C, USNRC. Region III A. T. Gody, Jr. - USNRC Licensing Project Manager (2 copies).
Manager - Electric Department,-Missouri Public-Service Commission B. L. Bartlett - USNRC Senior Resident Inspector Shaw, Pittman, Potts & Trowbridge
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STATE OF MISSOURI )
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-1 Donald F. Schnell, of lawful age, being first' duly sworn upon oath says that he is Senior Vice President-Nuclear and an officer of Union Electric Company; that he has read the foregoing document and knows the content thereof; that he has executed the same for and on behalf of said company with full-power and authority to do so; and that the facts therein stated are true and correct to the best of his knowledge, information and belief..
M By Donald F. Schnell Senicr Vice President Nuclear SUBSCRIBED and sworn to-before me this [.M day of-
, 1991.
fW.li BARBARA FAFF
- NOTARY PU8 tlc, STATE Of MISSOUR1
- 22. 1993 NY COMMISSION EXPlRis april ST LOUIS COUNTY.
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