ML20082N486
| ML20082N486 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/17/1995 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3195, NUDOCS 9504250259 | |
| Download: ML20082N486 (4) | |
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- '9 1901 Chouteau Avenue Port Offwe Box 149 St. Lows. M.ssouri 63166 314 $54 2650 Union Agrii 17,1995 s,,,'get,r-le, o-Euccnuc w
13 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 ULNRC-3195 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/95004 CALLAWAY PLANT This responds to Mr. M. J. Farber's letter dated March 23,1995, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/95004. 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.
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Very truly yours, m
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Donald F. Schnell DFS/tmw
Attachment:
- 1) Response to Violation cc:
J. B. Martin - Regional Administrator, USNRC Region III M. J. Farber - Chief, Reactor Projects Section 3A, 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 49 nr# m usw.,-
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. Attachment to ULNRC-3195 Page 1 of 3 Response to Violation 50-483/95004 r
Statement of Violation During an NRC inspection conducted January 15, through March 11,1995 a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
Callaway Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the fire protection program implementation.
Procedure APA-ZZ-00741. paragraph 5.2.2.5, states that "The fire protection engineer (s) must be consulted before transient combustibles...are temporarily retained to support an on-going work activity inside a building housing safety related equipment... The consultation shall be documented on Form CA-712."
Contrary to the above, on January 31,1995 and on February 1,1995, NRC inspectors identified transient combustibles inside buildings housing safety related equipment which exceeded the limits of APA-ZZ-00741, and in which the fire protection engineers had not been consulted. Specifically, in the lower cable spreading room of the Control Building the inspectors identified a 95 pound cable reel and in the Normal Charging Pump room in the Auxiliary building the inspectors identified 23 partially full cans of paint (50-483/95004-01(DRP)).
This is a Severity Level IV violation.
Reason for the Violation The requirements of procedure APA-ZZ-00741, " Control and Transportation of Combustible Materials", were not correctly interpreted. In the case of the wooden cable reel, it did not occur to the personnel inv-!ved that the cable reel would fall under the guidelines of combustible material in APA-ZZ-00741. In the case of the paint, the supervisor believed there was no concern when the paint was in tightly closed containers staged for the job in-progress.
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. Attachment to ULNRC-3195 Page 2 of 3 Although it was not identified at the time of the incident, in October,1994 a CA-712 (Relief From General Requirements in Control and Transportation of Transient Combustible Materials) form was completed for the paint to be used in the Normal Charging Pump room. liowever, the job was not completed until February,1995 and the relief permit had expired.
Corrective Steps That Have Been Tsken The cable reel was removed from the room after the cable was installed. The supervisors in the Maintenance Department were instructed in the requirements of APA-ZZ-00741, and were directed to train their respective crews to ensure awareness of the requirements for taking combustibles into safety related areas. This training has been completed.
The paint was removed from the Normal Charging Pump room. The responsible llealth Physics supervisor, the fire marshal, and the fire protection engineer conducted walkdowns to check for other deficiencies. The walkdowns also served to provide clarification on transient combustibles.
The Rad / Chem helpers were given training on the requirements of APA-ZZ-00741 on March 2,1995. The Ilealth Physics supervisors were also informed of the requirements.
Additionally, for the short term, the following actions have been initiated:
1.
Personnel awareness of transient combustible controls has been increased through articles in As the Turbine Turns (plant newspaper) and staff meetings.
2.
The fire protection staff conducted several walkdowns of safety related areas to assess compliance with controls and correct any deficiencies.
3.
The fire protection engineer initiated and evaluated CA-712 forms for various areas housing safety related equipment where increased combustibles due to outage activities were anticipated.
4.
Firewatches were initiated one week prior to the start of Refuel 7 for the duration of the outage. These compensatory watches are on a scheduled one i
hour frequency. Firewatches were trained on the requirements of procedure APA-ZZ-00741.
5.
A Fire / Safety coordinator was added to each outage management shift crew for Refuel 7 to ensure fire protection and industrial safety procedure adherence.
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Attachment to
' ULNRC-3195 Page 3 of 3
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Corrective Stens That Will Be Taken To Avoid Further Violations Procedure APA-ZZ-00741 will be revised to make the requirements clearer regarding transient combustibles and provide clarification for items made of non-treated wood such as cable reels and tools. The procedure revision will also provide clarification for identification of flammable and combustible liquids.
Following the procedure revision, training will be provided to appropriate personnel.
Date When Full Comoliance will be Achieved i
The procedure revision and training will be completed by September 1,1995.
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