ML20099D335

Responds to NRC Re Violations & Proposed Imposition of Civil Penalties Noted in Insp Rept 50-483/84-36.Corrective Actions:Procedures Revised to Require Lamp Test on Partial Trip Status Panel

ML20099D335
Person / Time
Site:	Callaway
Issue date:	11/15/1984
From:	Schnell D UNION ELECTRIC CO.
To:	Deyoung R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
ULNRC-976, NUDOCS 8411200320
Download: ML20099D335 (7)

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November: 15, 1984-1 Donald F.SchneE yce PosiderW my, 1;;

Mr.9 Richard C. DeYoung, Diractor Office =of' Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

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Dear Mr. DeYoung:

ULNRC-976 INSPECTION REPORT NO.- 50-483/84-36 This reply 'is Liri response to your letter of October 19, 1984 "which transmitted the report of the inspection conducted at-Callaway Plant, Unit 1 during 'the period of July 30 through August-3 and August 13-17, 1984.

Our responses to the ituate of-noncompliance are presented-below in the order listed within the.

body of inspection report number 50-483/84-36.

None of the material in the inspection report or in this response.

is considered proprietary by Union Electric Company.

(50-483/84-36-01) SEVERITY LEVEL III VIOLATION -(Civil Penalty)

Technical Specification 3.6.2.1 states, "Two independent Containment spray Systems shall be OPERABLE with each Containment spray System capable of taking suction from the RWST'and trans-ferring suction to the containment sump."

This requirement is applicable for operational Modes 1, 2, 3, and 4.

Technical Specification 3.0.3 states, "Nhen a Limiting condition for Operation is not met, except as provided in the associated ACTION requirements, within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> ACTION'shall be initiated to place the unit in a MODE in which the specification does not ap-ply by placing,it, as applicable, int a.

At least NOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, b.

.At least HOT SHUTDONN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and c.

At least COLD SHUTDONN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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' ' Contrary ~ to <the above, at 6:30 a.m. (CDT) on ' August' 10, 1984, the licensee. entered operational Mode 4 (hot shutdown) with i

icontainment Spray manual isolation valves EM-V014 and EM-V018

, closed and,.therefore, with both Containment spray systems t.

inoperable. ~The. plant-remained in Mode 4 with.both valves closed.

until the closed: valves were subsequently-identified by the licensee and ~ opened at;10:50 ' a.m. (CDT) on August 14, 1984.

Response, Admission or Denial of-the Alleged violation As previously notEd in Licensee Event Report 84-029-00 transmit-

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ted.to the NRC September 10, 1984, Union Electric acknowledges the. cited violations.

Reasons for the violation If-Admitted a

The~ reasons for the. violation were failure-to follow procedures and orders and failure to recognise the interrelationships among-administrative controls.as listed belows o

On May 7, 1984 Containment spray manual isolation valves (EN-V014 and EM-V018) were closed,' locked and tagged on Workman's Protection Assurance (WPA) 84-3252 to prevent inadvertent discharge into containment.

At this time, the valves were not entered on.the Equipment Out of Service Log (EOSL).

o On May 9, 1984 valves BM-V014, BM-V018 and EN-V097 were noted as exceptions upon completion of OTN-EN-00001, but their status was not entered in the EOSL as required by Standing Order 84-24.

o On August 3, 1984 in preparation for entering Mode 4 a review was made of WPA.

WPA 84-3252 for valves EM-V014 and EN-V018 was not identified as being required for Mode 4.

o On August 8,1984 Temporary Change Notice (TCN)84-945 to ODP-38-00014 was executed to delete the sign-off requirement for the review of the EO8L, the WPA log review,'and the

. Temporary Modification log review.

o On August 10,1984 Mode 4 was entered.

o On August 14, 1984 WPA 84-3252 showing valves EN-V014 and EN-V018 closed was found.

These valves were subsequently opened, locked and independently verified.

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CorrectiveJActions Taken And The Resultsi chieved'

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On August L 14, 1984,upon discovery of the Containment Spray Manual:

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' Isolation valves being locked.olosed,'the valves were-immediately t

. opened,Llooked,(and? independently verified., Also when3the E3SL was found to beLout'of,date, immediate reviews of.the"

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surveillance Master. Tracking log, outstanding Work Requests, out-standing WPA,'and outstanding Temporary Modifications were initi-'

ated against the 30SL to-bring it up toidate.

These reviews. wore, l

completed and the EOSL brought'up_to date on_ August-20, 1984.

i The. individuals. responsible for not entering EM-V014 and EM-V018L J

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in the BOSL were ' counseled by August 30,l1984.-

P The Plant Manager 1and/or,the Assistant Plant Managers held a 4

iseries of meetings with plant staff and support' personnel.

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purpose:of.these meetings was to re-emphasise management's' deter-mination to: ensure < compliance with callaway operating procedures; and Technical Specifications to all' levels of the' work force, 1

highlight ~the recent'Callaway events, and stresetthe necessity

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.for improving individual performance, group' performance, and-communication.

These nestings were completed September 7, 1984..

In addition, on August 20, 1984,the content of: Standing Order 84-24 was incorporated into.007-55-00002, Equipment Status l

control, and APA-55-00310, Workman's Protection' Assurance.

'And finally, on August'15, 1984 TCM 84-945, whichjremoved the-1 requirement for review of BOSL,1NPA, and Temporary Modifications, a

..was eliminated by a" revision to procedure ODP-35-00014, i

-Operational Mode change Requirements.

This revision also in-l cluded the requirement togdo the same reviews for all mode ascensions.

It previously applied'to the change from Mode 5.to l

Mode'4 only.

The individuals who initiated TCM 84-945 were coun-seled on August 17, 1984 and August 19,.1984.. They had been aware of the limitations imposed on temporary changes and had not-6 intended the TCM to delete the reviews of the BOSL,'WPA, and j

Temporary Modifications.

They had intended only to delete what i

they bel;.eved to be redundant documentation of.the reviews.

As an added precaution, a letter was issued on August 718, 1984 to

'l Nuclear Operations personnel'and contractors emphasising the lin-i

'itations on:the~use of' temporary changes.

l corrective Actions To to Taken To-Avoid Further Violations No further corrective action is considered necessary.

Date When Full compliance:Will Be Achieved d

i Union Electric achieved full compliance September 7, 1984.

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Propose'd Civil' Penal'ty m

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Union' Electric'acknowledgesftheLaited violation'and appreciates the.reduetion'in the amount of. civil penalty'from.the. base

' amount.

Bowever,iweLfeel thero"are' additional oircumstances

' which.may not have been. considered and lshould : result ;in complete

[-l' mitigation of'the penalty.

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TheLaubject-severity Level:III Violation'is"the'only severity-

-Level III Violation Union Electric has received. eThis incident

regarding the containment spray valves ais :the first :and 'only. in-cident of-that' nature to have occurred 4at-Callaway.=

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~The commission's General. Policy and Procedures for Enforcement 1 f'

. Actions provide that civil penalties " ate considereda for l Severity '

Love 1 III Violations."

In contrast, the Policy is to impose Jaivil penalties for severity Level I-Violationsjand to impose civil. penalties " absent mitngating* circumstances" for severityT Level II violations:(10 C.F.R. Part 2, Appendix C, Section.V.B.).'

y More specifically, the Commission's Policy' indicates that a civil.

penalty may be considered appropriate for the second and subse--

quent Severity Level III Violations of.a. "similar" nature (10 C.F.R. Part 2, Appendix C, Section, V.D., Table : 2). 'In making the most recent change to Table 2, the Commission. stated:1" Table 2 has been changed to indicate that a civil penalty might not'be' imposed.for the fitst Severity Level,III. Violation in an area of concern...." 49 Fed. h 8586._ (March,8,1984).

In addition, 10CFR2, Appendix C, V.B.l.,

2. and 3. provide reduc-tions of civil penalties of 50%, 50% and 1004 respectively for prompt identification and reporting, corrective action to prevent recurrence, and good prior performance.

We feel that the Callaway Plant staff took timely action regarding identification, reporting and corrective action and has demonstrated good prior performance.

Por these reasons, Union Electric Company believes that the-proposed penalty should be reduced by 1004-rather than only 50%

and we request your reconsideration of these factors.

Nevertheless, if your position is that these factors do not

. justify a-further reduction in the penalty, the proposed penalty of.525,000'will be paid and we will-not further contest it.

Please advise us of your decision.

(50-443/84-36-03) SEVERITY LEVEL IV VIOLATION 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, states in part, " Measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, j;

deficiencies, deviations, defective material and equipment, and "u

nonconformance are promptly-identified and corrected..."

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TheiCallaway, Plant'PSAR,:SectionLl7.2.16, states in part,.

V d Neasureccsheil be established'to-assure'that conditions adverse <

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' 4toi40ality p promptly:identifled,' reported,jand corrected..."

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. 3 Contra $y 'to the above, ' adequate' measures were not estab1'ished to

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3 assure /that conditions adverse to quality were promptly:.identi '

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fied and

corrected in'that a deficient Bechtel: design drawing:

associated with bistable 4563 being installed:

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'resulted-in a' card'ough this< condition' existed since NovemberL

,' incorrectly.

Alth 1983, - it-- was ncN;7&a,ected during preoperational testing. and '.the lidensee did-not b'e'come aware of it until.this: condition caused.

an inadvertent safety-thjection which occurred on August!13,"1984 whenfbis6hle 4563 was'Cripped during a loop calibration surveil-

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'knoiin~ procedure.

Additionally, the' trip status of 4563 was-un-:

t4cause the: indicator light for~it on the PartialiTrip.

status fanel' located'in the1 Control Room was' burned out../ Work 1

Request'No. 30740sto relamp the' Partial Trip Status Panel was autnorised on July'28, 1984,- sfith a requested. completion date of August 1, 1984,.although the work was not accomplished until-

, August 13, 1984, after.the inadvertent safety' injection occurred..

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- Corrective Action Takeliand *The liesults Achieved t

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The circumstances regarding' th'i'A' item were reported to the NRC. by

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U Licensee = Event Report (LER) 50-483/84-028-00 transmitted to the j

NRC September $1;, 1984, J

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As stated in the iER, three?of the four instrument. channels that-i monitor RCS pressure feed a:psreissive circuit (P-11) which - per-

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mits blocking of the Pressuriser Low Pressure /Steamline Low 1

l Pressure' Safety Injection JSI) Eignals at low RC8 pressures.

Prior to'this event, P-11 4as in the "SLOCK" mode as the plant-was-in Mode 4 and at low R0s pressure.-. Also,'one of the three f

pressure loops (Loop 456) 'th7.t,make up the~ 2 out of 3 coincidence

's logic for P-il was failed iothe tripped-state'due'to incorrect-f g

strapping on the associated' bistable.

This design error caused f

the-bistable to provide A triNed output when plant conditions l;

did not< require it.

This Trip went' undetected due to' failed lamps on.the assog(ated tdndow,,of the Partial: Trip Status Panel.-

i Also, the i'nitial curveillance' tests 1had not yet been performed i

i on any of these presquee loops { prior'to'this' event.

Thus,'when i

the pressure loop '(Loop '455) belog-calibrated was placed in test,'

the required 2.out og.3 coincidence for P-ll'was satisfied,'the L

block of the 81 signal *was 'autosatically reset and the Pressuriser Low Preeieure 81raignal intiated.

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Thelfailedclamps4in the'PartialjTrip' Status' Panel;have beenL

replaced and the: bistable thattreset's P-ll on Loop 456-has,been;

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A step was?added to-procedure IsL-as-0P455'on'AugustL21,1 984-to require a1 lamp test-1 on the Partial TriplStatus Panellprior' to puttingian instrument:

channel in the; test mode.

Corrective Action ~To Be Taken To AvoidFurther N'ncompliance s

.A step simil'arLto'the one' adde'd tc?ISL-BB-OP455'is~beingbadded to.

'other applicable Instrumentationiand Controlfprocedures..

' Lit.iUhenFullCompliance-wiibseAchieved-Procedure revisions?are-; expected to'bebcompleted{by. December.'7,.

1984.-

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.If.you:have any' questions regarding:this response'.or'if addi-tional information is required, please.letLusiknow.

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.Very=truly yours,

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Donald F.,Schnell t

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-cca James G. Keppler, Regional Administrator, NRC Region III

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'W. L. Forney, NRC Region III NRC Resident Inspectors,-Callaway Plant (2) r l

Missouri Public Service Commission-i e

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. STATE OF MISSOURI'.)'

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.- S ;S; CITY OF -ST. - LOUIS;)

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... Donald F. Sch'nell,:::of lawful' age, being first : duly sworn :

.upon oath,says _.that he,is Vice: President-Nuclear and ~an' officer of-

. Union E55ctric Company; that he has-. read the' foregoing;documentland.-

knova the content: thereof;- that-he has. executed the same for and on.

behalfL ct* s' aid ' company with 'fuir power 'andEauthority to.do so;: and.

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.that'the~factsithegoin ' stated are.true and correct;to the best:of.his knowledge, information and' belief.

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By

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Donald F Schnell Vice President

. Nuclear SUBSCRIBED'.and' sworn to.before me'this [

day'of b d N f.19'8 [

D Agut.

BARBARA $. PFA[

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, NOTARY PUBUC. STATE OF MISSOURI 3

. MY COMMISSION EXFIRES april' 22,1985

}g ST. LOUIS COUNTY -

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