ML20101A749

Forwards Response to NRC Re Violations Noted in Insp Rept 50-483/96-01 on 960108-12.Corrective Actions: Corrective Action Document Was Initiated 960110 to Evaluate Concern Identified by NRC Insp

ML20101A749
Person / Time
Site:	Callaway
Issue date:	03/04/1996
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-3339, NUDOCS 9603130263
Download: ML20101A749 (4)

Text

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'3 March 4,1996 i Document Control Desk Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop P1-137 Washington, DC 20555 ULNRC-3339 Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/96001 CALLAWAY PLANT This responds to Mr. Thomas P. Gwynn's letter dated February 9,1996, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96001.

Our response to the violation is presented in the attachment.

None of the material in the response is considered proprietary by Union Electric.  ;

1 Ifyou have any questions regarding this response, or if additional information is required, l please let me know. I Very truly yours, O

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Donald F. Schnell l

DFS/tmw j

Attachment:

1) Response to Violation l

130053 .

9603130263 960304 d

/\t PDR ADOCK 05000483 1 G PDR

ULNRC-3339 l March 4,1996 Page 2 i

cc: Mr. L. J. Callan Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064  ;

NRC Resident Inspector ,

l Ms. Kristine M. Thomas (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission i Mail Stop 13-E-21 Washington,DC 20555 ,

I Manager, Electric Department l

Missouri Public Service Commission ,

PO Box 360 l Jefferson City, MO 65102  !

Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W. i Washington,DC 20037 I Manager, Plant Support Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839 l l

1 Attachment to ULNRC-3339 March 4,1996

. .Page1 Statement of Violation During an NRC inspection conducted on January 8-12,1996, a violation ofNRC ,

requirements was identified. In accordance with the " General Statement ofPolicy and ,

Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 6.12.2 states, in part, " areas accessible to personnel with radiation levels greater than 1000 mR/hr at 45 cm (18 in.) from the radiation source .

or any surface which the radiation penetrates shall be provided with locked doors to prevent unauthorized entry, and the keys shall be under the administrative control of the Shift Supervisor / Operating Supervisor on duty, and/or health physics supervision."

Contrary to the above, on Jaruary 9,1996, an NRC inspector discovered that the door to the waste hold-up tank room (Room 7122), a room that had general area dose rates up to 1200 mR/hr, had an opening in the door large enough to permit reaching through the door and unlocking the door without a key, thereby not preventing unauthorized entry to the area.

This is a Severity Level IV violation (Supplement IV) (483/96001-01).

Reason for the Violation I

A difference of opinion between the inspector and licensee regarding barrier configurations that would adequately control access to the waste hold-up tank room.

Corrective Steps Taken and Results Achieved:

After notification by the NRC inspector, the Superintendent, Health Physics inspected the door on January 9,1996 to determine what actions were necessary to address the concern.

It was, and still is, Union Electric's position that the door satisfied the Technical Specification requirement. It was aise determined that the door was locked and met the requirements of Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants. The decision was made to place a chain and supplemental lock on the door until the matter could be resolved.

1 A corrective action document was also initiated on January 10,1996 to formally evaluate the concern identified by the NRC inspection and determine what actions may be warranted.

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' Attachment to ULNRC-3339 March 4,1996

- .Page 2 Corrective Stens to Avoid Further Violationg;,

It is inconceivable to us that anyone possessing the knowledge to qualify for entry into a radiological control area at Callaway Plant would willfully violate a locked entry point clearly identified as a high radiation area. Nonetheless, the door in question was modified to minimize the amount of free space around the instrument tubing which passes through

! the doorway. All Danger, High Radiation Area (DHRA) doors were inspected to '

l determine if additional doors could be subject to the NRC interpretation oflocked high radiation area (HRA) doors. Two additional doors with a similar configuration were modified as a result of this inspection.

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Date when Full Comoliance will be Achieved:

Door modifications were completed on Febmary 8,1996.

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