ML20108C385
| ML20108C385 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/30/1996 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3368, NUDOCS 9605060306 | |
| Download: ML20108C385 (4) | |
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1901 Chouteau Avenue
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Post Office Box 149 St Louis.Mssouri63166 314-554-2650 Uurou Aprii 30,1996 oe ier sca e<<
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33 U. S. Nuclear Regulatory Commission Document Control Desk Mail Stop P1-137 Washington, DC 205554)001 ULNRC-3368 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/96002 CALLAWAY PLANT This responds to Mr. J. E. Dyer's letter dated April 2,1996, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96002. Our response to the violation is presented in the attachment.
None of the material in the response is considered proprietary by Union Electric.
If you have any questions regarding this response, or if additional information is required, please let me know.
Very truly yours, j
b alb Donald F. Schnell DFS/tmw t
Attachment:
- 1) R.esponse to Violation l
060105 9605060306 960430
) l PDR ADOCK 05000483 I
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t ULNRC-3368 April 30,1996 l
Page 2 i
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cc: Mr. L. J. Callan Regional Administrator U.S. Nuclear Regulatory Commission l
Region IV
- 61) Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 l
NRC Resident Inspector l
l Ms. Kristine M. Thomas l
Licensing Project Manager, Callaway Plant l
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13-E-21 Washington, DC 20555 l-Manager, Electric Department l
Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 l
l Mr. Thomas A. Baxter l
Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington, DC 20037 Manager, Plant Support l
Wolf Creek Nuclear Operating Corporation l
PO Box 411 Burlington, KS 66839 l
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Attachment to ULNRC-3368 April 30,1996 Page1 Statement of Violation During an NRC inspection conducted on February 4 through March 16,1996,a violation of NRC requirements was identified. In accordance with the ' General Statement of Policy and Procedure for NRC Enforcement Actions,"(60 FR 34381; June 30,1995), the violation is listed below:
Callaway Plant Technical Specification 6.8.1.a states that written procedures shall 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, paragraph 9.a, requires that maintenance that can affect the performance of safety-related equipment be properly preplanned and performed in accordance with written procedures, documented instructions, or drawings appropriate to the circumstances.
Section 4.11 of Administrative Procedure APA-ZZ-00330 requires that I
Preventive Maintenance Deferral Notices be processed when an extension of a preventive maintenance activity late date becomes necessary.
Contrary to the above, on February 28,1996, Preventive Maintenance Deferral Notices were not processed on the following pieces of safety-related equipment when the time interval for performing the preventive maintenance had expired as described below:
Inspect and clean Component Cooling Water Heat Exchanger B - late January 12, 1996; Check tripping sequence of feeder breaker to Component Cooling Water Pump A - late October 27,1995; Calibrate time delay relay of Component Cooling Water Pump A - late July 1,1995; Calibrate tir.ie delay relay of Component Cooling Water Pump C - late e
July 1,1995; Saraple outboard bearing oil of Motor-Driven Auxiliary Feedwater Pump B
-late November 28,1995; Inspect coupling and pins on Charging Pump A main lubricating pump -
late December 31,1995.
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Attachment to ULNRC-3368 April 30,1996 i-Page 2 l
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This is a Severity Izvel IV violation (Supplement 1) (483/9602-01).
Reason for the Violation Failure of responsible personnel to adhere to the requirements of the preventive l
maintenance (PM) program for safety related equipment.
t Corrective Steps Taken and Results Achieved:
l The consequences oflate notices for the six subject PMs were evaluated by l
Engineering. No adverse effect on equipment, plant safety or reliability could be l
identifiu!. The PMs have subsequently been completed or rescheduled within an i
acceptable time. A check of the remaining PMs on safety related equipment revealed no other program discrepancies. Typically, over 3400 safety related PMs are completed annually at Callaway.
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Corrective Stens to Avoid Further Violations:
The Callaway Plant PM program in conjunction with surveillance testing, predictive performance monitoring and trend analysis, is designed to insure the operational readiness of plant equipment. Generally, if a PM task is not performed by the scheduled 'lat: clate", this does not result in an immediate operability concern.
Nonetheless, we have implemented administrative improvements in the PM program j
designed to ensure that PM tasks are scheduled before their late date and that tasks not able to be performed as scheduled are promptly identified, evaluated and dispositioned.
l A software lock has been placed in the computerized Callaway Work Control l
System database to prevent the PM schedule date from being extended beyond the late date without completion of the above-noted deferral process.
Failure to adhere to program requirements was also discussed with the personnel involved. This discussion provided management expectations and clarified individual responsibilities.
Date when Full Compliance will be Achieved:
1 Full compliance was achieved by February 23,1996 l
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