ML20116M803
| ML20116M803 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/13/1992 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-2721, NUDOCS 9211230078 | |
| Download: ML20116M803 (3) | |
Text
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UM,ON November 13, 1992 Donald t. scAue#
x a nnan Etuernic u-33 UINRC-2721 U.
S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-403/92012 CALLAWAY PLANT This responds to L. R.
Greger's letter dated October 14, 1992, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/92012. Our response to the violation is presented below.
None of the aaterial in the response is considered proprietary by Union Electric Company.
Statement of Violation During an NRC inspection conducted on August 1, 1993 through September 30, 1992, a violation cf NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions."
10 CFR Part 2, Appendix C, the violation is listed below:
Technical Specification (TS) 6.8.1.a requires that written procedures be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide (RG) 1.33, Revision 2, February 1978.
Item 1.c of FG 1.33 requires administrative procedures on equipment controls (e.g. locking and tagging). Cperations Department Procedure 00P-ZZ-00004, Revision 13, " Locked Component Control" was instituted to impleacnt this requirement.
Contrary to the above, on September 2, 1992, damper GKD0325 and the upper cable-spreading room exhaust register-were not locked ~as required by ODP-ZZ-00004.
This ic a severity level IV violation (Supplement I).
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ULNRC-2721 Page 2 of 3 Reason for the violation j
The reason for this violation was a combination of inadequate procedural controls and personnel error. The procedure inadequacies are contained in ODP-ZZ-00004 Fev.
13, " Locked Component Control"; MPE-GK-QG001 Rev.
1,
" Control Room Emergency Vel.tilation System Train A Flow Verification"; and MPE-GK-QG002 Rev. 1 "Contro; r som Emergency Ventilation Syctem Train B Flow Verl' eation". The j
personnel error was incorrect per!ormance of a castoration
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step in procedure MPE-GK-QG001.
Procedure ODP-ZZ-00004 currently allows personnel cther than Operations or Padwaste and Chemistry person'.el to remove locking devices when working to an approve.' 7rocedure.
Maintenance procedures MPE-GK-QG001 and MPE-GN-QG002 do not direct the procedure performer to have locks removed per the requirements of ODP-ZZ-00004. They also do not specifically require notification to the Control Room that the testing is complete and tha locking devices are to be restored. There is a restoration step to verify that adjusted dampars and registers are relocked but the procedure does not provide clear direction on how this is to be done.
The originally installed locking devices were apparently removed as part of system flow balancing activities and were not replaced due to personnel error in implementing restoration.
Corrective steps that_have been tcken and the results achieved:
At the time of discovery, the damper and register were-verified to be in their correct position and were relocked.
SOS 92-1718 was initiated to evaluate the cause end i
determine the corrective action to prevent recurrence, g_orrective Actions to ke taken to avoid further violations:
ODp-ZZ-00004 will be revised to clarify that only Operations or Radwaste and Chemistry personnel are allowed to remove and testore locking devices.
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J ULNRC-2721 Page 3 of 1 To ar,sure oositive control of locked campers and registers, MPE-GK-QG001 and MPE-GK-QG002 will be revised to have opcrations personnal remove the locking devices and ensure that the compotivate are entered in the Locked Component Deviaticn List. These ocedures will also require that the Control Room is informed when testing is complete and locking devices can be restored. The procedures will then require specific verification that locking devices have been restored.
Date when full compliance will be achieved:
' all compliance will be achieved by December 31, 1992.
If you have any questions regarding this response, or if additional information is required, please let me know, i
Very truly yours, gr Donald F.
Schnell DFS/tmw cc:
A.
B.
Davis - Regional Administrator, USNRC Region III I.
N. Jackiw - Chief, Reactor Projects Section 3C, USNRC Region III L.
R. Wharton - USNRC Licensing Project Manager (2 copies)
USNRC Document Control Desk (original)
Manager - Electric Department, Missouri Public Service Commission D.
L.
Bartlett - USNRC Senior Resident Insper. tor Shaw,~Pittman, Potts, & Trowbridge l
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