ML20134A572

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/96-11
ML20134A572
Person / Time
Site: Callaway Ameren icon.png
Issue date: 01/23/1997
From: Dyer J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Schnell D
UNION ELECTRIC CO.
References
NUDOCS 9701290001
Download: ML20134A572 (5)


See also: IR 05000483/1996011

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Donald F. Schnell, Senior Vice

President - Nuclear

Union Electric Company

P.O. Box 149

St. Louis, Missouri 63166

SUBJECT: NRC INSPECTION REPORT 50-483/96-11

Thank you for your letter of January 10,1997,in response to our letter and Notice

of Violation dated December 12,1997. We have reviewed your reply and find it

responsive to the concerns raised in our Notice of Violation. We will review the

implementation of your corrective actions during a future inspection to determine that full

compliance has been achieved and will be maintained.

Sincerely,

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J .,

4 J. E. yer, Director

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Division of Reactor Projects

Docket No.: 50-483

License No.: NPF-30

cc:

Professional Nuclear Consulting, Inc. I

19041 Raines Drive j

Derwood, Maryland 20855

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Gerald Charnoff, Esq. l

Thomas A. Baxter, Esq. i

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, N.W.

Washington, D.C. 20037

H. D. Bono, Supervising Engineer

Site Licensing

Union Electric Company

P.O. Box 620

Fulton, Missouri 65251

9701290001 970123

PDR ADOCK 05000483

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Manager - Electric Department

Missouri Public Service Commission

301 W. High

P.O. Box 360 -

Jefferson City, Missouri 65102

Ronald A. Kucera, Deputy Director

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Department of Natural Resources

P.O. Box 176

Jefferson City, Missouri 65102

Neil S. Carns, President and

Chief Executive Officer

Wolf Creek Nuclear Operating Corporation

P.O. Box 411

Burlington, Kansas 66839

Dan 1. Bolef, President

Kay Drey, Representative

Board of Directors Coalition

for the Environment

6267 Delmar Boulevard

University City, Missouri 63130

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Lee Fritz, Presiding Commissioner

Callaway County Court House

10 East Fifth Street

Fulton, Missouri 65151

Alan C. Passwater, Manager  ;

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Union Electric Company

P.O. Box 149 i

St. Louis, Missouri 63166

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J. V. Laux, Manager

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Union Electric Company

P.O. Box 620

Fulton, Missouri 65251

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Union January 10,1997 o ~r sca << l

ELECTRIC fi"A[**"*"' .

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U. S. Nuclear Regulatory Commission l

Attn: Document Control Desk

Mail Stop P1-137 )

Washington, DC 20555-0001 ULNRC-3509 l

Gentlemen:  ;

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REPLY TO NOTICE OF VIOLATION  ;

INSPECTION REPORT NO. 50-483/96011 ]

CALLAWAY PLANT

This responds to Mr. J. E. Dyer's letter b.ted December 12,1996, which

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transmitted a Notice of Violation for events discussed in Inspection Report I

i 50-483/9f 1. Our response to the violation is presented in the attachment. )

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None of the material in the response is considered proprietary by Union l

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Electric.

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! If you have any questions regarding this response, or if additional i

information is required, please let me know. J

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Very truly yours, 1

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onald F. Schnell

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ULNRC-3509

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January 10,1997 .

Page 2

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cc: Mr. James E. Dyer

i Regional Administrator l

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'U.S. Nuclear Regulatory Commission

Region IV

611 Ryan Plaza Drive, Suite 400 _

Arlington, TX 76011-8064

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Senior Resident Inspector , ,

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Callaway Resident Office

U.S. Nuclear Regulatory Commission

8201 NRC Road

Steedman,MO 65077

Ms. Kristine M. Thomas (2 copies)

Licensing Project Manager, Callaway Plant

Office of Nuclear Reactor Regulation

U. S. Nuclear Regulatory Commission

Mail Stop 13E16

Washington, DC 20555-2738

Manager, Electric Department

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MissouriPublic Service Commission

PO Box 360

! Jefferson City, MO 65102

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Mr. Thomas A. Baxter

Shaw, Pittman, Potts, & Trowbridge

l 2300 N. Street N.W.

Washington,DC 20037

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Manager, Plant Support

Wolf Creek Nuclear Operating Corporation

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PO Box 411

Burlington,KS 66839

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, , . . Attachment to

ULNRC-3509

January 10,1997

Page1

Statement of Violation

During an NRC inspection conducted October 13 through November 23,1996, a violation

of NRC requirements was identified. In accordance with the " General Statement of

Policy and Procedures for NRC Enforcement Actions," (60 FR 34381; June 30,1995) the

violation is listed below:

Callaway Plant Technical Specification 6.8.1 states, in part, that written procedures

shall be established, implemented, and maintained covering the applicable procedures

recommended in Appendix A ofRegulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Appendix A 3.e requires, in part, that procedures be written

for component cooling water system startup, operation, and shutdown.

Normal Operating Procedure OTN-EG-1, Revision 14, "C omponent Cooling

Water," was written to provide the appropriate operating instructions for the

component coolir.g water system. Step 2.7 of this procedure stated that, during

, normal operation, the maximum component cooling water flow should not exceed

110 percent of the flow listed in Attachment I of the procedure.

Contrary to the above, the NRC inspectors observed that Procedure OTN-EG-1 did

not give appropriate instructions for proper system operation. Attachment 1 of the

procedure listed minimum flow values only and not a range of flow rates. In addition,

the procedure did not identify minimum system temperature and did not provide

guidance on maintaining proper system temperature. The procedure was unclear as

to the required flow rates to the various components (483/96011-01).

This is a Severity Level IV Violation (Supplement I).

Reason for the Violation

Development and review of Normal Operating Procedure OTN-EG-00001 had primarily

focused on ensuring the Component Cooling Water System was capable of providing

sufficient cooling to perfonn its design basis function. The reviews had not explicitly

evaluated concerns of excessive cooling during cold weather operation.

Corrective Steps Taken and Results Achieved:

The Component Cooling Water (CCW) System wn adjusted to restore flow to the proper

limits. A corrective action document, SOS 96-1795, was initiated on November 14,1996

to address the concerns identified by the NRC ' Resident Inspector. Based on an

engineering evaluation, the FSAR was revised to indicate an allowed minimum CCW

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Attachment to (

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ULNRC-3509 *

January 10,1997 {

Page 2 i

System temperature of 40 F. Revision 15 of OTN-EG-00001 incorporated the FSAR

change and was issued on November 21,1996.

Corrective Stens to Avoid Further Viciations:

On November 24,1996, Quality Assurance commenced a review of the FSAR for CCW

System operating parameters. This review was requested by Nuclear Engineering as a

result of SOS 96-1795 which identified that the minimum temperature for CCW System

operation described in the FSAR had not been captured as an operating parameter in any

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plant procedures. The Quality Assurance review identified some minor discrepancies in

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j the normal operating procedures of the CCV.' system but concluded that the emergency

l operating procedures for the system were generally consistent with the system description i

and design parameters included in the FSAR. These findings were published in Quality

Assurance Surveillance Report SP96-103 dated December 18,1996. FSAR Change i

< Notice 96-075 was subsequently initiated December 26,1996 to more accurately describe

the operation of the CCW System. After processing the change notice, Operations will

revise OTN-EG-00001 and the Operator Logs to ensure the CCW System design

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parameters for flow and temperature are properly maintained.

, Union Electric is also evaluating the concerns identified by this violation for potential

. generic applicability to other systems. Our response to the NRC's 10CFR50.54(f) letter,

dated October 9,1996, will address whether additional actions are required.

Date when Full Compliance will be Achieved:

Full compliance will by achieved by February 7,1997. Further evaluation of potential

generic concerns will be described in our response to the 10CFR50.54(f) letter.

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