ML20134A572
| ML20134A572 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| 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. E.
yer, Director
Division of Reactor Projects
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Docket No.: 50-483
License No.: NPF-30
cc:
Professional Nuclear Consulting, Inc.
19041 Raines Drive
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Derwood, Maryland 20855
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Gerald Charnoff, Esq.
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Thomas A. Baxter, Esq.
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
ADOCK 05000483
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G. L. Randolph, Vice President
Nuclear Operations
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Fulton, Missouri 65251
Manager - Electric Department
Missouri Public Service Commission
301 W. High
P.O. Box 360 -
Jefferson City, Missouri 65102
Ronald A. Kucera, Deputy Director
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
Lee Fritz, Presiding Commissioner
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Callaway County Court House
10 East Fifth Street
Fulton, Missouri 65151
Alan C. Passwater, Manager
Licensing and Fuels
Union Electric Company
P.O. Box 149
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St. Louis, Missouri 63166
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Union Electric Company
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J. V. Laux, Manager
Quality Assurance
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
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1901 Chouteau Avenue
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Post Office Box 149
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Union
January 10,1997
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U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Stop P1-137
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Washington, DC 20555-0001
ULNRC-3509
Gentlemen:
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REPLY TO NOTICE OF VIOLATION
INSPECTION REPORT NO. 50-483/96011
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CALLAWAY PLANT
This responds to Mr. J. E. Dyer's letter b.ted December 12,1996, which
transmitted a Notice of Violation for events discussed in Inspection Report
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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
Electric.
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If you have any questions regarding this response, or if additional
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information is required, please let me know.
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Very truly yours,
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onald F. Schnell
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Attachment: 1) Response to Violation
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ULNRC-3509
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January 10,1997
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Page 2
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cc: Mr. James E. Dyer
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Regional Administrator
'U.S. Nuclear Regulatory Commission
Region IV
611 Ryan Plaza Drive, Suite 400
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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
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Jefferson City, MO 65102
Mr. Thomas A. Baxter
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Shaw, Pittman, Potts, & Trowbridge
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2300 N. Street N.W.
Washington,DC 20037
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Manager, Plant Support
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Wolf Creek Nuclear Operating Corporation
PO Box 411
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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
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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
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Page 2
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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
plant procedures. The Quality Assurance review identified some minor discrepancies in
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the normal operating procedures of the CCV.' system but concluded that the emergency
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operating procedures for the system were generally consistent with the system description
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and design parameters included in the FSAR. These findings were published in Quality
Assurance Surveillance Report SP96-103 dated December 18,1996. FSAR Change
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Notice 96-075 was subsequently initiated December 26,1996 to more accurately describe
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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
parameters for flow and temperature are properly maintained.
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Union Electric is also evaluating the concerns identified by this violation for potential
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generic applicability to other systems. Our response to the NRC's 10CFR50.54(f) letter,
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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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