ML20136F465
| ML20136F465 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/07/1997 |
| From: | Affolter R UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3545, NUDOCS 9703140115 | |
| Download: ML20136F465 (4) | |
Text
pm Ca!!away P! ant Post Office Box 620 Fulton. Missowi 65251 j
Umon Etucnue March 7,1997
'5 h
U. S. Nuclear Regulatory Commission j
Atta: Document ControlDesk Mail Stop PI-137 Washington, DC 20555-0001 ULNRC-3545 Gentlemen:
AMENDED REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/96011 CALLAWAY PLANT
References:
Inspection Report No. 50-483/96011 dated December 12,1996 ULNRC-3509 dated.Tanuary 10,1997 This amends our response to Mr. J. E. Dyer's letter dated December 12,1996, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96011.
Our amended 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, Ro
. Affolter RDA/tmw
Attachment:
- 1) Amended Response to Violation
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C ULNRC-3545 March 7,1997 Page 2 cc: Mr. James E. Dyer Regional Administrator-Acting U.S. Nuclear Regulatory Commission RegionIV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Resident Inspector 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 y
Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102
~i Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington,DC 20037 Manager, Plant Support Wolf Creek Nuclear Operating Corpoiation PO Box 411 Burlington, KS 66839
Attachment to ULNRC-3545 March 7,1997 c
Page1 Statement of Violation During an NRC inspection conducted October 13 through November 23,1996, a violation ofNRC 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.c requires, in part, that procedures be written for component cooling water system startup, operation, and shutdown.
Normal Operating Procedure OTN-EG-1, Revision 14, " Component Cooling Water,"
was written to provide the appropriate operating instmetions for the component cooling 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 1 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 j
procedure listed minimum flow values only and not a range offlow 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 te the various components (483/96011-01).
H This is a Severity Level IV Violation (Supplement I).
Reason for the Violation Development and review ofNormal Operating Procedure OTN-EG-00001 had primarily focused on ensuring the Component Cooling Water Sptem was capable of providing sufficient cooling to perform its design basis function. The reviews had not explicitly evaluated concerns of excessive cooling during co!d weather operation.
Corrective Steps Taken and Results Achieved:
The Component Cooling Water (CCW) System was 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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.s.
Attachment to y
UL}{RC-3545 March 7,1997 L
Page 2 l
System temperature of 40*F. Revision 15 of OTN-EG-00001 incorporated the FSAR i
change and was issued on November 21,1996.
Corrective Steps to Avoid Further Violations:
On November 24,1996, Quality Assurance commenced a review of the FSAR for CCW.
i 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 the normal operating procedures of the CCW system but concluded that the emergency operating procedures for the system were generally consistent with the system description and design parameters included in the FSAR. These findings were published in Quality Assurance Surveillance Report SP96-103 dated December 18,1996. FSAR Change Notice %-075 was subsequently initiated December 26,1996 to more accurately describe j
the operation of the CCW System. After processing the change notice, Operations will J
revise OTN-EG-00001 and the Operator Logs to ensure the CCW System design I
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 generic applicability to other systems. Our response to the NRC's 10CFR50.54(f) letter, 3
dated October 9,1996, will address whether additional actions are required.
3 Date when Full Compliance will be Achieved:
l Full compliance will be achieved by April 15,1997. Union Electric comnutted to full i
compliance by February 7,1997, via ULNRC-3509, dated January 10,1997. On March 5,1997, the NRC Resident Inspector determined the revision to procedure OTN-EG-00001 had not been completed. Upon notification by the NRC, Union Electric determined corrective action document SOS 96-1981 was tracking completion of corrective action in response to the Notice of Vioistion. The completion date for corrective action specified by SOS 96-1981 was revised after the Notice of Violation response was submitted. A significant engineering evaluation is required to support revision of OTN-EG-00001. However, the need to revise the full compliance date stated in ULNRC-3509 was not recognized.
Corrective action document SOS 97-0292 was initiated on March 5,1997 to address the failure to meet the compliance date established by the violation response. This letter was also initiated on March 5,1997 to revise Union Electric's response to the violation identified in Inspection Report No. 50-483/96011.
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