ML20196J159

Forwards Response to NRC Re Violations Noted in Insp Rept 50-483/97-05 on 970210-14 & 970224-28.Corrective Action:Ler Will Be Submitted Reporting as-found Condition of MSSVs IAW 10CFR50.73(a)(2)(ii)

ML20196J159
Person / Time
Site:	Callaway
Issue date:	07/25/1997
From:	Laux J UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-3612, NUDOCS 9708040015
Download: ML20196J159 (8)

Text

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. Post Offsce Box 620 Fulton, Missoun 65251 1

Union Etucnuc n

July 25,1997

U. S. Nuclear Regulatory Commission

Attn

Document Control Desk Mail Stop PI-137 '-

,, Washingjon DC 20555-0001 ULNRC-3612 ,

Gentlemen:

REPLY TO NOTICE OF VIOLATION

, INSPECTION REPORT NO. 50-483/97005 ,

CALLAWAY PLANT This responds to Mr. Howell's letter dated June 26,1997, which transmitted two Notices of Violation for events discussed in Inspection Report 50-483/97005. Our response to these violations 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,

/

. V. Laux Manager, Quality Assurance JVL/tmw/lh

Attachment:

1) Response to Violations (

9708040015 970725 -

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l ULNRC-3612 July 25,1997

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Mr. Ellis W. Merschoff i

Regional' Administrator j U.S. Nuclear Regulatory Commission j Region IV

611 Ryan Plaza Drive, Suite 400 i Arlington, TX 76011-8064 i

Senior Resident Inspector -i 8

Callaway Resident Office i U.S. Nuclear Regulatory Commission

{ 8201 NRC- Rsad - - - ~ - e -- - + - - - - ~ ~ . + - <. -

Steedman, MO 65077 Mr. Barry C. Westreich (2 copies)

. Licensing Project Manager, Callaway Plant l Office of Nuclear Reactor Regulation i U. S. Nuclear Regulatory Commission MG Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.

Washington, DC 20037 Plant Manager Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839 l

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l Attachment to

! ULNRC-3612 c July 25,1997 l I

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A. Statement of Violation

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e During an NRC inspection conducted on February 10-14 and 21-28,1997, two - I i violations of NRC requirements were identified. In accordance with the " General i ,

Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, l i the violations are listed below:

s h 10 CFR 50.73(a)(2)(vii) states, in part, that the licensee shall report any event where i two independent trains or channels become inoperable in a single system designed to f mitigate the consequences of an accident, i

Contrary to the above, during Refueling Outage 7, in the spring of 1995, an event i involving a single condition that caused independent trains to become inoperable l was not reported. This event involved surveillance tests of the main steam safety valves that resulted in 14 out of 20 of these valves failing their as-found setpoint -

tests with setpoints greater than their Technical Specification setpoint tolerance ofi I percent.

This is a Severity Level IV violation (Supplement 1).

Reason for the Violation Callaway is a four loop plant. Each steam generator is protected from overpressurization via five safety valves installed on the secondary side steam supply  !

lines. The lowest valve setpoint is 1185 psig. Valve setpoints are sequenced at I approximately 12 psi increments with a maximum setpoint of 1234 psig to provide increasing relief capacity based on increasing pressure. This design ensures j secondary coolant system pressure will be limited to 110% of the design pressure during the most severe system operational transient.

During surveillance testing in Refuel 7, the Main Steam Safety Valves (MSSVs) were individually tested and set to Technical Specification requirements. One valve was tested at a time. If a valve failed to meet the Technical Specification criteria, the action statement was entered, the valve was reset, and the action statement was .

exited prior to testing the next valve. At the completion of testing, a summary of the test results was evaluated for reportability in accordance with Callaway corrective action program requirements. i i

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Attachment to  !

ULNRC-3612 July 25,1997 Page 2 i

l The results were riot considered reportable for the following reasons; The response to question 2.3 in NUREG 1022 Revision 0, Supplement 1 published February 1984, states that " In general, for the purpose of evaluating the reportability of situations found during surveillance tests, it should be assumed that the situation occurred at the time of discovery unless there is firm evidence to believe otherwise."

This position is normally used to determine reportability in accordance with 10 CFR 50.73(a)(2)(i)(B) for Technical Specification violations. Consistent with the

. NUREG position, the failures.were censidered to occur at the time of discovery since they were identified during a surveillance test. In addition there was no firm evidence to believe otherwise on individual MSSVs. The action statement was l complied with appropriately as each MSSV was tested.

On September 12,1994, an Operating License Amendment, OL #1114, was submitted to the NRC to increase the Technical Specification setpoint tole-ance for the MSSVs to +3/-1%. The analysis supporting this amendment enveloped all but j four of the Refuel 7 as found valve setpoints. Preliminary review of the test data by ,

Westinghouse (September,1996) determined there was no adverse effect on any j existing safety or fatigue analysis. The operability of the main steam line (i.e., train) )

was not adversely impacted by the MSSVs as found condition. The condition noted did not meet the criteria of 10 CFR 50.72(b)(ii) and 10 CFR 50.73(a)(2)(ii) or 10 CFR 50.72(b)(2)(iii) and 10 CFR 50.73(a)(2)(v) and, therefore, was not considered to be reportable.

During the subject NRC inspection, the inspectors referred to correspondence from the NRC Office of Nuclear Reactor Regulation to the Director, Division of Reactor

, Safety, USNRC Region IV, dated November 2,1993. In addition to the above l l criteria, the letter indicated the most relevant crite.ia for the case in question was 10 CFR 50.73(a)(2)(vii) which states:

"Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent j trains or channels to become inoperable in a single system designed to :

(A) Shut down the reactor and maintain it in a safe shutdown condition, (B) Remove residual heat, (C) Control the release of radioactive material, or (D) Mitigate the consequences of an accident"

O 8 Attachment to ULNRC-3612 July 25,1997 Page 3 The letter refers to guidance contained in the second draft of NUREG 1022, revision 1 which indicates that " Valves found outside the technical specification tolerance band can reasonably be considered to have been inoperable during operation." The discussion further states "Given that most plants can satisfy pressure relief requirements with several main steam safety valves unavailable, a rigid interpretation of this criterion regarding secondary safety valves (i.e., any case with more than one safety valve outside the tolerance band) may be overly l conservative."

Based on review of these criteria the event was not considered to be reportable because;

1. The criteria does not apply at tLuomponent level, but at the train level. Steam l

line operability is dependent on operation of the five valves per train as a set.

The individual valves are not considered to meet the definition of an independent '

train.

2. The evaluations discussed above determined that the as found condition of the valves did not result in their associated steam lines becoming inoperable.

It should be noted the second draft ofNUREG 1022, Rev. I referred to by the NRC Jetter, was published for comment in February 1994, and has yet to be approved for use. While the information contained in the Region IV letter and the Draft NUREG may provide useful insights on a particular issue, Union Electric is concerned that these would be used to develop the basis for a violation, since the review and approval process is not complete.

On July 14,1997 Westinghouse supplied an evaluation of the effects ofincreasing the setpoint tolerance to +3.6% for the MSSVs at Callaway. The evaluation determined the as-found conditions in Refuel 7 would not have impacted system operability. Ilowevet, based on the likelihood that a number of the valves exceeded their acceptance criteria before the time of discovery, and considering all of the out of tolerance conditions could have existed at the same time, then the condition was not bounded by the analysis supporting OL #1114. Therefore, this condition should have been reported as a condition that was outside the design basis of the plant per 10 CFR 50.73(a)(2)(ii).

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, u l i Attachment to i ULNRC-3612 I

July 25,1997 Page 4 l

l The cause of the violation was the failure to adeo'iately consider all reporting requirements and their applicability to the circumstances related to surveillance testing ofMSSVs during Refuel 7.

Corrective Steps Taken and Results Achieved:

A Licensee Event Report will be submitted reporting the as-found condition of the MSSVs in accordance with 10 CFR 50.73(a)(2)(ii).

Corrective Steps to Avoid Further Violations:

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• l'his eve'nf fill be reviewelspecif'ically Mth persoimel responsible for making and approving reportability determinations.

On October 3,1996, OL #1114 was denied by the NRC. Subsequently, Union I

, Electric contracted with Westinghouse to supply the analysis for a new Operating License amendment. The Westinghouse analysis will utilize the LOFTRAN code.

The analysis provided with OL #1114 was developed by Union Electric using the RETRAN code. Use of the LOFTRAN code is expected to expedite the NRC review process. Union Electric is pursuing a submittal schedule that will support approval of the Operating License amendment by Refuel 9, targeted for April,1998.

. This Operating License amendment will provide Technical Specification acceptance i criteria that are consistent with the operational characteristics of the MSSVs and i

current Inservice Testing Program performance criteria.

Date when Full Compliance will be Achieved

Full compliance will be achieved upon approval of the Operating License amendment.

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• i Attachment to

' ULNRC-3612

-July 25,1997 ,

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B. Statement of Violation During an NRC inspection conducted on February 10-14 and 24-28,1997, two i violations of NRC requirements were identified. In accordance with the " General l 2

Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, )

l the violations are listed below:

10 CFR 50.59(b)(2) states, in part, that the licensee shall submit, as specified in 10 CFR 50.4, a report containing a brief description of any changes, tests, and i experiments, including a summary of the safety evaluation of each.

i j Contrary to the above, during the period of June 14,1988, to February 28,1997, a i brief description of changes due to temporary modifications (e.g., TM 95-M002) and the associated safety evaluation summaries were not reported to the NRC.

This is a Severity Level IV violation (Supplement 1).

l 4 Reason for the Violation i i j Procedure APA-ZZ-00140, Safety, Environmental and Other Licensing Evaluations i did not require summaries of safety evaluations performed for temporary

modifications to be included in the report required by 10 CFR 50.59(b)(2).

Temporary modifications had been excluded from this report since they were typically installed for a limited duration.

Corrective Steps Taken and Results Achieved:

The practice of not reporting safety evaluation summaries for temporary modifications began with the reporting period commencing May 1,1987. Letter ULNRC-1524 dated June 5,1987 represents the last report to include temporary modification safety evaluation summaries prior to the change in reporting criteria.

As a result of the concern identified during NRC Inspection No. 50-483/97005 safety evaluation summaries for temporary modifications will be included in future reports.

ULNRC-3580 dated May 9,1997 for the period of May 11,1995 through December 31,1996 transmitted the most recent summary report as required by 10 CFR 50.59(b)(2) and includes safety evaluation summaries for temporary modifications for the period.

An evaluation was made of the reporting periods from May 1,1987 through May 10,1995 to determine whether any additional actions were warranted. A i

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Attachment to ULNRC-3612 July 25,1997 Page 6 l

determination was made not to provide summaries of temporary modification safety evaluations for this period for the following reasons:

. Temporary modifications were short lived and have been removed from the plant or were incorporated in permanent design changes which were reported. <

e There is no impact on the current design and license basis for Callaway Plant.

Corrective Steps to Avoid Further Violations:

. . .. . ... .. ._ .Procedur,e ,APA-2'Z.-00140 g,uidaneg fpr geppting.per,LO.CER 50.5P(b)(2)hac hw - -

g corrected to include temporary modification summaries in future re ports.

Date when Full Compliance will be Achieved:

t Full compliance was achieved on June 24,1997

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