ML20198A123

Notice of Violation from Insp on 980914-1002.Violation Noted:Listed Activities Affecting Quality Either Not Prescribed by Documented Instructions Appropriate to Circumstances or Not Accomplished with Procedures

ML20198A123
Person / Time
Site:	Callaway
Issue date:	12/04/1998
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20198A079	List: IR 05000483/1998018 ML20198A074 ML20198A123
References
50-483-98-18, NUDOCS 9812160159
Download: ML20198A123 (3)

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l ENCLOSURE 1 NOTICE OF VIOLATION 5

Union Electric Company Docket No.; 50-483 Callaway Plant License No.: NPF-30 During an NRC inspection conducted on 'ieptember 14 through October 2,1998, two violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

A. 10 CFR Part 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings,"

states, in part, that activities affecting quality shall be prescribed by procedures appropriate to the circumstances and shall be accomplished in accordance with these procedures. Procedures shallinclude appropriate acceptance criteria for determining that important activities have been satisfactorily accomplished.

Contrary to the above, the following activities affecting quality were either not prescribed by documented instructions appropriate to the circumstances or not accomplished in accordance with procedures.

1. On June 27,1997, calculation checking activities for Calculation ZZ-62, " Load Flow Voltage Drop Calculation," Revision 4, were not accomplished in accordance with Procedure EDP-ZZ-04023," Calculations," Revision 13, Section 5.3.3, which stated that checking responsibilities include checking calculation assumptions against design input documents to verify conformance with specified configurations. The calculation assumed one control room heating, ventilation, and air conditioning unit would be shut down for loss-of-coolant accident Cases 2 thru 13; whereas, plant drawings correctly specified that both control room heating, ventilation, and air conditioning units would be running in the postulated circumstances.

2. From July 12,1994, to October 2,1998, a calculation revision was not adequately accomplished in accordance with Procedure EDP-ZZ-0F 35,

" Design Development," Revision 30, in that Drawing E-21005, " List of Loads Supplied by Emergency Diesel Generator," Revision 21, a calculation was not updated to reflect the loads added in Modification 92-1014. Section 4.6.1 of Procedure EDP-ZZ-04005 states that if existing calculations are impacted by modifications, then the calculations are revised as needed. In addition, from ,

March 19,1985, to October 2,1998, calculation revisions were not adequately accomplished for Drawing M-018-0389, " Analysis of Load Table and Predictions of Voltage and Frequency Excursions at the Various Load Step Conditions,"

Revision 1, also a calculation. Drawing M-018-0389 had not been updated to evaluate the impact of load changes documented in Drawing E-21005, '

Revisions 3 through 21, as required by various design control procedures.

This is a Severity Level IV violation (Supplement 1)(50-483/9818-02).

1 9812160159 981204 PDR ADOCK 05000483 G PDR

l B. Technical Specification 6.8.1 requires that written procedures shall be established, implemented, and maintained covering the activities referenced in Appendix A of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," dated February 1978. Appendix A, Sections 3 and 8.a. recommend that procedures of a type appropriate to the circumstances be provided to ensure that readout instruments are properly calibrated and adjusted at specified periods to maintain accuracy and that procedures be developed for operation of the access circuits to the off-site electrical system.

Contrary to the above, as of October 2,1998, preventive maintenance instructions were not prescribed appropriate to the circumstances, i.e., as needed to provide reliable switchyard voltage indication, which would enable operators to assure operation within the analyzed range of switchyard voltages. In addition, as of October 2,1998, Procedure OSP NB-00001, " Operations Surveillance Procedure for Class 1E Electrical Source Verification," Revision 8, and Procedure ODP-ZZ-00016," Reactor Operator Watch Station Practices and Log," Rev;sion 38, did not adequately assure evaluation of plant operation outside of the analyzed range of switchyard voltages, which was needed to confirm operability of the offsite power supplies.

This is a Severity Level IV violation (Supplement 1)(50-483/9818-03).

The NRC has concluded that information regarding tt'e reason for these violations, the corrective actions taken and planned to correct the viclations and prevent recurrence, and the date when full compliance will be achieved is already adequately addressed on the docket in NRC Inspection Report 50-483/98-18, dated December 4,1998. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Repy to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Doct ment Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Tcxas 76011, and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.

Because your response, if you choose to provide one, will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you

, request withholding of such material, you must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financialinformation). If safeguards information is 2

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i. necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

i Dated at Arlington, Texas, l this 4th day of December 1998.

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