ML20198P067
| ML20198P067 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 01/09/1998 |
| From: | Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| 50-483-97-05, 50-483-97-5, EA-97-168, NUDOCS 9801210320 | |
| Download: ML20198P067 (5) | |
See also: IR 05000483/1997005
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UNITED STATES ~
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. NUCLEAR REGULATORY COMMISSION --
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REGION N
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'611 RYAN PLAZA DRNE SUITE 400
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ARLINGTON, T EXAS 76011 8064
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lJanuaryy 9,;1998
EA: 97-1681
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Garry L; Randolph, Vice President and .-
Chief Nuclear Officer
Union Electric Company =
' P.O. Box 620
Fulton, Missouri 65251
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SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50 483/97-05.
7-Dear Mr, Randolph:
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- Thank you for your letter of November 20,1997, in response to our October 22,1997, -
- letter and Notice of Violation concoming the failure to perform safety evaluations as required by
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.10 CFR 50.59. - We have reviewed your reply and find it responsive to the concems raised in our -
Notice of Violation. We will review the imple,nentation of your corrective actions during a futuru -
- inspection to determine that full compliance has been achieved and will be maintained.
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Sincerely,
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Thomas F. Stetka, Actiry Chief -
Engineering Branch
Division of Reactor Safety
Docket No.: 50-483-
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License No.: NPF-30
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Professional Nuclear Consulting, Inc.
19041 Raines Drive -
Derwood, Maryland 20855
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Gerald Chamoff, Esq.
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iThomas A. Baxter, Esq.
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Shaw, Pittman, Potts & Trowbridge.
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2300 N. Street, N.W.
. Washington, D.C.- 20037
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Union Electric Company
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H. D. Bono, Supervising Erigineer
Quality Assurance Regulatory Support
Union Electric Company. -
P.O. Box 620
Fulton, Missouri 65251
Manageri Electric Department
Missouri Public Service Commission
301 W, High :
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P.O. Box 360
Jefferson City, Missouri 65102
Ronald A. Kucera, Deputy Director-
P.O. Box 176 -
Jefferson City, Missouri 65102
- Otto L. Maynard, Pres; dent and
Chief Executive Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Buriington, Kansas 66839
Dan 1. Bolef, President
Kay Drey, Representative
Board of Directors Coalition
for the Environment
6267 Delmar Boulevard
Univers'ty 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
. Licensing and Fuels
Union Electric Company
P.O. Box 66149
- St. Louis, Missouri 63166-6149
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Union Electric Company
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Quality Assurance
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Union Elodric Company
. P.O. Box 620
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- Union Electric Company:
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E-Mail r6 port to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDFSK)
bec to DCD (lE01) -
bec distrib. by RIV:
Rogeonal Administrator
Resident inspector
DRP Director
DRS-PSB
Branch Chief (DRP/B)
MIS System
Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS) -
DRS Al 97-G@74
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DOCUMENT NAME: r:(CVWCW705ak. tis
' To receive copy of document, Indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy
RIV: SRI:E8
AC:EB
D:DRS
LJSmith/Imb e-
TFStetka L33 -
ATHowell lil
01/i/98
01/9/98 7
01/ /98
OFFICIAL RECORD COPY
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Union Electric Company
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E-Mail report to T. Frye (TJF)
E-Mail report to T. Hiltz (TGH)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (lE01)
bec distrib. by RIV:
Regionc! Administrator
Resident inspector
DRP Director
DRS-PSB
Branch Chief (DRP/B)
MIS System
Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS)
DRS Al 97-G-0074
COCUMENT NAME: r:\\_CW\\CW705ak. tis
To receive copy of document, Indicato in box: "C" = Copy without enclosures""E" = Copy with enclosures "N" = No copy
RIV:SRl:EB
AC:EB
D:DRS
LJSmith/Imb m -
TFStetka G
ATHowell 111
0tl'} /98
01/9/98 f*
01/ 198
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OFFICIAL RECORD COPY
210043
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Fulton. Missatm 65251 -
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l November 20,1997 -
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.U. S. Nuclear Regulatory Commission
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Atta: Document Control Desk
Mail Stop PI-137
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- Washing'on, DC 20555-0001
ULNRC-3670 -
Gentlemen:
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REPLY TO NOTICE OF VIOLATION.
INSPECTION REPORT NO. 50-483/97005
- CALLAWAY PLANT
This responds to Mr. Merschoff's letter dated October 22,1997, which transmitted a
Notice of Violation for events discussed in Inspection Report 50-483/97005. Our response
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to these violations 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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We concur with the primary conclusions of the Notice of Violation, those being that
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Formal Safety Evaluations were not performed as required by 10 CFR 50.59, the
violations were not indicative of a programmatic concern, and resulted in no actual safety
' consequences. We agree that a sound safety evaluation prog
foundation to ensure the fidelity of the Licensing and Design basis. Changes to
evaluation program as well as Callaway staff training have been implemented to further
strengthen this foundation.
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We are proceeding with the elimination of as many Technical Specification Interpretations
as possible; Please note that completion'of this effort is dependent on implementation of'
the Callaway Plant Improved Technical Specifications.
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LULNRC-3670
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Noventer 20,1997
Page 2
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ifyou have any questions regarding this response, or if additional information is required,
please let me know.'
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' Very truly yours,
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J.
.Laux
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Manager, Quality Assurance
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Attachment: 1) Response to Violation
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ULNRC-3670
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November 20,1997c
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cc: ' Mr. Ellis W. Merschoff
Regional Administrator
U.S. Nuclear Regulatory Commisdon
Region IV-
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611 Ryan Plaza Drive, Suite 400
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Arlington, TX 76011-8064
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l Senior Resident Inspector -
Callaway Resident Office
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U.S. Nuclear Regulatory Commission
8201 NRC Road
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Steedman,MO 65077
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- Mr. Barry C. Westreich (2 copies)
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Acting Licensing Project Manager, Callaway Plant
Office ofNuclear Reactor Regulation
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U. S. Nuclear Regulatory Commission -
Mail Stop 13E16
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Washington,DC 20555-2738
Manager, ElectricDepartment
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MissouriPublic Service Commission
PO Box 360
Jefferson City, MO 65102-
Mr. Thomas A. Baxter
Shaw, Pittman, Potts, & Trowbridge
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2300 N. Street N.W.
Washington,DC 20037
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Manager, Plant Support-
- Wc X Creek Nuclear Operating Corporation
PG Lox 4i1-
Burlington,KS 66839.
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Attedunent to
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ULNRC-3670
November 20,1997
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Statament of Violaties
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During an NRC inspection completed June 24,1997, violations ofNRC requirements -
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were identined. In accordance with the "Oeneral Statement of Policy and Procedure for '
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NRC Enforcement Actions," NUREG 1600, the violations are listed below:
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10 CPR 50.59(a)(1) states, in part, that a licensee may make changes in the facility as
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described in the safety analysis report and changes in procedures as described in the safety
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an@ sis without pnor Commission approval unless the proposed change involves a change .
in the technical speci6 cations incorporated in the license or an unreviewed safety question;
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10 CFR 50.59(b)(1) states, in part, that the licensee shall maintain records of changes in
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the facility and of changes in procedures made pursuant to this section to the extent that
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these changes constitute changes in the facility as described in the safety analysis report or
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changes in procedures as described in the safety analysis report. These records must
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include a written safety evaluation which provides the bases for the determination $at the
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change does not involve an unreviewed safety question.
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A. The Final Safety Analysis Report (FSAR) for the Callaway Plant states in Section -
9.4,7.2.3 that the diesel generator building supply fans automatically start when the
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room temperature exceeds 90*F and rutomatically shut down when room
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temperature falls below b6'F.
Contrary to the above, until February 27,1997, Technical Specification Interpretation
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(TSI) No.18 and Procedure OTN NE-00002 (and superceded Procedures
OTN NE-0001 A and OTN-NE-0001B) pennitted manual, vice automatic, operation
of the supply fans by placing them in " pull-to-lock," a condition inconsistent with the
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description in the FSAR, and the. licensee did not have a record of a written safety
evaluation which provided the bases for the determination'that this change to_the
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facility and procedures as described in the FSAR did not involve an unreviewed safety
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qu,mtion. ~ Specifically, TSI No.18 and the procedure permitted placing a supply fan
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in' pull-to-lock "... provided it is still under the total contti of the Reactor Operetor"
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. and stated that this was based on administrative controls that allow the' operator to
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maintain the room temperature be!nw the FSAR-described limit of Il9'F. (01014)
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l This is a Severity Level IVviolation (Supplement 1),
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Attachment to
ULNRC-3670
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- November 20,1997
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Raasem for the Vlainties
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in 1985, Technical Specification Interpietation (TSI) No.18 provided guidance to the .
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plant operators that aBowed them to place the emergency diesel generator supply fan'
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switches to the pull-to-lock position. The TSI required the licensed operator maintain
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direct control of the ihn and to maintain the room temperature below the 119'F _
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l adnunistrative limit. With cooler outside air temperatures, an opemting diesel generator
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roons apply thn could cause low temperature alarms in the diesel generator lube oil and
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thejacket water keep warm support systems. Placing the supply fan in pull-to-lock
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nilowed the keep warm systems to maintain the preferred temperatures.
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A utility engineer did not rghe in 1985 the Final Safety Analysis Report (FSAR)
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Section 9.4.7.2.3 System Operation description required a change to allow pull-to-lock
operation cf the supply fans. The engineer had performed a general engineer *.ng
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evaluation that became the basis for TSI No 18, but failed to perform a 10 CFR 50.59
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Formal Safety Evaluation.
On November 4,1986 a second utility engineer initiated a formal change to the FSAR to
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only allow pull-to-lock operation of the supply fan if ambient temperature is less than or
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equal to 65 degrees F. The limit wcs based on a 10 CFR 50.59 Formal Safety Evaluailon
and calculations supported by the architect / engineer. This change was incorporated into
the FSARby revision 014 in June 1990.
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The first twi wagraphs ofTSI 18, Rev. 7 provided the following guidance:
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"Each diesel generator supply fan !s considered capable of performing its
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intended safety function (the supply fan is OPERABLE) if the fan is in pull-
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to-lock and provided it is still'under the total control of the Reactor
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. Operator. The ihn must be operable in all other respects. This is based on
administrative controls that allow the operator to ma8ntain the room
temperature below its Technical Speci6 cation 3.7.12 limit (119'F.). If e
supply fan is placed in pull-to-lock, the Reactor Operator must assign t**e
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associated BOP room temperature point (GMT0001 or GMT00ll) to
" annunciate on Window 65 F, " Optional Parameter Setpoint" at or below
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110'F,
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The diesel generators may be considered OPEKABLE with their associated
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ventilation supply fans (CGM 01 A/B) inoperable, as long as the outside
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ambient temperature is less than or equal to 65'F."
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Attachment to
ULNRC 3670
November 20,1997
Page 3
la 1995, procedure OTN-NE-00002 was revised to irwrperate the guidance of each of
the above TSI 18 paragraphs as Precaution 2.2.7 and a Section 5 Note, respectively. At -
this time, the potental con 8ict between the paragraphs was not identiSed. Note that the
657 limit stated in the FSAR was accurately resected by the amond paragraph of the TSI
and was incorporated in the procedure at the appropriate location.
In 1996, procedure OTN NE-00002 was deleted and replaced with train specinc
procedures OTN-NE-0001 A and OTN-NE-0001B. No changes were made with respect
to the TSI 18 guidance.
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On Febmary 23,' 1990 a design modi 6 cation was completed to re-direct the supply fan
discharge. This prevented further low temperature alarms in the keep warm support
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6ystems.
On February 27,1997 the Srst paragraph of TSI No.18 was deleted. On February 27,
1997, Precaution 2.2.7 of procedures OTN NE-0001 A and OTN-NE-0001B was deleted.
'Ihese changes made TSI 18 and the implementing procedures consistent with the FSAR.
Corrective S**as to Avoid Further Violations:
On May 15,1997, Union Electric submitted the application' for improved Technical
Speci6 cations (ITS). Once approved, the ITS will substutially reduce the need for TSIs.
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' Callaway has also established goals to reduce TSIs to the minimum number possible. All
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TSis will be reviewed _' y February 28,1998 This review will determine what changes are
required to the implementing procedures and licensing docurnents in order to eliminate the
_ respective TSis. Priorities will also be established for deletion of the appropriate TSIs.
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- Additional enhancements have also been implemented in the 10 CFR 50.59 Formal Safety
- Evaluation program and are described in the response to Violation 'C'.
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ULNRC 3578. dated May 15.1997, transmitted Union Electric's Technical Specification Comwsion
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- Application
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Attachment to
ULNRC-3670
November 20,1997
Page 4
Date when FmE Coenallance wid be Achieved
TSis that are not dependent on the ITS approval will be deleted where possible by
- August 1,1998J TSIs that are dependent on ITS approval will be deleted consistent with
the ITS implementation schedule.
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Attachment to
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ULNRC-3670
November 20,1997 -
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Stadassant af Violaties
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B. The PSAR for the Callaway Plant sta6es in Section 16.9.2.la that the reibeling
machine trip set points for the load overload trips (wet conditions) and load reductionr
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trips (wet or dry conditions) be set at 250 pounds above and below the suspended
loads,r W d y.
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Contrary to the above, as of October 20,1995, TSI No. 25 permitted the trip set
points to be based on the heaviest fbel assembly for the overload trip and the lightest
ibel assembly for the load reduction trip, as opposed to the " suspended loads" as
described in the FSAR, and the licensee did not have a record of a written safety
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evaluation which provided the bases for the determination that this change to the
ihcility as described in the FSAR did not involve an urs&d safety question. TSI
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' No. 25 allowed these trips to be set in excess o 250 pounds by approximately 150
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pounds. (01024)
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This is a Severity Level IV violation (Supplement 1).
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Ransom for the Violation
The load set points stated in the original Callaway Plant Technical Specifications (and the
Westinghouse Standard upon which they were based) did not provide for weight
diferences between various Fuel Assembly types and insert combinations. An
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Interpretation to prevent spurious overload and underload trips caused by the known
weight differences was approved and implemented aAer cc,i.f...dng that the technical
bases fer the Technical Specification was not challenged.
This violation occurred because a 10 CFR 50.59 Formal Safety Evaluation was not
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performed.
Car:3ctive Stens T-6 ==d Results AeM*ved:
The applicable speci6 cation was relocated to Chapter 16 of the FSAR in 1995. TSI # 25
was deleted,' an FSAR change notice was initiated to incorporate the TSI and a 10 CFR
~ 50.59 Formal Safety Evaluation has been approved which determined that no Unreviewed
Safety Question existed.
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' Additionally, an upgrade to the refueling machine controls is currently planned for
L Refbel 9 that will permit selection ofload set points specific to the fuel assembly / insert
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. combination being moved!
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Attachment to
ULNRC-3670
November 20,1997
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Corrective Stens to Avoid Further Violationst
As noted above, TSI #25 has been deleted.
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Additional enhancements have also been implemented in the 10 CFR 50.59 Formal Safety -
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Evaluation program and are described in the response to Violation 'C'.
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Date when Fuu Comd==ce will be Achievedr
The 10 CFR 50.59 Formal Safety Evaluation and FSAR Change Notice were approved by
July 17,1997.
Refuel 9 is scheduled to begin April 4,1998. The specified upgrade to the refueling
machine will be completed prior to fuel move.wnt.
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ULNRC-3670 =
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November 20,1997
Page 7
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Statassant af Vaalation
C. Final Safety Analysis Report, Section 18.2.3, speci6es that details regarding the
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design of the post accident sampling system (PASS) were described in a letter to the
- NRC, dated February 4,1983. This letter describes the post-accident sampling
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system as a computer controlled automated system
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Contrary to the above, on November 1,1995, the licensee changed tha PASS (RMP
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94 2005A) by changing the computer controlled operation of the sample panel
equipment to a manually controlled operation, a change that was inconsistent with the
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~ description in the FSAR, and the licensee did not have a record of a written safety
evaluation which provided the bases for the determination that this change to the
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facility as described in the PSAR did not involve an unrehte:d safety question.
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(01034).-
This is a Severity Level IV violation (Supple' ment 1).
Bassen for the Violaties
Engineering believed that the previous FSAR Change Notices 94-05 and 94-23, which
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contained 10 CFR 50.59 Formal Safety Evaluations, adequately addressed the removal of
the Post Accident Sampling System (PASS) computer. Therefore, the PASS Design
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Change Package 94 2005 took credit for the previous FSAR Change Notices and did not
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perform another 10 CFR 50.59 Formal Safety Evaluation.
Corrective Stens T=La= ned Results Achieved:
FSAR Change Notice 97 20 modified the FSAR description to state that the PASS
computer controls have been replaced with manual controls. As part of this Change
Notice another 10 CFR 50.59 Formal Safety Evaluation was performed which determined
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that no Unreviewed Safety Question resulted from the removal of the PASS computer.
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f Convective Stens to Avoid Further Violations:
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Procedure APA-ZZ-00140, " Safety, Environmental and Other Licensing Evaluations" was
revised to enhance guidance regarding when a 10 CFR 50.59 Formal Safety Evaluation
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must_ be performed. This revision provided detailed guidance requiring a 10 CFR 50.59
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- Formal Safety Evaluation be performed when changing the facility as described in a
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document referenced in the FSAR. Guidance has also been enhanced for determination of -
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when accident consequences or the probabilities of malfunctions of equipment important
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' to' safety ere increased.
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Attachment to
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ULNRC-3670
November 20,1997
Page8-
Training was provided to Engineering Departments concerning the changes made to
procedure APA-ZZ-00140.-
Date wk*= FuB Com diance wiB be Achieved:
FSAR CN 97 20 was approved on May 1,1997. Full compliance was achieved upon
training of Engineering Department personnel on the changes to APA-ZZ-00140. This
training was completed on July 2,1997.
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