ML20203L867
| ML20203L867 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/03/1998 |
| 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, NUDOCS 9803060277 | |
| Download: ML20203L867 (4) | |
See also: IR 05000483/1997005
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UNITE D ST ATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
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611 RYAN PLAZA DRIVE, Sulf E 400
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AR LINGTON, T E XAS 760110064
March 3, 1998
Garry L Randolph, Vice President and -
Chief Nuclear Officer
Union Electric Company
P,0, Box 620
FuMon, Missouri 65251
SUBJECT:
- RESPONSE TO NRC NOTICE OF VIOLATION (INSPECTION
REPORT 50-483/9745)
Dear Mr. Randolph-
Thank you for your letter of July 25,1997, in response to our June 26,1997, letter and Notice of
Violation concoming the failure to report an event involving a single condition that caused
independent trains to become inoperable and the failure to report plant chances due to
Due to an administrative oversight, this acknowledgment of your response letter was delayed.
We apologize for any inconvenience that this oversight may have caused.
- We have rewswed your reply and find it responsive to the concerns raised in our Notics 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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Thomas F. Stetka, Acting Chief
Division of Reactor Safety
Dccket No.:
50-483
License No.: NPF-30
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Professional Nuclear Consu3ing, Inc.
19041 Raines Drive
Derwood, Maryland 20855
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9803060277 983303
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Union Electric Company
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Gerald Chamoff, Esq.
Thomas A. Baxter. Esq.
Shaw, Pittman, Potts & Trowbridge
2300 N. Street, N.W.
Washington, D.C. 20037
H. D. Bono, Supervis ng Engineer
Quality Assurance Regulato;y Support
Union Electric Company
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P.O. Box 620
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
Otto L. Maynard, President and
Chief Executive Officer -
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
Dan 1. Bolef, President
Kay Drey, Representati fe
Board of Directors Coalition
for the Environment
6267 Delmar Boulevard
University City, Missouri 63130
Lee Fritz, Presiding Commissioner
Callaway County Court House
10 East Fifth Street
Fulton, Missouri 65151
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Union Electric Company
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Alan C. Passwater, Manager
Licensing and Fuels
AmorenUE
One Amoren Plaza
1901 Chouteau Avenue
P.O. Box 66149
St. Louis, Missouri 63166-6149
J. V, Laux, Manager
Quality Assurance
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
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Union Eler*ic Company _
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E-Mail report to T. Frye (TJF)
E-Meil report to T. Hiltz (TGH)
E-Mail report to NRR Event Trocking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
bec to DCD (IE01)
boc distrib. by RIV:
Regional Admirktrator
Resident inspector
DRS Director
DRS Deputy Director
DRP Director _ .
DRS-PSB
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Branch Chief (DRP/B)-
MIS System
Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS)
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To receive copy or document, Indicate in box: "C" = Copy without enclosures E" = Copy wdh enclosures "N" = No copy
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OFFICIAL RECORD COPY
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Union F.lectric 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 (IE01)
bec distri' . by RIV:
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Regional Administrator
Resident inspector
DRS Director
DRS Deputy Director
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DRP Director
DRS-PSB
Branch Chief (DRP/B)
MIS System
Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS)
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DOCUMENT N *,ME: R:\\CW\\CW70Sak.tfs
To recelve copy of document. Indicate in box: "C" = Copy without en osures "E" = Copy w;th enclosures "N" = No copy
RIV:AC:EB
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03/3/98
OFFICIAL RECORD COPY
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Callaway Plant
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July 25,1997
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Mail Stop Pl-137
Washington, DC 20555-0001
ULNRC-3612
Gentlemen:
REPLY TO NOTICE OF VIOLATION
INSPECTION REPORT NO. 50-483/97005
CALLAWAY PL, ANT
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 infonnation is required,
please let me know.
Very truly yours,
j
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. V. Laux
Manager, Quality Assurance
JVIJtmw/lh
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Attachment: 1) Response to Violations
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UL,NRC-3612
July 25,1997
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cc: Mr. Ellis W. Merschoff
Regional Administrator
U.S. Nuclear Regulatory Commission
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Region IV
611 Ryan Plaza Drive, Suite 400
Arlington, TX 76011-8064
Senior Re::ident Inspector
Callaway Resident Office
U.S. Nuclear Regulatory Commission
8201 NRC Road
Steedman,MO 65077
Mr. Barry C. Westreich (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
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
Plan' Manager
Wol. creek Nuclear Operating Corporation
PO Box 411
Burlington,KS 66839
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Attachment to
ULNRC-3612
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July 25,1997
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A.
Statement of Violation
During an NRC inspection conducted on February 10-14 and 24-28,1997, 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:
10 CFR 50.73(a)(2)(vii) states, in part, that the licensee shall report any event where
two independent trains or channels become inoperable in a single system designed to
mitigate the consequences of an accident.
Contrary to the above, during Refueling Outage 7, in the spring of 1995, an event
involving a single condition that caused independent trains to become inoperable
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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.
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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 or the secondary side steam supply
lines. The lo, vest valve setpoint is 1185 psig. Valve mtpoints are sequenced at
approximately 12 pri increments with a maximum setpoint of 1234 psig to provide
increasing relief capacity based on increasing pressure. This design ensures
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secondary coolant system pressure will be limited to 110% of the design pressure
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during the most severe system operational transient.
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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.
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Attachment to
ULNRC 3612
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July 25,1997
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The results were riot considered reportable for the following reasons;
The responae to question 2.3 in NUREO 1022 Revision 0, Supplement I
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."
Tids position is normally used to determine reportability in accordance with
10 CFR 50.73(a)(2)(1)(B) for Technical Specification violaticas. Consistent with the
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NUREO position, the failures were considered to occur at the time of discovery since
they were identified during a surveillance test. In addition '.here was no firm
evidence to believe othenvise on individual MSSVs. The action statement was
complied w'th 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 tolerance for
'he MSSVs to +3/ l%. The analysis supporting this amendmem enveloped all but
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
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
criteria, the letter indicated the most relevant criteria for the case in question was
10 CFR 50.73(a)(2)(vil) 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
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)Itemove residual heat,
(C) Control the release of radioactive material, or
(D) Mitigate the consequences of an accident"
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Attachment to
ULNRC 3612
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July 25,1997
Page 3
The letter refers to guidance contained in the second drah of NUREO 1022,
revision I 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 hterpretation of this criterion regarding secondary safety valves (i.e., any case
with more than one safety valve outside the tolerance band) may be overly
Conservative."
Based on review of these criteria the event was not considered to be reportable
because;
1. The cr t ia does not apply at the component level, but at the train level. Steam
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line operability is dependent on operation of the five valves per train as a set.
The individual valves are not considered to meet the dermition of an independent
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train,
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2. The nyaluations discussed above determined that the as found condition of the
valves did not result in their associaied steam lines becoming inoperable.
It should be noted the second draft of NUREO 1022, Rev. I referred to by the NRC
letter, was published for wmment in February 1994, and has yet to be approved for
use. While the information contained in the Region IV letter and the Drah NUREO
may provide useful insights on a particular issue, Union Electric is concemed 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 Westiaghouse 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. However, 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
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Attachment to
ULNRC 3612
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July 25,1997
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The cause of the violation was the failure to adequataly consider all reporting
requirements and their applicability to the circumstances related to surveillance
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testing of MSSVs 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)(li).
Corrective Stens to Avold Further Violations:
This event will be reviewed specifically with personnel responsible for making and
approving reportability determinations.
On October 3,1996, OL #1114 was denied by the NRC. Subsequently, Union
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, targetod for April,1998.
This Operating License amendment will provida Technical Specification acceptance
criteria that are consistent with the operational characteristics of the MSSVs and
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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Attachment to
ULNRC 3612
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July 25,1997
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11. Statement of Vlotation
During an NRC inspection conducted on February 1014 and 24 28,1997, two
violations of NRC requirements were identified, in accordance with the " General
Statement of Policy and Procedure for NRC Enforcement Actions," NUREO 1600,
the violations are listed below:
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10 CFR 50.59(b)(2) states, in pan, that the licensee shall submit, as specified in
10 CFR 50.4, a report containing a brief descdption of any changes, tests, and
experiments, including a summary of the safety evaluation of each.
Contrary to the above, during the period of June 14,1988, to February 28,1997, a
brief descdption 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).
Reason for the Violation
Procedure APA ZZ-00140, Safety, Environmental and Other Licensing Evaluations
did not require summaries of safety evaluations performed for temporary
modifications to be included in the repon 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 praunce 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 summe. ries prior to the change in reporting criteria.
As a result of thc concem identified during NitC 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 ovsluation sas madh 6f tlie reporting periods from May 1,1987 through
May 10,1995 to determine whether any additional actions were warranted. A
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Attachment to
ULNRC 3612
July 25,1997
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determination was made not to provide summaries of temporary modification nafety
evaluations for this period for the following reasons:
Temporary modificatloas were short lived and have been removed from the
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plant or were incorporated in pennanent design changes which were reported.
There is no irnpact on the current design and license basis for Callawny Plant.
Corrective Stens to Avoid Further Violation.11
Procedure APA ZZ-00140 guidance for reporting per 10 CFR 50.59(b)(2) has been
corrected to include temporary modification summaries in future reports.
Ibte when Full Compliance will be Achieved:
Full compliance was achieved on June 24,1997
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