IR 05000483/1986010

Forwards Insp Repts 50-483/86-10 & 50-483/86-17 on 860415-0531 & 0604-11,respectively & Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $25,000

ML20209J034
Person / Time
Site:	Callaway
Issue date:	09/09/1986
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Schnell D UNION ELECTRIC CO.
Shared Package
ML20209J038	List: IR 05000483/1986010 ML20209J056
References
EA-86-119, NUDOCS 8609160125
Download: ML20209J034 (4)

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SEP 3198Q Docket No. 50-483 License No. NPF-30 EA 86-119 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Gentlemen:

SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORTS NO. 50-483/86010 AND NO. 50-483/86017)

This refers to the inspections conducted during the periods April 15 -

May 31, 1986 and June 4-11, 1986 at the Callaway Plant of activities authorized by NRC License No. NPF-30. The inspections addressed three violations of NRC requirements that were identified by your staff and were reported to the NR The results of the April 15 - May 31, 1986 inspection were discussed on June 3, 1986 during an enforcement conference held in the NRC Region III office between you and others of your staff and Mr. A. B. Davis and others of the NRC Region III staff. A copy of the associated inspection report (50-483/86010)

was sent to you by letter dated June 23, 1986. The results of the June 4-11, 1986 inspection were discussed during a meeting between Mr. S. E. Miltenberger and others of your staff and Messrs. A. B. Davis and R. F. Warnick of the Region III staff during their visit to the Callaway Plant on June 10, 1986. A copy of the associated inspection report (50-483/860117) was sent to you by letter dated July 2, 198 Violation I.A in the enclosed Notice of Violation and Proposed Imposition of Civil Penalties occurred on April 12, 1986 when the plant remained in Hot Standby (Mode 3) for six hours and eight minutes with both trains of the Intermediate Head Safety Injection (IHSI) system inoperable and action was not taken within one hour to place the Unit in Hot Shutdown (Mode 4) as required by the Technical

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Specification. The system became inoperable during the performance of a l surveillance test when licensee personnel closed valve EM-HV-8835 which blocked all IHSI injection paths to the reactor and rendered both IHSI trains inoperabl Plant personnel had improperly changed the procedure for this surveillance test to be performed in Mode 3 rather than Mode 4. Although the safety significance of the violation was reduced because of plant conditions of low temperature and pressure with backup emergency core cooling systems available, the NRC considers

this violation significant in that the personnel who changed the procedure were unaware of plant conditions that resulted from the shutting of the valve and the l

CERTIFIED MAIL RETURN RECEIPT REQUESTED gRo916o125 e60909 G ADOCK 05000483 l

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t Union Electric Company 2 EEP' 9 1986 ensuing Technical Specification (TS) violatio In addition, plant personnel failed to make a timely report of this event to the NR This event was reported the day after the problem was discovered, and not within four hours as require This violation is described in Violation Violation II in the enclosed Notice occurred on May 30, 1986 while the plant was in Mode 2 at 3% power. Auxiliary Feedwater Pumps (AFP) Engineered Safety Features Actuation System (ESFAS) blocking switches were left in the " block" position after the first Main Feedwater Pump (MFP) was put into service to prevent an inadvertent start of the AFPs. This condition, which is prohibited by TS requirements, was not recognized by licensee personnel and existed for approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />. This event is also considered significant because of procedural and personnel performance deficiencies. The Shift Supervisor, Senior Reactor Operator, and the unit reactor operators failed to recognize the TS violatio It was not until the next shift that an off going Reactor Operator, during a control board walkdown prior to shift turnover, observed the mispositioned blocking switches, notified the Shift Supervisor, and correctly positioned the switche To emphasize the need for: (1) conducting licensed activities in accordance with established procedures, (2) providing adequate attention to detail to minimize personnel errors, and (3) ensuring that procedures and changes in procedures have the proper level of review and are adequate for performing work activities, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of Twenty Five Thousand Dollars ($25,000). In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations have been classified in the aggregate as a Severity Level III problem. The base civil penalty for a Severity Level III problem is $50,000. The staff considered escalation of the civil penalties because of a prior enforcement action issued on October 19, 1984 for similar problems in the general area of concern (EA 84-97). However, the NRC recognized that your staff identified the violations, and reported them to NRC. In addition, once the violations were identified, they were given management attention and prompt and extensive corrective actions were taken. Therefore, the base civil penalty is being mitigated 50 percen You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further enforcement action is necessary to ensure compliance with NRC regulatory requirement In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

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Union Electric Company 3 lSEP g 1986 The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, Crichla) c.ighed by

.tae: C. FAjp;cr James G. Keppler Regional Administrator Enclosures: Notice of Violation and Proposed Imposition of Civil Penalties Inspection Reports No. 50-483/86010(DRP);

No. 50-483/86017(DRP)

cc w/ enclosures:

A. P. Neuhalfen, Manager Quality Assurance S. E. Miltenberger, General Manager, Nuclear Operations DCS/RSB (RIDS)

Licensing Fee Management Branch Resident Inspector, RIII Region IV Resident Inspector, Wolf Creek K. Drey Chris R. Rogers, Utility Division, Missouri Public Service Commission SNUPPS

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Union Electric Company I SEP ,s g 1986 DISTRIBUTION POR-SECY CA JMTaylor, IE RStarostecki, IE JAxelrad, IE BBeach, IE JGKeppler, RIII JLieberman, OGC Enforcement Officers RI, RII, RIII, RIV, RV LCobb, IE FIngram, PA JCrooks, AE00 BHayes, 01 SConnelly, 0IA DNussbaumer, OSP JPartlow,'IE IE:ES File IE:EA File DCS i

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