ML20215G403
| ML20215G403 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 10/09/1986 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| ULNRC-1384, NUDOCS 8610200355 | |
| Download: ML20215G403 (8) | |
Text
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,og Et..scraic ocr 1901 Gratiot Street. St. Louis Donald F. SchneII Vice President October 9, 1986 Mr. James M. Taylor, Director
' Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ULNRC-1384
Dear Mr. Taylor:
INSPECTION REPORT NOS. 50-483/86010 AND 50-483/86017 This responds to Mr. James G.
Keppler's letter dated September 9, 1986 which transmitted a Notice of Violation and Proposed Imposition of Civil Penalties for. items of noncompliance identified by inspections conducted at Callaway Plant during the periods April 15 through May 31, 1986 and June 4 through June 11, 1986.
Our respons-es to the items of noncompliance are presented below in the order listed within the body of the Notice.
Also included.
is our decision with respect to the proposed Civil Penalty.
None of the material in this response is considered proprie-tary by Union Electric Company.
(50-483/86010-04) SEVERITY LEVEL III:
VIOLATION I.A Technical Specification 3'.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems be operable with each subsystem comprised of an operable flow path when the unit is in operational Modes 1, 2, and 3.
Technical Specification 3.0.3 requires that when a Limiting Condition for Operation is not met, except as provided in the associated Action requirements, within one hour action must be initiated to place the unit in a Mode in which the specification does not apply.
When in Hot Standby (Mode 3) the unit must be placed in at least Hot' Shutdown (Mode 4) within the following six hours and Cold Shutdown within the subsequent.24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Contrary to the above, on April 12, 1986, at 4:02 a.m., with the unit in Hot Standby, licenses personnel closed safety injection cold leg isolation valve EM-HV-8835 while perform-ing a surveillance test.
This action blocked the operable 8610200355 861009
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Mading Address: P.O. Box 149. St. Louis. MO 63166
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Mr. Jcm:s M. Taylor Page 2 October 9, 1986 flow path and rendered both trains of the Intermediate Head Safety Injection System, an ECCS subsystem, inoperable.
The licensee did not take action within one hour to place the unit in Hot Shutdown (Mode 4) within the following six hours, and the valve remained closed until 10:10 a.m.
Response
Admission or Denial of the Alleged Violation As previously noted in Licensee Event Report 86-009-01 transmitted to the NRC May 16, 1986, Union Electric acknowl-edges the cited violation.
Reasons for the Violation if Admitted This violation occurred because of unintentional personnel errors during the scheduling, reviewing, and-performance of OSP-EP-V0003 "Section XI Accumulator Safety Injection Valve Operability".
The errors and contributing factors are summarized as follows:
A.
Scheduling personnel identified surveillance test OSP-EP-V0003 as required to be performed in Mode 3 prior to RCS pressure reaching 1000 p.s.i.g., which failed to recognize the Surveillance Task Sheet (STS),
" Task Performance Mode" requirements.
The STS stipulated performance of the surveillance in Mode-4 ONLY.
B.
The April 12, 1986 Mode 3 change letter confused operating personnel.
In an attempt to provide addi-tional information to the Control Room, mode change letters have been used to identify surveillances due in the near future which would be affected by the mode change, as well as surveillances required for the mode change.
Surveillance tracking personnel identi-fied OSP-EP-V0003 on the Mode 3 change letter'to be performed in Mode 3 when conditions permit (RCS pres-sure greater than 300 p.s.i.g.).
This was based on our need to perform the surveillance (18-month surveil-lance - due June 1986) prior to declaring the safety injection accumulators operable.
C.
Operations personnel erroneously authorized performance of the OSP in Mode 3.
During review of OSP-EP-V0003 prior to running the test, Operations personnel noted that the OSP initial conditions stipulated performance of the procedure in Mode 4 only.
They reviewed the
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Mr. Jcmas M. Taylor.
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Page 3 October 9, 1986 OSP, the mode change letter and the schedule, and i
erroneously authorized performance of this surveillance in Mode 3 by a Temporary Change Notice (TCN) to the procedure. overlooking the effect of~ closing EM-HV-8835 when in Mode 3._This_ mistake was caused by confusion between the schedule, the initial conditions of the procedure, and the. mode change letter'.
D.
Revision of the Surveillance Task' Sheet did not follow the existing review and approval cycle.
With issuance of the TCN, the Surveillance Task Sheet " Task Perfor-mance Mode" was changed by Operations personnel without 4
the appropriate reviews and approvals.
i Corrective Steps That Have Been Taken and the Results Achieved
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At 10:10 a.m. on April 12, 1986, during the routine Control Room Shift and Daily Log Readings and Channel Checks, a Reactor Operator found valve position switch EM-HIS-8835 indicating closed.
Technical Specification Action j
Statement 3.0.3 was immediately entered since Technical Specification 3.5.2 does not provide Action Statements for two inoperable Intermediate Head Safety Injection Trains.
EM-HV-8835 was restored to'the open position within the one hour time constraint in Technical Specification 3.0.3.
The following corrective actions address each paragraph j
listed in the preceding " Reasons'for the Violation" section.
A.
Progressive Discipline was imposed on the responsible Outage Department personnel and Outage Planning and Scheduling personnel were advised of the necessity to l
v comply with programmatic controls.
These actions were complete as of April 18, 1986.
On April 30, 1986, Scheduling personnel initiated program changes to assure that OSP-EP-V0003 is performed in Mode 4 as a Mode 3 restraint.during future outages.
Outage Department procedure BDP-ZZ-00007, " Outage Planning and Scheduling; Schedule Development and Review Requirements", was issued on August 20, 1986 to specifically address the use of the Surveillance Task 3
i Sheet " Task Performance Mode" for scheduling Technical Specification Surveillances.
B..
Procedure ODP-ZZ-00014, " Operational Mode Change Requirements", was revised May 21, 1986 to assure that r
future Mode Change letters reflect only required task
c.
Mr. Jamss M. Taylor Page 4 October 9, 1986 performance conditions and Technical Specification re-quirements for Mode changes.
Surveillances due in the near future will not be identified in the mode change letter.
These will be identified to the operators separately by the Planning and Scheduling Department or by the Outage Department (for 18-month surveillances).
The Compliance group assists other departments by identifying infrequent surveillances.that become due within the next 18~-month period.
All Compliance group personnel have been instructed in the proper method of initiating mode change letters and properly identifying exceptions to the letter in accordance with the above guidelines.
This will remove the confusion experienced by the operating personnel as to when OSP-EP-V0003 should have been performed.
C.
TCN 86-570, which allowed the performance of OSP-EP-V0003 in Mode 3 was voided on April 12, 1986.
This action returned'the surveillance procedure to its original correct form.
Progressive discipline for the responsible Operations Department personnel was completed on June 13, 1986.
This included reminding the persons involved of their responsibility to be aware of plant conditions resulting from surveillance activities and the need to remain within Technical Specification requirements.
Procedure APA-ZZ-00101, " Preparation, Review, Approval and Control of Procedures", was revised on June 2, 1986 to more explicitly define the-limits on the use of TCNs.
Subsequently, the use of TCNs was removed from APA-ZZ-00101 and issued as a new procedure i
APA-ZZ-00114, " Temporary Changes to Procedures".
APA-ZZ-00114 was issued August 21, 1986 to define the use and processing of Temporary Change Notices.
The procedure does not allow significant changes to initial j
conditions by using a TCN.
Therefore, changing the Mode for performing a surveillance procedure is no longer allowed by a Temporary Change Notice; a complete procedure revision and review is required.
D.
Management has re-emphasized adherence to administrative controls for revisions to task sheets I
and surveillance procedures to appropriate plant personnel.
Corrective Steps Which Will Be Taken to Avoid Further Violations No further corrective action is considered necessary.
Mr. Jamss M. Taylor Page 5 October 9, 1986 Date When Full Compliance Will Be Achieved Union Electric has accomplished all corrective actions necessary to prevent recurrence.
(50-483/86010-03) SEVERITY LEVEL III:
VIOLATION I.B 10CFR50. 72 (b) (2) (iii) requires that a licensee notify the NRC within four hours of any event or condition that alone could have prevented.the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident.
Contrary to the above, on April 12, 1986 the licensee identified at 10:10 a.m.
that both trains of the Intermedi-ate Head Safety Injection System had been rendered inopera-ble, a condition that could have prevented the fulfillment of'the safety function of a system needed to mitigate the consequences of an accident, and did not notify the NRC within four hours after identifying this condition.
Response
Admission or Denial of the Alleged Violation As previously noted in Licensee Event Report 86-009-01 transmitted to the NRC May 16, 1986, Union Electric acknowl-edges the cited violation.
I Reasons for the Violation if Admitted l
The reason for this violation was a failure to recognize that the 10CFR50.72 (b) (2) (iii) reporting requirement per-tained to the April 12, 1986 event.
The requirement was later identified as being applicable during the event investigation.
Corrective Steps That'Have Been Taken and the Results Achieved Compliance group personnel have been re-instructed on the j
applicability -of 10CFR50.72 (b) (2) (iii).
I The Compliance Department transmitted training material to the Training Department which consists of a paragraph-by-paragraph explanation of 10CFR50.72 requirements.
This material is to be included in the Licensed Operator Requalification Training.
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Mr. Jamss M. Taylor Page 6 October 9, 1986 Operations personnel.have been made aware of the. content of LER 86-009-01, and the reporting requirements of 10 CFR'50.72.
Corrective Steps Which Will be Taken to Avoid Further d'
Violations The Training Department will update the Reporting Require-ments Requalification Training Course to include the de--
tailed reporting information.
Date When Full Compliance Will Be Achieved Union Electric will achieve full compliance by December 5, 1986.
(50-483/86017-01) SEVERITY LEVEL III:
VIOLATION II Technical Specification 3.3.2 requires that the Engineered Safe.ty Features Actuation System (ESFAS) instrumentation channels shown in Table 3.3-3 be operable.
Table 3.3-3, Item 6.g requires that when the plant is operating in Modes 1 or 2, a minimum of three of four instrumentation I
channels be operable to start Auxiliary Feedwater Pumps
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(AFP) after the trip of all Main Feedwater Pumps (MFP).
Contrary to'the.above, from 7:51 p.m. on May 30, 1986 until 6:48 a.m. on May 31, 1986 (a period of approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />), the plant operated in Modes.1 and 2 with all four channels of the AFP ESFAS inoperable.(blocked).
As a result, the. automatic start capability of the AFP on loss of the MFP was defeated.
While preparing for the next turnover the indication was noted and corrected.
Response
Admission or Denial of the-Alleged Violation As previously noted in Licensee Event Report 86-018-00 transmitted to the NRC June 30, 1986, Union Electric ac-knowledges the cited violation.
Reasons for the Violation if Admitted I
' Placing the switches in the " block" position was addressed in the Final Safety Analysis Report (FSAR) and Safety Evaluation Report (SER).
The Technical Specifications are
o.
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Mr. Jcmon M. Taylor Page 7 October 9, 1986 inconsistent with the FSAR and SER.
Leaving the switches in the " block" position was the result of Operations personnel error and inadequate. procedural controls to address the evolution in progress (transfer from Auxiliary Feedwater Pumps to Main Feedwater Pumps).
Corrective Steps That Have Been Taken and the Results Achieved The immediate action taken upon discovery of the block switches being in the " block" position was to place the block switches in the " permit" position.
Use of the block switches in Modes 1 and 2 has been prohib-ited on an interim basis by Operations Department Night Orders (issued June 2, 1986).
Subsequent procedural con-trols were provided by issuance of a change to Operations Department procedure ODP-ZZ-00014, " Operational Mode Change Requirements".
Operations personnel were briefed on the liabilities of taking action outside of procedures and were instructed to promptly bring procedure deficiencies to the attention of their supervisor.
A letter (UOMO 86-186) was issued June 10, 1986 to all Operations Department personnel to reiterate the importance for all on-shift Operations personnel to be thoroughly familiar with any abnormalities associated with their watchstation.
The letter stated that each Reactor Operator and Control Room Supervisor should be able to explain the reason for every lighted annunciator and abnormal control board indication.
l Operating procedure OTN-AE-00001, "Feedwater System", has been revised to address the transfer of feedwater between l
the Auxiliary Feedwater System and the Main Feedwater System, including guidance on the use of the block switches.
Corrective Steps Which Will Be Taken to Avoid Further Violations t
No further corrective action is considered necessary.
Date When Full Compliance Will be Achieved Union Electric has accomplished all corrective actions necessary to prevent recurrence.
p.,
Mr. Jaman M. Taylor Page 8-October 9, 1986 Related Steps Being Taken For Violation II
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A Technical Specification amendment request (#1048) is being evaluated to allow u'se of the block switches as intended by the FSAR/SER.
Proposed Civil Penalty Union Electric does not contest the proposed Civil Penalty..
Enclosed is a check in the amount of twenty-five thousand dollars ($25,000) payable to the Treasurer of the United States.
Please favor us with an acknowledgement of your receipt of this payment.
If you have any questions regarding this response or if additional information is required, please let us know.
Very truly yours,
/
Donald F.
Schnell DFS/JJW/bjp Enclosure - Check cc:
James G. Keppler, Regional Administrator, NRC Region III l
W. L. Forney, NRC Region III l
NRC Inspectors, Callaway Plant (2) l Manager, Electric Department, Missouri Public Service Commission I
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