ML20217F192

Notice of Violation from Insp on 980202-06.Violation Noted: Licensee Did Not Demonstrate That Either Train of Auxiliary Fuel Bldg Emergency Filter Sys Adsorbers Could Comply W/Ts 4.7.7.b.2 Until Charcoal from Each Train Was Replaced

ML20217F192
Person / Time
Site:	Callaway
Issue date:	03/26/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20217F179	List: IR 05000483/1998002 ML20217F175 ML20217F192
References
50-483-98-02, 50-483-98-2, NUDOCS 9803310306
Download: ML20217F192 (2)

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ENCLOSURE 1 NOTICE OF VIOLATION Union Electric Company Docket No.: 50-483 Callaway Plant License No.: NPF-30 During an NRC inspection conducted on February 2-6,1998, one violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violation is listed below:

Technical Specification 4.0.1, states, in part, that surveillance requirements shall be met during the operational modes or other conditiens specified for individual limiting conditions for operation unless otherwise stated in an individual surveillance requirement.

Technical Specification 4.7.7.b.2 required that within 31 days after removal of a representative charcoal sample from the emergency exhaust system it be verified in accordance with Regulatory Position C.6.b of Regulatory Guide 1.52, Revision 2, March 1978, to meet the laboratory testing criteria of ASTM D-3803-1989 when tested at 30*C and 70 percent relative humidity, for a methyliodide penetration of less than 2 percent.

Technical Specification Amendment 118 was issued on November 13,1996, was effective on issuance, and was required to be implemented within 30 days of the date of issuance.

Contrary to the above, the licensee did not obtain representative charcoal samples from either  !

train of the auxiliary / fuel building emergency filter system adsorbers to demonstrate that the samples would meet the ASTM D-3803-1989 criteria within the 30-day Technical Specification implementation period required by Technical Specification Amendment 118. The licensee did not demonstrate that either train of the auxiliary / fuel building emergency filter system adsorbers could comply with Technical Specification 4.7.7.b.2 until charcoal from each train was replaced.  ;

Charcoal for Train A was replaced on February 1,1998. Charcoal for Train B was replaced on January 24,1996.

This is a Severity Level IV violation (Supplement I) (50-483/9802-01).

Pursuant to the provisions of 10 CFR 2.201, Union Electric Company is hereby required to l submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN: I Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator,  ;

Region IV,611 Ryan Plaza Drive, Suite 400, Arlington, Texas 76011, and a copy to the NRC l 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). This reply should be clearly marked as a

" Reply to a Notice of Violation" and should include for each violation: (1) the reason for the l violation, or, if contested, the basis for disputing the violation or severity level, (2) the corrective j

steps that have been taken and the results achieved, (3) the corrective steps that will be taken to i

avoid further violations, and (4) the date when full compliance will be achieved. Your response l may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response, if an adequate reply is not received within the time specified in this Notice, an order or a Demand for Information may be issued as to why the license should  ;

9803310306 980326 PDR ADOCK 05000483 G PDR

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l , not be modified, suspended, or revoked, or why such other action as may be proper should not

! be taken. Where good cause is shown, consideration will be given to extending the response time.

l if you contest this enforcement action, you should also provide a copy of your response to the l Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 2055'i 0001.

Because your response 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 i 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 i response that deletes such information. If you request withholding of such material, you.Jnust i 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 l 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 financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

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l Dated at Arlington, Texas this 26th day of March 1998 l

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