ML20236V131
| ML20236V131 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/09/1987 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236V108 | List: |
| References | |
| EA-87-194, NUDOCS 8712040101 | |
| Download: ML20236V131 (4) | |
Text
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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES Union Electric Company
. Docket No. 50-483 Callaway, Unit 1 License No. NPF-30 EA 87-194 During NRC inspections conducted during the periods August 24 through September 11, 1987 and September 8-11, 1987, violations of NRC requirements were identified.
In accordance with the " General Statement of Policy and
' Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C (1987), the Nuclear Regulatory Commission proposes to impose' civil penalties pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violations and associated civil penalties are set forth below:
1.
Control Room Emergency Ventilation System A.
Technical Specification Limiting Condition for Operation (LCO) 3.7.6 requires two. independent Control Room Emergency Ventilation Systems (CREVS) to be operable during all modes.
Technical Specification Surveillance Requirement 4.7.6.e.3 states, in part, that each of the CREVS shall be demonstrated operable by verify-ing that the system maintains the control room at a positive pressure greater than or equal to 0.25 inch water gauge (w.g.) relative to the outside atmosphere during system operation.
Technical Specification LC0 3.0.3 requires that when an LCO is not met, except as provided in the associated ACTION requirements, action shall be initiated within one hour to place the unit in hot standby within the next six hours, hot shutdown 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, from approximately June 8 to July 9, 1987, while the Unit operated in Mode 1, both independent CREVS were inoper-able in that each could not maintain the control room at a pressure equal to or greater than 0.25 inch w.g. due to the breaching of elec-trical penetration seals, and action was not initiated within one hour to place the unit in hot standby within the next six hours, hot shut-down 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 />.
B.
10 CFR 50.59 states, in part, that the holder of a license may make changes in the facility as described in the safety analysis report without prior Commission approval, unless the change involves a change in the technical specifications incorporated in the license or an i
unreviewed safety question.
The change shall be deemed to involve an h
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Notice of Violation November 9, 1987 unreviewed safety question if the consequences of an accident pre-viously evaluated in the safety analysis report may be increased.
The licensee shall maintain records of changes to the facility which include a written safety evaluation providing the bases for the deter-minmination that the change does not involve an unreviewed safety question.
Callaway Final Safety Analysis Report (FSAR) Section 6.4.2.3 requires in part, that, during the emergercy mode of operation, the control room is maintained at a positive pressure.of 0.25 inch w.g.(minimum) to prevent infiltration from surrounding areas of unfiltered. air.
Contrary to the cbove, as of July 9, 1987, the licensee failed to prepare an adequate safety evaluation to support a change which was made to the area radiation monitoring system annunciators that affected the capability of the control room to maintain positive i
pressure.
The safety evaluation should have considered work actions-l to be taken to accomplish the modification wherein the electrical penetration seals were breached, creating a situation in which the minimum positive pressure in the control room could not be established. This increased the potential for airborne activity a
inleakage and thus created an unreviewed safety question by 1
increasing the consequences of a Loss of Coolant Accident.
Collectively, the above violations have been evaluated as a Severity Level III problem (Supplement I).
Civil Penalty - $25,000 (assessed equally between the violations).
II.
Essential Service Water System 10 CFR Part 50, Appendix B, Criterion XVI requires, in part, that measures be established to assure that conditions adverse to quality, such as deficiencies and nonconformances, are promptly identified and corrected, q
l Contrary to the above, although in May 1984, Valve EF-V-0017 of the train l
"B" Essential Service Water (ESW) system was identified as being partly closed, thereby possibly reducing available ESW flow and constituting a' condition adverse to quality, measures were not taken to assure that this condition was promptly corrected.
The valve remained in the partly closed condition until August 15, 1987.
The ESW train "B" flow rate was determined to be 11,000 gpm with the valve partially closed while the design flow rate i
specified in the Callaway FSAR is 13,594 gpm.
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This is a Severity Level III violation (Supplement I).
Civil Penalty - $25,000 i
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. Notice of Violation November 9, 1987 Pursuant to the provisions of 10 CFR 2.201, Union Electric Company is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission ~, within 30 days of the date of this Notice.
This reply should be clearly marked as a " Reply to a Notice l
of Violation" and should include for each alleged violation:
(1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, j
(3) the corrective steps that have been taken and the results achieved (4) the 1
corrective steps that will be taken to avoid further violations, and (5) the j
date when full compliance will be achieved.
If an adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
Consideration may be given to extending the response time for good cause shown.
Under the authority of Section 182 of the Act,'42 U.S.C. 2232, this response shall be submitted under oath or affirmation.
Within the same time as provided for the response. required above under 10 CFR 2.201, the Licensee may pay the civil penalties by letter to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, or money order payable to the Treasurer of the United States in the amount of civil penalties proposed above, or may protest imposition of the civil penalties in whole or in part by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission.
Should the Licensee fail to answer within the time specified, an order imposing the civil penalties will be issued.
Should the Licensee elect to file an answer in accordance with 10 CFR 2.205 protesting the civil penalties, in wi. ole or in part, such answer should be clearly marked as an " Answer to a Notice of Violation" and may:
(1) deny the violations listed in this Notice in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other reasons why the penalties should not be imposed.
In addition to protesting the civil penalties, such answer may request remission or mitigation of the penalties.
In requesting mitigation of the proposed penalties, the five factors addressed in Section V.B of 10 CFR Part 2, Appendix C (1987), should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 10 CFR 2.201, but may incorporate parts of the 10 CFR 2.201 reply by specific reference (e.g.,
citing page and paragraph numbers) to avoid repetition. The attention of the Licensee is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.
Upon failure to pay any civil penalties due which subsequently have been deter-mined in accordance with the applicable provisions of 10 CFR 2.205, this matter l
may be referred to the Attorney General, and the penalties, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act, 42 U.S.C. 2282c.
c_
Notice of Violation November 9, 1987 The responses to the Director, Office of Enforcement, noted above (Reply to a Notice of Violation, letter with payment of civil penalty, and answer to a Notice of Violatim) should be addressed to:
Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555 with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region III, 799 Roosevelt Road, Glen Ellyn, Illinois, 60137, and a copy to the NRC Resident Inspector at the Callaway Station.
FOR THE NUCLEAR REGULATORY COMMISSION A. Bert"Davi Regional Administrator Dated at Glen Ellyn, Illinois this v[ day of November 1987 i
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