ULNRC-05323, 30-Day Response to Plant - NRC Special Inspection Report 05000483/2006011, Dated July 14, 2006

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30-Day Response to Plant - NRC Special Inspection Report 05000483/2006011, Dated July 14, 2006
ML062270494
Person / Time
Site: Callaway Ameren icon.png
Issue date: 08/10/2006
From: Keith Young
AmerenUE, Union Electric Co
To:
Document Control Desk, NRC/RGN-III
References
IR-06-011, ULNRC-05323
Download: ML062270494 (4)
v • d • e


Text

AmerenUE PO Box 620 CallawayPlant Fulton, MO 65251 August 10, 2006 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852 Ladies and Gentlemen: ULNRC-05323 DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.

30-DAY RESPONSE TO CALLAWAY PLANT - NRC SPECIAL

.AmernH INSPECTION REPORT 05000483/2006011, dated July 14, 2006 U/E The CALLAWAY PLANT - NRC SPECIAL INSPECTION REPORT 5000483/2006011, dated July 14, 2006, was received on July 17, 2006. This report, its enclosure, and attachments were reviewed by Callaway Plant representatives and the following concern was identified within the report.

In the NRC Special Inspection Report, one green finding was listed regarding failure to correct Emergency Operating Procedure deficiencies associated with Final Safety Analysis Report requirements. This finding was described as NRC identified and self revealing. Callaway Plant disagrees with the characterization of this finding as NRC identified and self revealing.

On March 27, 2006, Callaway Plant personnel identified a procedure deficiency due to the amount of time required for Control Room crews to establish component cooling water to the residual heat removal heat exchangers as demonstrated in License Operator simulator training. A Safety Analysis Engineer researched the issue and a corrective action document was initiated regarding the deficiency in the existing procedure. A root cause analysis team of Callaway Plant personnel was formed to investigate the issue, its extent of condition, and any generic related issues.

An NRC Special Inspection Team was formed after the procedure discrepancy was identified and after the root cause analysis team was formed. The Callaway root cause analysis team informed the NRC Special Inspection Team members of the root cause team progress and the NRC Special Inspection Team contributed in discussions regarding the issue during the inspection period. While we recognize the NRC Special Inspection Team members' interactions and discussions with our root cause analysis team, we do not believe that this qualifies the procedure discrepancy to be categorized as NRC identified, on the basis of this input alone.

a subsidiary ofAmeren Corporation

ULNRC-05323 August 10, 2006 Page 2 We do not support a conclusion that our root cause analysis team would not have correctly identified the causes, contributors, and corrective actions for the procedure discrepancy issue without the NRC Inspection Team's involvement.

Callaway Plant believes this finding in the CALLAWAY PLANT - NRC SPECIAL INSPECTION REPORT 5000483/2006011 should be categorized as licensee identified, rather than NRC identified or self revealing, and hereby requests the inspection findings and results be re-evaluated in consideration of this correction.

This letter does not contain any commitments. If you have questions regarding this response, please contact K. A. Mills at 573-676-4317.

Sincerely, Manager, Regulatory Affairs KDY/DWG/slk

ULNRC-05323 August 10, 2006 Page 3 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Ron Reynolds Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

ULNRC-05323 August 10, 2006 Page 4 bcc: C. D. Naslund A. C. Heflin K. D. Young G. A. Hughes D. E. Shafer (470)

S. L. Gallagher (100)

L. M. Belsky (NSRB)

K. A. Mills P. M. Bell A 160.0761 Certrec Corporation 4200 South Hulen, Suite 630 Fort Worth, TX 76109 (Certrec receivesALL attachments as long as they are non-safeguards andpublicly disclosed,).

Ms. Diane M. Hooper Mr. Dennis Buschbaum Supervisor, Licensing TXU Power WCNOC Comanche Peak SES P.O. Box 411 P.O. Box 1002 Burlington, KS 66839 Glen Rose, TX 76043 Mr. Scott Bauer Mr. Stan Ketelsen Regulatory Affairs Manager, Regulatory Services Palo Verde NGS Pacific Gas & Electric P.O. Box 52034, Mail Stop 104/5/536 Mail Station 7636 P.O. Box 56 Phoenix, AZ 85072-2034 Avila Beach, CA 93424 Mr. Scott Head Mr. John O'Neill Supervisor, Licensing Pillsbury Winthrop Shaw Pittman LLP South Texas Project NOC 2300 N. Street N.W.

Mail Code N5014 Washington, DC 20037 P.O. Box 289 Wadsworth, TX 77483

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