IR 05000483/1997005

Ack Receipt of 970725 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/97-05 on 970626

ML20203L867
Person / Time
Site:	Callaway
Issue date:	03/03/1998
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Randolph G UNION ELECTRIC CO.
References
50-483-97-05, 50-483-97-5, NUDOCS 9803060277
Download: ML20203L867 (4)

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'80 UNITE D ST ATES

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.#g  %,k NUCLEAR REGULATORY COMMISSION

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REGION IV

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.s 611 RYAN PLAZA DRIVE, Sulf E 400

1. 't, ,0[*'- AR LINGTON, T E XAS 760110064 March 3, 1998 Garry L Randolph, Vice President and -

Chief Nuclear Officer Union Electric Company P,0, Box 620 FuMon, Missouri 65251 SUBJECT: - RESPONSE TO NRC NOTICE OF VIOLATION (INSPECTION REPORT 50-483/9745)

Dear Mr. Randolph-Thank you for your letter of July 25,1997, in response to our June 26,1997, letter and Notice of Violation concoming the failure to report an event involving a single condition that caused independent trains to become inoperable and the failure to report plant chances due to temporary modifications.-

Due to an administrative oversight, this acknowledgment of your response letter was delayed.

We apologize for any inconvenience that this oversight may have caused.

- We have rewswed your reply and find it responsive to the concerns raised in our Notics of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

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Thomas F. Stetka, Acting Chief Division of Reactor Safety Dccket No.: 50-483 License No.: NPF-30 cc:

Professional Nuclear Consu3ing, Inc.

19041 Raines Drive Derwood, Maryland 20855 0ilO O ?;i  ! i lllR E\E!EE,EMI 9803060277 983303 hDR ADOCK C3000483 PDR

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Union Electric Company -2-Gerald Chamoff, Esq.

Thomas A. Baxter. Esq.

Shaw, Pittman, Potts & Trowbridge 2300 N. Street, N.W.

Washington, D.C. 20037 H. D. Bono, Supervis ng Engineer Quality Assurance Regulato;y Support Union Electric Company P.O. Box 620

] Fulton, Missouri 65251 Manager - Electric Department Missouri Public Service Commission 301 W. High P.O. Box 360 Jefferson City, Missouri 65102 Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 Otto L. Maynard, President and Chief Executive Officer -

Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839 Dan 1. Bolef, President Kay Drey, Representati fe Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 Lee Fritz, Presiding Commissioner Callaway County Court House 10 East Fifth Street Fulton, Missouri 65151

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Union Electric Company -3-l Alan C. Passwater, Manager Licensing and Fuels AmorenUE One Amoren Plaza 1901 Chouteau Avenue P.O. Box 66149 St. Louis, Missouri 63166-6149 J. V, Laux, Manager Quality Assurance Union Electric Company P.O. Box 620 Fulton, Missouri 65251

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o Union Eler*ic Company _ -4-E-Mail report to T. Frye (TJF)

E-Meil report to T. Hiltz (TGH)

E-Mail report to NRR Event Trocking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

boc distrib. by RIV:

Regional Admirktrator Resident inspector DRS Director DRS Deputy Director DRP Director _ . DRS-PSB ' ' , _

Branch Chief (DRP/B)- MIS System Project Engineer (DRP/B) RIV File Branch Chief (DRP/TSS)

i DOCUMENT NA;AE: R:\CVWCW705ak.tfs To receive copy or document, Indicate in box: "C" = Copy without enclosures E" = Copy wdh enclosures "N" = No copy RIV:AC:EB A TFStetkallmb (g 03t3/98 OFFICIAL RECORD COPY

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Union F.lectric Company -4-E-Mail report to T. Frye (TJF) .

E-Mail report to T. Hiltz (TGH)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

bec distri'o. by RIV:

Regional Administrator Resident inspector DRS Director DRS Deputy Director .

DRP Director DRS-PSB Branch Chief (DRP/B) MIS System Project Engineer (DRP/B) RIV File Branch Chief (DRP/TSS)

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DOCUMENT N *,ME: R:\CW\CW70Sak.tfs To recelve copy of document. Indicate in box: "C" = Copy without en osures "E" = Copy w;th enclosures "N" = No copy RIV:AC:EB ,0 l TFStetkallmo d&

03/3/98 OFFICIAL RECORD COPY j

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July 25,1997 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl-137 Washington, DC 20555-0001 ULNRC-3612 Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/97005 CALLAWAY PL, ANT This responds to Mr. Howell's letter dated June 26,1997, which transmitted two Notices of Violation for events discussed in Inspection Report 50-483/97005. Our response to these violations is presented in the attachment.

None of the material in the response is considered proprietary by Union Electric.

If you have any questions regarding this response, or if additional infonnation is required, please let me know.

Very truly yours, j . V. Laux <h Manager, Quality Assurance JVIJtmw/lh

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Attachment: 1) Response to Violations (

7PDR 70004 N 70725 5'PO ADOCK 05000483 G PDR I

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UL,NRC-3612

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July 25,1997 Page 2 I <

cc: Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission ,

Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 Senior Re::ident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman,MO 65077 Mr. Barry C. Westreich (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.

Washington,DC 20037 Plan' Manager Wol. creek Nuclear Operating Corporation PO Box 411 Burlington,KS 66839

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Attachment to

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ULNRC-3612 July 25,1997 Page1 A. Statement of Violation During an NRC inspection conducted on February 10-14 and 24-28,1997, two violations of NRC requirements were identified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

10 CFR 50.73(a)(2)(vii) states, in part, that the licensee shall report any event where two independent trains or channels become inoperable in a single system designed to mitigate the consequences of an accident.

Contrary to the above, during Refueling Outage 7, in the spring of 1995, an event

involving a single condition that caused independent trains to become inoperable l was not reported. This event involved surveillance tests of the main steam safety valves that resulted in 14 out of 20 of these valves failing their as-found setpoint tests with setpoints greater than their Technical Specification setpoint tolerance ofi I percent.

( This is a Severity Level IV violation (Supplement 1).

Reason for the Violation Callaway is a four loop plant. Each steam generator is protected from overpressurization via five safety valves installed or the secondary side steam supply lines. The lo, vest valve setpoint is 1185 psig. Valve mtpoints are sequenced at approximately 12 pri increments with a maximum setpoint of 1234 psig to provide increasing relief capacity based on increasing pressure. This design ensures )

secondary coolant system pressure will be limited to 110% of the design pressure !

during the most severe system operational transient. I During surveillance testing in Refuel 7, the Main Steam Safety Valves (MSSVs)

were individually tested and set to Technical Specification requirements. One valve was tested at a time. If a valve failed to meet the Technical Specification criteria, the action statement was entered, the valve was reset, and the action statement was exited prior to testing the next valve. At the completion of testing, a summary of the test results was evaluated for reportability in accordance with Callaway corrective action program requirements.

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Attachment to

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ULNRC 3612 July 25,1997 Page 2 The results were riot considered reportable for the following reasons; The responae to question 2.3 in NUREO 1022 Revision 0, Supplement I published February 1984, states that " In general, for the purpose of evaluating the reportability of situations found during surveillance tests, it should be assumed that the situation occurred at the time of discovery unless there is firm evidence to believe otherwise."

Tids position is normally used to determine reportability in accordance with r 10 CFR 50.73(a)(2)(1)(B) for Technical Specification violaticas. Consistent with the NUREO position, the failures were considered to occur at the time of discovery since they were identified during a surveillance test. In addition '.here was no firm evidence to believe othenvise on individual MSSVs. The action statement was complied w'th appropriately as each MSSV was tested.

On September 12,1994, an Operating License Amendment, OL #1114, was submitted to the NRC to increase the Technical Specification setpoint tolerance for

'he MSSVs to +3/ l%. The analysis supporting this amendmem enveloped all but four of the Refuel 7 as found valve setpoints. Preliminary review of the test data by Westinghouse (September,1996) determined there was no adverse effect on any existing safety or fatigue analysis. The operability of the main steam line (i.e., train)

was not adversely impacted by the MSSVs as found condition. The condition noted did not meet the criteria of 10 CFR 50.72(b)(ii) and 10 CFR 50.73(a)(2)(ii) or 10 CFR 50.72(b)(2)(iii) and 10 CFR 50.73(a)(2)(v) and, therefore, was not considered to be reportable.

During the subject NRC inspection, the inspectors referred to correspondence from the NRC Office of Nuclear Reactor Regulation to the Director, Division of Reactor Safety, USNRC Region IV, dated November 2,1993, in addition to the above criteria, the letter indicated the most relevant criteria for the case in question was 10 CFR 50.73(a)(2)(vil) which states:

"Any event where a single cause or condition caused at least one independent train or channel to become inoperable in multiple systems or two independent trains or channels to become inoperable in a single system designed to :

(A) Shut down the reactor and maintain it in a safe shutdown condition, (B)Itemove residual heat, (C) Control the release of radioactive material, or (D) Mitigate the consequences of an accident"

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ULNRC 3612 July 25,1997 Page 3 The letter refers to guidance contained in the second drah of NUREO 1022, revision I which indicates that " Valves found outside the technical specification tolerance band can reasonably be considered to have been inoperable during operation." The discussion further states "Given that most plants can satisfy pressure relief requirements with several main steam safety valves unavailable, a rigid hterpretation of this criterion regarding secondary safety valves (i.e., any case with more than one safety valve outside the tolerance band) may be overly Conservative."

Based on review of these criteria the event was not considered to be reportable because; 1. The cr t ia does not apply at the component level, but at the train level. Steam

line operability is dependent on operation of the five valves per train as a set.

The individual valves are not considered to meet the dermition of an independent train, i

2. The nyaluations discussed above determined that the as found condition of the valves did not result in their associaied steam lines becoming inoperable.

It should be noted the second draft of NUREO 1022, Rev. I referred to by the NRC letter, was published for wmment in February 1994, and has yet to be approved for use. While the information contained in the Region IV letter and the Drah NUREO may provide useful insights on a particular issue, Union Electric is concemed that these would be used to develop the basis for a violation, since the review and approval process is not complete.

On July 14,1997 Westiaghouse supplied an evaluation of the effects ofincreasing the setpoint tolerance to +3.6% for the MSSVs at Callaway. The evaluation determined the as found conditions in Refuel 7 would not have impacted system operability. However, based on the likelihood that a number of the valves exceeded their acceptance criteria before the time of discovery, and considering all of the out of tolerance conditions could have existed at the same time, then the condition was not bounded by the analysis supporting OL #1114. Therefore, this condition should have been reported as a condition that was outside the design basis of the plant per 10 CFR 50.73(a)(2)(ii).

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ULNRC 3612 July 25,1997 Page 4 The cause of the violation was the failure to adequataly consider all reporting l requirements and their applicability to the circumstances related to surveillance testing of MSSVs during Refuel 7.

Corrective Steps Taken and Results Achieved:

A Licensee Event Report will be submitted reporting the as.found condition of the MSSVs in accordance with 10 CFR 50.73(a)(2)(li).

Corrective Stens to Avold Further Violations:

This event will be reviewed specifically with personnel responsible for making and approving reportability determinations.

On October 3,1996, OL #1114 was denied by the NRC. Subsequently, Union Electric contracted with Westinghouse to supply the analysis for a new Operating License amendment. The Westinghouse analysis will utilize the LOFTRAN code.

The analysis provided with OL #1114 was developed by Union Electric using the RETRAN code. Use of the LOFTRAN code is expected to expedite the NRC review process. Union Electric is pursuing a submittal schedule that will support approval of the Operating License amendment by Refuel 9, targetod for April,1998.

This Operating License amendment will provida Technical Specification acceptance criteria that are consistent with the operational characteristics of the MSSVs and current inservice Testing Program performance criteria.

Date when Full Compliance will be Achieved:

Full compliance will be achieved upon approval of the Operating License amendment.

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Attachment to

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ULNRC 3612 July 25,1997 Page5 11. Statement of Vlotation During an NRC inspection conducted on February 1014 and 24 28,1997, two violations of NRC requirements were identified, in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREO 1600, the violations are listed below:

I 10 CFR 50.59(b)(2) states, in pan, that the licensee shall submit, as specified in 10 CFR 50.4, a report containing a brief descdption of any changes, tests, and experiments, including a summary of the safety evaluation of each.

Contrary to the above, during the period of June 14,1988, to February 28,1997, a brief descdption of changes due to temporary modifications (e.g., TM 95-M002) and the associated safety evaluation summaries were not reported to the NRC.

This is a Severity Level IV violation (Supplement 1).

Reason for the Violation Procedure APA ZZ-00140, Safety, Environmental and Other Licensing Evaluations did not require summaries of safety evaluations performed for temporary modifications to be included in the repon required by 10 CFR 50.59(b)(2).

Temporary modifications had been excluded from this report since they were typically installed for a limited duration.

Corrective Steps Taken and Results Achieved:

The praunce of not reporting safety evaluation summaries for temporary modifications began with the reporting period commencing May 1,1987. Letter ULNRC 1524 dated June 5,1987 represents the last report to include temporary modification safety evaluation summe. ries prior to the change in reporting criteria.

As a result of thc concem identified during NitC Inspection No. 50 483/97005 safety evaluation summaries for temporary modifications will be included in future reports.

ULNRC-3580 dated May 9,1997 for the period of May 11,1995 through December 31,1996 transmitted the most recent summary report as required by 10 CFR 50.59(b)(2) and includes safety evaluation summaries for temporary modifications for the period.

An ovsluation sas madh 6f tlie reporting periods from May 1,1987 through May 10,1995 to determine whether any additional actions were warranted. A

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Attachment to ULNRC 3612

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July 25,1997 Page 6 determination was made not to provide summaries of temporary modification nafety evaluations for this period for the following reasons:

. Temporary modificatloas were short lived and have been removed from the plant or were incorporated in pennanent design changes which were reported.

• There is no irnpact on the current design and license basis for Callawny Plant.

Corrective Stens to Avoid Further Violation.11 Procedure APA ZZ-00140 guidance for reporting per 10 CFR 50.59(b)(2) has been corrected to include temporary modification summaries in future reports.

Ibte when Full Compliance will be Achieved:

Full compliance was achieved on June 24,1997

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