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| | number = ML20196J159 | | | number = ML20196J159 |
| | issue date = 07/25/1997 | | | issue date = 07/25/1997 |
| | title = Forwards Response to NRC 970626 Ltr Re Violations Noted in Insp Rept 50-483/97-05 on 970210-14 & 970224-28.Corrective Action:Ler Will Be Submitted Reporting as-found Condition of MSSVs IAW 10CFR50.73(a)(2)(ii) | | | title = Forwards Response to NRC Re Violations Noted in Insp Rept 50-483/97-05 on 970210-14 & 970224-28.Corrective Action:Ler Will Be Submitted Reporting as-found Condition of MSSVs IAW 10CFR50.73(a)(2)(ii) |
| | author name = Laux J | | | author name = Laux J |
| | author affiliation = UNION ELECTRIC CO. | | | author affiliation = UNION ELECTRIC CO. |
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| | contact person = | | | contact person = |
| | document report number = ULNRC-3612, NUDOCS 9708040015 | | | document report number = ULNRC-3612, NUDOCS 9708040015 |
| | | title reference date = 06-26-1997 |
| | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE | | | document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE |
| | page count = 8 | | | page count = 8 |
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| REPLY TO NOTICE OF VIOLATION | | REPLY TO NOTICE OF VIOLATION |
| , INSPECTION REPORT NO. 50-483/97005 , | | , INSPECTION REPORT NO. 50-483/97005 , |
| CALLAWAY PLANT 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. | | CALLAWAY PLANT This responds to Mr. Howell's {{letter dated|date=June 26, 1997|text=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. | | None of the material in the response is considered proprietary by Union Electric. |
| If you have any questions regarding this response, or if additional information is required, please let me know. | | If you have any questions regarding this response, or if additional information is required, please let me know. |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217K1051999-10-19019 October 1999 Ack Receipt of Ltr Dtd 990707,which Transmitted Rev 29 to Callaway Plant Physical Security Plan,Under Provisions of 10CFR50.54(p).Based on Determination That Changes Do Not Decrease Effectiveness of Plan,No NRC Approval Required ML20217G2071999-10-14014 October 1999 Forwards Insp Rept 50-483/99-10 on 990913-16.No Violations Noted.Insp Was to Review Emergency Plan & Procedures During Biennial Emergency Preparedness Exercise ML20217B5901999-10-0505 October 1999 Informs That Staff Concludes That Licensee Responses to GL 97-06 Provides Reasonable Assurance That Condition of Util SG Internals in Compliance with Current Licensing Bases for Callaway Plant,Unit 1 ML20217B5711999-10-0505 October 1999 Discusses GL 98-01 Issued by NRC on 980511 & Uec Responses for Callaway NPP Unit 1 ,990224 & 990628.Informs That Staff Reviewed Responses & Concluded That All Requested Info for GL 98-01 Provided ML20212G0221999-09-22022 September 1999 Forwards Insp Rept 50-483/99-11 on 990812-20.No Violations Noted.Team Found,Weakness in flow-accelerated Corrosion Monitoring Program Resulted in No Previous Insp of Pipe Segment Which Failed ML20212D9341999-09-16016 September 1999 Informs That on 990818,NRC Completed Midcycle PPR of Callaway Plant.In Area of Ep,C/As Taken in Response to Problems Identified During Previous Exercises Warrant More in-dept Review.Details of Insp Plan Through March 2000 Encl ML20217D5791999-09-15015 September 1999 Provides Formal Documentation of Reviews & Discussions Re Technical Ltr Rept for Proprietary Info.Review of Ltr Was Discussed in Telcon & Via e-mail Messages. Summary of Telcons as Documented on 990708,included ML20212A4921999-09-13013 September 1999 Forwards Insp Rept 50-483/99-08 on 990725-0904.Two Severity Level IV Violations of NRC Requirements Identified & Being Treated as Noncited Violations Consistent with App C of Enforcement Policy ML20212A4701999-09-10010 September 1999 Rssponds to NRC 990709 RAI Re Util Relief Request to Allow Use of 1998 Edition of ASME Section Xi,Subsection Iwe. Acceptance Criteria for Liner Plate Pressure Boundary Thickness Will Be Limited to 10% Nominal Thinning ML20212B1521999-09-10010 September 1999 Forwards Insp Rept 50-483/99-07 on 990809-13.No Violations Noted.Inspectors Used Annual Licensed Operator Requalification Exams to Assess Licensed Operator Performance ML20211N0321999-09-0202 September 1999 Forwards SE Concluding That Util Adequately Addressed Actions Requested in GL 95-07, Pressure Locking & Thermal Binding of Safety-Related Power-Operated Gate Valves ML20211B0241999-08-18018 August 1999 Ack Receipt of Ltr Dtd 990714,transmitting Scenario for Licensee Upcoming Biennial Exercise.Based on Review,Nrc Determined That Exercise Scenario Sufficient to Meet Emergency Plan Requirements & Exercise Objectives ML20210T9121999-08-13013 August 1999 Forwards Insp Rept 50-483/99-06 on 990613-0724.One Severity Level 4 Violation Occurred & Being Treated as Ncv,Consistent with App C of Enforcement Policy ML20210R7241999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data Rept for Callaway Nuclear Plant for 990101-990630,IAW 10CFR26.71(d) ML20211A9501999-08-12012 August 1999 Discusses 990720-21 Workshop Conducted in Region IV Ofc,Re Exchange of Info in Area of Use of Risk Insights in Regulatory Activities.List of Attendees,Summary of Topic & Issues,Agenda & Copies of Handouts Encl ULNRC-04085, Forwards Rev 4 to Callaway Plant Cycle 10 COLR, Per TS 6.9.1.9.COLR Has Been Revised to Update Rod Bank Insertion (Ril) Limits,As Function of Rated Thermal Power1999-08-11011 August 1999 Forwards Rev 4 to Callaway Plant Cycle 10 COLR, Per TS 6.9.1.9.COLR Has Been Revised to Update Rod Bank Insertion (Ril) Limits,As Function of Rated Thermal Power ML20210P0371999-08-10010 August 1999 Forwards SE Granting Licensee 980710 Requests for Relief (ISI-13 - ISI-18) from Requirements of Section XI of 1989 Edition of ASME B&PV Code for Second 10-year Interval ISI at Plant,Unit 1 ML20210L1461999-08-0303 August 1999 Informs That NRC Plans to Administer Gfes of Written Operator Licensing Exam on 991006.Requests Submittal of Ltr Identifying Individuals Taking Exam,Personnel Allowed Access to Exams & Mailing Address for Exams ULNRC-04079, Forwards 180-day Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal1999-08-0202 August 1999 Forwards 180-day Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ML20210H6381999-07-30030 July 1999 Forwards SE Accepting Relief Request for Approval for Use of Alternate Exam Requirement for Plant Inservice Insp Program A93443, Forwards Addl Info as Committed to in Telcon Between Amerenue & NRC Personnel on 990616,re GL 95-07, Pressure Locking & Thermal Binding of MOV Gate Valves1999-07-28028 July 1999 Forwards Addl Info as Committed to in Telcon Between Amerenue & NRC Personnel on 990616,re GL 95-07, Pressure Locking & Thermal Binding of MOV Gate Valves ULNRC-04075, Forwards Response to NRC 990618 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of SR Motor-Operated Valves1999-07-28028 July 1999 Forwards Response to NRC 990618 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of SR Motor-Operated Valves ULNRC-04076, Informs of Implementation of Amend 131 to License NPF-30, Revising OL to Reflect Requirement in TS 3/4.7.1.7 for Four Operable ASD Lines & Associated Revs,Rather than Three Operable ASDs1999-07-28028 July 1999 Informs of Implementation of Amend 131 to License NPF-30, Revising OL to Reflect Requirement in TS 3/4.7.1.7 for Four Operable ASD Lines & Associated Revs,Rather than Three Operable ASDs ULNRC-04070, Forwards Rev 3 to Callaway Plant Cycle 10 COLR, IAW TS 6.9.1.9.COLR Has Been Revised to Update RAOC Axial Flux Difference (Afd) Limits,As Function of Rated Thermal Power1999-07-27027 July 1999 Forwards Rev 3 to Callaway Plant Cycle 10 COLR, IAW TS 6.9.1.9.COLR Has Been Revised to Update RAOC Axial Flux Difference (Afd) Limits,As Function of Rated Thermal Power 05000483/LER-1998-008, Forwards Amended Response to GL 81-07, Control of Heavy Loads, to Address Corrective Action Described in LER 98-008-00.Discrepancy Between Earlier Submittals of Snupps Rept on Control of Heavy Loads & TS Re RHR Sys,Resolved1999-07-27027 July 1999 Forwards Amended Response to GL 81-07, Control of Heavy Loads, to Address Corrective Action Described in LER 98-008-00.Discrepancy Between Earlier Submittals of Snupps Rept on Control of Heavy Loads & TS Re RHR Sys,Resolved ULNRC-04071, Informs That Util Anticipates Approx Ten Licensing Actions That Could Occur During Fys 2000 & 2001,in Response to Administrative Ltr 99-021999-07-27027 July 1999 Informs That Util Anticipates Approx Ten Licensing Actions That Could Occur During Fys 2000 & 2001,in Response to Administrative Ltr 99-02 ML20210B5611999-07-20020 July 1999 Forwards Review of Ltr & Encl Objectives for Plant,Unit 1,1999 Emergency Plan Exercise Scheduled for 990914 ML20210B4021999-07-19019 July 1999 Ack Receipt of Facility Emergency Plan Implementing Procedure EIP-ZZ-00101, Classification of Emergencies, Rev 23,issued on 990513,under Provisions of 10CFR50,App E, Section V ML20210B4401999-07-19019 July 1999 Ack Receipt of Revs to Facility Radiological Emergency Response Plan,Chapters 8.0 & 4.0,issued Respectively on 990512-14,under Provisions of 10CFR50,App E,Section V ML20212A3291999-07-15015 July 1999 Forwards Scenario Manual Containing Description of Callaway Plant 1999 Biennial Emergency Response Plan Exercise to Be Conducted 990914.Correspondence to Satisfy 60-day Submittal Requirement ML20209F3471999-07-0909 July 1999 Forwards Response to NRC 990624 RAI to Complete NRC Review of Relief Request to Allow Use of 1998 Edition of ASME Section Xi,Subsection IWE ML20209E5591999-07-0808 July 1999 Informs That as Result of NRC Review of Util Responses to GL 92-01,rev 1,suppl 1 & Suppl 1 Rai,Staff Revised Info in Reactor Vessel Integrity Database & Releasing Database as Rvid Version 2.TAC MA0531 Closed ML20209H2471999-07-0707 July 1999 Forwards Rev 29 to Physical Security Plan,Per 10CFR50.54(p). Rev Withheld,Per 10CFR73.21 ML20196J9501999-07-0202 July 1999 Ack Receipt of Plant Ep,Rev 22,received on 981207 & Submitted Under Provision of 10CFR50,App E,Section V.Changes Does Not Decrease Effectiveness of EP & Continues to Meet Stds of 10CFR50.47(b).NRC Approval Not Required ML20209B6851999-06-28028 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Nuclear Power Plants. Disclosure Rept Encl ML20209C0171999-06-28028 June 1999 Forwards Special Rept 99-01 Re Fifteenth Year Inservice Containment Bldg Tendon Surveillance Failure.Observed Voids in Sheathing Filler Grease Do Not Indicate Degradation of post-tensioning Sys,Based on Encl Evaluation ML20196F8101999-06-25025 June 1999 Informs That J Donohew Will Assume Project Manager Responsibilities,Effective 990621 ML20196H2521999-06-25025 June 1999 Forwards Insp Rept 50-483/99-05 on 990502-0612.Two Violations Occurred & Being Treated as Noncited Violations, Consistent with App C of Enforcement Policy ML20196F8181999-06-24024 June 1999 Forwards RAI Re 990111 Request for Relief from Certain ASME Code ISI Requirements for Containment Liners.Response Requested within 30 Days from Date of Agreement ML20196G5621999-06-21021 June 1999 Informs NRC of Implementation of Amend 132 to Callaway License NPF-30 to Allows Installation of Electrosleeves for Steam Generator Tube Repair for Two Cycles Following Installation of First Electrosleeve IR 05000483/19990041999-06-18018 June 1999 Refers to GL 96-05 Issued by NRC on 960918,UE Responses & 970313 & NRC Insp Rept 50-483/99-04,dtd 990427. Forwards Request for Addl Info Re GL 96-05 Program at Callaway Plant,Unit 1 ML20212J2441999-06-18018 June 1999 Submits Request for Alternate Exam Requirements for Plant Re ISI Program Plan.Plant Does Not Torque Bolted Connections to Stress Values Greater than 100 Ksi ML20195H0971999-06-14014 June 1999 Discusses Une 990407 Request That Proprietary Document Entitled, Thermal Stability Assessment - Electrosleeved Tubes, Be Withheld from Public Disclosure.Determined Info to Be Proprietary & Will Be Withheld from Public Disclosure ML20207H3751999-06-14014 June 1999 Discusses 990407 Une Request That Proprietary Version of Document Entitled, Evaluation of Severe Accident Simulation, Dtd April 1999,be Withheld from Public Disclosure.Determined Info Proprietary & Will Be Withheld ML20195H9731999-06-11011 June 1999 Forwards Requested Addl Info Related to Relief Request ISI-16,encountered During Refuel 9 ML20195J9301999-06-0808 June 1999 Informs That Refuel 9 OAR-1 Owners Data Rept for ISI & Summary Rept for Interval 2 Was Submitted with Typographical Error,In That Commercial Service Date Should Be 841219,vice 941219.Please Substitute Encl Corrected Document ML20207G3201999-06-0707 June 1999 Ack Receipt of Change Notice 98-008 Dtd 980918,which Transmitted Changes to Callaway Plant Ep,Rev 21,under Provisions of 10CFR50,App E,Section V.No NRC Approval Required.No Violations Identified ML20207G3151999-06-0707 June 1999 Ack Receipt of Callaway Plant EP Implementing Procedure EIP-ZZ-001001M,Classification of Emergencies,Rev 22,issued on 981222 Under 10CFR50,App E,Section V Provisions.No Violations Identified ML20195C5131999-05-28028 May 1999 Forwards Revs to Sections 3.9 & 5.6 of Its,Based on Resolution Telcons Held Between NRC Staff & Util on 990526 & 27 A98803, Forwards Certified ITS & ITS Bases for Callaway Plant,In Response to NRC 990402 Draft SE for License Amend to Convert TSs to Format & Expanded Bases of ITS1999-05-27027 May 1999 Forwards Certified ITS & ITS Bases for Callaway Plant,In Response to NRC 990402 Draft SE for License Amend to Convert TSs to Format & Expanded Bases of ITS 1999-09-22
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D5791999-09-15015 September 1999 Provides Formal Documentation of Reviews & Discussions Re Technical Ltr Rept for Proprietary Info.Review of Ltr Was Discussed in Telcon & Via e-mail Messages. Summary of Telcons as Documented on 990708,included ML20212A4701999-09-10010 September 1999 Rssponds to NRC 990709 RAI Re Util Relief Request to Allow Use of 1998 Edition of ASME Section Xi,Subsection Iwe. Acceptance Criteria for Liner Plate Pressure Boundary Thickness Will Be Limited to 10% Nominal Thinning ML20210R7241999-08-12012 August 1999 Forwards semi-annual Fitness for Duty Program Performance Data Rept for Callaway Nuclear Plant for 990101-990630,IAW 10CFR26.71(d) ULNRC-04085, Forwards Rev 4 to Callaway Plant Cycle 10 COLR, Per TS 6.9.1.9.COLR Has Been Revised to Update Rod Bank Insertion (Ril) Limits,As Function of Rated Thermal Power1999-08-11011 August 1999 Forwards Rev 4 to Callaway Plant Cycle 10 COLR, Per TS 6.9.1.9.COLR Has Been Revised to Update Rod Bank Insertion (Ril) Limits,As Function of Rated Thermal Power ULNRC-04079, Forwards 180-day Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal1999-08-0202 August 1999 Forwards 180-day Response to NRC GL 99-02, Lab Testing of Nuclear-Grade Activated Charcoal ULNRC-04075, Forwards Response to NRC 990618 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of SR Motor-Operated Valves1999-07-28028 July 1999 Forwards Response to NRC 990618 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of SR Motor-Operated Valves A93443, Forwards Addl Info as Committed to in Telcon Between Amerenue & NRC Personnel on 990616,re GL 95-07, Pressure Locking & Thermal Binding of MOV Gate Valves1999-07-28028 July 1999 Forwards Addl Info as Committed to in Telcon Between Amerenue & NRC Personnel on 990616,re GL 95-07, Pressure Locking & Thermal Binding of MOV Gate Valves ULNRC-04076, Informs of Implementation of Amend 131 to License NPF-30, Revising OL to Reflect Requirement in TS 3/4.7.1.7 for Four Operable ASD Lines & Associated Revs,Rather than Three Operable ASDs1999-07-28028 July 1999 Informs of Implementation of Amend 131 to License NPF-30, Revising OL to Reflect Requirement in TS 3/4.7.1.7 for Four Operable ASD Lines & Associated Revs,Rather than Three Operable ASDs 05000483/LER-1998-008, Forwards Amended Response to GL 81-07, Control of Heavy Loads, to Address Corrective Action Described in LER 98-008-00.Discrepancy Between Earlier Submittals of Snupps Rept on Control of Heavy Loads & TS Re RHR Sys,Resolved1999-07-27027 July 1999 Forwards Amended Response to GL 81-07, Control of Heavy Loads, to Address Corrective Action Described in LER 98-008-00.Discrepancy Between Earlier Submittals of Snupps Rept on Control of Heavy Loads & TS Re RHR Sys,Resolved ULNRC-04070, Forwards Rev 3 to Callaway Plant Cycle 10 COLR, IAW TS 6.9.1.9.COLR Has Been Revised to Update RAOC Axial Flux Difference (Afd) Limits,As Function of Rated Thermal Power1999-07-27027 July 1999 Forwards Rev 3 to Callaway Plant Cycle 10 COLR, IAW TS 6.9.1.9.COLR Has Been Revised to Update RAOC Axial Flux Difference (Afd) Limits,As Function of Rated Thermal Power ULNRC-04071, Informs That Util Anticipates Approx Ten Licensing Actions That Could Occur During Fys 2000 & 2001,in Response to Administrative Ltr 99-021999-07-27027 July 1999 Informs That Util Anticipates Approx Ten Licensing Actions That Could Occur During Fys 2000 & 2001,in Response to Administrative Ltr 99-02 ML20212A3291999-07-15015 July 1999 Forwards Scenario Manual Containing Description of Callaway Plant 1999 Biennial Emergency Response Plan Exercise to Be Conducted 990914.Correspondence to Satisfy 60-day Submittal Requirement ML20209F3471999-07-0909 July 1999 Forwards Response to NRC 990624 RAI to Complete NRC Review of Relief Request to Allow Use of 1998 Edition of ASME Section Xi,Subsection IWE ML20209H2471999-07-0707 July 1999 Forwards Rev 29 to Physical Security Plan,Per 10CFR50.54(p). Rev Withheld,Per 10CFR73.21 ML20209C0171999-06-28028 June 1999 Forwards Special Rept 99-01 Re Fifteenth Year Inservice Containment Bldg Tendon Surveillance Failure.Observed Voids in Sheathing Filler Grease Do Not Indicate Degradation of post-tensioning Sys,Based on Encl Evaluation ML20209B6851999-06-28028 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Systems at Nuclear Power Plants. Disclosure Rept Encl ML20196G5621999-06-21021 June 1999 Informs NRC of Implementation of Amend 132 to Callaway License NPF-30 to Allows Installation of Electrosleeves for Steam Generator Tube Repair for Two Cycles Following Installation of First Electrosleeve ML20212J2441999-06-18018 June 1999 Submits Request for Alternate Exam Requirements for Plant Re ISI Program Plan.Plant Does Not Torque Bolted Connections to Stress Values Greater than 100 Ksi ML20195H9731999-06-11011 June 1999 Forwards Requested Addl Info Related to Relief Request ISI-16,encountered During Refuel 9 ML20195J9301999-06-0808 June 1999 Informs That Refuel 9 OAR-1 Owners Data Rept for ISI & Summary Rept for Interval 2 Was Submitted with Typographical Error,In That Commercial Service Date Should Be 841219,vice 941219.Please Substitute Encl Corrected Document ML20195C5131999-05-28028 May 1999 Forwards Revs to Sections 3.9 & 5.6 of Its,Based on Resolution Telcons Held Between NRC Staff & Util on 990526 & 27 A98803, Forwards Certified ITS & ITS Bases for Callaway Plant,In Response to NRC 990402 Draft SE for License Amend to Convert TSs to Format & Expanded Bases of ITS1999-05-27027 May 1999 Forwards Certified ITS & ITS Bases for Callaway Plant,In Response to NRC 990402 Draft SE for License Amend to Convert TSs to Format & Expanded Bases of ITS ML20196L2911999-05-19019 May 1999 Forwards Responses to NRC 990315 RAI Concerning GL 95-07, Pressure Locking & Thermal Binding of MOV Gate Valves A36791, Forwards Response to NRC 990510 RAI Re GL 96-06 with Respect to Analysis of Water Hammer & two-phase Flow Issues. Supporting Calculation Also Encl1999-05-17017 May 1999 Forwards Response to NRC 990510 RAI Re GL 96-06 with Respect to Analysis of Water Hammer & two-phase Flow Issues. Supporting Calculation Also Encl ULNRC-04034, Forwards Amerenues Risk Evaluation Summary & Provides Listing of Other Documents Which Have Been Previously Provided to Support Evaluation of Electrosleeves at High Temp Severe Accident Conditions1999-05-17017 May 1999 Forwards Amerenues Risk Evaluation Summary & Provides Listing of Other Documents Which Have Been Previously Provided to Support Evaluation of Electrosleeves at High Temp Severe Accident Conditions 05000483/LER-1998-003, Forwards LER 98-003-01 Re Inadvertent Actuation of ESFAS Due to 'A' SG High Level During Refuel 9.Rept Is Submitted to Report Change in C/A from That Reported in Original Rept1999-05-12012 May 1999 Forwards LER 98-003-01 Re Inadvertent Actuation of ESFAS Due to 'A' SG High Level During Refuel 9.Rept Is Submitted to Report Change in C/A from That Reported in Original Rept ML20206Q9551999-05-12012 May 1999 Responds to NRC Re Violations Noted in Insp Rept 50-483/99-04.Corrective Actions:Une Commits to Make Available for NRC Review,Action Plan Outlining Scope & Completion Dates of Project ULNRC-04027, Forwards Comments on Draft SE Re Proposed Conversion to Improved Tss.Copy of ITS & ITS Bases Will Be Provided by 990524,to Support Issuance of License Amend on or About 9905281999-05-0404 May 1999 Forwards Comments on Draft SE Re Proposed Conversion to Improved Tss.Copy of ITS & ITS Bases Will Be Provided by 990524,to Support Issuance of License Amend on or About 990528 ML20206E3211999-04-28028 April 1999 Forwards Special Rept 98-03 Re Inservice Insp of CP Sgs,Per Plant TS 4.4.5.5.b.Insp Was Performed in Apr 1998 During Plant Ninth Refueling Outage.Rept Is Being Resubmitted Due to Typos in Original Rept ML20206E5781999-04-23023 April 1999 Informs That R Schukai Is No Longer Employed with Amerenue & Info Sent Is No Longer Required.Name Should Be Removed from Mailing Lists.Mailing Label Used by Company Which May Assist in Matter,Submitted ULNRC-04018, Submits follow-up Items Re Proposed Conversion to ITS Sections 1.0,3.3,3.4,3.6,3.7 & 3.9.Suppl to Ltr Will Be Submitted at Later Date1999-04-21021 April 1999 Submits follow-up Items Re Proposed Conversion to ITS Sections 1.0,3.3,3.4,3.6,3.7 & 3.9.Suppl to Ltr Will Be Submitted at Later Date ML20205Q7751999-04-16016 April 1999 Forwards Special Rept 98-03 Concerning ISI of Callaway SGs Performed in Apr 1998 During Callaway Plants Ninth Ro. Rept Documents Final SG Insp Results ULNRC-04015, Forwards Cash Flow Projection & Certification to Satisfy Guarantee of Payment of Retrospective Premiums,Per 10CFR140.211999-04-15015 April 1999 Forwards Cash Flow Projection & Certification to Satisfy Guarantee of Payment of Retrospective Premiums,Per 10CFR140.21 ULNRC-04005, Forwards Proprietary & non-proprietary White Paper Entitled, Evaluation of Severe Accident Simulation, as Addl Info to Facilitate Approval of Requested Amend to Revise TS to Use Repair SG Tubes.Proprietary Info Withheld,Per 10CFR2.7901999-04-0707 April 1999 Forwards Proprietary & non-proprietary White Paper Entitled, Evaluation of Severe Accident Simulation, as Addl Info to Facilitate Approval of Requested Amend to Revise TS to Use Repair SG Tubes.Proprietary Info Withheld,Per 10CFR2.790 ULNRC-04004, Forwards Proprietary Thermal Stability Background Data Along with Time/Temp Graph Requested in 990402 Telcon with NRC & Contractor,Argonne Natl Lab.Proprietary Info Withheld1999-04-0707 April 1999 Forwards Proprietary Thermal Stability Background Data Along with Time/Temp Graph Requested in 990402 Telcon with NRC & Contractor,Argonne Natl Lab.Proprietary Info Withheld ULNRC-04007, Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6 & 3.7.Encl Includes mark-ups of ITS Sections 3.5,3.6 & 3.8.Suppl to Ltr Will Be Provided at Later Date1999-04-0707 April 1999 Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6 & 3.7.Encl Includes mark-ups of ITS Sections 3.5,3.6 & 3.8.Suppl to Ltr Will Be Provided at Later Date ULNRC-04000, Forwards Rept Re Present Level of Insurance & Sources of Insurance Applicable to Callaway Plant,Per 10CFR50.54(w)1999-04-0101 April 1999 Forwards Rept Re Present Level of Insurance & Sources of Insurance Applicable to Callaway Plant,Per 10CFR50.54(w) ULNRC-03998, Forwards Required Financial Info Re Decommissioning Callaway Nuclear Plant,Per 10CFR50.751999-03-30030 March 1999 Forwards Required Financial Info Re Decommissioning Callaway Nuclear Plant,Per 10CFR50.75 ML20205G2211999-03-25025 March 1999 Submits Rev 28A to Callaway Plant Physical Security Plan, Incorporating Addendum Re Security Sys Replacement Transition Plan,Per 10CFR50.54(p).Encl Withheld,Per 10CFR73.21 ML20205R5251999-03-25025 March 1999 Forwards Special Rept 98-03 Re Results of Tenth SG Tube Inservice Insp,Per Requirements of Plant TS 4.4.5.5.b.Insp Was Performed in Apr 1998 During Plant Ninth Refueling Outage ULNRC-03988, Requests Approval of Alternative Exam ISI-12A Per 10CFR50.55a(a)(3)(i) & (II) for 1989 Edition of ASME Section IX,IWA-5242(a) for Class I Bolted Connections Inside Bioshield for RFO 101999-03-19019 March 1999 Requests Approval of Alternative Exam ISI-12A Per 10CFR50.55a(a)(3)(i) & (II) for 1989 Edition of ASME Section IX,IWA-5242(a) for Class I Bolted Connections Inside Bioshield for RFO 10 ULNRC-03991, Forwards 1998 Annual Rept of Individual Monitoring Results, Per 10CFR20.2206.Rept Provided in Electronic Format on Diskette IAW Gudiance of Reg Guide 8.7.Without Diskette1999-03-19019 March 1999 Forwards 1998 Annual Rept of Individual Monitoring Results, Per 10CFR20.2206.Rept Provided in Electronic Format on Diskette IAW Gudiance of Reg Guide 8.7.Without Diskette ML20204F7211999-03-17017 March 1999 Forwards Amended Fitness for Duty Program Performance Data for Six Month Period Beginning Jul-Dec 1998 ML20204E1331999-03-17017 March 1999 Responds to NRC Re Violations Noted in Insp Rept 50-483/99-02 on 990208-12.Corrective Actions:Will Revise Security Plan to Increase Min Staffing by Three Armed Security Force Response Personnel Per Shift ML20207C3631999-03-12012 March 1999 Forwards Exam Matl & Associated QA Checklist for Written Exam to Support Plant RO Retake Exam Scheduled for 990423. Exam Matls Requested to Be Withheld from Public Disclosure Until After Exam Completion 05000483/LER-1998-001, Forwards LER 98-001-01,being Submitted to Clarify Scope of Original Reviews Performed for Corrective Action Number 3 in LER 98-001-00.Reviews Have Identified Case of Failure to Properly Establish Equipment Operability1999-03-10010 March 1999 Forwards LER 98-001-01,being Submitted to Clarify Scope of Original Reviews Performed for Corrective Action Number 3 in LER 98-001-00.Reviews Have Identified Case of Failure to Properly Establish Equipment Operability ULNRC-03979, Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6,3.7,3.8,3.9 & 5.0.Suppl to Ltr Dtd 970515,will Be Provided at Later Date1999-03-0909 March 1999 Submits follow-up Items Related to Proposed Conversion to ITSs Sections 3.3,3.4,3.6,3.7,3.8,3.9 & 5.0.Suppl to Ltr Dtd 970515,will Be Provided at Later Date ULNRC-03975, Informs of No Reportable ECCS Evaluation Model Revs for Callaway During Time Period from Mar 1998 to Mar 1999,IAW 10CFR50.46.ECCS Evaluation Model Margin Assessment Encl1999-03-0505 March 1999 Informs of No Reportable ECCS Evaluation Model Revs for Callaway During Time Period from Mar 1998 to Mar 1999,IAW 10CFR50.46.ECCS Evaluation Model Margin Assessment Encl ULNRC-03971, Forwards Annual Personnel Exposure & Monitoring Rept for 1998, Per TS Sections 6.9.1.4 & 6.9.1.5.Rept Includes One Incident of Specific Activity Analysis of RCS in Which Limits of TS 3.4.8 Were Exceeded1999-02-26026 February 1999 Forwards Annual Personnel Exposure & Monitoring Rept for 1998, Per TS Sections 6.9.1.4 & 6.9.1.5.Rept Includes One Incident of Specific Activity Analysis of RCS in Which Limits of TS 3.4.8 Were Exceeded ML20207A4311999-02-17017 February 1999 Forwards semi-annual Fitness for Duty Program Performance Data Rept for Callaway Nuclear Plant for Period of 980701-981231 1999-09-15
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Text
-+_,.-A .7 a-----1 -+4+lia 6 b a,4 -4L A L- A .a 2.-A-- a & k = ,m, t s Callaway Piant
. Post Offsce Box 620 Fulton, Missoun 65251 1
Union Etucnuc n
July 25,1997
- U. S. Nuclear Regulatory Commission
- Attn
- Document Control Desk Mail Stop PI-137 '-
,, Washingjon DC 20555-0001 ULNRC-3612 ,
Gentlemen:
REPLY TO NOTICE OF VIOLATION
, INSPECTION REPORT NO. 50-483/97005 ,
CALLAWAY PLANT 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 information is required, please let me know.
Very truly yours,
/
. V. Laux Manager, Quality Assurance JVL/tmw/lh
Attachment:
- 1) Response to Violations (
9708040015 970725 -
PDR ADOCK 05000483 G PDR g10072 Illlllllllll!lllillllLillli
l ULNRC-3612 July 25,1997
- Page 2 i-
- cc
- Mr. Ellis W. Merschoff i
Regional' Administrator j U.S. Nuclear Regulatory Commission j Region IV
- 611 Ryan Plaza Drive, Suite 400 i Arlington, TX 76011-8064 i
Senior Resident Inspector -i 8
Callaway Resident Office i U.S. Nuclear Regulatory Commission
{ 8201 NRC- Rsad - - - ~ - e -- - + - - - - ~ ~ . + - <. -
- Steedman, MO 65077 Mr. Barry C. Westreich (2 copies)
. Licensing Project Manager, Callaway Plant l Office of Nuclear Reactor Regulation i U. S. Nuclear Regulatory Commission MG 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 Plant Manager Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839 l
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l Attachment to
! ULNRC-3612 c July 25,1997 l I
] Page1 i
A. Statement of Violation
]
e During an NRC inspection conducted on February 10-14 and 21-28,1997, two - I i violations of NRC requirements were identified. In accordance with the " General i ,
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, l i the violations are listed below:
s h 10 CFR 50.73(a)(2)(vii) states, in part, that the licensee shall report any event where i two independent trains or channels become inoperable in a single system designed to f mitigate the consequences of an accident, i
Contrary to the above, during Refueling Outage 7, in the spring of 1995, an event i 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 on the secondary side steam supply !
lines. The lowest valve setpoint is 1185 psig. Valve setpoints are sequenced at I approximately 12 psi increments with a maximum setpoint of 1234 psig to provide increasing relief capacity based on increasing pressure. This design ensures j secondary coolant system pressure will be limited to 110% of the design pressure during the most severe system operational transient.
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. i i
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Attachment to !
ULNRC-3612 July 25,1997 Page 2 i
l The results were riot considered reportable for the following reasons; The response to question 2.3 in NUREG 1022 Revision 0, Supplement 1 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."
This position is normally used to determine reportability in accordance with 10 CFR 50.73(a)(2)(i)(B) for Technical Specification violations. Consistent with the
. NUREG position, the failures.were censidered to occur at the time of discovery since they were identified during a surveillance test. In addition there was no firm evidence to believe otherwise on individual MSSVs. The action statement was l complied with 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 tole-ance for the MSSVs to +3/-1%. The analysis supporting this amendment enveloped all but j 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 j 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 l l criteria, the letter indicated the most relevant crite.ia for the case in question was 10 CFR 50.73(a)(2)(vii) 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 j 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) Remove residual heat, (C) Control the release of radioactive material, or (D) Mitigate the consequences of an accident"
O 8 Attachment to ULNRC-3612 July 25,1997 Page 3 The letter refers to guidance contained in the second draft of NUREG 1022, revision 1 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 interpretation of this criterion regarding secondary safety valves (i.e., any case with more than one safety valve outside the tolerance band) may be overly l conservative."
Based on review of these criteria the event was not considered to be reportable because;
- 1. The criteria does not apply at tLuomponent level, but at the train level. Steam l
line operability is dependent on operation of the five valves per train as a set.
The individual valves are not considered to meet the definition of an independent '
train.
- 2. The evaluations discussed above determined that the as found condition of the valves did not result in their associated steam lines becoming inoperable.
It should be noted the second draft ofNUREG 1022, Rev. I referred to by the NRC Jetter, was published for comment in February 1994, and has yet to be approved for use. While the information contained in the Region IV letter and the Draft NUREG may provide useful insights on a particular issue, Union Electric is concerned 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 Westinghouse 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. Ilowevet, 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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, u l i Attachment to i ULNRC-3612 I
July 25,1997 Page 4 l
l The cause of the violation was the failure to adeo'iately consider all reporting requirements and their applicability to the circumstances related to surveillance testing ofMSSVs 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)(ii).
Corrective Steps to Avoid Further Violations:
~ " ' ' ' ~^
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- l'his eve'nf fill be reviewelspecif'ically Mth persoimel responsible for making and approving reportability determinations.
On October 3,1996, OL #1114 was denied by the NRC. Subsequently, Union I
, 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, targeted for April,1998.
. This Operating License amendment will provide Technical Specification acceptance i criteria that are consistent with the operational characteristics of the MSSVs and i
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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' ULNRC-3612
-July 25,1997 ,
Page 5 l l
B. Statement of Violation During an NRC inspection conducted on February 10-14 and 24-28,1997, two i violations of NRC requirements were identified. In accordance with the " General l 2
Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, )
l the violations are listed below:
10 CFR 50.59(b)(2) states, in part, that the licensee shall submit, as specified in 10 CFR 50.4, a report containing a brief description of any changes, tests, and i experiments, including a summary of the safety evaluation of each.
i j Contrary to the above, during the period of June 14,1988, to February 28,1997, a i brief description 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).
l 4 Reason for the Violation i i j Procedure APA-ZZ-00140, Safety, Environmental and Other Licensing Evaluations i did not require summaries of safety evaluations performed for temporary
- modifications to be included in the report 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 practice 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 summaries prior to the change in reporting criteria.
As a result of the concern identified during NRC 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 evaluation was made of the reporting periods from May 1,1987 through May 10,1995 to determine whether any additional actions were warranted. A i
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Attachment to ULNRC-3612 July 25,1997 Page 6 l
determination was made not to provide summaries of temporary modification safety evaluations for this period for the following reasons:
. Temporary modifications were short lived and have been removed from the plant or were incorporated in permanent design changes which were reported. <
e There is no impact on the current design and license basis for Callaway Plant.
Corrective Steps to Avoid Further Violations:
. . .. . ... .. ._ .Procedur,e ,APA-2'Z.-00140 g,uidaneg fpr geppting.per,LO.CER 50.5P(b)(2)hac hw - -
g corrected to include temporary modification summaries in future re ports.
Date when Full Compliance will be Achieved:
t Full compliance was achieved on June 24,1997
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