IR 05000483/1997005: Difference between revisions

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{{Adams
{{Adams
| number = ML20203L867
| number = ML20212B688
| issue date = 03/03/1998
| issue date = 10/22/1997
| title = Ack Receipt of 970725 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/97-05 on 970626
| title = Discusses Insp Rept 50-483/97-05 on 970624 & Forwards Nov. Violation Involved Three Instances Which Appeared That SEs Required by 10CFR50.59 Had Not Been Performed for Changes to Facility as Described in Fsar,As Listed
| author name = Stetka T
| author name = Merschoff E
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Randolph G
| addressee name = Randolph G
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-483-97-05, 50-483-97-5, NUDOCS 9803060277
| document report number = 50-483-97-05, 50-483-97-5, EA-97-168, NUDOCS 9710280172
| package number = ML20212B693
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 4
| page count = 7
}}
}}


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==REGION IV==
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.s   611 RYAN PLAZA DRIVE, Sulf E 400
NUCLEAR RFGULATORY COMMISSION   l
#'t,  ,0[*'- AR LINGTON, T E XAS 760110064 March 3, 1998 Garry L Randolph, Vice President and -
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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)
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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.-
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Due to an administrative oversight, this acknowledgment of your response letter was delayed.
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We apologize for any inconvenience that this oversight may have caused.
611 RY AN PLAZA oRIVE, SulTE 400 k'***** ' /  ARLINGTON. If X As 76011-8064 -
 
October-22.:1997
- 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.
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EA 97-168 Garry L Randolph,-Vic6 President and Chief Nuclear Officer Union Electric Company       :
Sincerely,
  -P.O. Box 620 Fulton, Missouri 65251 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50 483/97 05)
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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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==Dear Mr. Randolph:==
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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
This is in reference to the predecisional enforcement conference conducted with you and
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other Union Electric Company representatives on August 15,1997, in the NRC's Arlington, Texas office, and subsequent requests for additional information, as discussed below. The conference was conducted to discuss three apparent violations of NRC requirements related to the Callaway Plant. The apparent violations were identified during an NRC inspection completed on June 24,1997, and were described in an inspection report issued June 26,1997,. Following receipt of the inspection report, which indicated that the NRC
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was considering escalated enforcement action for these apparent /iolations, Union Electric requested a predecisional enforcement conference.
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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)
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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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o      a Callaway Plant
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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
The apparent violations involved three instancer in which it appeared that safety evaluations required by 10 CFR 50.59 had not been performed for changes to the facility as it is described in the Final Safety Analysis Report, including: 1) a Technical Specification interpretation (TSI) and related procedures that permitted manual operation of
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  ' diesel generator bui' ding supply fans: 2) a TSI that modified overload and load reduction trip setpoints for the refueling machine; and 3) a modification that required manual operation of the Post Accident Sampling System (PASS). With respect to manual  l
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operation of diesel generator building supply f ans, the NRC's concerns included whether  /
this change resulted in an unreviewed safety question (USQ), which would have required
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NRC approval prior to the change, and whether emergency diesel generator technical .
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f specifications may have been violated when the diesel generator building supply fans were in the . manual ti.e., pull-to lock)-mode of operation.    .
At the conference, Union Electric: acknowledged that the diesel generator building supply fan issue had not been subjected to a safety evaluation from 1985 to 1987; characterized
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the PASS issue as an isolated f ailure to implement 10 CFR 50.59; and denied any violation related to the refueling machine issue. Union Electric also stated that: 1) none of the changes involved USQs; 2) no technical specification violations had occurred; and 3) there
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twas no safety significance to any of the issues. Following the conference, the NRC-
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requested additional technicalinformation from Union Electric regarding its position that the 9710290172 971022
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Attachment to
Union Electne Company  2-operability of the emergency diesel generators would not be affected with the building supply f ans in the " pull to-lock" mode. Union Electric provided additional information in letters dated Septernber 15 and October 2,1997.
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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
Based on the information developed during the inspection and our review of the information that you provided during and subsequent to the conference, the NRC has determined that violations of NRC requirements occurred in each instance discussed above.
;  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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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.
The violations are cited in the enclosed Notice of Violation (Notice); the circumstances surrounding the violations were described in the subject inspection report, Although the NRC believes in each case that safety evaluations were not performed as required by 10 CFR 50.59, we view these as isolated failures to assure consistency with the FSAR and not indicative of a programmatic concern. In addition, there were no actual safety consequences as a result of any of these changes. Therefore, each of the violations has been classified at Severity LevelIV in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.


On September 12,1994, an Operating License Amendment, OL #1114, was submitted to the NRC to increase the Technical Specification setpoint tolerance for
Nonetheless, it is important for Union Electric to understand that changes to the f ac"ity or to procedures described in the FSAR that are not subjected to safety evaluations may result in unrecognized USOs. Until such changes are subjected to safety evaluations and are well understood, there is uncertainty in the basis (the FSAR) upon which the NRC made a decision to license the facility. Thus, if changes are made that result in unrecognized USQs, the NRC would consider the failure to follow the regulatory process established by 10 CFR 50.59 as a significant regulatory concern.
  '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:
With regard to the diesel generator building supply f ans (Violation A), described in the FSAR as automatically starting when room temperatures exceed 90 F and shutting down automatically when room temperatures fall below 86 F, Union Electric's position at the conference was that a safety evaluation had been performed in late 1986 which showed that the supply fans were not needed as long as outside air temperatures were below 65*F. This analysis resulted in TSI No. 35 in February 1987 which allowed diesel generators to be considered operable with the supply fans out of service and outside temperatures less than 65 F. Union Electric's position, therefore, was that from February 1987 forward, sufficient guidance existed to operators to preclude placing the f ans in pull-to lock if outside temperatures were above 65 F. Union Electric also stated that a recent analysis showed that operability of the diesel generators would not be affected even if supply fans were inoperable and outside temperatures were at 97aF, the maximum outside temperature assumed in the FSAR.
  "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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Notwithstanding Union Electric's position on this issue, the f act remains that at the time of the NRC's on site inspection in February 1997, TSI No.18 and Procedure OTN NE-0002 (and superceded procedures OTN NE-0001 A and OTN-NE-0001B) permitted placing the supply f ans in pull to-lock "... provided it is still under the total control of the Reactor Operator." The TSI and procedure indicated that this was based on hdministrative controls that allow the operator to maintain the room temperature below the FSAR (and former
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Technical Specification) !imit of 119 F. This provision, which appears to have permitted
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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."
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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
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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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_ Union Electric Company  -3-placing the fans in pull to lock regardless of outside temperatures, was inconsistent with the FSAR and was not subjected to a safety evaluation, as required by 10 CFR 50.59, Union Electric's position on the refueling machine issue (Violation B)is that the trip setpoints were in accordance with applicable vendor guidance and interpretations, and, therefore, that there was no change to the description in the FSAR._ This position is based on an interpretation _that the trip setpoints were aporopriately set based on the heaviest and lightest loads, and not on the " suspended loads" as indicated in Section 16.9.2.1 of the FSAR The NRC disagrees with this interpretation because the FSAR descripti_on of these trip setpoints indicates an expectation that the actual or estimated weight of the ,
suspended load is considered in setting the trip points by referring to the overload trip l setpoint in relation to the "... indicated suspended weight." Therefore, we conclude that TSI No. 25 was inconsistent with the description in the FSAR and that this change had not been subjected to a safety evaluation.


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With regard to the PASS issue (Violation C), Union Electric agreed that a modification to the PASP was made which altered the operation of the system from that described in the FSAR, ard that elimination of computer-controlled operation of the system had not specifically been subjected to a safety evaluation. Union Electric attributed this to a mistalren belief, when the actual modification was made, that all changes from the FSAR had previously been analyzed.
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Attachment to
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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:
As previously stated, the NRC does not view these violations as an indication of a programmatic concern with respect to the implementation of 10 CFR 50.59 at the Callaway Plant. But there are lessons to be learned, nonetheless. For example, as discussed at the conference, an FSAR description that requires a carefully worded interpretation, as in the case of the refueling machine trip setpoints, should be revised.
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.
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With regard to the diesel generator building supply f an TSI, the guidance that was provided to operators was confusing, at best, and seemed to serve little purpose after 1990 when the hardware problem that was the genesis for TSI No.18 was fixed. The NRC supports Union Electric's stated plan to eliminate as many TSis as possible.


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.
You are required to respond to this letter and should follow the instructions specifiad in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.


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.
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Date when Full Compliance will be Achieved:
Sincerely, i
Full compliance will be achieved upon approval of the Operating License amendment.
Ellis W. Merse Regional Administrator


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Union Electric Company 4-Docket: 50-483 License: NPF-30 Enclosure: Notice of Violation cc w/ Enclosure:
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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.
.19041 Raines Drive Derwood, Maryland 20855 Gerald Charnoff, Esq.


This is a Severity Level IV violation (Supplement 1).
Thomas A. Baxter, Esq.


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


Temporary modifications had been excluded from this report since they were typically installed for a limited duration.
Washington,-D.C. 20037 H. D. Bono, Supervising Engineer Site Licensing 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 I. Bolef, President Kay Drey, Representative i Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 l
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Corrective Steps Taken and Results Achieved:
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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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Union Electric Company -5-Lee Fritz, Presiding Commissioner-Callaway County' Court House
Attachment to ULNRC 3612
  :- 10 East Fifth Street Fulton, Missouri 65151 Alan C. Passwater, Manager Licensing and Fuels Union Electric Company -
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P.O. Box 66149 St. Louis, Missouri 63166 6149
July 25,1997 Page 6 determination was made not to provide summaries of temporary modification nafety evaluations for this period for the following reasons:
  - J.'V. Laux, Manager Quality Assurance Union Electric Company P.O. Box 620 Fulton, Missouri 65251 f'
    . 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.
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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.
Union Electric Company  -6-bec w/ Enclosure:  [
I rt 4 PDR LPDR  4UDOCS SECY  EC's: RI, Ril, Rlli CA  PA (0 2G4)
EDO (017G21)  OlG (T-5D28)
DEDO (017G21)  OE (0-7H5)
OE:EAFile (0-7H5)  01 (0 3E4)
OGC (015B18)  OGC (0-15818)
NRR (0-12G18)  NRR/ADP (0-12G18)
OC/DAF (T-9E10)  OC/LFDCB (T-9E10)
AEOD (T-4D18)
RA R3ading File  GSanborn-EAFile RIV Files  MIS Coordinator PAO  RSLO RIV Files  TStetka E-Mall DISTRIBUTIQN:
OEMAIL  JDyer (JED2)
EMerschoff (EWM)  WBrown (WLB)
GSanborn (GFS)  GMVasquez (GMV)
AHowell (ATH)  DChamberlain (DDC)
WJohnson (WDJ)  TStetka (TFS)
PGwynn (TPG)  KBrockman (KEB)
DPasschl (DXP)  WBateman (WHB)
KThomas (KMT)
DOCUMENT NAME: G:\EA\ DRAFT \EA97168.DFT To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "t** = No copy EO  C:EB  D:DRS  RC  b(iA
'SANBORN  ' STETK A ' AHOWELL  "WBROWN JDYQR 10/17/97  10/20/97 10/20/97  10/21/97 10/ /B7 h RR/PD4-h n\@RA~ '{g { l  l  l  l BATEMAN%'g MER9dROFF 10fA97 ggcq 10 ( )97      '
*previously cdh6urred  D~FFICIAL RECORD COPY


Ibte when Full Compliance will be Achieved:
,.
Full compliance was achieved on June 24,1997
,
  -
e Union Electric Lompany  -6-bec w/ Enclosure:
  . , , ,
PDR  IE 14 LPDR  NUDOCS SECY  EC's: Rl,Ril,Alli CA  PA (0 2G4)
EDO (017G21)  OlG (T-5D28)
DEDO (017G21)  OE (0-7H5)
OE:EAFile (0-7H5) 01 (0-3E4)
l OGC (0-15B18)  OGC (015B18)
NRR (012G18)  NRR/ADP (012G18)
OC/DAF (T 9E10)  OC/LFDCB (T 9E10)
AEOD (T-4D18)
RA Reading File  GSanborn-EAFile RIV Files  MIS Coordinator PAO  RSLO RIV Files  TStetka E Mall DISTRIBUTION:
OEMAll  JDyer (JED2)
EMerschoff (EWM)  WBrown (WLB)
GSanborn (GFS)  GMVasquez (GMV)
AHowell (ATH)  DChamberlain (DDC)
WJohnson (WDJ)  TStetka (TFS)
PGwynn (TPG)  KBrockman (KEB)
DPassehl (DXP)  WBateman (WHB)
KThomas (KMT)
DOCUMENT NAME: G:\EA\ DRAFT \EA97168.DFT To receive copy of pcument, inscete in box: ac = copy weout fnclosures *E" = Copy we enposures "N" = No copy EO ff/\, C:EB , D:DRS M  RC /R% DRA SANBO W1G  STETKAq% ,_ AHOW ELV  WBROWNV JDYER 10ff/97  10/po/9749910GQ97  10/p/97 10/ /97 RA    l MERSCHOFF      __
10/ /97
    ~
OFFiClAL RECDRD COPY
}}
}}

Latest revision as of 22:35, 18 December 2021

Discusses Insp Rept 50-483/97-05 on 970624 & Forwards Nov. Violation Involved Three Instances Which Appeared That SEs Required by 10CFR50.59 Had Not Been Performed for Changes to Facility as Described in Fsar,As Listed
ML20212B688
Person / Time
Site: Callaway Ameren icon.png
Issue date: 10/22/1997
From: Merschoff E
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Randolph G
UNION ELECTRIC CO.
Shared Package
ML20212B693 List:
References
50-483-97-05, 50-483-97-5, EA-97-168, NUDOCS 9710280172
Download: ML20212B688 (7)
v • d • e


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EA 97-168 Garry L Randolph,-Vic6 President and Chief Nuclear Officer Union Electric Company  :

-P.O. Box 620 Fulton, Missouri 65251 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT 50 483/97 05)

Dear Mr. Randolph:

,

This is in reference to the predecisional enforcement conference conducted with you and

_

other Union Electric Company representatives on August 15,1997, in the NRC's Arlington, Texas office, and subsequent requests for additional information, as discussed below. The conference was conducted to discuss three apparent violations of NRC requirements related to the Callaway Plant. The apparent violations were identified during an NRC inspection completed on June 24,1997, and were described in an inspection report issued June 26,1997,. Following receipt of the inspection report, which indicated that the NRC

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was considering escalated enforcement action for these apparent /iolations, Union Electric requested a predecisional enforcement conference.

The apparent violations involved three instancer in which it appeared that safety evaluations required by 10 CFR 50.59 had not been performed for changes to the facility as it is described in the Final Safety Analysis Report, including: 1) a Technical Specification interpretation (TSI) and related procedures that permitted manual operation of

' diesel generator bui' ding supply fans: 2) a TSI that modified overload and load reduction trip setpoints for the refueling machine; and 3) a modification that required manual operation of the Post Accident Sampling System (PASS). With respect to manual l

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operation of diesel generator building supply f ans, the NRC's concerns included whether /

this change resulted in an unreviewed safety question (USQ), which would have required

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NRC approval prior to the change, and whether emergency diesel generator technical .

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f specifications may have been violated when the diesel generator building supply fans were in the . manual ti.e., pull-to lock)-mode of operation. .

At the conference, Union Electric: acknowledged that the diesel generator building supply fan issue had not been subjected to a safety evaluation from 1985 to 1987; characterized

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the PASS issue as an isolated f ailure to implement 10 CFR 50.59; and denied any violation related to the refueling machine issue. Union Electric also stated that: 1) none of the changes involved USQs; 2) no technical specification violations had occurred; and 3) there

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twas no safety significance to any of the issues. Following the conference, the NRC-

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requested additional technicalinformation from Union Electric regarding its position that the 9710290172 971022

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Union Electne Company 2-operability of the emergency diesel generators would not be affected with the building supply f ans in the " pull to-lock" mode. Union Electric provided additional information in letters dated Septernber 15 and October 2,1997.

Based on the information developed during the inspection and our review of the information that you provided during and subsequent to the conference, the NRC has determined that violations of NRC requirements occurred in each instance discussed above.

The violations are cited in the enclosed Notice of Violation (Notice); the circumstances surrounding the violations were described in the subject inspection report, Although the NRC believes in each case that safety evaluations were not performed as required by 10 CFR 50.59, we view these as isolated failures to assure consistency with the FSAR and not indicative of a programmatic concern. In addition, there were no actual safety consequences as a result of any of these changes. Therefore, each of the violations has been classified at Severity LevelIV in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600.

Nonetheless, it is important for Union Electric to understand that changes to the f ac"ity or to procedures described in the FSAR that are not subjected to safety evaluations may result in unrecognized USOs. Until such changes are subjected to safety evaluations and are well understood, there is uncertainty in the basis (the FSAR) upon which the NRC made a decision to license the facility. Thus, if changes are made that result in unrecognized USQs, the NRC would consider the failure to follow the regulatory process established by 10 CFR 50.59 as a significant regulatory concern.

With regard to the diesel generator building supply f ans (Violation A), described in the FSAR as automatically starting when room temperatures exceed 90 F and shutting down automatically when room temperatures fall below 86 F, Union Electric's position at the conference was that a safety evaluation had been performed in late 1986 which showed that the supply fans were not needed as long as outside air temperatures were below 65*F. This analysis resulted in TSI No. 35 in February 1987 which allowed diesel generators to be considered operable with the supply fans out of service and outside temperatures less than 65 F. Union Electric's position, therefore, was that from February 1987 forward, sufficient guidance existed to operators to preclude placing the f ans in pull-to lock if outside temperatures were above 65 F. Union Electric also stated that a recent analysis showed that operability of the diesel generators would not be affected even if supply fans were inoperable and outside temperatures were at 97aF, the maximum outside temperature assumed in the FSAR.

Notwithstanding Union Electric's position on this issue, the f act remains that at the time of the NRC's on site inspection in February 1997, TSI No.18 and Procedure OTN NE-0002 (and superceded procedures OTN NE-0001 A and OTN-NE-0001B) permitted placing the supply f ans in pull to-lock "... provided it is still under the total control of the Reactor Operator." The TSI and procedure indicated that this was based on hdministrative controls that allow the operator to maintain the room temperature below the FSAR (and former

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Technical Specification) !imit of 119 F. This provision, which appears to have permitted

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_ Union Electric Company -3-placing the fans in pull to lock regardless of outside temperatures, was inconsistent with the FSAR and was not subjected to a safety evaluation, as required by 10 CFR 50.59, Union Electric's position on the refueling machine issue (Violation B)is that the trip setpoints were in accordance with applicable vendor guidance and interpretations, and, therefore, that there was no change to the description in the FSAR._ This position is based on an interpretation _that the trip setpoints were aporopriately set based on the heaviest and lightest loads, and not on the " suspended loads" as indicated in Section 16.9.2.1 of the FSAR The NRC disagrees with this interpretation because the FSAR descripti_on of these trip setpoints indicates an expectation that the actual or estimated weight of the ,

suspended load is considered in setting the trip points by referring to the overload trip l setpoint in relation to the "... indicated suspended weight." Therefore, we conclude that TSI No. 25 was inconsistent with the description in the FSAR and that this change had not been subjected to a safety evaluation.

With regard to the PASS issue (Violation C), Union Electric agreed that a modification to the PASP was made which altered the operation of the system from that described in the FSAR, ard that elimination of computer-controlled operation of the system had not specifically been subjected to a safety evaluation. Union Electric attributed this to a mistalren belief, when the actual modification was made, that all changes from the FSAR had previously been analyzed.

As previously stated, the NRC does not view these violations as an indication of a programmatic concern with respect to the implementation of 10 CFR 50.59 at the Callaway Plant. But there are lessons to be learned, nonetheless. For example, as discussed at the conference, an FSAR description that requires a carefully worded interpretation, as in the case of the refueling machine trip setpoints, should be revised.

_

With regard to the diesel generator building supply f an TSI, the guidance that was provided to operators was confusing, at best, and seemed to serve little purpose after 1990 when the hardware problem that was the genesis for TSI No.18 was fixed. The NRC supports Union Electric's stated plan to eliminate as many TSis as possible.

You are required to respond to this letter and should follow the instructions specifiad in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.

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Sincerely, i

Ellis W. Merse Regional Administrator

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Union Electric Company 4-Docket: 50-483 License: NPF-30 Enclosure: Notice of Violation cc w/ Enclosure:

.,

Professional Nuclear Consulting, Inc.

.19041 Raines Drive Derwood, Maryland 20855 Gerald Charnoff, Esq.

Thomas A. Baxter, Esq.

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

Washington,-D.C. 20037 H. D. Bono, Supervising Engineer Site Licensing 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 I. Bolef, President Kay Drey, Representative i Board of Directors Coalition for the Environment 6267 Delmar Boulevard University City, Missouri 63130 l

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Union Electric Company -5-Lee Fritz, Presiding Commissioner-Callaway County' Court House

- 10 East Fifth Street Fulton, Missouri 65151 Alan C. Passwater, Manager Licensing and Fuels Union Electric Company -

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 f'

- -

Union Electric Company -6-bec w/ Enclosure: [

I rt 4 PDR LPDR 4UDOCS SECY EC's: RI, Ril, Rlli CA PA (0 2G4)

EDO (017G21) OlG (T-5D28)

DEDO (017G21) OE (0-7H5)

OE:EAFile (0-7H5) 01 (0 3E4)

OGC (015B18) OGC (0-15818)

NRR (0-12G18) NRR/ADP (0-12G18)

OC/DAF (T-9E10) OC/LFDCB (T-9E10)

AEOD (T-4D18)

RA R3ading File GSanborn-EAFile RIV Files MIS Coordinator PAO RSLO RIV Files TStetka E-Mall DISTRIBUTIQN:

OEMAIL JDyer (JED2)

EMerschoff (EWM) WBrown (WLB)

GSanborn (GFS) GMVasquez (GMV)

AHowell (ATH) DChamberlain (DDC)

WJohnson (WDJ) TStetka (TFS)

PGwynn (TPG) KBrockman (KEB)

DPasschl (DXP) WBateman (WHB)

KThomas (KMT)

DOCUMENT NAME: G:\EA\ DRAFT \EA97168.DFT To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "t** = No copy EO C:EB D:DRS RC b(iA

'SANBORN ' STETK A ' AHOWELL "WBROWN JDYQR 10/17/97 10/20/97 10/20/97 10/21/97 10/ /B7 h RR/PD4-h n\@RA~ '{g { l l l l BATEMAN%'g MER9dROFF 10fA97 ggcq 10 ( )97 '

  • previously cdh6urred D~FFICIAL RECORD COPY

,.

,

e Union Electric Lompany -6-bec w/ Enclosure:

PDR IE 14 LPDR NUDOCS SECY EC's: Rl,Ril,Alli CA PA (0 2G4)

EDO (017G21) OlG (T-5D28)

DEDO (017G21) OE (0-7H5)

OE:EAFile (0-7H5) 01 (0-3E4)

l OGC (0-15B18) OGC (015B18)

NRR (012G18) NRR/ADP (012G18)

OC/DAF (T 9E10) OC/LFDCB (T 9E10)

AEOD (T-4D18)

RA Reading File GSanborn-EAFile RIV Files MIS Coordinator PAO RSLO RIV Files TStetka E Mall DISTRIBUTION:

OEMAll JDyer (JED2)

EMerschoff (EWM) WBrown (WLB)

GSanborn (GFS) GMVasquez (GMV)

AHowell (ATH) DChamberlain (DDC)

WJohnson (WDJ) TStetka (TFS)

PGwynn (TPG) KBrockman (KEB)

DPassehl (DXP) WBateman (WHB)

KThomas (KMT)

DOCUMENT NAME: G:\EA\ DRAFT \EA97168.DFT To receive copy of pcument, inscete in box: ac = copy weout fnclosures *E" = Copy we enposures "N" = No copy EO ff/\, C:EB , D:DRS M RC /R% DRA SANBO W1G STETKAq% ,_ AHOW ELV WBROWNV JDYER 10ff/97 10/po/9749910GQ97 10/p/97 10/ /97 RA l MERSCHOFF __

10/ /97

~

OFFiClAL RECDRD COPY

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