ML20199E882

Ack Receipt of 980113 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/97-20 on 971216.Finds Reply Responsive to Concerns Raised in Nov. Implementation of C/As Will Be Reviewed in Future Insps

ML20199E882
Person / Time
Site:	Callaway
Issue date:	01/26/1998
From:	Johnson W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Randolph G UNION ELECTRIC CO.
References
50-483-97-20, NUDOCS 9802020268
Download: ML20199E882 (4)

See also: IR 05000483/1997020

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UNITE 3 STATES

s>W!Og$\ NUCl. EAR REGULATORY COMMISSION

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JAN 2 61998

Garry L. Randolph, Vice President and

Chief Nuclear Officer

Union Electric Company

P.O. Box 620

Fulton, Missouri 65251

SUBJECT: NRC INSPECTION REPORT 50-483/97-20

Dear Mr. Randolph:

Thank you for your letter of January 13,1998, in response to our letter and Notice of

Violation dated December 16,1997. We have reviewed your reply and find it responsive to the

concerns raised in our Notice of Violation. We will rex & 'he implementation of your corrective

actions during a future inspection to determine that full compliance has been achieved and will

be maintained.

Sincerely,

W. . Johnson, Chief

Project Branch B

/

Division of Reactor Projects '/

Docket No.: 50483

License No.: NPF-30

cc:

Professional Nuclear Consulting, Inc.

19041 Raines Drive

Derwood, Maryland 20855

Gerald Chamoff, Esq.

Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, N.W.

. Washington, D.C. 20037

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Union Electric Co. -2-

H. D. Bono, Supervising Engineer

Quality Assurance Regulatory Support

Union Electric Company

P.0, 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

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

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" 4

Union Electric Company )

P.O. Box 620

Fulton, Missouri 65251 1

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JAN 2 61998

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U. S. Nuclear Regulatory Commissi8h'~d g29 N IV

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Mail Stop PI-137

Washington, DC 20555 0001 ULNRC-3705 ,

MIt Gentlemen:

WAmemn REPLY TO NOTICE OF VIOLATION ,

INSPECTION REPORT NO. 50-483/97020

CALLAWAY PLANT

UNION ELECTRIC CO.

This responds to Mr. William D. Johnson's letter dated December 16,1997, which

transmitted a Notice of Violation for events discussed in Inspection Report 50-483/97-

20. Our response to the violation 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,

, y bb'.

. V. Laux

Manager, Quality Assurance

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Attachment: 1) Response to Violation

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ULNRC-3705

January 13,1998-

Page 2

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 Resident Inspector .

Callaway Resident Office

U.S. Nuclear Regulatory Commission

8201 NRC Road '

Steedman,MO 65077

Mr.-Barry C, Westreich (2 c_opies)

Acting Licensing Project Manag r, 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 -

Manager, Plant Support

Wolf Creek Nuclear Operating Corporation

PO Box 411

Burlington,KS 66839

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Attachment to

ULNRC-3705

January 13,1998

Page1-

Statement of Violation

During an NRC inspection conducted on October 26 through December 6,1997, one

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- violation ofNRC requirements was identified. In accordance with ti,e " General

'

Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the

violation is listed below:

Technical Specification 6.8.1.a requires, in part, that written procedores shall be

established, implemented, and maintained covering the applicable procedures

recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.

Regulatory Guide 1.33, Revision 2, Apperdix A, Section 9.a., requires, in part, that

maintenance which can affect the performance of safety-related equipment be properly

performed in accordance with documented instructions.

Contrary to the above, on October 29,1997, licensee personnel failed to follow -

documented instructions during a preventive maintenance task to record ditTerential-

pressure across the essential service water supply and return lines to the Emergency

Diesel Generator A engine. Specifically, a temporary differential pressure gauge was left

installed for approximately 14.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> after completion of the preventive maintenance

task.

This is a Severity Level IV violation (Supplement 1) (50-483/9720-01).

Reason for the Violation

inadequate communication during shift turnover resulted in the Control Room

Supervisor understanding that all work had been completed on the Preventive

Maintenance (PM) task. The Control Room Supervisor understood that a discussion

with Nuclear Engineering regarding the test data was the only action still pending. The

non licensed operator had signed off the PM task as field complete. After the question

regarding the test data was resolved by the System Engineer, the Control Room

Supervisor signed off the PM task as complete without verifying that the restoration was

complete. Note that the auxiliary document for removing the differential pressure gauge

was still open and accurately reflected its status. However, the PM task instructions -

required the auxiliary document be completed prior to completion of the PM task.

The relationship between the PM task sheet and the auxiliary document which installed

and removed the temporary differential pressure gauge, also contributed to the

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Attachment to

ULNRC-3705

January 13,1998

Page 2

-inadequate communication. As written, the documents did not delineate a clear, concise

i work sequence.

Corrective Steos Taken and Results Achieved:

The differential pressure gauge was removed and the system test connections and valves

were restored to their normal positions on October 29,1997, A corrective action

document was also initiated on that date.

The PM task has been revised to provide a clear, concise work sequence.

This event was also reported as Licensee Event Report 97-011-00 on -

December 30,1997 3, in accordance with 10 CFR 50.73(a)(2)(i)(B) as a condition

prohibited by Technical Specification.

Corrective Stens to Avoid Further Violations:

This violation resulted from a personnel error, The concerns identified by this violation

have been discussed with appropriate Operations personnel No programmatic changes

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are required.

Date when Full Comoliance will be Achieved:

Full compliance was achieved by January 5,1998.

' Letter ULNRC-3700, dated December 30,1997 transmitted Licensee Event Report 97-01100, Docket

Number 50-483.

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