ML20235C035

Notice of Violation from Insp on 870812-21.Violation Noted: Licensee Conducted Tests Not Described in Safety Analysis Rept Involving Unreviewed Safety Questions W/O Prior Commission Approval from 1985-1987,including 870629 & 0715

ML20235C035
Person / Time
Site:	Callaway
Issue date:	09/17/1987
From:	Forney W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20235C005	List: IR 05000483/1987025 ML20235C004 ML20235C035
References
50-483-87-25, NUDOCS 8709240327
Download: ML20235C035 (1)

Text

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NOTICE OF VIOLATION Union Electric Company Docket No. 50-483 As a result of the inspection conducted on August 12 through 21, 1987, and in accordance with the " General Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985), the following violation was identified:

10 CFR 50.59(a)(1)(iii) states that the holder of a license authorizing operation of a utilization facility may conduct tests not described in the safety analysis report without prior Comission approval unless the proposed test involves an unreviewed safety question. 10 CFR 50.59(a)(2)(iii) states that a proposed change involves an unreviewed safety question if the margin of safety as defined in the basis for any technical specification is reduced.

10 CFR 50.59(b)(1) states that a safety evaluation shall be performed to determine if any unreviewed safety question exists.

Technical Specification 3.5.2 requires that two independent Emergency Core Cooling System (ECCS) subsystems be operable (each subsystem includes one operable Safety Injection Pump) while operating in Mode 1 (power operation). j The basis for Technical Specification 3.5.2 states that the OPERABILITY of  ;

two independent subsystems ensures that sufficient emergency core cooling capability will be available in the event of an accident while assuming the loss of one subsystem.

Contrary to the above, while the unit was in Mode 1, the licensee conducted tests not described in the safety analysis report without prior Commission approval on June 29 and July 15, 1987, and on prior occasions during 1985 through 1987, which involved an unreviewed safety question. Those tests, Operations Surveillance Procedure OSP-EM-P001A and B and maintenance retest instructions following work under WR No. W-414651 and PM 49488, required manual closure of valve BN-HV-8813, the safety injection combined recirculation to the Refueling Water Storage Tank isolation valve, rendering both ECCS safety injection subsystems inoperable reducing the margin of safety defined in the bases of Technical Specification 3.5.2.

This is a Severity Level IV violation (Supplement I) (483/8702601(DRP)).

Pursuant to the provisions of 10 CFR 2.201, you are required to submit to this office within thirty days of the date of this Notice a written statement or explanation in reply, including for each violation: (1) corrective action taken and the results achieved; (2) corrective action to be taken to avoid further violations; and (3) the date when full compliance will be achieved.

Consideration may be given to extending you: response time for good cause shown.

SEP 171m Dated QQ [ 34 W. L. ForneyT Chief C Reactor Projects Branch I h N O