IR 05000483/1996011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/96-11

ML20147G728
Person / Time
Site:	Callaway
Issue date:	03/24/1997
From:	Gwynn T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Schnell D UNION ELECTRIC CO.
References
NUDOCS 9703280252
Download: ML20147G728 (5)

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""%g UNITED STATES

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MAR 2 4 !997 Donald F. Schnell, Senior Vice President - Nuclear l

Union Electric Company P.O. Box 66149 St. Louis, Missouri 63166-6149 l

SUBJECT: NRC INSPECTION REPORT 50-483/96-11 l

Dear Mr. Schnell:

Thank you for your letter dated March 7,1997. We have reviewed your revised !

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dates for completion of your corrective actions associated with the Notice of Violation included in the subject NRC inspection report and find them satisfactory. We will review your corrective action during a future inspection.

S;ncerely,  !

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omas P. Gw nn, ire or Division of Re ctor roj cts Docket No.: 50-483 License No.: NPF-30 cc: ,

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, Maryland 20855 ,

J Gerald Charnoff, Esq. I Thomas A. Baxter, Esq.

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

Washington, D.C. 20037 l

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9703280252 970324

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. l Union Electric Company -2-i l

a H. D. Bono, Supervising Engineer  ;

Site Licensing (

Union Electric Company l

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.. P.O. Box 620 Fulton, Missouri 65251

G. L. Randolph, Vice President ,

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Nuclear Operations Union Electric Company P.O. Box 620 l Fulton, Missouri 65251 l Manager - Electric Department Missouri Public Service Commission 301 W. High  !

P.O. Box 360

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Jeffersc,n City, Missouri 65102 Ronald A. Kucera, Deputy Director .

Department of Natural Resources P.O. Box 176 Jefferson City, Missouri 65102 ,

l 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

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Union Electric Company -3-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

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Union Electric Company -4-PAR 2 41997 bec to DCD (IE01)

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Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/B) MIS System Project Engineer (DRP/B) RIV File Branch Chief (DRP/TSS) Leah Tremper (OC/LFDCB, MS: TWFN 9E10)

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DOCUMENT NAME: R:\_CW\CW611 AK.DP To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy t,ah enclosures "N" = No copy RIV:DRP/B l C:DRP/B l D:DRP l g) _ l l DNGraves;df, WDJohnspg, TPGwynn [J77 3M /97 V' 3/4f /97 F' 39f/97 ~

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DOCUMENT NAME: R:\ CW\CW611 AK.DP-

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To receive copy of document. Indicate in box: "C" = Copy wthout enclosures *E" = Copy with enclosures "N" = No copy ]

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U. S. Nuclear Regulatory Commission L

Attn: Document ControlDesk Mail Stop P1-137 l

Washington, DC 20555-0001 ULNRC-3545 Gentlemen:

AMENDED REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/96011 CALLAWAY PLANT  :

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References: Inspection Report No. 50-483/96011 dated December 12,1996 ULNRC-3509 dated January 10,1997

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This amends our response to Mr. J. E. Dyer's letter dated December 12,1996, which .

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transmitted a Notice of Violation for events discussed in Inspection Report 50-483/96011.

Our amended response to the violation is presented in the attachment.

None of the material in the response is considered ioprietary by Union Electric. i If you have any questions regarding this response, or if additional information is required, please let me know.

Very tfbly yours, Ro . Affolter RDA/tmw l Attachment: 1) Amended Response to Violation 99-080\

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/ A"eA=nt to  !

ULNRC-3545  !

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$ Statement of Violation ,

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During an NRC inWon conducted October 13 through November 23,1996, a violation i j ofNRC requirements was identified. In accordance with the " General Statement ofPolicy j and Procedures for NRC Enforcement Actions," (60 FR 34381; June 30,1995) the  ;

j violationis listed below: i

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j Callaway Plant Technical Specification 6.8.1 states, in part, that written procedures j shall be established, implemented, and maintained covering the applicable procedures j recommended in Appendix A ofRegulatory Guide 1.33, Revision 2, February 1978. )

Regulatory Guide 1.33, Appendix A 3.e requires, in part, that procedures be written i for component cooling water system startup, operation, and shutdown.

) No: mal Operating Procedure OTN-EG-1, Revision 14, " Component Cooling Water," ,

j was written to provide the appropriate operating instructions for the component i cooling water system. Step 2.7 of this procedure stated that, during normal

operation, the maximum component cooling water flow should not exceed 110  ;

j percent of the flow listed in Attachment 1 of the procedure. l l

!. Contrary to the above, the NRC inspectors observed that Procedure OTN-EG-1 did i i

not give appropriate instmetions for proper system operation. ' Attachment 1 of the l procedure listed minimum flow values only and not a range offlow rates. In addition, j. the proced ire did not identify minimum system temperature and did not provide j guidance on maintaining proper system temperature. The procedure was unclear as to the required flow rates to the various components (483/96011-01).

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l This is a Severity Level IV Violation (Supplement I).

Reason for the Violation -

Development and review ofNormal Operating Procedure OTN-EG-00001 had primarily focused on ensuring the Component Cooling Water System was capable of providing sufficient cooling to perform its design basis function. The reviews had not explicitly evaluated concems of excessive cooling during cold weather operation.

Corrcctive Steps Taken and Results Achieved:

The Component Cooling Water (CCW) System was adjusted to restore flow to the proper limits. A corrective action document, SOS 96-1795, was initiated on November 14,1996 to address the concerns identified by the NRC Resident Inspector. Based on an engineering evaluation, the FSAR was revised to indicate an allowed minimum CCW

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Ma"rchg997 Page 2 'j*'/

$$Ne 1 cc: Mr. James E. Dyer >

Regional Administratar- Acting U.S. Nuclear Regulatory Commission RegionIV 611 Ryan Plaza Drive, Suite 400 l Arlington, TX 76011 8064  !

Sen:or Resident Inspector ,

i Callaway Resident Office U.S. Nuclear Regulatory Commission  ;

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8201 NRC Road Steedman,MO 65077 l Ms. Kristine M. Thomas (2 copies)

Licensing Project Manager, Callaway Plant :

Office of Nuclear Reactor Regulation l U. S. Nuclear Regulatory Commission Mail Stop 13E16 i Washington, DC 20555-2738 l l

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 l

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- Attachment to

, ULNRC-3545 l March 7,1997 j Page 1 l Statement of Violation

! During an NRC inspection conducted October 13 through November 23,1996, a violation ofNRC requirements was identiSed. In accordance with the " General Statement of Policy

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f r.ad Procedures for NRC Enforcement Actions," (60 FR 34381; June 30,1995) the i

violationislisted below:

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Callaway Plant Technical Specification 6.8.1 states, in part, that written procedures

shall be established, implemented, and maintained covering the applicable procedures

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

l l Regulatory Guide 1.33, Appendix A 3.e requires, in part, that procedures be written

for component cooling water system startup, operation, and shutdown.

i Normal Operating Procedure OTN-EG-1, Revision 14, " Component Cooling Water,"

was written to provide the appropriate operating instmetions for the component cooling water system. Step 2.7 of this procedure stated that, during normal jl operation, the maximum component cooling water flow should not exceed 110

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percent of the flow listed in Attachment 1 of the procedure.

Contrary to the above, the NRC inspectors observed that Procedure OTN-EG-1 did j i not give appropriate instructions for proper system operation. Attachment 1 of the i procedure listed minimum flow values only and not a range offlow rates. In addition,  ;

the procedure did not identify minimum system temperature and did not provide

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guidance on maintaining proper system temperature. The procedure was unclear as j to the required flow rates to the various components (483/96011-01).

This is a Severity Level IV Violation (Supplement I).

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Reason for the Violation -  !

Development and review ofNormal Operating Procedure OTN-EG-00001 had primarily

focused on ensuring the Component Cooling Water System was capable of providing l sufficient cooling to perform its design basis function. The reviews had not explicitly l evaluated concerns of excessive cooling during cold weather operation.

j Corrective Steps Taken and Results Achieved:

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The Component Cooling Water (CCW) System was adjusted to restore flow to the proper limits. A corrective action document, SOS 96-1795, was initiated on November 14,1996 e to address the concerns identified by the NRC Resident Inspector. Based on an engineering evaluation, the FSAR was revised to indicate an allowed minimum CCW

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Attachment to ULNRC-3545 i March 7,1997 Page 2 System temperature of 40'F. Revision 15 of OTN-EG-00001 incerporated the FSAR change and was issued on November 21,1996.

Corrective Steps to Avoid Further Violations:

On November 24,1996, Quality Assurance commenced a review of the FSAR for CCW System operating parameters. This review was requested by Nuclear Engineering as a result of SOS 96-1795 which identified that the minimum temperature for CCW System operation described in the FSAR had not been captured as an operating parameter in any plant procedures. The Quality Assurance review identified some minor discrepancies in the normal operating procedures of the CCW system but concluded that the emergency operating procedures for the system were generally consistent with the system description and design parameters included in the FSAR. These findings were published in Quality Assurance Surveillance Report SP96-103 dated December 18,1996. FSAR Change Notice 96-075 was subsequently initiated December 26,1996 to more accurately describe the operation of the CCW System. After processing the change notice, Operations will revise OTN-EG-00001 and the Operator Logs to ensure the CCW System design parameters for flow and temperature are properly maintained.

Union Electric is also evaluating the concerns identified by this violation for potential generic applicability to other systems. Our response to the NRC's 10CFR50.54(f) letter, dated October 9,1996, will address whether additional actions are required.

Date when Full Compliance will be Achieved:

Full compliance will be achieved by April 15,1997. Union Electric committed to full compliance by February 7,1997, via ULNRC-3509, dated January 10,1997. On March 5,1997, the NRC Resident Inspector determined the revision to procedure OTN-EG-00001 had not been completed. Upon notincation by the NRC, Union Electric determined corrective action document SOS 96-1981 was tracking completion of.

corrective action in response to the Notice of Violation. The completion date for corrective action specified by SOS 96-1981 was revised afler the Notice of Violation response was submitted. A significant engineering evaluation is required to support revision of OTN-EG-00001. However, the need to revise the full compliance date stated in ULNRC-3509 was not recognized.

Corrective action document SOS 97-0292 was initiated on March 5,1997 to address the failure 6a meet the compliance date established by the violation response. This letter was also initiated on March 5,1997 to revise Union Electric's response to the violation identified in Inspection Report No. 50-483/96011.

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