ML20137C613

Responds to NRC Re Violations Noted in Insp Rept 50-483/97-03.Corrective Actions:Violation Has Been Discussed with Operations Management Personnel

ML20137C613
Person / Time
Site:	Callaway
Issue date:	03/14/1997
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-3546, NUDOCS 9703250059
Download: ML20137C613 (4)

Text

• 1901 Choutcau Avenue Post Office Boa 149 St Louis. Missouri 63166 314 554 2650 Union uarcu 14,199, oc 's' sc^"c" Etucmc 11  !"'~'*"'

s U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl-137 Washington, DC 20555-0001 ULNRC-3546 Gentlemen:

REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/97003 CALLAWAY PLANT This responds to Mr. Arthur T. Howell's letter dated Februny 28, 1997, which transmitted a Notice of Violation for events discussed in Inspection Report 50-483/97003. 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, 1

Donald F. Schnell DFS/tmw

Attachment:

1) Response to Violation f

i 9703250059 970314 PDR ADOCK 05000403 3 k l

G PDR 240109 i

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ULNRC-3546 March 14,1997 Page 2 1

cc: Mr. James E. Dyer l Regional Administrator- Acting l U.S. Nuclear Regulatory Commission Region IV l 611 Ryan Plaza Drive, Suite 400 l Arlington, TX 76011-8064 '

l Senior Resident hspector .

I Callaway Resident Office I U.S. Nuclear Reguk' tory Commission 8201 NRC Road l Steedman, MO 65077 l

l Ms. Kristine M. Thomas (2 copies) j Licensing Project Manager, Callaway Plant OfIice of Nuclear Reactor Regulation i

U. S. Nuclear Regulatory Conunission Mail Stop 13E16 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission i

PO Box 360 Jefferson City, MO 65102 i

Mr. Thomas A. Baxter bhaw, Pittman, Potts, & Tiowbridge 2300 N. Street N.W.

Washington, DC 20037 l Manager, Plant Support Wolf Creek Nuclear Operating Corporation l PO Box 411 Burlington, KS 66839 l

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. Attachment to  !

{ ULNRC-3546 )

l March 14,1997 I

Page 1

. Statement of Violation i

. During an NRC inspection conducted on January 5 through February 15,1997, one violation ofNRC requirements was identified. In accordance with the " General j 3'

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

, violation is listed below:

2 Caliaway Plant Technical Specification 6.2.2.f states, in part, that administrative

procedures shall be developed and implemented to limit the working hours of unit

! staff who perform safety-related functions, for example, licensed operators.

Administrative Procedure APA-ZZ-00905," Limitations of Callaway Plant Staff l Working Hours," Revision 3, Step 3.1.1.3, stated that individuals should not be j permitted to work more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in any 48-hour period. Additionally, Step j 3.2 stated that deviations from working hour restrictions shall be approved and j documented on Attachment 1," Request to Exceed NRC Overtime Restrictions,"

prior to exceeding the overtime restriction.

, Contrary to the above, on January 23,1997, the inspectors identified that two

] licensed operators exceeded the overtime limits by working greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 4-in a 48-hour period without prior approval and documentation on the " Request to Exceed NRC Overtime Restrictions" form. Specifically:

e On December 4 and 5,1996, Operator A worked 27.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in a 48-hour

period.

e On December 5 and 6,1996, Operator B worked 26.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> in a 48-hour i period.

l This is a Severity Level IV violation (Supplement I) (50-483/9703-01).

Reason for the Violation I

The violation occurred during a forced outage to repair hydraulic actuator leaks for I two main feedwater isolation valves. For both cases, the Superintendent, Operations and the Manager, Callaway Plant were cognizant the licensed operators required

authorization to exceed working hour restrictions specified by APA-ZZ-00905.

! Although Attachment 1," Request to Exceed NRC Overtime Restrictions" had not been

- completed, the working hour restriction deviations had been authorized by the appropriate management specified by APA-ZZ-00905. The reason for the violation l

was failure to document the authorization.

Attachment to ULNRC-3546 March 14,1997

. Page 2

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Corrective Stcos Taken and Results Achieved; A corrective action document, SOS 97-0098 was initiated on January 23,1997 to address the concern identified by the NRC resident staff.

l Corrective Steps to Avoid Further Violations:

This violation has been discussed with Opcrations management persolutel. This violation will also be a topic of discussion in meetings conducted by the Superintendent, Operations with Operations department management staff Date when Full Compliance will be Achieved:

Full compliance will be achieved by May 1,1997.

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