ML20086A114
| ML20086A114 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/26/1995 |
| From: | Schnell D UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| ULNRC-3225, NUDOCS 9507030059 | |
| Download: ML20086A114 (5) | |
Text
i,e 1901 Chouttau Avenue i
=1 Pust Ofice Box 149 i
' St Louis. Masoun 63166
?
314-554 2650 i
_ G7ggy une 26,1995 J
Donald F.Schnell
-Etscraic Senior Mce hesident n sc,,
U S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 i
ULNRC-3225 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/95006
'i CALLAWAY PLANT This responds to Mr. M. J. Farber's letter dated May 30,1995, which transmitted a Notice of Violation for events discussed in Inspection Report 50483/95006. Our response to the violation'is presented in the attachment.
i None of the material in the response is considered proprietary by Union Electric Company.
If you have any questions regarding this response, or if additional information is required, please let me know.
j Very truly yours, I
Donald F Schnell i
r DFShmw
Attachment:
- 1) Response to Violation cc:
J. B. Martin - Regional Administrator, USNRC Region III i
M. J. Farber - Chief, Reactor Projects Section 3A,.USNRC Region III L. R. Wharton - USNRC Licensing Project Manager (2 copies)
USNRC Document Control Desk (Original)
Manager - Electric Department Missouri Public Service Commission B. L. Bartlett - USNRC Senior Resident Inspector T. A. Baxter - Shaw, Pittman, Potts, and Trowbridge 3000Sa 9507030059 950626 l
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Attachment to
- ULNRC-3225 Page 1 of 4 i
j
- Response to Violation 50-483/95006 1
L Statement of Violation 1 During an NRC inspection conducted March 12 through April 29,1995, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions, "10 CFR Part 2 Appendix C, i
the violations are listed below:
1.
10 CFR Part 50, Appendix B, Criterion Il requires, in part, "The applicant 3
shall establish at tlie earliest practicable time... a quality assurance program which complies with the requirements of this appendix. This program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life...."
The licensee's operating quality assurance manual (OQAM) was established in r.ccordance with the above requirement.
e i
Appendix A of the.OQAM discusses the housekeeping requirements of 1
Regulatory guide 1.39 and adds clarifying information, " Cleanliness shall be maintained, consistent with the work being performed, so as to prevent the entry of foreign material into safety-related systems "
Contrary to the above, the licensee failed to prevent the entry of foreign material into safety-related systems as identified below:
A.
On April 4,1995 the licensee identified a latex glove inside safety-related valve BB 8949A (483/9500-Ola(DRP)).
B.
On April 20,1995, after the sumps had been inspei:ted and made available for service the NRC inspectors identified multiple pieces of foreign material in the containment emergency sumps t
(483/95006-Olb(DRP)).
This is a Severity Level IV violation (Supplement I).
Reason for the Violation Failure of Callaway Plant management to assign the appropriate priority and necessary oversight to develop and successfully implement the Foreign Material Exclusion (FME)
Program.
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Attachment to
.ULNRC-3225 Page 2 of 4 -
Corrective Stens f aktitand results achieved:
- The glove was removed from the valve and the foreign material was removed from the j
i sumps.
Following the incident involving foreign material in the containment emergency sumps, the resultant need for improvement in housekeeping and FME was conveyed to plant personnel at daily outage meetings and in the plant newspaper.
QA performed a surveillance of housekeeping during the refueling outage to assess effectiveness of the FME Program.
An extensive cleanup of Containment was conducted prior to startup.
A multi-discipline task team has been formed to identify actions to guard against intnxtuction of foreign objects into plant systems. The team has identified the following deficiencies in the existing FME program:
i Strict compliance with the Plant FME Program is not an established performance i
expectation.
Procedural controls governing the FME Program are spread over too many l
procedures resulting in program inconsistencies.
Outage tool control personnel do not have adequate authority to enforce program requirements.
Boundaries / control points for tool control exclusion areas around safety-related systems are ineffective.
Training of plant staff and vendors in FME program objectives prior to Refueling q
Outage 7 was ineffective.
Corrective steps to avoid further violationn The task team will identify corrective actions necessary to eliminate the above.
deficiencies.
1 The task team will establish housekeeping expectations to minimize the potential for entry of foreign material into plant systems.
The Outage Review Board will review FME plans prior to Refueling Outage 8.
n
4 Attachment to ULNRC-3225 Page 3 of 4 Date when full compliance will be achieved:
Corrective action recommendations from the task team will be established by September 30,1995. Full compliance with task team recommendations will be in place prior to the start of Refueling Outage 8 (Fall 1996).
Stairment of Violation 2 Duririg an NRC inspection conducted March 12 through April 29,1995, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violation is listed below:
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 of Regulatory Guide 1.33, Revision 2, February 1978.
Regulatory Guide 1.33, Appendix A,1.c, requires administrative procedures be established for procedure adherence.
Procedure MDP-ZZ-Mil 004, Revision 11, " Control of Heavy Loads and Special Lifting Devices," attachment 1, " Heavy / Light Loads With The Internals Removed (Fuel In The Vessel)," requires that heavy / light loads not be moved over the vessel area with the upper internals removed.
Contrary to the above, on April 12,1995, a box weighing approximately 450 pounds was moved over the reactor vessel. At the time there was fuel in the vessel and the upper internals were removed (483/95006-02(DRP)).
This is a Severity Level IV Violation (Supplement I).
Reason for the Violation The cause of this violation was personnel error by the polar crane operator.
Contributing factors were:
During the period proceeding the lift, there was no fuel in the reactor vessel and consequently no load path restrictions existed.
There was not an effective mechanism to notify the polar crane operator that fuel load had started and therefore load path restrictions were applicable.
o o
Attachment to ULNRC-3225 Page 4 of 4 Corrective Steps taken and results achieved:
The crane operator's supervision made each of the operators aware of current plant conditions prior to their next containment entry.
An evaluation was performed to determine the consequences of dropping the box over the vessel. It was concluded that the box was not a heavy load and the event was
-i bounded by the current load drop analysis, Corrective steps to avoid further violations:
Operations refueling procedures will be revised to assure polar crane operators are notified of plant conditions.
Date when full compliance will be achieved:
s Full compliance was achieved when the lift ended. The procedure revisions will be completed prior to the start of Refueling Outage 8.
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