ML20203L867

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/97-05 on 970626

ML20203L867
Person / Time
Site:	Callaway
Issue date:	03/03/1998
From:	Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Randolph G UNION ELECTRIC CO.
References
50-483-97-05, 50-483-97-5, NUDOCS 9803060277
Download: ML20203L867 (4)

See also: IR 05000483/1997005

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UNITE D ST ATES

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.#g  %,k NUCLEAR REGULATORY COMMISSION

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REGION IV

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.s 611 RYAN PLAZA DRIVE, Sulf E 400

1. 't, ,0[*'- AR LINGTON, T E XAS 760110064

March 3, 1998

Garry L Randolph, Vice President and -

Chief Nuclear Officer

Union Electric Company

P,0, Box 620

FuMon, Missouri 65251

SUBJECT: - RESPONSE TO NRC NOTICE OF VIOLATION (INSPECTION

REPORT 50-483/9745)

Dear Mr. Randolph-

Thank you for your letter of July 25,1997, in response to our June 26,1997, letter and Notice of

Violation concoming the failure to report an event involving a single condition that caused

independent trains to become inoperable and the failure to report plant chances due to

temporary modifications.-

Due to an administrative oversight, this acknowledgment of your response letter was delayed.

We apologize for any inconvenience that this oversight may have caused.

- We have rewswed your reply and find it responsive to the concerns raised in our Notics of

Violation. We will review the implementation of your corrective actions during a future inspection

to determine that full compliance has been achieved and will be maintained.

Sincerely,

)

[

Thomas F. Stetka, Acting Chief

Division of Reactor Safety

Dccket No.: 50-483

License No.: NPF-30

cc:

Professional Nuclear Consu3ing, Inc.

19041 Raines Drive

Derwood, Maryland 20855

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9803060277 983303

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Union Electric Company -2-

Gerald Chamoff, Esq.

Thomas A. Baxter. Esq.

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, N.W.

Washington, D.C. 20037

H. D. Bono, Supervis ng Engineer

Quality Assurance Regulato;y Support

Union Electric Company

P.O. 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 1. Bolef, President

Kay Drey, Representati fe

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-

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Alan C. Passwater, Manager

Licensing and Fuels

AmorenUE

One Amoren Plaza

1901 Chouteau Avenue

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 Eler*ic Company _ -4-

E-Mail report to T. Frye (TJF)

E-Meil report to T. Hiltz (TGH)

E-Mail report to NRR Event Trocking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

boc distrib. by RIV:

Regional Admirktrator Resident inspector

DRS Director DRS Deputy Director

DRP Director _ . DRS-PSB ' ' , _

Branch Chief (DRP/B)- MIS System

Project Engineer (DRP/B) RIV File

Branch Chief (DRP/TSS)

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DOCUMENT NA;AE: R:\CVWCW705ak.tfs

To receive copy or document, Indicate in box: "C" = Copy without enclosures E" = Copy wdh enclosures "N" = No copy

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03t3/98

OFFICIAL RECORD COPY

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Union F.lectric Company -4-

E-Mail report to T. Frye (TJF) .

E-Mail report to T. Hiltz (TGH)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

bec to DCD (IE01)

bec distri'o. by RIV:

Regional Administrator Resident inspector

DRS Director DRS Deputy Director .

DRP Director DRS-PSB

Branch Chief (DRP/B) MIS System

Project Engineer (DRP/B) RIV File

Branch Chief (DRP/TSS)

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DOCUMENT N *,ME: R:\CW\CW70Sak.tfs

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RIV:AC:EB ,0 l

TFStetkallmo d&

03/3/98

OFFICIAL RECORD COPY

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Callaway Plant

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July 25,1997

U. S. Nuclear Regulatory Commission

Attn: Document Control Desk

Mail Stop Pl-137

Washington, DC 20555-0001 ULNRC-3612

Gentlemen:

REPLY TO NOTICE OF VIOLATION

INSPECTION REPORT NO. 50-483/97005

CALLAWAY PL, ANT

This responds to Mr. Howell's letter dated June 26,1997, which transmitted two Notices

of Violation for events discussed in Inspection Report 50-483/97005. Our response to

these violations 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 infonnation is required,

please let me know.

Very truly yours,

j . V. Laux <h

Manager, Quality Assurance

JVIJtmw/lh

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Attachment: 1) Response to Violations (

7PDR 70004 N 70725 5'PO

ADOCK 05000483

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UL,NRC-3612

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July 25,1997

Page 2

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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 Re::ident Inspector

Callaway Resident Office

U.S. Nuclear Regulatory Commission

8201 NRC Road

Steedman,MO 65077

Mr. Barry C. Westreich (2 copies)

Licensing Project Manager, 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

Plan' Manager

Wol. creek Nuclear Operating Corporation

PO Box 411

Burlington,KS 66839

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Attachment to

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ULNRC-3612

July 25,1997

Page1

A. Statement of Violation

During an NRC inspection conducted on February 10-14 and 24-28,1997, two

violations of NRC requirements were identified in accordance with the " General

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

the violations are listed below:

10 CFR 50.73(a)(2)(vii) states, in part, that the licensee shall report any event where

two independent trains or channels become inoperable in a single system designed to

mitigate the consequences of an accident.

Contrary to the above, during Refueling Outage 7, in the spring of 1995, an event

involving a single condition that caused independent trains to become inoperable

l was not reported. This event involved surveillance tests of the main steam safety

valves that resulted in 14 out of 20 of these valves failing their as-found setpoint

tests with setpoints greater than their Technical Specification setpoint tolerance ofi

I percent.

( This is a Severity Level IV violation (Supplement 1).

Reason for the Violation

Callaway is a four loop plant. Each steam generator is protected from

overpressurization via five safety valves installed or the secondary side steam supply

lines. The lo, vest valve setpoint is 1185 psig. Valve mtpoints are sequenced at

approximately 12 pri increments with a maximum setpoint of 1234 psig to provide

increasing relief capacity based on increasing pressure. This design ensures )

secondary coolant system pressure will be limited to 110% of the design pressure  !

during the most severe system operational transient. I

During surveillance testing in Refuel 7, the Main Steam Safety Valves (MSSVs)

were individually tested and set to Technical Specification requirements. One valve

was tested at a time. If a valve failed to meet the Technical Specification criteria, the

action statement was entered, the valve was reset, and the action statement was

exited prior to testing the next valve. At the completion of testing, a summary of the

test results was evaluated for reportability in accordance with Callaway corrective

action program requirements.

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Attachment to

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ULNRC 3612

July 25,1997

Page 2

The results were riot considered reportable for the following reasons;

The responae to question 2.3 in NUREO 1022 Revision 0, Supplement I

published February 1984, states that " In general, for the purpose of evaluating

the reportability of situations found during surveillance tests, it should be

assumed that the situation occurred at the time of discovery unless there is

firm evidence to believe otherwise."

Tids position is normally used to determine reportability in accordance with

r 10 CFR 50.73(a)(2)(1)(B) for Technical Specification violaticas. Consistent with the

NUREO position, the failures were considered to occur at the time of discovery since

they were identified during a surveillance test. In addition '.here was no firm

evidence to believe othenvise on individual MSSVs. The action statement was

complied w'th appropriately as each MSSV was tested.

On September 12,1994, an Operating License Amendment, OL #1114, was

submitted to the NRC to increase the Technical Specification setpoint tolerance for

'he MSSVs to +3/ l%. The analysis supporting this amendmem enveloped all but

four of the Refuel 7 as found valve setpoints. Preliminary review of the test data by

Westinghouse (September,1996) determined there was no adverse effect on any

existing safety or fatigue analysis. The operability of the main steam line (i.e., train)

was not adversely impacted by the MSSVs as found condition. The condition noted

did not meet the criteria of 10 CFR 50.72(b)(ii) and 10 CFR 50.73(a)(2)(ii) or

10 CFR 50.72(b)(2)(iii) and 10 CFR 50.73(a)(2)(v) and, therefore, was not

considered to be reportable.

During the subject NRC inspection, the inspectors referred to correspondence from

the NRC Office of Nuclear Reactor Regulation to the Director, Division of Reactor

Safety, USNRC Region IV, dated November 2,1993, in addition to the above

criteria, the letter indicated the most relevant criteria for the case in question was

10 CFR 50.73(a)(2)(vil) which states:

"Any event where a single cause or condition caused at least one independent

train or channel to become inoperable in multiple systems or two independent

trains or channels to become inoperable in a single system designed to :

(A) Shut down the reactor and maintain it in a safe shutdown condition,

(B)Itemove residual heat,

(C) Control the release of radioactive material, or

(D) Mitigate the consequences of an accident"

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Attachment to

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ULNRC 3612

July 25,1997

Page 3

The letter refers to guidance contained in the second drah of NUREO 1022,

revision I which indicates that " Valves found outside the technical specification

tolerance band can reasonably be considered to have been inoperable during

operation." The discussion further states "Given that most plants can satisfy

pressure relief requirements with several main steam safety valves unavailable, a

rigid hterpretation of this criterion regarding secondary safety valves (i.e., any case

with more than one safety valve outside the tolerance band) may be overly

Conservative."

Based on review of these criteria the event was not considered to be reportable

because;

1. The cr t ia does not apply at the component level, but at the train level. Steam

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line operability is dependent on operation of the five valves per train as a set.

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The individual valves are not considered to meet the dermition of an independent

train,

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2. The nyaluations discussed above determined that the as found condition of the

valves did not result in their associaied steam lines becoming inoperable.

It should be noted the second draft of NUREO 1022, Rev. I referred to by the NRC

letter, was published for wmment in February 1994, and has yet to be approved for

use. While the information contained in the Region IV letter and the Drah NUREO

may provide useful insights on a particular issue, Union Electric is concemed that

these would be used to develop the basis for a violation, since the review and

approval process is not complete.

On July 14,1997 Westiaghouse supplied an evaluation of the effects ofincreasing

the setpoint tolerance to +3.6% for the MSSVs at Callaway. The evaluation

determined the as found conditions in Refuel 7 would not have impacted system

operability. However, based on the likelihood that a number of the valves exceeded

their acceptance criteria before the time of discovery, and considering all of the out

of tolerance conditions could have existed at the same time, then the condition was

not bounded by the analysis supporting OL #1114. Therefore, this condition should

have been reported as a condition that was outside the design basis of the plant per

10 CFR 50.73(a)(2)(ii).

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Attachment to

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ULNRC 3612

July 25,1997

Page 4

The cause of the violation was the failure to adequataly consider all reporting

l requirements and their applicability to the circumstances related to surveillance

testing of MSSVs during Refuel 7.

Corrective Steps Taken and Results Achieved:

A Licensee Event Report will be submitted reporting the as.found condition of the

MSSVs in accordance with 10 CFR 50.73(a)(2)(li).

Corrective Stens to Avold Further Violations:

This event will be reviewed specifically with personnel responsible for making and

approving reportability determinations.

On October 3,1996, OL #1114 was denied by the NRC. Subsequently, Union

Electric contracted with Westinghouse to supply the analysis for a new Operating

License amendment. The Westinghouse analysis will utilize the LOFTRAN code.

The analysis provided with OL #1114 was developed by Union Electric using the

RETRAN code. Use of the LOFTRAN code is expected to expedite the NRC review

process. Union Electric is pursuing a submittal schedule that will support approval

of the Operating License amendment by Refuel 9, targetod for April,1998.

This Operating License amendment will provida Technical Specification acceptance

criteria that are consistent with the operational characteristics of the MSSVs and

current inservice Testing Program performance criteria.

Date when Full Compliance will be Achieved:

Full compliance will be achieved upon approval of the Operating License

amendment.

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Attachment to

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ULNRC 3612

July 25,1997

Page5

11. Statement of Vlotation

During an NRC inspection conducted on February 1014 and 24 28,1997, two

violations of NRC requirements were identified, in accordance with the " General

Statement of Policy and Procedure for NRC Enforcement Actions," NUREO 1600,

the violations are listed below:

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10 CFR 50.59(b)(2) states, in pan, that the licensee shall submit, as specified in

10 CFR 50.4, a report containing a brief descdption of any changes, tests, and

experiments, including a summary of the safety evaluation of each.

Contrary to the above, during the period of June 14,1988, to February 28,1997, a

brief descdption of changes due to temporary modifications (e.g., TM 95-M002) and

the associated safety evaluation summaries were not reported to the NRC.

This is a Severity Level IV violation (Supplement 1).

Reason for the Violation

Procedure APA ZZ-00140, Safety, Environmental and Other Licensing Evaluations

did not require summaries of safety evaluations performed for temporary

modifications to be included in the repon required by 10 CFR 50.59(b)(2).

Temporary modifications had been excluded from this report since they were

typically installed for a limited duration.

Corrective Steps Taken and Results Achieved:

The praunce of not reporting safety evaluation summaries for temporary

modifications began with the reporting period commencing May 1,1987. Letter

ULNRC 1524 dated June 5,1987 represents the last report to include temporary

modification safety evaluation summe. ries prior to the change in reporting criteria.

As a result of thc concem identified during NitC Inspection No. 50 483/97005 safety

evaluation summaries for temporary modifications will be included in future reports.

ULNRC-3580 dated May 9,1997 for the period of May 11,1995 through

December 31,1996 transmitted the most recent summary report as required by

10 CFR 50.59(b)(2) and includes safety evaluation summaries for temporary

modifications for the period.

An ovsluation sas madh 6f tlie reporting periods from May 1,1987 through

May 10,1995 to determine whether any additional actions were warranted. A

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Attachment to

ULNRC 3612

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July 25,1997

Page 6

determination was made not to provide summaries of temporary modification nafety

evaluations for this period for the following reasons:

. Temporary modificatloas were short lived and have been removed from the

plant or were incorporated in pennanent design changes which were reported.

• There is no irnpact on the current design and license basis for Callawny Plant.

Corrective Stens to Avoid Further Violation.11

Procedure APA ZZ-00140 guidance for reporting per 10 CFR 50.59(b)(2) has been

corrected to include temporary modification summaries in future reports.

Ibte when Full Compliance will be Achieved:

Full compliance was achieved on June 24,1997

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