ML20199J290
| ML20199J290 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/20/1997 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-97-05, 50-483-97-5, ULNRC-3670, NUDOCS 9711280097 | |
| Download: ML20199J290 (11) | |
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. . o INION Eu{cnue 33 November 20,1997 U. S. Nuclear Regulatory Commission Attn: Documera Control Desk Mail Stop Pl.137 Washington, DC 20555-0001 ULNRC-3670 Gentlemen:
REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/97635 CALLAWAY PLANT This responds to Mr. Merschoff's letter dated October 22,1997, which transmitted a Notice 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.
We concur with the primary conclusions of the Notice of Violation, those being that s/
Formal Safety Evaluations were not performed as required by 10 CFR 50.59, the f[
violations were not indicative of a programmati c concern, and resulted in no acmal safety / '
consequences. We agree that a sound safety evaluation program provides the necessary foundation to ensure the fidelity of the Licensing and Design basis. Changes to the afetyfg evalnation program as well as Callaway staff training have been impiemented to further +
strengthen this foundation.
We are proceeding with the elimination of as many Technical Specification Interpretations as possible. Please note that completion of this efrort is dependent on implementation of the Callaway Plant Improved Technical Specifications.
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ULNRC-3670 November 20,1997 Page 2 If you have any questions regarding this response, or if additional information is required, please let me know.
Very truly yours, f .
J. .Laux Manager, Quality Assurance JVi/ MAR /tmw
Attachment:
- 1) Response to Violation
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- ULNRC-3670 November 20,1997 Page 3 - :
cc: Mr. Ellis W. Merschof Regional Administrator _ _
U.S, Nuclear Regulatory Com'r.!asion -
RegionIV
_611 Ryan Plaza Drive, Suite 400 Arlington, TX -760118064 Senior Resident Inspector
- Callaway Resident Office- ;
' U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman,MO 65077 Mr. Barry C. Westreich (2 copies) l Acting 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
- JeKerson 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
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I Attachment to .
ULNRC ~.670 ' '
~ November 20,1997
- Page1 ,
i Statesment of Violation During an NRC inspection completed June 24,1997, violations of NRC requirements '
1- mere identified? In accordance with the " General Statement 'of Policy and Procedure for
, NRC Enforcement Actions," NUREG-1600, the violations are listed below:
l 10 CFR 50.59(a)(1) states, in part, that a licensee may make changes in the facility as described in the safety analysis report and changes in procedures as described in the safety
! . analysis without prior Commission approval unless the proposed change involves a change in the technical specifications incorporated _in the license or an unreviewed safety question.
- 10 CFR 50.59(b)(1) states, in part, that the licensee shall maintain records of changes in the facility and of changes in procedures made pursuant to this section to the extent that these 'enanges constitute changes in the facility as described in the safety analysis report or changes in procedures as described in the safety analysis report. These records must ,
include a written safety evaluation which provides the baser for the detei.nination that the change does not involve an unreviewed safety question.
A. The Final Safety Analysis Report (FSAR) for the Callaway Plant states in Section 9.4.7.2.3 that the diesel generator building supply fans automatically start when the room temperature exceeds 90*F and automatically shut'down when ioom temperature falls below 86'F.
, . Contrary to the above, until February 27,1997, Technical Specification Interpretation (TSI) No.18 and Procedure OTN-NE-00002 (and superceded Procchres OTN-NE-0001 A and OTN-NE-0001B) permitted manual, vice automatic, operation of the supply fans by placing them in " pull-to-lock," a condition inconsistent with the description in the FSAR, and the licensee did not have a record of a written safety evaluation which provided the bases for the determination that this change to the facility and procedures as described in the FSAR did not involve an unreviewed safety question. Specifically, TSI No.18 and the procedure permitted placing a supply fan in pull-to-lock "... provided it is still under the total control of the Reactor Operator" and stated that this was based on administrative controls that allow the operator to maintain the room temperature below the FSAR-described limit of 119*F. (01014)
< This is a Severity Level IV violation (Supplement 1).
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' Attachment to ULNRC-3670 .
- November 20,1997 Page 2 i
Reason for the Violation ;
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In 1985, Technical Specification Interpretation (TSI) No.: 18 provided guidans t the ' i
- plant operators that allowed them to place the emergency diesel generator supply fan ,
switches to the pull-to-lock position. The TSI required the licensed operator maintain :
' direct control of the fan and to maintain the room temperature below the 119'F ?
administrative limit, With cooler outside air temperatures, an operating diesel generator room supply f an could cause low temperature alarms in the diesel generator lube oil and thejacket water keep warm support systems. Placing the supply fan in pull-to-lock allowed the keep warm systems to maintain the preferred temperatures.
- A utility engineer did not recognize in 1985 the Final Safety Analysis Report (FSAR)
- Section 9.4.7.2.3 System Operation description required a change to allow pull to-lock ,
operation of the supply fans. The engineer had performed a general engineering 2
- - evaluation that became the basis for TSI No.18, but failed to perform a 10 CFR 50.59 Formal. Safety Evaluation.
' On November 4,1986 a second utility engineer initiated a formal change to the FSAR to only allow pull-to-lock operation of the supply fan if ambient temperature is less than or .
equal to 65 degrees F. The limit was based on a 10 CFR 50.59 Formal Safety Evaluation and calculations supported by the architect / engineer. This change was incorporated into the FSAR by revision OL-4 Mune 1990.
- The first two paragraphs of TSI 18, Rev. 7 provided the following guidance
"Each diesel generator supp'y fan is considered capable of performing its latended safety function (the supply fan is OPERABLE) if the fan is in pull-to lock and provided it is still under the total control of the Reactor i~ Operator. The fan must be operable in all other respects. This is based on administrative controls that allow the operator to maintain the room temperature below its Technical Specification 3.7.12 limit (119'F.). If a supply fan is placed in aull-to-lock, the Reactor Operator must assign the associated BOP room temperature point (GMT0001 or GMT0011) to annunciate on Window 65 F, " Optional Parameter Setpoint'.' at or below 110*F.
t The diesel generators may be considered OPERABLE with their associated
_ ventilation supply fans (CGM 01 A/B) inoperable, as long as the outside ambient temperature is less than or equal to 65'F."
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Attachment to
' -ULNRC-3670 November 20,1997
- Page 3 4
In 1995, procedure OTN-NE-00002 was revised to incorporate the guidance of each of the above TSI 18 paragraphs as Precaution 2.2.7 and a Section 5 Note, respectively. At this time, the potential conflict between the paragraphs was not identified. Note that the 65'F limit stated in the FSAR was accurately reflected by the second paragraph of the TSI and was incorporated in the procedure at the appropriate location.-
In 1996, procedure OTN-NE-00002 was deleted and replaced with train specific procedures OTN-NE-0001 A and OTN NE-0001B No changes were made with respect to the TSI 18 guidance.
Corrective Stens Taken and Results Achieved:
On F4ruary 23,1990 a design modification was completed to re-direct the supply fan discharge. This prevented further low temperature alarms in the keep warm support l- systems.
On February 27,1997 the first paragraph of TSI No.18 was deleted. On February 27, 1997, Precaution 2.2.7 of procedures OTN-NE-0001 A and OTN-NE-0001B was deleted.
7 These changes made TSI 18 and the implementing procedures consistent with the FSAR.
Corrective Stens to Avoid Further Violations:
On May 15,1997, Union Electric submitted the application' for improved Technical Specifications (ITS). Once approved, the ITS will substantially reduce the need for TSIs.
Callaway has also established goals to reduce TSIs to the minimum number possible. All TSIs will be reviewed by February 28,1998. This review will determine what changes are required to the implementing procedures and licensing documents in order to eliminate the respective TSis. Priorities will also be established for deletion of the appropriate TSIs.
Additional enhancements have also been implemented in the 10 CFR 50.59 Formal Safety Evaluation program and are described in the response to Violation 'C'.
8 ULNRC-3578, dated May 15,1997, transmitted Union Electric's Technical Specification Conversion
' Applicatum.
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.9 Attachment to ULNRC-3670
- November 20,1997 Page 4 Date when FuM Compliance wiu be Achieved:
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. TSIs that are not dependent on the ITS approval will be deleted where possible by August 1,1998. TSIs that are dependent on ITS approval will be deleted consistent with the ITS implementation schedule, f
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Attachmat to
' ULNRC-3670. ~
. November 20,1997 Page 5 ,
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'5 Ftatenient of Violation B. The FSAR for the Callaway Plant states in Section 16.9.2.la that the refueling -
machine trip' set points for the load overload trips (wet conditions) and load reduction ' .
trips (wet or dry conditions) be set at 250 pounds above and below the suspended -
loads, respectively.
Contrary to thE above, as of October 20,1995, TSI No. 25 permitted the trip set '
points to be based on the heaviest fuel assembly for the overload trip and the lightest ;
fuel assembly for the load reduction trip, as opposed to the " suspended loads" as described in the FSAR, and the licensee did not have a record of a written safety evaluation which provided the bases for the determination that this change to the facility as described in the FSAR did not involve an unreviewed safetmuestion. TSI .
No. 25 allowed these trips to be set in excess of 250 pounds by approximately 150 pounds. (01024)
This is a Severity Level IV violation (Supplement 1).
Reason for the Violation The load set points stated in the original Callaway Plant Technical Specifications (and the
. . Westinghcuse Standard upon which they were based) did not provide for weight differences between various Fuel Assembly types and insert combinations. An-Interpretation to prevent spurious overload and underlohd trips caused by the known -
weight differences was approved and implemented after confirming that the technical bases for the Technical Specification was not challenged.
This violation occurred because a 10 CFR 50.59 Formal Safety Evaluation was not
. performed.
j Corrective Stens Taken and Results Achieved:
l L The applicable specification was relocated to Chapter 16 of the FSAR in 1995. TSI # 25 L was deleted, an FSAR change notice was initiated to incorporate the TSI and a 10 CFR 50.59 Formal Safety Evaluation has been approved which determined that no Unreviewed Safety Question existed.
Additionally, an upgrade to the refueling machine controls is currently planned for
- Refuel 9 that will permit selection ofload set points specific to the fuel assemblyrmsert combination being moved.
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Attachment to ULNRC-3670 November 20,1997 Page 6 Corrective Stens to Avoid Further Violations:
As noted above, TSI #25 has been deleted.
Additional enhancements have also been implemented in the 10 CFR 50.59 Formal Safety-Evaluation program and are described in the response to Violation 'C',
D3te when Full Comoliance will be Achieved:
The 10 CFR 50.59 Formal Safety Evaluation and FSAR Change Notice were approved by July 17,1997.
Refuel 9 is scheduled to begin April 4,1998. The specified upgrade to the refueling machine will be completed prior to fuel movement.
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f .4 ^' Q httachment to .
. - ULNRC-3670.
November 20,1997 ,
Page 7 _ i f
Statement of Violation l : C. Final Safety Analysis Report, Section 18.2.3, specifies that details regarding the _
design of the post-accident sampling system (PASS) were described in a letter to the -i' NRC, dated February 4,- 1983.L This letter describes the post accident sampling.-
system as a computer controlled automated system.-
Contrary to the above, on November 1,1995, the licensee changed the PASS (RMP 94-2005 A) by changing the computer controlled operation of the sample panel equipment to a manually controlled operation, a change that was inconsistent with the .
- description in the FSAR, and the licensee did not have a record of a written safety evaluation which provided the bases for the determination that this change to the l
facility as described in the FSAR did not involve an unreviewed safety question.
- (01034)
! This is a Severity Level lV violation (Supplement 1). ;
- Reason for the Violation Engineering believed that the previous FSAR Change Notices 94-05 and 94-23, which .
I contained 10 CFR 50.59 Formd Safety Evaluations, adequately addressed the removal of.
the Post Accident Sampling System (PASS) computer. Therefore, the PASS Design Change Package 94-2005 took credit for the previous FSAR Change Notices and did not perform another 10 CFR 50.59 Formal Safety Evaluation.
Corrective Stens Taken and Results Achieved: ;
V FS AR Change Notice 97-20 modified the FSAR description to state that the PASS computer controls have been replaced with manual controls. As part of this Change Notice another 10 CFR 50.59 Formal Safety Evaluation was performed which determined
. that no Unreviewed Safety Question resulted from the removal of the PASS computer.
Corrective Steos to Avoid Further Violations:
Procedure APA-ZZ-00140, " Safety, Environmental and Other Licensing Evaluations" was revised to enhance guidance regarding when a 10 CFR 50.59 Formal Safety Evaluation must be performedc This revision provided detailed guidance requiring a 10 CFR 50.59 Formal Safety Evaluation be performed when changing the facility as described in a document referenced in the FSAR.- Guidance has also been enhanced for determination of when accident consequences or the probabilities of malfunctions of equipment important
- to safety are increased.
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November 20,1997 Page 8 Training was provided to Engineering Departments concerning the changes made to procedure APA-ZZ-00140.
Date when Full Comoliance will be Achieved:
FSAR CN 97-20 was approved on May 1,1997. Full compliance was achieved upon training of Engineering Departmeat personnel on the changes to APA-ZZ-00140. This training was completed on July 2,1997, t
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