IR 05000483/1997011

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-483/97-11 on 971224

ML20217Q872
Person / Time
Site:	Callaway
Issue date:	04/08/1998
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Randolph G UNION ELECTRIC CO.
References
50-483-97-11, EA-97-469, NUDOCS 9804130212
Preceding documents:	ML20249C275 (19 June 1998)
Download: ML20217Q872 (5)

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April 8,1998 EA 97-469 Garry L. Randolph, Vice President and Chief Nuclear Officer Union Electric Company

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P.O. Box 620 Fulton, Missouri 65251 SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-483/97-11 AND NOTICE OF VIOLATION

Dear Mr. Randolph:

Thank you for your letter of February 6,1998, in response to our December 24,1997, letter and i Notice of Violation conceming the findings of the Maintenance Rule baseline inspection at the Callaway Plant. We have reviewed your reply, and require additional information for each of the three violations.

Violation A ,

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I In regard to your response to Example 1, additional information regarding the planned change to !

the performance criteria for the containment isolation function is needed in order to evaluate the effectiveness of the corrective actions. Specifically, we request that you provide the definition of

" failure" which is referred to in item 2 of the planned changes to the performance criteria on page 5 of your response. As presently stated, simultaneous failures of both valves in a penetration could be interpreted to mean: both valves of a penetration exceeding their individual-administrative leakage limits; both valves, as well as, eight other valves exceeding their administrative leakage limits; or both valves exceeding 0.4 l . Please explain simultaneous failure of both valves in a penetration with regard to test program leakage.

In regard to your response to Example 2, you did not agree that a violation had occyrred in your monitoring of feedwater heaters. We agree with your position that the feedwater heaters are not classified as run-to-failure and are presently being monitored at the plant level. We also recognize that a design change to replace the feedwater heater tube bundles with an improved

' design is in progress. However, additional information is needed before we can further consider you denial of this portion of Violation A, Example 2. Specifically, have there been, or could there be, occasions where tube failures have been repaired without incurring a power loss?. In --

addition, how will your plant-level performance criteria recognize and capture degraded heater performance using unplanned capacity loss when there is an existing reduced power level for core axial offset, or any other reason?

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9004130212 980408 PDR s. ' ADOCK 05000483 G PDR Y- x .

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r Union Electric Company -5-E-Mail report to T. Frye (TJF)

E-Mail report to D. Lange (DJL)

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

E-Mail report to Document Control Desk (DOCDESK)

E-Mail report to Richard Correia (RPC)

E-Mail report to Frank Talbot (FXT)

bec to DCD (IE01)

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bec distrib. 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)

C. Goines (RIV Al 98-0058)

C. Gordon (RIV Al 98-0058)

OE File .

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D DOCUMENT NAME: r:\_cw\cw711ak. jew *Previously concurred To receive copy of document, indicate in box:"C" = Copy without enclosures "E" = Copy with enclosures "N" a No qepy RIV: SRI:MB * C:MB* C NRR* C:PBB* D:DRLf JEWhittemore/imb DAPowers RCorreia WDJohnson ATHd4eh lli 02/26/98 02/26/98 02/27/98 03/31/98 04/7/98

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OFFICIAL RECORD COPY

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Union Electric Company -2-In regar'dto your response to Example 2 that addressed heater drain pump seals, the planned

- corrective action to evaluate the heater drain pump seals for monitoring in a run-to-failure mode is satisfactory. We will verify the implementation of your planned corrective action during future inspection activities at the Callaway site.

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!/ Violation B l:

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In regard to your response to Violation B, we note that you intend to review all suggestion occurrence solution reports that have been initiated since July 10,1993, in order to verify that all'

structures, systems, or components (SSCs) within the program secpe have been properly L evaluated and classified as Category (a)(1) or.(a)(2). This corrective action is satisfactory and l will be reviewed during a future inspection. However, we request clarification on your completed -

, corrective action. In particular, the team noted in the inspection report that a failure would not be i classified as a functional failure on the basis that an equipment operator was available at the -

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L valve to open it and that personnel errors during the performance of maintenance activities were not considered for functional failure evaluations. As a result of your response to Violation C, e please discuss your current position relative to taking credit for operator intervention for -

functional failure evaluation. Also, please describe how your program evaluates personnel

errors in determining whether functional failures have occurred.

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Violation _Q

! . In regard to your response that provides train unavailability criteria for monitoring the reactor.

protection trip system, we find the planned corrective action to be acceptable. We will review the implementation of the corrective action during a future inspection.

Your planned program change concoming the evaluation of unavailability does not take into consideration the unavailability of risk-significant SSCs during surveillance if there is a minimal restoration time for those SSCs and is, therefore, not acceptable because this action would not necessarily preclude future violations. Your reference to INPO performance indicator reporting guidelines for taking credit for operator action to quickly restore SSCs undergoing surveillance is not endorsed by NRC. NUMARC 93-01 guidance, which is endorsed by NRC, is clear with i respect to availability determination in that SSCs, which respond automatically, must be subject to direct control or function automatically without human action to be considered available. Your.

approach does not take into consideration that maintenance / surveillance time be counted as

- unavailable for the purpose of determining the effectiveness of the maintenance and

. surveillance performed on SSCs.' Furthermore, your stated tr.tention to take exception to the guidance of NUMARC 93-01 for availability determination, by allowing a " minimal * intervention

- time, was not accompanied by an acceptable alternative for NRC review, L ~

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Union Electric Company -3- g

- You are required to respond to our concems relating to your response to Violations A, B,'and C within 30 days of receipt of this letter. If you have questions about this letter, please contact Dr. Dale A. Powers at 817/860-8195. For your completed and planned corrective actions that are considered to be appropriate, we will review the implementation of those corrective actions '

. during a future inspection to determine that full compliance has been achieved and will be maintained.

As discussed in our letter of December 24,1997, we wish to hold a management meeting with

. Union Electric to discuss your plans to improve your Maintenance Rule program. At this meeting, we want to include, as agenda items, the results of your continuing corrective action -

~" evaluations that were targeted for completion by April 30,1998, and your response'to the

- questions in this letter. As discussed between Messrs. Mark Reid.meyer and Dale Powers on

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February 17,1998, we understand that your proposed time for this meeting is near the end of May _1998. Dr. Powers will be contacting your representative to obtain details for the meeting and to establish the meeting date.

Sincerely,

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ArthurT. H eli lli,' Director Division of ctor Safety -

Docket No.: 50 483 i

License No.: NPF-30 cc:-

Professional Nuclear Consulting, Inc.

19041 Raines Drive Derwood, Maryland 20855-

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'.. Gerald Chamoff, Esq.

Thomas A. Baxter, Esq.

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

Washington, D.C.- 20037 H. D. Bono, Supervising Engineer Quality Assurance Regulatory Support Union Electric Company.~

P.O. Box 620 Fulton, Missouri 65251

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Union Electric Company -4-Manager- Electric Department Missouri Public Service Commission 301 W. High .

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P.O.' Box 360 Jefferson City, Missouri 65102 Ronald A. Kucera, Deputy Director Department of Natural Resources P.O. Box 176 ,

i- , Jefferson City, Missouri 65102 Otto L. Maynard, President and -

Chief Executwe Officer Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, Kansas 66839

- ..' Dan I. Bolef, President

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= Kay Drey, Representative Board of Directors Coalition .

l- for the Environment 6267 Delmar Boulevard University City, Missouri 63130 l

Lee Fritz, Presiding Commissioner

! Callaway County Court House 10 East Fifth Street Fulton, Missouri 65151 Alan C. Passwater, Manager

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Licensing and Fuels

AmorenUE *

i One Ameren Plaza q

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1901 Chouteau Avenue j P.O. Box 66149 '

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St. LoiJis, Missouri 63166-6149_

J. V. Laux, Manager Quality Assurance a Union Electric Company. 1 P.O. Box 620 I

Fulton, Missouri 65251 I

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