ML053570261

Reply to Inspection No 50-483/05-004

ML053570261
Person / Time
Site:	Callaway
Issue date:	12/14/2005
From:	Keith Young AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IR-05-004, ULNRC05240
Download: ML053570261 (6)

Text

AmerenUE PO Box 620 Callaway Plant Fulton, MIO 65251 December 14, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC05240 w Amerel Ladies and Gentlemen:

REPLY TO INSPECTION REPORT NO. 50-483/2005-004 UNION ELECTRIC CO.

This responds to Mr. William B. Jones letter dated November 5, 2005, which transmitted Inspection Report 50-483/2005-004. Following discussions with Mr.

Jones the week of December 1, an extension was requested to provide clarification to the analysis of one finding and one apparent violation. These clarifications do not contest the violations or their significance. Our response to the report is presented in the attachment.

None of the material in the response is considered proprietary by Union Electric.

This letter does not contain new commitments.

If you have any questions regarding this response, or if additional information is required, please let me know.

Sincerely, thDoung Manager, Regulatory Affairs KDY/MAR/slk Attachment 1: Response a subsidiary of Ameren Corporation

ULNRC05240 December 14, 2005 Page 2 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360

7.

ULNRCO524O Enclosure Page I of 4 Following are comments related to the 2005 third quarter integrated inspection of Callaway Plant - Report 50-483/2005-004.

Statement of Finding:

50-483/2005004-02 NCV, Misalignment of the TDAFP due to Personnel Error (Section 1R15):

Green. A self-revealing noncited violation of Technical Specification 5.4.1 .a, "Procedures," was identified after AmerenUE failed to properly align the turbine driven auxiliary feedwater pump mechanical overspeed trip mechanism after surveillance testing. The trip mechanism was misaligned from August 1 - 18, 2005. The misaligned trip mechanism increased the probability the turbine would trip if the pump would have been required to respond to an event. This issue was entered into the corrective action program as Callaway Action Request 200505801. This finding, which involved the failure of an operator to follow procedure, was associated with the crosscutting area of human performance.

This finding is greater than minor because the degraded trip mechanism affected the reactor mitigating systems cornerstone and the equipment performance attribute to ensure availability of systems that respond to prevent core damage.

This finding is only of very low safety significance because the condition was not a design or qualification deficiency confirmed to result in loss of function per Generic Letter 91-18; did not result in an actual loss of safety function of a system; did not increase the likelihood of a fire; and did not screen as potentially risk significant due to a seismic, flooding, or severe weather initiating event (Section IR15).

Response to Finding:

1. NRC Manual Chapter 0612, dated 1/14/2004, defines "licensee-identified" findings as "thosefindings identified through a licenseeprogram orprocess that are specifically intended to identify the problem. " "Self Revealing" findings are defined as "thosefindings that reveal themselves to either the NRC or licensee through a change inprocess, capability orfunctionality of equipment, orprograms through routine operation" This finding is better characterized as "licensee identified" vice "self-revealing". The responsibilities of the System Engineer include monitoring the system's condition to ensure its operational readiness. The condition of the trip mechanism was identified by the System Engineer while performing a walkdown of the Turbine Driven Auxiliary Feedwater Pump (TDAFP). The discovery method is consistent with the definition of a "licensee-identified" finding. It was not detected as a result of an operational event such as a spurious trip of the pump or plant alarm. The action on the part of the system

r ULNRC05240 Enclosure Page 2 of 4 engineer required critical thinking skills to discern the condition given the ambiguity of the procedural guidance.

2. The description of the event contained in report section lRl5b.1., states in part "The trip linkage misalignmentresulted in increasedprobability of an inadvertent TDAFP trip duringaccident conditions."

Following inspection and testing performed on the TDAFP after the linkage misalignment was identified, no limiting upset conditions were identified that would cause the linkage to change state unexpectedly. For the period the trip linkage was misaligned, the TDAFP remained capable of performing its safety function. No increase in the probability of an inadvertent TDAFP trip during accident conditions was identified.

Statement of Finding:

50-483/2005004-01 AV, Failure to Maintain Cold Overpressure Mitigation Measures as Required by TSs (Section 1R14):

TBD. A self-revealing apparent violation of Technical Specification 5.4.1.a, "Procedures," was identified after an operator error resulted in the failure to maintain the required cold overpressure mitigation system configuration while the reactor was in Mode 5. Technical Specification 3.4.12, "Cold Overpressure Mitigation System," prohibited more than one centrifugal charging pump from being capable of injecting into the reactor vessel. An operator inadvertently defeated administrative controls and enabled a centrifugal charging pump during a diesel generator and sequencer test restoration lineup on September 20, 2005.

Contributing causes to the event were inadequate procedural controls and pie-job brief. This issue was entered into the corrective action program as Callaway Action Request 200507092.-This finding, which involved the failure of an operator to follow procedure, was associated with the crosscutting area of human performance.

This finding is greater than minor because, if left uncorrected, it would have become a more significant safety concern involving the integrity of the reactor coolant system boundary (barrier integrity cornerstone). The finding was evaluated using Manual Chapter 0609, "Significance Determination Process,"

Appendix G, Shutdown Operations Significance, Checklist 2. Although the performance deficiency did not result in a Technical Specification violation, discussions with the Office of Nuclear Reactor Regulation identified a Phase 3 analysis should be performed and is currently under evaluation (Section IR14).

t ULNRC05240 Enclosure Page 3 of 4 Response to Finding:

1. NRC Manual Chapter 0612, dated 1/14/2004, defines "licensee-identified" findings as "those findings identified through a licensee program orprocess that are specifically intended to identify the problem." "Self Revealing" findings are defined as "thosefindings that reveal themselves to either the NRC or licensee through a change in process, capabilityorfitnctionality of equipment, orprogramisthrough routine operation" This finding is more appropriately classified as "licensee identified" vice "self-revealing". Section lR14b. of the inspection report stated in part:

"The operator ignoredthe administrative controls and unlocked and opened the dischargevalve. The auxiliary operatorreturnedthe placardand lock to the test director. The test director recognizedthe inappropriateconfiguration and immediately had the improper alignment corrected "

The test director's application of critical thinking skills led to recognition of the incorrect lineup, given the activities in progress at the time. This discovery method is consistent with the definition of a "licensee-identified" finding.

Identification of the condition did not result from an event such as a plant alarm, equipment actuation or change in plant conditions.

2. The description of the finding indicated that "inadequateproceduralcontrols andpre-job brief' were contributing causes to the event. The root cause analysis, which was completed after the end of the inspection period, did not identify an issue with the procedure quality or pre-job brief. An adequate procedure was established, however, it was not followed.

3. As noted in the finding, "A'lthough the performance deficiency did not result in a Technical Specification violation, discussionswith the Office of Nuclear Reactor Regulation identified a Phase 3 analysis should be performed and is currently under evaluation".

The error in question did result in the failure to meet the Limiting Condition for Operation (LCO) for Technical Specification 3.4.12, "Cold Overpressure Mitigation System" (COMS). The required action for not meeting the LCO is to "Initiate action to verify a maximum of one centrifugalchargingpump is capable of injecting into the RCS" with a completion time of "Immediately."

Because the required action was completed in the specified completion time, compliance with the COMS Technical Specification (TS) was maintained. As noted in the Enforcement Policy, a violation of the Technical Specification does not occur unless the required action and completion time cannot be met.

ULNRC05240 Enclosure Page 4 of 4 NRC Manual Chapter 0609, Significance Determinations Process, Appendix G Attachment 1, "Shutdown Operations, Significance Determination Process, Phase 1 Operational Checklist for Both PWRs and BWRs" requires a phase 2 or 3 analysis for non-compliance with COMS Technical Specifications.

However, since there was no COMS Technical Specification non-compliance, the phase 3 analysis does not appear to be required.