ML060830412

IR 05000483-05-005, Union Electric Co., Reply to Notice of Violation

ML060830412
Person / Time
Site:	Callaway
Issue date:	03/14/2006
From:	Keith Young AmerenUE
To:	Document Control Desk, NRC/RGN-III
References
ULNRC05262 IR-05-005
Download: ML060830412 (4)

Text

AL v, AmerenUE P0 Box 620 Callaway Plant Fulton, MO 65251 March 14, 2006 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1-137 Washington, DC 20555-0001 ULNRC05262

'Amer/Et Ladies and Gentlemen:

UE REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 50-483/2005-005 UNION ELECTRIC CO.

Response to finding 2005 005-05 This responds to Mr. William B. Jones letter dated February 14, 2006, which transmitted Inspection Report 50-483/2005-005. We contest Finding 2005005-05, "Failure to Conduct Simulator Testing in Accordance with ANSI/ANS 3.5-1998".

Our response to the finding 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 call me at 573/676-8659 or Michael Evans at 573/676-8258.

Sincerely, KeithD.D ng Manager, Regulatory Affairs Attachment 1: Response I 0(

J' . C--

a subsidiaryolAmeren Corporation

- t ULNRC05262 March 14, 2006 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 O-7D1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360

by. lo ULNRC05262 Attachment Page 1 Contesting of GREEN violation on simulator in NRC report of 14 Feb 2006 Statement of Finding:

50-483/2005005 Simulator Facility Performance Failure to adhere to ANSI/ANS 3.5-1998 Green. The inspectors determined that the failure to adhere to ANSI/ANS 3.5-1998, as endorsed by Regulatory Guide 1.149, "Nuclear Power Plant Simulation Facilities for Use in Operator Training and License Examinations", Revision 3. October 2001, as committed to in the Callaway Plant Simulation certification dated March 13, 2000, was a performance deficiency. Specifically, the simulator performance testing did not meet the standards specified in ANSI/ANS 3.5-1998 in that: (1) all required parameters during the simulator test were not recorded; and (2) simulator to baseline data comparisons were unavailable.

The NRC has determined that traditional enforcement does not apply because the issue did not have any actual safety consequence or potential for affecting the NRC's regulatory function and did not result in any willful violation of NRC requirements or licensee procedures. The performance deficiency is more than minor because it affected the ability of the simulator transient tests to detect fidelity issues with the simulator and affects the Human Performance (Human Error) attributes of the Initiating Events and Mitigating Systems cornerstones.

Response to Finding:

1. ANSI/ANS 3.5-1998, paragraph 4.4.3, "Simulator Performance Testing" states "A recordof the conduct of these tests, and data comparison that the results meet reference unit data, shall be maintained. Simulator performance testing shall be conducted in a fully integratedmode of operation. Simulatorperformance testing comprises operabilityand scenario-basedtesting." Additionally, paragraph 4.4.3.1, "Simulator Operability Testing" states "A recordof this test and its evaluation shall be maintained."

Additionally, paragraph 4.4.3.2, "Simulator Scenario-Based Testing" states "A recordof the conduct of theses tests, typically in theform of a completed scenario or lesson plan checklist, and the evaluation of the test results, shall be maintained."

2. Part 10CFR55.46 paragraph (c)(3)

"A Simulation facility consistingsolely of a plant-referenced simulator must meet the requirementsofparagraph(c)(1) of this section and the criteria in paragraphs(d)(1) and (4) of this sectionfor the Commission to accept the plant-referenced simulatorfor conducting operatingtests"

ULNRC05262 Attachment Page 2

3. Paragraph (d)(1) addresses the required performance testing "Conductperformance testing throughoutthe life of the simulation facility in a manner sufficient to ensure thatparagraphs(2)(2)(iU), as applicable, and (d)(3) of this section are met. The results ofperformance tests must be retainedforfouryearsafter the completion of each performance test or until supercededby updated test results;"

4. Simulator procedure TDP-IS-00002 closely parallels the latest ANSI/ANS-3.5-1998 standard and we presently use hidden text to clearly show the links back to the standard. We do not duplicate the standard details. "It SHALL be demonstrated that the simulator correctly represents the response of the CallawayPlant at three differentpower levels. "

Simulator performance testing results have been recorded and the records have been retained. The performance testing documentation was produced for review by the NRC inspectors during the on-site portion of the inspection. Additional detailed supporting data and individual test results are also available for review. Steady state operations are documented using a combination of tests including: log comparisons, analog monitor tests and a heat balance tests. Although only three different power levels are required to be documented, data has been recorded for many power levels.

All analog points (meters), not just those parameters listed in the standard, have also been recorded. This data collection far exceeds the required testing parameter data collection described in the regulation and the standard. We also obtain plant data from various sources such as: plant procedures, surveillances, plant computer and plant pictures.

As a result of a series of miscommunications between the inspectors and simulator staff, an inadequate understanding of how the required performance tests are conducted and documented allowed for the mischaracterization as a failure to record and compare parameters. Callaway is confident that these misunderstandings will be clarified during the scheduled follow-up discussions the week of 20 March 2006.