ML20065D385

Comment on Draft NUREG-1022, Event Reporting Systems, 10CFR50.72 & 50.73

ML20065D385
Person / Time
Site:	Callaway
Issue date:	03/22/1994
From:	Passwater A UNION ELECTRIC CO.
To:	Meyer D NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-59FR5614, RTR-NUREG-1022 59FR5614-00002, 59FR5614-2, NUDOCS 9404070068
Download: ML20065D385 (6)

Text

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canday Piant: , '

..-S- hst 0 lice 84 t?o .,h)h15,gn ration. ussowics251 jy 5(p I LPR ~4 nj D/?/7f UNION.

Etucrusc g March 22,1994 U.S. Nuclear Regulatory Commission Attn: Mr. David L. Meyer Chief, Regulatory Publications Branch Division of Freedom of Information and Publication Services Office of Administration

-Washington, D.C 20555 '!

ULNRC-02979 {

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Dear Mr. Meyer:

DOCKET NUMBER 50-483 CALLAWAY PLANT >

COMMENTS ON DRAFT NUREG-1022 '

" EVENT REPORTING SYSTEMS,10CFR50.72 AND 50.73" i

Union Electric Company submits the attached comments to the subject draft .

NUREG-1022. The comments are marked on the attached applicable pages of the draft - -!

NUREG. A summary of the comments is also provided on a separate attachmenti >

- Sincerely,:

/ p f e

A. C. Passwater-Manager, Licensing ~ & Fuels.

ACIYTPS/JGB/lrj -

1 -

Attachments

-- cci distribution attached l 9404070068 940322f PDR NUREG-1022 C PDRj i

. , , ________.________.______________________---___J

.o.

'l cc distribution for ULNRC-02979 T. A. Baxter Shaw, Pittman, Potts & Trowbridge 2300 North Street, N.W.

Washington, D.C 20037 Dr. J. O. Cermak CFA, Inc.

18225-A Flower Hill Way Gaithersburg, MD 20879-5334 l Mr. M. J. Farber -

Chief, Reactor Projects Section'III A l U.S. Nuclear Regulatory Commission Region ll!

801 Warrenville Road l Lisle, IL 60532-4351 l

' Bruce Bartlett Callaway Resident Office U.S. Nuclear Regulatory Commission l

L. R. Wharton (2 copies)

Licensing Project Manager ,

Office of Nuclear Reactor Regulation .)

U.S. Nuclear Regulatory Commission j Mail Stop 13-E Washington, D.C 20555 Manager, Electric Department

- Missouri Public Service Commission P. O. Box 360 Jefferson City, MO 65102 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Mail Station PI-137 Washington, D.C. 20555 Mr. Art Mah Wolf Creek Nuclear Operating Corporation P. O. Box 411 Burlington, KS 66839 i

____________-_-______-___________-_______--________O

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UNION ELECTRIC, CALLAWAY PLANT ATTACIIMENT TO ULNRC-02979 l SUMM ARY OF DRAFT NUREG-1022 COMM ENTS SPECIFIC CO51NIENTS:

l 2.7, page 13 Disagree that a single component failure discovered durmg  ;

paragraph 3 surveillance testing is reportable if the failure mechanism could l reasonably be expected to occur in one or more redundant components j and thereby prevent fulfillment of the system's safety functio _n.

Merely predicting failure is not firm evidence that the redundant components could have failed. Surveillance testing of the redundant l components would uncover the failure mechanism.

J 3.2.1, page 24 The definition of initiation of any nuclear plant shutdown is not clear ~

c for a T/S required shutdown begun in Modes 3 or 4 with completion in Modes 4 or 5 The temperature / pressure reductions of these modes l

occur after the plant is subcritical. Suggest a Mode 3 or 4 initiation of a shutdown be triggered on the deliberate' reduction of RCS j temperature with the intent of reducing the plant mode. >

page 115 The draft NUREG currently requires the inclusion of all corrective actions that are tracked by the licensee's internal corrective action system. Suggest this requirement be revised to list only the major, directly related corrective actions for the event. 3 page 115 Delete the requirement to include a statement regarding the performance and results of a IIPES evaluation. It appears this added requirement was made for the sole purpose of increasing reporting - t requirements without changing the rule.- ,

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staff,_thare was no need to report under 10 CFR 50.72 and 50.73 because the NRC was aware of the situation. Some licensee personnel have also expressed a simila. understanding for cases in which the NRC staff identified a reportable event or condition to the licensee via inspection or assessment activities.

Sue's means of reporting do not satisfy 10 CFR 50.72 and 50.73. The rcquirement is-to report to the ENS and LER systems events or conditions meeting the criteria stated in the rules.

2.7 Hultiple Component Failures There have been cases in which licensees have not reported multiple, sequentially discovered failures of systems or components occurring during planned testing. This situation was identified as a generic concern on April 13, 1985, in NRC Information Notice (IN) 85-27, " Notifications to the NRC Operations Center and Reporting Events in Licensee Event Reports," regarding the reportability of multiple events in accordance with 9650.72(b)(2)(iii) and 50.73(a)(2)(v) (event or condition that alone could prevent fulfillment of a safety function). [This reporting criterion is discussed in Section 3.3.3 of this report.]

IN 85-27 described multiple failures of a reactor protection system during I control rod insertion testing of a reactor at power. One of the control rods i stuck. Subsequent testing identified 3 additional rods that would not insert l (scram) into the core and 11 control rods that had an initial hesitation l before insertion. The licensee considered each failure as'a single random failure; thus each was determined not to be reportable. Subsequent assessments indicated that the instrument air system, which was to be oil-free, was contaminated with oil that was causing the scram solenoid valves to fail. While the failure of a single rod to insert may not cause a reasonable doubt that other rods would fail to. insert, the failure of more than one rod does cause a reasonable doubt that other rods could be affected, thus  !

affecting the safety function of the rods.

V A single component failure in a safety _ system is re)ortable if it is determined that the failure mechanism (could reasona)1yJ1 expected toMinj

• one or more redundant compone_nts and thereby event fulf 1 ment of thef ,

s tem's safejt function j n addition, as indica ed n IN 85-27, multiple l failures of redQmiant components of a safety system are. sufficient reason to ,

expect that the failure mechanism, even though not known, could prevent'the fulfillment of the safety function.

Relief Valve Testina When performing periodic surveillance tests of safety or relief valves it is 4 not uncommon to find more than one valve to be lifting outside of the TS-allowed tolerance band, which is typically plus.or minus 1 percent.

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usinos Second Draft, 13 NUREG-1022, Rev. 1

. . - - . = -. -. .

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3.2.1 Plant Shutdown Required by Technical Specifications 550.72(b)(1)(1)(A) 550.73(a)(2)(1)(A) )

Licensees shall report: "The Licensees shall submit a Licensee initiation of any nuclear plant Event Report on: "The completion of shutdown required by the plant's any nuclear plant-shutdown required Technical Specifications." by the plant's Technical Specifications."

If not reported as an emergency under 650.72(a), licensees are required to- ,

report the initiation of a plant shutdown required by TS to the NRC via the ENS as soon as practical and in all . cases within 1-hour of the initiation of a plant shutdown required by TS to the NRC via the ENS. If the shutdown is completed, licensees are required to submit an LER within 30 days.

Discussion This 50.72 reporting requirement is intended to capture those events for which TS require the initiation of reactor shutdown to provide the NRC with early warning of safety significant conditions serious enough-to warrant that the  ;

plant be shut down.

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For 950.72 reporting purposes, the phrase " initiation of any nuclear plant shutdown" includes the performance of any action to start reducing reactor g r to achieve a nuclear plant shutdown required by TS. s AWeducti6Fiiiiiioweri forTiosothd[p0Fp5isiV6 AWE 6 sit'itstWB61fMfG6i~3fEi  !

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1s1not reportableiunder hisTcriterionMTh'is" shutdownfrequired;by,TSf lyffor;the;purp_osenofg@epaining;a;componeng '

includesyreducing power on For 550.73 reporting purposes, the phrase " completion of any nuclear plant h' shutdown" is defined as the point in time during a TS required shutdown when the plant enters the first shutdown condition required by a limiting condition- I

/ for operations (LCO) e.g., hot standby (Mode 3] for PWRs with the standard \ l

( technical specifications (STS). For example, if at 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> a plant enters ') ,

7 an LC0 action statement that states, " restore the inoperable channel to-operable status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least Hot Standby within the next - I ,

,\ 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />." the plant must be shut down (i.e., at least in hot standby) by 2000~

hours. An LER is required if the inoperable channel is not.' returned to

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\-- operable status by 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> and the plant. enters hot' standby.

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An LER is not required if a failure was or could have been be corrected before a plant has completed shutdown (as discussed above) and no other criteria in 50.73 apply. This includes a situation where the plant is shutdown, the ,

problem is fixed, and the plant is restarted before the shutdown was required by TS.

Second Oraft, I 24 NUREG-1022, Rev. 1 C

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.J Reasonable and credible alternative conditions may include normal plant operating conditions, potential accident conditions, or additional component failures, depending on the event. Normal alternative operating conditions and off-normal conditions expected to occur during the life of the plant should be considered. The intent of this section is to obtain the result of the considerations that are typical in the conduct of routine operations, such as event reviews, not to require extraordinary studies.

(4) Corrective Actions 950.73(b)(4)

The LER shall contain: "A description of any corrective actions planned as a result of the event, including those to reduce the probability of similar events occurring in the future."

Di sessifal l Tc6rfecti ve J acti 6n s16FTinhi6EsMstTIthitWsihl tidIfr5miithiisseht k r The narranve;should; includes thetcorrectiveTections2that%emtracked:byethe7 l i censee! s sin ternals c'oisrectiveiactichisiiteehgncludes.whetut.he# corrective

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^^ actionnthatrwilh reducektheTpF66abilitynffabialliffevintiokusingsin?ths mQaM futdrek FoMexam;ilek.*the pumpfwakrepaired?indisiddiskussibsf6fytheyeveritNii At i ncl uded N nsthe t tra'i n i ng ?1 ecture si"MAno theg6xa aryMilcastion

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eventi wastinitiated."

In addition to a description of any corrective actions planned as a result of the event, describe corrective actions on similar or related components that were done, or are planned, as a direct result of the event. For example, if pump 1 failed during an event and required corrective mainte At g ejand that /

same maintenance also was done on pump 2, so state.

I ff a~ humih~p erfann anc e? sini10itidd7ssiTiff6Wisd F"i KEliids'iFit'ifiiii6t' tiiii th a v al u ation: wa s "pe r formed i and h i ts kre sul ts su st; corrective r acti on st adopted i by ,

manag ementw incl ud i ng (org an i za ti onalie rs peisonnel s chiniesysifs theicorrective a cti on !t'aken (i ncl udes; pers onne%d i s ci pij n aryla cti onshdos notfrefirf totspeci fi c individualsiby; names If" inh 6dspidde6tHontFactoE"orioninl tahtTsisiWF6EihtIW tBWsWisiths?ivent?

solstateMNote(any;pertinentfindustryjupportedistudiesi^~~~~ ~ ~ t l

If a study was conducted, and results are not available within the 30-day j period, report the results of the study in a revised LER if they result in substantial changes in the corrective action planned. (See Section 5.1.6 for l further discussion of submitting revised LERs.)

i Second Draft, I 115 NUREG-1022, Rev. 1

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