ML20107K119

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Submits Analysis of LERs at Facility Since Issuance of Ol. Categories Re Security Personnel & Equipment Radiation Monitor Sys,Malicious Mischief,Discretionary Reactor Trips & Rooms Overlooked During Fire Watch Discussed
ML20107K119
Person / Time
Site: Callaway 
Issue date: 08/09/1984
From: Schnell D
UNION ELECTRIC CO.
To: James Keppler
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20107J952 List:
References
FOIA-84-671 ULNRC-904, NUDOCS 8502280148
Download: ML20107K119 (4)


Text

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u UNION ELECTRIC COMPANY 8908 GR Allo? 5THEET st Louis, Missouni

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DO**e k L F A C *e'e t L 6 P O 902 Sep August 9, 1984

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Mr. James G.

Keppler Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 ULNRC-904 i

Dear Mr. Keppler:

L ANALYSIS OF LICENSEE EVENT REPORTS CALLAWAY PLANT DOCKET NUMBER 50-483 You have expressed a concern with the number of Licensee Event _ Reports (LER's) generated at Callaway Plant since the issuance of the operating license.

In response to your concern, Messrs. Warnick and Forney from your staff visited Callaway on July 24 and_25 to discuss the LER's in detail and to observe our operations.

Subsequently, on August 8, 1984, members of my staff and I came to your offices to review these items with you, members of your staff, and NRR representatives.

As I emphasized to you, we also have concerns over the number of LER's experienced to date and have initiated actions to improve this situation.

By way of review, we have currently a total of twenty-three Licensee Event Reports, which may be categorized as follows:

Category 1:

Twelve reports relate to security personnel and equipment and, as we discussed with you, we have l '-

an aggressive corrective action program in progress.

We are working' closely with the supplier of our security system hard-i

[

ware and.other support personnel to improve the reliability and capability of the existing security computer system.

In addition, we intend to replace the present security computers with more powerful machines to provide assurance that the system performs as expected.

We have noted improvement in the relia-bility of the system from the actions already undertaken, and we expect this improvement to continue.

Category 2:

We have experienced five events related to our system of radiation monitors.

Corrective action has been initiated which includes a revised alarm response procedure for the radiation monitoring system and additional training programs l

8502280148 840925 I

PDR FOIA VARRICC84-617 PDR ggg i 31984

y'y m.

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Mr. James G.

Keppler

+Page 2 August 9, 1984 on operation of the radiation monitor console and the relevant Technical Specifications.

In addition, we have initiated design changes to provide for audible alarms and re-flash capability for annunciators associated with the system.

These actions have improved our operations in this area.

We have not experienced a reportable event related to radiation monitors since June 18, the effective date of our corrective action.

Category 3:

We reported one item of malicious mischief which caused loss of power to several radiation monitors and initiation of containment purge and control room vent isolation signals.

Our extensive investigation of this event.and corrective action ~is addressed in our letter to you relative to Licensee Event Report 84-011, ULNRC-890, dated August 9, 1984.

Category 4:

We have reported two events because of discretionary. reactor trips.

These discretionary actions were taken not because unsafe conditions were experienced, but as a precautionary measure by the Reactor Operator because numerous,

simultaneous activities were diverting his attention.

In situations of this type, it is our opinion that an LER should not be required since the operator's action was taken to enhance protection of the plant.

Category 5:

We experienced three non-related events as follows:

one involved a fire watch survey during which'some rooms were overlooked.

This occurred early in our fire watch program and corrective action for this item has been implemented.

Another event dealt with a procedural error which caused a valve

-to be opened out of sequence and resulted in depressurization of the reactor coolant system.

This procedure had been utildzed on at least two previous occasions under different plant configura-

-tions without incident.

However,'the procedure was in error for this particular configuration.

Appropriate corrective action has been implemented for this item.

The third event dealt with a technical specification violation involving the source range flux doubling circuit.

During the system testing sequence,.both trains of the flux. doubling circuit were not always operable although plant operators maintained the plant in a known, safe condition at all times.

The violation occurred primarily because of a misinterpretation.of_a requirement.

In our discussions with you,'we noted that Callaway is the first plant to operate with source range flux doubling circuitry designed to prevent boron dilution, and the first plant with Technical Specification

,G

Mr. James G.

Keppler Page 3 August 9, 1984 requirements governing this circuitry.

We have initiated a request to clarify the Technical Specifications to assure resolution of this problem.

In summary, we believe that we have aggressively pursued. corrective action for the personnel errors, equipment problems and procedural difficulties which initiated the subject Licensee Event Reports.

As an additional action to improve our overall performance, we have initiated a 12-hour, 4-shift rotation for our operating personnel to provide fewer shift

. turnovers and more supervision on watch.

We have also placed our Superintendent-Operations and his assistants on shift to provide more direct management support for plant activities.

We are determined to reduce the number of LER's generated by operation of Callaway Plant and believe that the actions described herein will be effective.

Very truly yours,

/Ab Donald F.

Schnell DFS/bjp cc:

Mr. Harold R. Denton Mr.

J.

Holonich

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cc:

Gerald Charnoft, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M.

Street, N.W.

Washington, D.C.

20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 John H. Neisler Callaway Resiaent Office U.S.

Nuclear Regulatory Commission RR#1 Steecman, Missouri 65077 William Forney [

Division of Projects and Resident Programs, Chief, Section lA U.S.

Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S.

Nuclear Regulatory Commission RR#1 Steedman, Missouri 65077 i

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