ML20127K052

Forwards Response to Youngblood 850313 Request for Addl Info Following Preliminary Staff Review of Responses to Generic Ltr 83-28.Items Include Reactor Trip Sys Components & Nuclear Util Task Action Committee Program

ML20127K052
Person / Time
Site:	Callaway
Issue date:	05/17/1985
From:	Schnell D UNION ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
GL-83-28, ULNRC-1098, NUDOCS 8505220023
Download: ML20127K052 (7)

Text

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May 17,'1985 1901 Grotiot Street,St. Louis Donoid F.Schnell Vice President Mr. Harold:R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear-Mr. Denton:

ULNRC-1098 DOCKET NUMBER 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT, UNIT 1 GENERIC LETTER 83-28

References:

1.

Youngblood to Schnell letter dated 3-13-85, Request for Additional Information Following Preliminary Staff Review of Licensee Responses to Generic Letter 83-28 2.

ULNRC-1002 dated 12-27-84, same subject 3.

ULNRC-829 dated 5-21-84, same subject 4.

ULNRC-763 dated 3-12-84, same subject 5.

ULNRC-687 dated 11-18-83, same subject Reference one transmitted several NRC requests for additional information regarding Union Electric Company's implementation of Staff positions in Generic Letter 83-28.

The attachment provides the requested.information.

Should you have further questions after reviewing the attachment, please contact us.

Very truly yours, 7

es-(( Donald F. Schnell GGY/lw

Attachment:

Responses to NRC Information Requests 8

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8505220023 850517 PDR ADOCK 05000483 l

P PDR Moiling Address: P.O Box 149, St. Louis MO 63166

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-Robert J. Schukai, of~1 awful age,.being first duly sworn

- upon-oath says.that he is General l Manager-Engineering (Nuclear) 1 for Union Electric Company;'that.he has read.the foregoing document and

- knows the-content thereof;-.that he has executed the same for and'on

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behalf (of said company with full power and authority to do so;.and that"theffacts therein stated are.true and correct to the best of his-knowledge, information and belief.

By Robe

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ukai Gene ager-Engineering Nuclear SUBSCRIBED and sworn to before me this 17 day of $"[

, 1985

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Nicholas A. Petrick 4

Executive Director

'SNUPPS-

-5 Choke Cherry' Road

-Rockville, Maryland -20850 John'.H. Neisler-Callaway Resident Office.

U.S.' Nuclear Regulatory Commission'

'RR$1 Steedman, Missouri '65077 William Forney

- Division of Projects and Resident Programs,-Chief, Section lA U.S. Nuclear Regulatory Commission

-Region III.-

f 799 Roosevelt Road Glen Ellyn,, Illinois 60137

-Bruce Little Callaway Resident Office-U.S. Nuclear Regulatory Commission RR$1' Steedman, Missouri 65077-Tom-Alexion JOffice of, Nuclear Reactor. Regulation U.S. Nuclear Regulatory. Co:nmission Mail.Stop P-316 7920 Norfolk Avenue Bethesda, MD-20014 A

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UINRC 1098 1/4 ATTACHMENT t

NRC Request

' Item-2.1 (Part'1)

.The licensee m'ust" supply.a statement confirming that reactor trip system' components were' reviewed and that they are identified as safety-related on documents, procedures,;and information handling systems.

-Union-Electric Response - Item 2.1 (Part 1)

All. components whose functioning is required to trip the reactor

.were reviewed and are identified as safety-related in accordance

with.Callaway-Plant administrative procedures. _The Callaway Q-List, as described.in references 4.and 5, contains these

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icomponents and is controlled by: Administrative Procedure JAPA-ZZ-00430 and Departmental Procedure.WEP-ZZ-00011.

Additionally, these components are classified as safety-related

-on: CHAMPS - (Computerized' History and-Maintenance Planning System)

which.is.used for generation of Work Requests, Surveillances,-and Preventive Maintenance tasking.

Our DS-416 reactor trip breaker maintenance manual, M-766-1175, contains the following caution statement:

'"DS-416 Reactor Trip Circuit Breaker is classified as Class

~1E' equipment and is critical to-reactor-safety.

Therefore,

. personnel performing maintenance;should be aware of the safety significance of this. equipment."

NRC Request - Item 2.1 (Part 2)

The licensee,needs to submit detailed information describing

-their-vendor-interface program'for reactor trip system

. components, including any non-NSSS reactor trip system

. components.~

Information supplied should state how the program assures that vendor technical information is kept. complete,

current-and controlled throughout the life of the plant and.

4 should also indicate.how the program will be implemented at

- Callaway 1.

Union Electric Response - Item 2.1 (Part 2)

The' Westinghouse interface program was described in detail in reference 5.and summarized hereinafter.

This program consists of the controlled distribution of Technical Bulletins by Westinghouse:and implementation, as appropriate, by Union

' Electric.

These Technical Bulletins are transmitted with a receipt acknowledgement form which is signed and returned to

- Westinghouse.

Union Electric reviews each Technical Bulletin for applicability and, if applicable, revises operating and maintenance-procedures as needed.

In addition, Union Electric and Westinghouse have entered into a Service Agreement which controls NSSS vendor activities at Callaway.

All work on NSSS E

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G25C 1098 2/4 components performed by Westinghouse Water Reactors Division is subject lto the. controls of approved QA programs.

Non-NSSS

reactor trip _ system components are covered under the response to Item 2.2.2 below. _.

'NRC Request

-Item'2.2.2 The licensee needs to describe how the recommendations of the.

NUTAC; program will be implemented at Callaway 1.

The staff found

-that'the NUTAC program fails to address the concern about.

establishing-and maintaining an interface between all vendors of safety-related equipment :and the utility.

Accordingly,.the licensee 1will need.to supplement his_ response to address this

-concern.

This additional information should. describe how current procedures will be modified and~new ones initiated to meet each

' element of Item 2.2.2 concern.

Union Electric' Response - Item 2.2.2 1

.The Vendor Equipment Technical'Information Program (VETIP) as defined in the March 1984 NUTAC document is considered a valid response to all concerns presented in Item 2.2.2 of NRC Generic Letter 83-28.

Union Electric.will implement this program as

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described herein.

The VETIPl program addresses vendor interface via the Nuclear

. Plant Reliability Data System (NPRDS) and Significant Event Evaluation and Information Network (SEE-IN).

Union = Electric i

provides equipment failure data to the NPRDS and reviews SEE-IN documents.

In this way industry operating experience is accumulated and disseminated in the most cost-effective uanner.

'The.NPRDS reporting system is in place and being utilized at Callaway' Plant.

The NUTAC recommended enhancements are currently theing. incorporated.into our NPRDS procedures with an. expected completion date of August 1, 1985.

Total. implementation of the program is to be complete by September 1, 1985 per our commitment

.in references 2 and 3.

The SEE-IN review program is in place at Callaway Plant, l

-controlled by Administrative Procedure APA-ZZ-00530 and Quality Standard-QS-21. INPO formally screens nuclear plant events as identified by operating experience entries in Nuclear NETWORK, LER's, monthly operating reports, IE Bulletins and Notices, AEOD

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reports, event-related Generic Letters, NSSS technical bulletins, 4

reports made pursuant to 10CFR21 and 10CFR50.55(e), and significant trends:from INPO's NPRDS and LER data bases. This screening process.identifics significant events.and trends which are then analyzed by INPO for.the purpose of developing remedial actions.

This information is disseminated to the industry via L

lNETWORK in the form of a Significant Event Report (SER).

For P

events requiring utility action, remedial action recommendations are disseminated via Significant Operating Experience Reports (SOER's) which Union Electric evaluates and acts upon, as

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UINRC 1098 yJ,

3/4 Lappropriat2.

Events'thatLaren?t significant but yield valuable operations and maintenance.'informationLare issued in the form of-an Operations and Maintenance Reminder (OEMR).

The SEE-IN program provides copies of draft SER's, SOER's, and O&MR's to the affected vendors for review.

Vendor comments are considered in

preparation of final ~SEE-IN reports.

Once. finalized, the-reports

-are sentito.the utilities...These reports are formally. reviewed

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at' Union Electric by the onsite Independent Safety _ Engineering Group.(ISEG) as; discussed'in.the Callaway FSAR Site Addendum,

, Sections 18.1.7.2 and 18.1.12.2.

Further evidence of Union Electric's adherence to the Staff positions in Item 2.2.2 is seen in the1following Administrative tand Departmental procedures:

(i)- APA-ZZ-00141 controls and documents revisions to approved vendor manuals via vendor manual change notices (VMCN's).

(ii).APA-ZZ-00101 covers the incorporation of references (e.g., vendor technical information) in maintenance and operations procedures.

(iii)

PDP-ZZ-00001 and -00002 implement CHAMPS which is a Lset of computer programs and data-files used to provide information on plant equipment.

It also.

provides tracking, control, and. history of 1mai'ntenance activitics.

PDP-ZZ-00004 and EDP-ZZ-04012 discuas the trending of data taken from-the CHAMPS data base cn'a semi-annual basis.

Equipment with recurring maintenance problems, as evidenced by the number of work requests issued, is evaluated for corrective action.

These programs ensure adequate vendor back-up.

-(iv)

APA-ZZ-00401 contrcls vendor activities at Callaway, including-associated ~QA requirements-(i.e., work performed per approved procedures and in accordance; with an approved QA program).

This program is considered to be a viable approach to vendor.

interface, especially since most vendors don't have departments that analyze operational data nor are vendors always aware of the service conditions and maintenance-history associated with-a given component failure.

Further, technical problems known by vendors typically originate from a utility experiencing a hardware problem.

NRC Request - Item 4.5.3-

'The_ licensee needs to submit a description of the specific implementation plan for Callaway 1 after NRC reviews the WCAP-10271-and Supplement 1.

,a UINFC. ' 098 4/4-Union Electric Responso - Item 4.5.3 NRC completed the review of WCAP-10271 and Supplement 1 on February 21,'1985 (SER issuance date).

The Westinghouse Owners Group is preparing a license' amendment guidance document which.

details.all-requested Technical Specification changes and

. includes.a generic significant hazards evaluation.

This guidance

.docuinent is expected to be issued in June, 1985.

Union Electric intends to submit a Callaway-specific amendment request in July, 1985.

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