ML20151W753
| ML20151W753 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 08/16/1988 |
| From: | Perkins K Office of Nuclear Reactor Regulation |
| To: | Schnell D UNION ELECTRIC CO. |
| References | |
| NUDOCS 8808250119 | |
| Download: ML20151W753 (3) | |
Text
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August 16, 1988 Docket No. 50-483 Mr. Donald F. Schnell Vice President - Nuclear Union Electric Company Post Office Box 149 St. Louis, Missouri 63166
Dear Mr. Schnell:
I am pleased to respond to your June 23, 1988 letter to the U.S. Nuclear Regulatory Comission in which you expressed a number of concerns regarding the NRC's use of certain perfonnance indicators (PI's). The performance indicators to which you refer are six of the seven indicators approved by the Comission.
They are contained in a quarterly report issued by AE0D. We sent you a copy of the PI's applicable to the Callaway facility covering the period from January 1986 to December 19.87 attached to our letter dated April 27, 1988.
Your first concern is related to the validity of some PI's which have very small industry averages. The two PI's you cite are the Safety System Actuations and Significant Events. Your specific cournent is that "...a plant will have either zero or one safety system actuation during the course of a year." This statement is basically true for most of the operating units and is the reason that the industry average of these two particular PI s is quite small. Our purpose in tracking these two performance indicators, as well as the others, is to detect any significant deviction by a plant. While we note that these two indicators have relatively low industry averages, we tocus our attention on individual plant trends. We view any significant deviation by a plant from the low industry average as an indication that a problem may exist which we and the plant management should addrets.
Your second concern is related to our definition of what constitutes a safety system actuation. Your point that it is inappropriate to count an actuation of a safety system not needed when the plant is in cold shutdown (i.e., Mode 5),
appears reasonable. However, our purpose in tracking actuations of safety-related equfAmnt, even when a plant is shut down, is to enable us to determine if there is taulty equipment or inadequate attention to detail by plant operat-ing personnel. Our presumption is that if there are reasons why safety-related systems are being inadvertently actuated when a plant is in a cold shutdown condition, these same reasons could also cause spurious actuations while at power.
The Institute of Nuclear Plant Operations (INPO) definition of Unplanned Safety System Actuations is the same as the NRC definition of Safety System Actuations although the methods of compiling the data are different.
INPO obtcins their inforination directly from the licensees while NRC obtains theirs from the DFoi GGOG250119 000816 PDR ADOCK 05000403 P
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Mr. Donald Schnell Licensee Evaluation Reports (LER's) submitted pursuant to 10 CFR 50.73. Additionally, a difference between INP0 and NRC data for this indicator can arise from INP0 not counting actuations if a facility has operated at less than 25% capacity during the period. The NRC has no such restriction in its definition.
As you point out, the NRC looks at Safety System Failure while INPO evaluates Safety System Performance.
These are different indicators. The NRC indicator is consistent with the reporting requirements in 10 CFR 50.72 and 50.73, as well as the philosophy used in the accident analysis in Chapter 15 of your Final Safety Analysis Report.
If you have comments on the AE0D Perfonnance Indicator Report in the future, please provide them to me, so that I may pass them to AE00.
Sincerely, 4/
Kenneth E. Perkins, Director Project Directorate III-3 Division of Reactor Projects - III, IV, Y and Special Projects cc: See next page DISTRIBUTION a Docket-File ? NRC & Local PDRs PD3 r/f KPerkins GHolahan PKreutzer TAlexion 0GC-0WF EJordan BGrimes ACRS(10)
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o Mr. D. F. Sclinell Callaway Plant Union Electric Company Unit No. 1 CC:
Dr. J. O. Cermcck Mr. Bart D. Withers CFA Inc.
President and Chief 4 Professional Dr., Suite 110 Executive Officer Gaithersburg, MD 20870 Wolf Creek Nuclear Operating Corporation Gerald Charnoff, Esq.
P. O. Box 411 Thomas A. Baxter, Esq.
Burlington, Kansas 66839 Shaw, Pittman, Potts & Trowbridge 2300 N Street, N. W.
Mr. Dan I. Bolof President Washington, D. C.
20037 Kay Drey, Representative Board of Directors Coalition Mr. T. P. Sharkey for the Environment Supervising Engineer, St. Louis Region Site Licensing 6267 Delmar Boulevard Union Electric Company University City, Missouri 63130 Post Office Box 620 Fulton, Missouri 60251 U. S. Nuclear Regulatory Commission Resident Inspectors Office RRf1 Steedman, Missouri 65077 Mr. Alan C. Passwater, Manager Licensing and Fuels Union Electric Company Post Office Box 149 St. Louis. Missouri 63166 Manager - Electric Department Missouri Public Service Conmission 301 W. High Post Office Box 360 Jefferson City, Missouri 65102 Regional Administrator U. S. NRC, Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Mr. Ronald A. Kucera, Deputy Director Department of Natur al Resources P. O. Box 176 Jefferson City, Mitsouri 65102