ML20195J924
| ML20195J924 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 06/23/1988 |
| From: | Randolph G UNION ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| ULNRC-1791, NUDOCS 8806290284 | |
| Download: ML20195J924 (3) | |
Text
..s N&N ELECTRIC June.'3, 1988 rstlassy Plant ULNRC-1791 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 b
CALLAWAY PLANT FACILITY OPERATING LICENSE NPF30 RESPONSE TO TRANSMITTAL OF PERFORMANCE INDICATOR DATA
Reference:
T. W. Alexion letter to D. F. Schnell, dated April 27, 1988 This letter is a veluntary comment on the recent use of the commercial nuclear power plant performance indicators identified by the NRC Office for Analysis and Evaluation of Operational Data (AEOD). A review of the referenced letter has led to two concerns as to the reliability of the performance indicator data. The first concern deals with the validity of indications which have very small industry averages. Performance indicators for Safety System Actuations and Significant Events describe events that rarely or never occur.
Normally, a plant will have either zero or one safety system actuation during the course of a year. Those plants which do have an actuation will be above the average. even if the actuation is an isolated occurrence and does not denote e trend.
Similar logic can be applied to the Significant E'.ents indl.cator.
The second concern addresses the definition used for Safety System Actuations. Tha referenced letter states:
"Actuations of any of the equipment associated with the specific ECCS or emergency AC power system are considered necessary and sufficient to constitute a data count."
Using this definition, Callaway was attributed with two safety system actostions in the fourth quarter of 1987.
Review of operating data reveals that these were two separate events when NB01, a Class 1E emergency AC power bus, was deenergized. The emergency diesel generator for that bus did not start, as it was removed for maintenance. Since the plant was in Mode 5, Cold Shutdown, only one of the two available Class 1E busses was required by Technical Specificatiote, and the NB01 losses did not require an actuation of the emergency AC diesel generator. The inclusion of safety system actuations in an operating j
mode where these safety systems are not required appears to decrease the validity of this performance indicator.
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n ULNRC-1791 page 2 The numbers used in the referenced' report are in agreement with our records with one exception. The collective radiation exposure for Callaway in 1985 was actually 35.96 Man-Rem, not the 70 Man-Rem listed in Attachment 3 page 131 of the referenced NRC performance indicator letter. This_information was provided in our letter ULNRC-1264 of 2/27/86, on page 2.
Relationrhip Between INP0 and NRC Performance Indicators A comparison between the definitions given in the. referenced latter and those used'by INPO shows that performance indicators _for Automatic Scrams While Critical, Forced Outage Rate, and Collective Radiation Exposure are the same for both organizations.
Performance indicators for Significant Events and Equipment Forced Outages per 1000 Critical Hours, have no corresponding INPO indicator.
For the two remaining indicators, the INPO and NRC definitions disagree. The NRC definition for Safety System Actuations allows the actuation of components (i.e. a valve) associated with the specific safety system to count as a data point even if the system itself did not actuate.
INPO counts only those incidants when an ECCS signal is generated and major equipment within the safety system actuates.
For Safety System Failures the NRC tallys all events that, by themselves, could prevent fulfillment of the safety function of a system. This definition parallels NRC reporting requirements in 10CFR50.72 and 10CFR50.73. The closest INPO ind'cator, Safety System Performance, measures the unavailability of the safety injection, auxiliary feedwater, and emergency AC power systems for PWRs. This monitors the readiness of these safety systems to respond to off-normal events or accidents.
Review of Safety System Failures Each of the safety system fa11 urea were isolated incidents and do not denote an adverse trend.
If you have any comments, please contact Mr. T. P. Sharkey at (314) 676-8336.
Respectfully,
/
G. L. Randolph General Manager, Nuclear Operations TPS/MKD:jlh Attachments cc: distribution attached
~,
e cc distribution for ULNRC-1791 A. Bert Davis, Regional Administrator U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137 T. W. Alexion (2 copies)
Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13-E-21 i,
Washington, D.C.
20555-O. Maynard Licensing Manager Wolf Creek Nuclear Operating Corporaion P.O. Box 411 Burlington, KS 66839 NRC Resident Inspector D. F. Schnell (400)
R. J. Schukai (470)
F. D. Field (480)
A. P. Neuhalfen A. C. Passwater/D. E. Shafer/D. J. Walker (470)
T. P. Sharkey NSRB (S. L. Auston) (470)
H. Wuertenbaecher (100) bec:
N. Date (S. L. Auston) (470)
E.210.01 A160.761 GLR Chrono i
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