ML20202C664
| ML20202C664 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 02/06/1998 |
| From: | Laux J UNION ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-483-97-11, NUDOCS 9802120310 | |
| Download: ML20202C664 (18) | |
Text
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.l Union Electric PO llox 620 C#taway hant Fulton, M0 65251 February 6,1998 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop Pl.137 Washington, DC 20555-0001 ULNRC-3709 Gentlemen:
b REPLY TO NOTICE OF VIOLATION "jfff$fSff INSPECTION REPORT NO.56483/97011 g
CALLAWAY PLANT UNION ELECTRIC COMPANY This responds to Mr. Arthur T. Howell's letter dated December 24,1997, which transmitted three Notices of Violation for events discussed in Inspection Report 50-483/97011, Our response to these violations are presented in the attachment. On January 7,1998, Mr. David N. Graves authorized a response due date of February 6,1998.
None of the material in the response is conside'ed proprietary by Union Electric.
We welcome the opportunity to meet with you in the Region IV ofYice to discuss changes made to our Maintenance Rule Program in response to your inspection. We believe this will be an appropriate forum to discuss Callaway's holistic maintenance program and our plans to more fully integrate these into the Maintenance Rule Program. We believe integration of all maintenance programs is essential to achieve high standards for plant material condition.
If you have any questions regarding this response, or if additional information is required, please let me know.
Sincerely, J. V. Laux Manager, Quality Assurance JVUMAR/tmw
Attachment:
- 1) Response to Violations
- 2) Cycle 8 Unplanned Capacity Loss Due to Maintenance Related Causes Evaluation f
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- 3) L w Pressure Heater Corrective Action Summary
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ULNRC-3709 February 6,1998 Page 2 cc: Mr. Ellis W. Merschoff Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 8064 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steed. nan, MO 65077 Mr Barry C. Westreich (1 copies)
Acting Licensing Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U, S. Nuclear Regulatory Commission Mail Stop 13E16 Washington, DC 20555-2738
- Manager, Electric Department MissouriPublic Service Commission "O Box 360 Jefferson City, MO 65102 Mr. Thomas A. Baxter Shaw, Pittman, Potts, & Trowbridge 2300 N. Street N.W.
Washington,DC 20037 Manager, Plant Support Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839
Attachment I to
+
ULNRC-3709 February 6,1998 '
Pagel-Statement of. Violation A During an NRC inspection conducted from August 18 through December 19,1997, three vialations ofNRC requirements were identified. In accordance with the " General
. Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the p
violations are listed below:
[
A.
10 CFR 50.6S(a)(1) states, in part, that holders of an operating license shall
- monitor the performance or condition of structures, systems, and wmponents, as defined by 10 CFR 50.65(b), against hcensee established goals, in a manner ruf5cient to provide reasonable am.orance that such stmetures, systems, and components are capable of fulfilling their intended functions. When the performance or condition of a simcture, system, or component does not meet established goals, appropriate corrective ution shall be taken.
10 CFR 50.65(a)(2) states that the monitoring as specified in 10 CFR 50.65(s)(1) is not required where it has been demonstrated that tN performance or condition of a Structure, system, or component is being effectively controlled through the l
performance of appropriate preventive maintenance, such that, the structure, -
I.
system, or component remains capable of performing its intended function.10 CFR 50.65(c) states that. the requirements of this Section shall be implemented by each licensee no later %n July 10,1996.
I' Contrary to 10 CFR 50.65(a)(2):
1.
As of July 10,1996, the licensee failed to demonstrate that the reliability of the containment integrity function was assured by appropriate preventive maintenance on the containment isolation valves. The integrity function was not adequately monitored by the licensee's program because a maintenance rule functional failure of a containment isolation valve, due to test leakage, was not recognizable until the limit of 0.6 L, imposed by L
Technical Specification 6.8.4.g was reached. Therefore, the ability of preventive maintenance to acure the reliability of the containment isolation valves to maintain the containment integrity function was not demonstrated because it did not allow for early detection of degradation.
2.
As of July 10,1996, the licensee failed to demonstrate that the performance or condition of nonsafety-significant systema and components, whose failure could impose a plant transient, was effectively controlled j
through the performance of appropriate preventive maintenance, in that the i
Attachment I to ULNRC.3709 February 6,1998 Page 2 l
licensee had not demoristrated that adequate reliability measnres were in place to assure that the structures, systems, and components remained capable of performing their functions identified in the licensee's Maintenance Rule Program. Specifically, the low pressure feedwater heaters and the heater drain pump mechanical seals were operated in a run to failure mode, without an evaluation to determine the consequences of thei.- failure or degradation on plant safety.
l This is a Severity Level IV violation (Supplement 1) (50-483/9711-01).
Reason for the Violation Example 1 Callaway acceptu this violation as reliability performance citeria for the containment
- isolation function was not established below the Technical Specification limit.
Callaway considered that our Maintenance Rule Program met the requirements of 10 CFR 50.65 for the containment isolation function and the reactor i uilding. 'The notice ofviolation stated that Callaway's reliability performance criterion was inadequate, as it did not allow far early detection ci degradation to the containment integrity function. Our
- performance criterion was our 10 CFR 50 Appendix J Program.- Callaway believed that the performance criteria established was predictive in nature to ensure that a design basis limit was not exceeded. Technical Specification 6.8.4.g specifies that the maximum -
allowable containment leakage rate (L.) shall be 0.20% of the containment air weight per
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day. Technical Specification 6.8.4.g then identifies speciSc leakage rate acceptance criteria at a value low enough to ensure that the design basis limit (L.) is not challenged. Technical
- Specification 6.8.4.g sets these acceptance criteria for Type A Tests (ILRT) at 0.75L.(as left), for Type B and C Tests (LLRT) at 0.6 L., and for air locks at 0.05L.. A functional failure would have been identified whenever one of these limits was exceeded. Therefore, by maintaining the leakage rates below Technical Specification 6.8.4.g acceptance criteria Callaway is ensuring that a design basis limit is not challenged and that this performance criteria is predictivein nature.
It should be noted that Callaway does monitor the leakage rates of the containment isolation function. Procedure ESP-SM-01001, Containment Leakag; Rate Testing Progwn, requires the LLRT Engineer to " Maintain a trend of all test results to aid in identifying valve or penetration degradation. "
It should also be noted that our maintenance program has assured the reliability of the containment integrity function. For reference, our as-left overall containment LLRT value
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j UiNRC-3709 February 6,1908
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1 aAer Refuel 7 was 105,740 SCCM (0.251 L.). After Refuel 8 this salue was 78,167
. SCCM (0.187 L.). This represents n' decrease of more than 25%. Callaway considers this indicative of very effective maintenance on our containment isolation system. We have also aggressively pursued improvements ce our containment isolation function as evidenced by the replacement of the carbon steel essential servicc water containment isolation valves with stainless steel valves. This modification was installed at a cost of approximately $513,000. Callaway initiates a work request to repair the component when.
. a maintenance activity on a containment isolation valve does not meet our expectations.
L This is evidenced by the initiation ofwork requests on valves EMV0006 and EFHV0048
- (not EFHV0084 as identified in the body of the Ir.spection Report). A work request was initiated on EFHV0048 even though the as left leakage was below the 10 CFR 50 Appendix J administrative limit for the valve.
Example 2
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Callaway accepts this violation as thejustification of the inconsequential contribution to safety by the heater drain pump mechanical seals was not adequately documented as required by Regulatory _ Guide 1.160 Rey, 2 Section 1.8.. However, a violation ofNRC
- requirements did not occur for the tube failures of the LP Feedwater Heaters.
i-The low pressure feedwater heaters and heater drain pumps are contained in non-Risk
~ Significant normally operating systems. These systems are monitored utilizing Plant Level i.
Performance Criteria in accordance with NUMARC 93-01 Rev. 2. The reliability of these two SSC's is monitored via the Plant Level Performance Critetia.
There were five heater drain pump mechanical seal failures that were originally classified as functional failures. One of these failures was classified as a Maintenance Preventable 4
Functional Failure. A modification was initiated to correct the problems encountered with accelerated aging from the system environmental chemistry conditions. The Expert -
l:
Panel evaluated these piece parts of the heater drain pump to be 'run-to-failure' and F
documented this decision in an Expert Panel meeting on September 16,1996 (Reference UOMP 96 0010) as allowed per NUMARC 93-01 Rev. 2 Section 9.3.3. However, this evaluation did not adequately document the justification of the inconsequential J
contribution to safety by tlw heater drain pump mechanical seals as required by Regulatory Guide 1.160 Rev. 2 Section 1.8.
j As part of our Functional Failure review to address Violation 'B' these failures were re-3 evaluated. The mechanical seal failures of the heater drain pumps are no longer considered to be functional failures. The basis for this decision is that the failures of the mechanical seals on the heater drain pumps did not cause a loss of a Maintenar.ce Rule Function that
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. to UlNRC.3709 F4tuary 6,1998 Page 4 l
1 placed the heater drain system within the scope of the Maintenance Rule (i.e., could cause a reactor trip).
The low pressurt reedwater heaters are not considered run to failure components.
Calluny has weblished a preventive maintenance program for the low pressure l
feedwater heaters. Callaway has recognized there will be tube +1ures in spite of a comprehensive preventive maintenance prcgram that includea eddy current testing. Wee tube fhilures are monitored and evaluated for Maintenance Rule impact as load is generally -
reduced to repair the tube fhilures, resulting in an increase in the plant level performance criteria of Unplanned Capacity Loss Factor (UCLF). Also, Callaway has been aggressively i
pursuing corrective actions for performance problems of the low presscre foodwater heaters. Corrective actions have included replacing three low pressure feedwater heaters and monitoring corrective and preventive maintenance to ensure that plant reliability is being maintained See Attachment 3 for a chronology ofcorrective actions taken and pla:
' for the low pressure feedwater heators.
The.
prest.ure feedwater heaters are part of the Condensate System. W Condensate System is within the scope of the Maintenance Rule because it is utilized in the Emergency Operating Procedures (EOP's) (as a heat sink) and it could cause a reactor trip (e.g., loss of condenser vacuum). To date, none of the low pressure feedwater heater tube failures has resulted in an actual loss of one of the Maintenance Rule Functions of the Condensate System. Therefore, the Callaway maintenance program has ensured the reliability of the low pressure feedwater heaters in accordance with the requirements of 10 CFR 50.65.
Each time we reduced power in Cycle 8 to repair failures of the low pressure feedwater heaters and the mechanical seals on the heater drain pumps, the loss ofproduction was captured as UCLF. A spreadsheet with this information was provided to the NRC F
Inspection Team during the Maintenance Rule Baseline inspectiots the week of August 18-22,1997. A copy of this spreadsheet is a:so included as part of this response. See. Callaway monitors UCLF throughout the operating cycle to determine if a
- performance criterion is being met or if an adverse trend is developing. If the UCLF exceeds performance criteria or an adverse trend has developed, the cause is investigated and appropriate corrective action is taken.
ferrective Steen T=L-===d R** des Achieved:
Example 1 Callaway has revised the safety significant classification for the containment isolation function and the reactor building. These two SSC's are now classified as " Risk Significant". The reactor building will ontinue to be monitored per our structural
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- Attachment I to ULNRC 3709 February 6,1998 Page 5 monitoring program. The wntainment isolation ibnction's performance criteria vill be revised to the following:
1, - No more than ten valves or other local leak rate tested perutrations hg., electrical penetration, hatches, or flanged peneh adon) that have leakasc at greater than their administrative limit at any given time.
Note: There are 115 valves,55 ele:trical penetrations,5 flanged penetrations, and 3 hatches in the 10 CFR 50 Appendix J Program at Callaway.
- 2. No simultaneous failure of both the inside and outside containment isoletion valves in a single penetration.
3 No more than two MPFF't per cycle for failure to activate on a valid Containment Isolation Signal.
- 4. Containment leakage for Type B and C tests shall be leu than or equal to 0.4 L.,
Availability of both SSC's will be monitored utilizing the Plant Level Performance Criteria of UCLF, as these SSC's are essentially equired to be available 100% of the time.
A review of the history of these SSC's monitored against this new performance criteria indicates that the (a)(2) classification for these SSC's is correct.
The safety signincance of this item is low as Callaway has been monitoring the performance of the containment isolation function through existing programs. Callaway has aggressively pursued resolutions to potential problem components, and the as-lea containment leakage has been very low (e.g., 0.187L.) at the conclusion of the refuel t
outages.
hamp 2 Callaway will enhance the run io failure evaluation for the heater drain pump mechanical seals.
Corrective Stens to Avoid Further Violations:
Examplej The corrective actions described above will ensure the reliability of the containment isolation function. No further action is required.
Example 2 No further action is required.
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l to ULNRC.3709 February 6,1998 Page 6 Date when FmM Comaliance wBl be Achieved:
Framals1 Full compliance was cchieved on February 5,1998.
Exampic.2 The enhanced run to failure evaluation will be comp leted by Ar - 30,1998.
At,tachment 1 to l
ULNRC.370?
I February 6, Wi8 l
Page 7 l
Stataanaat af Vialatian B During an NRC inspection conducted flrom August 18 through December 19,1997, three violations of NRC requirements were identined. In accordance with the ' General l
Statement of P4cy and Procedure for NRC Enforcement Actions," NUREO 1600, the violations are listed below:
B.
10 CFR 50.65(aXI) states, in part, that holders of an operadnp Mcense shall 7
monitor the performance or condition of structures, systems, etJ cor@nents, at 3
detal by 10 CFR 50.65(b), against licensee established goals, in a manner sumclent to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions When the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken, 10 CFR 50.65(aX2) states that the monitoring as specified in 10 CFR 50,65(aXI) is not required where it has been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that, the structure, system, or component remains capable of performing its intended function.10 CFR 50,65(c) states that, the requirements of this section shall be hnplemented by each licensee no later than July 10,1996.
Contrary to 10 CFR 50.6$(aX2), the licensee failed to demonstrate that the perfonrance of the following structures, systems, and components, that are within the scope of 10 CFR 50.65, had been effectively controlled through the performance of appropriate preventive maintenance activities Specifically, the licensee did not adequately evaluate the failures of the equipment listed below such
' the,t the effectiveness of preventive maintenance was no longer demonstrated.
1, Essential Service Water Valve EFV0090 experienced a through wall crack in the yoke on April 14,1997, 2.
liigh pressure safety injection pump miniflow recirculation Valve EMHV8814A failed to open while performing Surveillance OSP EM VOOl A on June 4,1997.
3.
- Valve EMilV8814A was inadvertently closed and not immediately revpened during a functional check for troubleshooting on June 11,1997.
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Attachment I to ULNRC 3709 Febmary 6,1998 Page 8 This is a Severity Level IV violation (Supplement 1) (50-483/9711-02)
Reason for the Violation Callaway did not adequately evaluate some functional failures nor were all functional failures identified as such within our Corrective Action Program (SOS).
Corrective Stens Taken and Results Achieved:
Callaway is reviewing all SOS's from July 10,1993 to the present to ensure all functional failures have been identified and evaluated. July 10,1993 was chosen as the start date for this review to enable Callaway to evaluate all MPFF's to ensure that none were repetitive.
After this review is complete Callaway will evaluate the performance of the SSC's within the scope of the Maintenance Rule to ensure that the current performance (Cycles 8 and
- 9) of the SSC's has been properly evaluated and classified as (a)(1) or (a)(2).
hamplc_1 Tha failure of the yoke on EFV0090 has been evaluated as a Functional Failure. This failure was determined not to be a Main,cnance Preventable Functional Failure as the crack was due to a manufacturing defect and was in such a location and size that it was not reasonable to expect to find the defect during receipt inspection or installation.
Example 2 The Mme of EMIIV8814A to open during a surveillance test was determined to be a Functional Failure. It was determ:ned not to be a Mainteaance Preventable Functional Failure as the failure could not be repeated and no reasonable maintenance could have prevented this failure nor was it caused by the improper performance of a maintenance
- actisity, hampte3 The inadvertent closure of EMllV8814 A during a functional check while troubleshooting was determined to be a functional failure and a Maintenance Preventable Functional Failure.
Corrective Stens to Avoid Further Violations:
Procedure APA-ZZ-00500 (not PDP-ZZ-00020 as identified in the body of the report) has been revised to enhance the definition of a Functional Failure. The definition now includes a loss ofintended function (s) as a Functional Failure. This was discussed with the NRC Inspection Team during the week of the Inspection.
' Attachment I to ULNRC-3709 February 6,1998 Page 9 Training has been provided to the QA Regulatory Support Group on January 6,1998 to ensure all potent!al functional failures are properly identified. This will ensure that Callaway evaluates all potential functional failures.
Date when Full Comoliance will be Athleved:
The SOS review and evaluation for functional failures will complete by April 30,1998.
This will allow Callaway to evaluate each SSC's performance to ensure the correct (aXI) or (aX2) classification of each SSC within the scope of the Maintenance Rule after completion of the MPFF determination for the Functional Failures identified during this review.
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Attachment I to ULNRC 3709 February 6,1998 Page 10 Statement cf Viola 11on C During an NRC inspection conducted from August 18 through December 19,1997, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
C.
10 CFR 50.65(aXI) states, in part, that holders of an operating license shall monitor the performance or condition of structures, systems, and components, as dermed by 10 CFR 50.65(b), against licensee established goals, in a manner sufficient to provide reasonable assurance that such structures, systems, and components are capable of fulfilling their intended functions. Wnen the performance or condition of a structure, system, or component does not meet established goals, appropriate corrective action shall be taken.
10 CFR 50.65(aX2) states that the monitoring as specified in 10 CFR 50.65(a)(1) is not required where it bas been demonstrated that the performance or condition of a structure, system, or component is being effectively controlled through the performance of appropriate preventive maintenance, such that, the structure, system, or component remains capable of performing its intended function.10 CFR 50.65(c) states that, the requirements of this section shall be implemented by each licensee no later thaa July 10,1996.
Contrary to 10 CFR 50.65(a)(2), as of July 10,1996, the time tht. the licensee elected to not monitor the performance or condition of certain structures, systems, and comoonents against licensee-established goals pursuant to the requirements of 10 CFR 50.65(a)(1), the licensee failed to demonstreie thu the performance or condition of structures, systems, and components within scope of 10 CFR 50.65 had been effectively controlled through the performance of appropriate preventive maintenance in accordance with the requirements of 10 CFR 50.65(a)(2).
Specifically, the licensee failed to establish adequate measures to evaluate the appropriateness of the performance of preventive maintenance on certain structures, systems, and components prior to placing them under Section (a)(2).
1, The licensw failed to demonstrate that the reactor protection system performance was adequately controlled through preventive maintenance or surveillance, in that, only unavailability due to corrective maintenance and not preventive maintenance or surveillance testing was evaluated. During periods of unavailability, while performing surveillance testing, the licensee relied on the expeditious restoration of systems and components and, n
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- Attachment 1 to ULNRC-3709 February 6,1998 Page11 i
therefore, did not evaluate them as unavailable. However, rapid restoration was not pc saible in all situations. Therefore, the licensee failed to demonstrate that the performance of safety significant structures, systems, and components was effectively controlled by preventive maintenance because excessive unavailability would not assure that the structures, systems, or components would remain capable of performing their intended Ibnctions when they were impaired due to the performance of surveillance testing.
2.
The licensee failed to demonstrate that the emergency diesel generator and the residual heat removal systems' posformance were adequately controlled through preventive maintenance, in that, unavailability for these systems was only evaluated when the plant was in Mode 1. Without evaluating unavailability in other reactor modes (Modes 2-6) when the systems weie -
required to be operable, the appropriateness of the preventive mahitenance activities was not demonstrated to be effective because excessive unavailability would not assure that the systems remained capalle of -
performing their intended fbnctions.
This is a Seve:ity Level IV violation (Supplement 1) (50-483/9711-03).
Reason for the Violation hmole 1 NUMARC 93-01 Rev. 2 contains the definition for ' Unavailability' which includes the statement "An SSC that is required to be available for automatic operation must be available and respond without human action". Callaway failed to document our position of taking exception to the NUMARC 93-01 definitu for unavailability.
Callaway does not include periods of unavailability during performance of some surveillance tests. The Callaway IPE assumes that these SSC's are functional and therefore available during performann of these surveillance tests prosided the component can be aligned to its demand position in a short period of time from the Control Room or the field by an operator or technician that is dedicated to the performance of the task. If an LCO was entered for the activity the time was counted in the unavailability data gathered for the IPE.
Callaway established availability performance criteria in accordance with the requirements of NUMARC 93-01 Rev. 2, Section 9.3.2. This section requires that the availability and reliability performance criteria be established to assure the assumptions in the IPE/PRA
1 Attachment I to ULNRC 3709 February 6,1998 Page 12 are maintained or adjusted when determined necessary by the utility. Since the Callaway 4
IPE did not assume any unavailability during the surveillance tests when the component can be aligned to its demand position in a short period of time flrom the Control Room or by an operator or technician in the field that is dedicated to the perfonnance of the task, our Maintenance Rule monitoring does not count this unavailability.
Example 2 Callaway did not include monitoring of unavailability of the emergency diesel generator and the residual heat removal systems in other than Mode 1 as rer,uired by 10 CFR 50.65 t
when the Maintenance Rulu was implemented on July 10,1996.
l Corrective Steps Taken and Results Achieved:
Example 1 Callaway will include monitoring the unavailability of the Reactor Trip System during the 4
Trip Actuating Device Operational Tests (TADOT) of the reactor trip breakers. Callaway will consider that a train of reactor trip breakers is unavailable whenever the TADOT surveillance is being performed. Our performance criteria will be revised accordingly to i
account for this increase in unavailability. Callaway will start monitoring the Reactor Trip 4
System por this revised performance criteria upon completion of Refuel 9 scheduled for April-May,1998.
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Callaway has determined that our methodology for collection of SSC unavailability time does not need to be revised, except for performance of the Reactor Trip Breaker TADOT testing described above. Procedure ODP-ZZ-00002, Equipment Status Control, requires an Equipment Out-of Service Log (EOSL) entry for all Safety Related equipment that is rendered inoperable (entry into a LCO) except for those items that are under the direct control of an operator or technician that can readily restore the SSC to full operability in a timely manner.
Example 2 As a result of the Self Assessment of the Maintenance Rule Program in March 1997, our monitoring of unavailability was revised to include all modes of operation whenever the
- system / train was required. We evaluated the unavailability of the emergency diesel generator and the residual heat removal systems for Cycle 8 in all modes as documented in
- our Periodic Assessment. This resulted in no additional unavailability for these SSC's when they were required to be Operable.
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i Attachment I to ULNRC-3709 February 6,1998 Page 13 The safety significance of thu two examples in this violation is low as most of the required actions were ah eady being performed and the only corrective action is administrative in nature.
Corrective Stens to Avoid Further Violationar bampit.1 Callaway will modify our Maintenance Rule Program to clarify the unavailability definition to allow for minimal operator action.
This is typical for most surveillance test activities. Taking credit for operator action is based on INPO guidelines for Safety System Performance Indicator (SSPI) reporting and standard industry practice, which credit manual operator action. Use of the INPO unavailability definition is also consistent with modeling assumptions for operator actions credited in Callaway's IPE. This ensures a meaningful comparison to the unavailability values in Callaway's IPE. Positions similar to this have been validated by NRC baseline inspections at other plants.
hamole 2 Callaway reviewed all other SSC's within the scope of the Maintenance Rule ant revised the unavailability monitoring for those SSC's that are required in Modes other than aiode1.
Date when Full Compliance will be Achieved:
Example 1 Procedure PDP ZZ-00020 will be revised by April 30,1998 to include Callaway's position on unavailability. Our performance criteria for the Reactor Trip System will be resised by April 30,1998. Monitoring the unavailability of the reactor trip breakers will begin upon completion of Refuel 9 scheduled for April May,1998.
hamplt_2 As a result of the Self Assessment of the Maintenance Rule Program in March 1997, Full compliance was achieved on July 14,1997 with the issuance of our Periodic Assessment for Cycle S.
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< 12 ULNRC 3709 February 6,1998 PaEc1of1 LOW PRESSURE IIEATER CORRECTIVE ACTION
SUMMARY
h low Pressure Foodwater licaters, in the period 1985 through 1990, were determined to be a challenge to naintaining plant reliability. Plant power reductions to repair premature tube failures were occurring at an unacceptable rate, it became the primary focus of the System Engineer to determine the cause and recommend appropriate corrective action. W following table sumtr.arizes those fmdings, actions taken, and associated coets:
DATE ACTION COST Summer 1991 Feedwater heater consultant brought in to evaluate
$ 10,000 heaters, determine failure mechanisms, and make recommendations. 'Ihose recs...cr.dations provided the basis for the corrective actions taken.
Fall 1991 -Spring System Engineer provided training to the Operations 1992 stafT on the importance of maintaining proper Icwl in the low pressure heaterr.
Spring 1992 A partial re tube was performed on EAD02B. 200
$ 60,000 plus the tubes were replaced in an cfrort to imprcyc tubes performance An autopsy of the heater proved the root cause of failure determined in the summer of 1991 to be correct. Re-tube did not correct the problan.
Summer 1992 Modification 91 2012 implemented to improve the S 82,000 level control system. 'Ihc level control wu inappropriately installed during initial construction, Spring 1994 Tube bundic replacement was determined to be the most reliabic method ofimproving heater performance.
An impicmentation schedule was devcicped at this time.
Spring 1995 Field implementation completed on the first
$ 850,000 replacement tube bundle, in EAD02B.
Fall 1996 Field implementation completed on units EAD02A and
$ 1,700,000 EAD02C.
Spring 1998 EAD01C is scheduled to be replaced in refuel nine.
$ 1,400,000 Increased cost is due to the #1 units being approximately 50% larger than the #2 units presiously trplaced.
Fall 1999 EAD01 A and EAD01B tcntatively scheduled for S 3,300,000 replacement in refuel 10.
TOTAL COST:
5 7,402,000 The rate of failure in the number three heaters has been significantly reduced due to the improwments in level control. A rcplacement schedule for the number three heaters will be evaluated after refuel 10. The number four heaters have not experienced the same failures as the aforementioned heaters and will be evaluated for replacement after the number three heaters.
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