ML20202H490
| ML20202H490 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/14/1986 |
| From: | Oconnor P Office of Nuclear Reactor Regulation |
| To: | Bernero R, Miraglia F, Novak T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8607160330 | |
| Download: ML20202H490 (14) | |
Text
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[ p, NUCLEAR REGULATORY COMMISSION 5 ;y WASHINGTON, D. C. 20555 i
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Docket No. 50-482 i MEMORANDUM FOR: Thomas M. Novak, Acting Director Division of PWR Licensing-A, NRR Frank J. Miraglia 3 Director Division of PWR Licensing-B ;
1 Robert Bernero, Director i Division of BWR Licensing William T. Russell, Director Division of Human Factors Technology Themis Speis, Director Division of Safety Review and Oversight THRU: B.J. Youngblood, Director PWR Project Directorate #4 Division of PWR Licensing-A, NRR FROM: Paul O'Connor, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A, NRR
SUBJECT:
SALP REPORT - CALLAWAY Enclosed is a draft of NRR's SALP input for Callaway covering Union Electric Company licensing activities for the period of from June 1,1985 through May 31, 1986. The report is based on inputs provided by NRR reviewers and ob-servations by NRR project management during their interactions with us during the SALP period. A perfonnance rating of 2 has been assigned by the NRR SALP Evaluation effort for the current licensing period.
Please review the draft assessment and provide any comments you feel appropriate.
All coments received by July 15 will be considered for incorporation in the final report. ;
The following information is enclosed for your information:
- 1. Summary of previous NRR evaluation for Callaway licensing activities
- 2. Sumary of previous NRR SALP evaluations for Callaway 8607160330 860714 PDR ADOCK 05000482 G PDR l
JUL 141985
- 3. Callaway SALP input matrix for NRP, licensing activities
- 4. Record of Meetings and Official documents The NRC SALP Board meeting for Callaway is scheduled for August 8,1986.
The SES representative assigned to this SALP is B.J. Youngblood, b\
Paul O'Connor . Project Manager PWR Project Directorate #4 Division of PWR Licensing-A, NRR
Enclosure:
- 1. Draft NRP,SALP Report
- 2. Sumary Tables cc: H. Denton R.Lerch, RIII
- r. DISTRIBUTION:,
' Uoctet II Ie.
PWR#4 Reading P0'Connor MDuncan PWRf4/DPWR-A
&f PWR#4/WWlPA i eN PWR#4/DPWR-A P0'Connor/ rad TAlexion BJYoungblood 07/s/ /86 07/l(/86 07/g/86 l
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- 4. Record of Meetings and Official documents The NRC SALP Board meeting for Callaway is scheduled for August 8,1986.
The SES representative assigned to this SALP is B.J. Youngblood.
0- WW Paul O'Connor, Project Manager PWR Project Directorate #4 Division of PWR Licensing-A, NRR
Enclosure:
- 2. Sumary Tables cc: H. Denton R.Lerch, RIII l
Sumary - Licensing Activities
- 1. Analysis This functional area was rated Category 1 in the previous SALP appraisal period (December 1, 1983 to May 31, 1985). During the current rating period, the primary licensing activity involved the resolution of license conditions which remained from the full power license issuance and the completion of licensing actions relating to the completion of licensing actions relating to first cycle operations and the approval of Reload 2 for cycle 2 operation.
The licensee's management has participated in licensing activities and has assured timely response to the staff's requirements. In particular, the UE management has been actively involved in major licensing activities such as the Cycle 2 reload that they considered to be critical path items for the UE operational schedule.
UE is generally aware of NRC requirements and usually provides the staff with adequate technical infonnation to resolve staff concerns. However, on two occasions during the first half of this rating period licensing actions were delayed by deficient no significant hazards considerations analyses provided by UE in support of amendment requests.
Enclosure 1 contains the detailed SALP, Enclosure 2 contains supporting data, Enclosure 3 contains the matrix of branch inputs, and Enclosure 4 contains additional supporting data.
- 2. Conclusion The licensee has been responsive and technically competent in pursuing its licensing activity during this SALP rating period. Concerns relatively to the no significant hazards consideration findings during the first half of this period appear to have been resolved. The licensee is considered to be in perfonnance Category 2 in this rating area.
- 3. Board Recomendation The licensee should address license conditions and other licensing activity, as well as any future licensing activity with a high level of management attention to detail to assure that the staff's requirements are addressed on all licensing issues.
Enclosure 1 Docket No. 50-483 FACILITY: Callaway LICENSEE: Union Electric Company EVALUATION PERIOD: June 1, 1985 to May 31, 1986 FULL-POWER LICENSE: Issued October 18, 1984 PROJECT MANAGER: Paul W. O'Connor I. INTRODUCTION This report contains NRR's input to the SALP review for Callaway. The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, NRR Inputs to SALP Process, dated January 3, 1984.
This Office Letter incorporates NRC Manual Chapter 0516, Systematic Assess-ment of Licensee Performance.
II.
SUMMARY
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2, or 3) based on a composite of a number of attributes. The performance of Union Electric Company (UE) in a functional area of Licensing Activities is rated Category 2. The licensee was rated Category 1 in the areas of Licensing Activities during the previous SALP period.
III. CRITERIA The evaluation criteria used for this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
IV. METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (0 RPM) and those technical reviewers who expended significant amounts of effort on Callaway licensing actions during the current rating period. Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer applied specific evaluation criteria to the relevant licensee per-formance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1,2 or 3) to each attribute. The reviewers included this information as part of each Safety Evaluation Report transmitted to the i
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Division of PWR Licensing-A. The ORPM, after reviewing the inputs of the tech-
! nical reviewers, combined this information with his own assessment of licensee performance and, using appropriate weighting factors, arrived at a composite rating for the licensee. A written evaluation was then prepared by the ORPM and circulated to NRR management for coments, which were incor-porated in the final draf t.
The basis for this appraisal was the licensee's performance in support of amendment requests and responses to generic letters which have been reviewed and evaluated by the staff during the rating period. The subjects involved l 1
include the following:
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Generic Reviews: Plant Specific Reviews j Reactor Trip System l Reliability (B-80) Enrichment Increase in Spent Detailed Control Room Fuel Pool (Amendment 12)
Design (F-71)
Post Trip Review (B-85) Fire-pump Diesel Inspection Safety Parameter Display (Amendment 11)
System (F-09)
Surveillance Interval Extension (Amendment 8)
Deletion of Fuse Testing (Amend 9)
Low Temperature Overpressure Protection Organization Change (Amendment 10)
Revised Value of Pa (Amendment 13)
Quality Systems Department Change (Amendment 14)
Reload for Cycle 2 (Amendment 15)
Fuel Drop Accident Inside Containment Low Temperature Over Pressure Circuitry f Use of Code Case N416 Extension of Performance on Type C tests V. ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's perfonnance evaluation is based on a consideration of four of the seven attributes specified in NRC Manual Chapter 0516. These are:
-- Management Involvement and Control in Assuring Quality
-- Approach to Resolution to Technical Issues from a Safety Standpoint
- -- Responsiveness to NRC Initiatives l -- Reporting and Analysis of Reportable Events For the remaining three attributes (enforcement, training and qualification effectiveness, and staffing), no basis exists for an NRR evaluation for the functional area of Licensing Activities.
A. Management Involvement and Control in Assuring Quality During the present rating period the licensee's management demonstrated active participation in licensing activities and kept abreast of current and anticipated licensing actions. In addition, the management's involvement in licensing activities assured timely response to the requirements of the Commission's rules related to Environmental Qualification of Electrical Equipment and license conditions related to Detailed Control Room Design Review, Emergency Response Capabilities, and Regulatory Guide 1.97. The implementation schedules for compliance with these issues have been met by the licensee and their submittals have generally been of high quality and have not required significant rework to satisfy staff requirements.
UE management was particularly effective in assuring that high quality submittals were provided to the staff during the preparation and review of the UE's reload submittal for Cycle 2 operation. The submittal was timely and more than usually complete. UE requested a pre-review meeting with the staff in order to facilitate their submittal and our review.
Based on the above discussion the overall rating of 2 is assigned to this category.
B. Approach to Resolution of Technical Issues from a Safety Standpoint The licensee's management and its staff have demonstrated sound technical under-standing of issues involving licensing actions. Their approach to resolution of technical issues has demonstrated extensive technical expertise in all tech-nical areas involving licensing actions. The decisions related to licensing issues have routinely exhibited conserva usm in relation to significant safety matters. The licensee's clear understanding of the staff's concerns assured sound technical discussions regarding resolution of safety issues.
UE is generally aware of NRC requirements and their licensing submittals usually provide the staff with the information needed to complete its review without extensive requests for additional information.
On two occasions the staff was unable to prepare a no significant hazards con-sideration (NSHC) finding related to a UE amendment request because the NSHC analysis provided by UE was deficient. In both cases the required notice to the public was delayed while UE was requested to provide a NSHC analysis that satisfied the requirements of 10 CFR 50.91 (a)(1).
Based upon the above the overall rating of 2 is assigned to this category.
C. Responsiveness The licensee has been generally responsive to NRC initiatives. During the rating period, they have made efforts to meet the established commitments as illustrated by their responses to TMI action items, and compliance with the rules related to environmental qualification of safety related electrical equipment. In several subject areas the licensee responded in a timely and thorough manner. In response to NRC requests and suggestions related to the staff's review of generic issues and license amendment requests, the requested information was usually provided quickly and was adequate to allow the staff to resolve the issue promptly.
Based on the above discussion, the overall rating of 2 is assig'ned to this category.
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D. Enforcement History No basis exists for an NRR evaluation of this attribute.
E. Reporting and Analysis of Reportable Events During this SALP interval a total of 83 events have been reported. Of these, 42 were non-security events reported to the NRC Operations Center under the requirements of 10 CFR 50.72 and 41 were Licensee Event Reports (LER's) reported per 10 CFR 50.73. Review of the LER's indicates that about half of them in-volved minor technical specification violations and were not significant enough to be reported to the Operations Center.
Sixteen of the events reported per 50.72 involved reactor scrams which is a very high number compared to the industry average of 5.8 scrams per plant year. Of these sixteen reactor scrams, twelve occurred from a power level above 15%, and ten occurred from above 85%. Of these sixteen events five were due to operator error, seven were due to electrical failures, two due to mechanical failures, one due to a failed slave cycler counter card, and one was due to a spurious spike in the source range caused by welding. The large number of scrats due to operator error may be indicative of inadequate training or procedures. Seven of the sixteen scrams were combined with an engineered safety feature actuation. All scrams were promptly corrected and reported to the NRC Op trations Center.
The licensee has started a scram reduction program which Region III is following.
Callaway was the subject of only one operating reactors briefing during this SALP evaluation period. A reactor trip occurred on August 20, 1985 due to loss of field to the main generator. The plant was operating at 100% power. This resulted in a turbine trip, which in turn caused a reactor trip. Due to shrink in the steam generators (S/G) as a result of the turbine trip / reactor trip transient, a feedwater isolation, auxiliary feedwater actuation, and a S/G blow-down isolation occurred as expected. This scram was interesting because it occurred while reducing load.
Of the 42 non-security events reported per 50.72, 22 events involved actuations of engineered safety features. A large number of these events involved spurious Containment Purge Isolation (CPI), Control Room Ventilation Isolation (CRVI),
and Fuel Building Ventilation Isolation (F8VI). Two events were caused by personnel error. A number of events were due to spurious signals generated during gas sampling evolutions.
The licensee's review of the CRVIS indicated that removing the downscale trips from the radiation monitors that provide protective actions would have prevented several of these actuations.
In 1985 (note the SALP period is 6/1/85 through 5/31/86), the reactor critical hours of operation were 8,161, the forced outage rate was 6.4% or 536.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the unit had 20 scrams which is equivalent to 2.45 scrams per 1000 critical hours of operation, which is much higher than the industry average of 1.47 scrams /1000 critical hours in 1985. However, the plant availability factor for 1985 was 90% which is much higher than the 61% national average availability factor for 1985. This high availability factor in spite of the high number of scrams is because the plant was not refueled during 1985.
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The total exposure at Callaway for 1985 was 35.96 man-rem. This total exposure is low in comparison with the industry average of about 550 man-rem per plant in 1985. This lower than average exposure is probably due to two things: there was not a refueling outage during 1985, so the accompanying maintenance doses were avoided; and because the plant is relatively new, contamination levels should be lower than the average plant's. It is noteworthy that no one individual at Callaway received a whole body exposure of greater than 1 rem during 1985.
To summarize, Callaway had a high number of reactor scrams and engineered safety features actuations during the SALP rating period. It had a high availability factor and lower than average exposures for 1985. During this SALP rating period the licensee promptly reported the events to the NRC Operations Center per 10 CFR 50.72, and promptly initiated corrective actions. Thus, we recommend a rating of 2 for this attribute.
F. Staffing No basis exists for an NRR evaluation of this attribute.
G. Training No basis exists for an NRR evaluation of this attribute.
VI. OTHER FUNCTIONAL AREA During site visits on June 24, 1985, August 28, 1985 and April 29, 1986, the staff toured several plant areas including the reactor building, turbine building, auxiliary building, the radwaste building and the control room. The staff found that the plant was in relatively good order with respect to cleanliness, and housekeeping. Activities in the control room were observed to be conducted in a professional manner with assigned personnel appearing to be alert and attentive to duty.
Based on the above discussion, the overall rating of 2 is assigned to this category.
VII. CONCLUSION A complete performance rating of 2 has been assigned by the NRR SALP evaluation effort for the current rating period.
e e e &
Enclosure 2
SUMMARY
TABLES I
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Table 1 Summary of Previous NRR SALP Evaluations for Callaway Licensing Activities 12/01/83 10/01/82 thru thru 05/31/85 11/30/83 A. Licensing Activities
- 1. Management Involvement and Control in Assuring Quality 1 1
- 2. Approach to Resolution of Technical Issues from a Safety Standpoint 1 2
- 3. Responsiveness to NRC Initiatives 2 1
- 4. Enforcement History N/A* N/A
- 5. Reporting and Analysis of Reportable Events 1 N/A
- 6. Staffing (Including Management) 1 N/A
- 7. Training Effectiveness and Qualifications N/A N/A Overall 1 1
- Not assessed L_
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Table 2 Summary of Previous NRC SALP Evaluations for Callaway 12/01/83 10/01/82 thru thru. !
Functional Area 05/31/85 11/30/83 A. Plant Operations 2 NA**
B. Radiological Controls 2 1 C. Maintenance 2 NA D. Surveillance 2 NA E. Fire Protection 1 2 F. Emergency Preparedness 2 NA G. Security 2 2 H. Initial Fuel Loading 1 NA I. Construction Completion Activities 2 2 Ja. Electrical 1 2
- b. Instrument and Control Systems
- 1 1 K. Preoperational Testing 2 2 L. Startup Testing 1 NA M. Quality Programs and Administrative Controls 2 NA N. Licensing Activities 1 1
- Ja. and b. are combined under heading Electrical Power Supply and Distribution.
- NA - Not assessed
Table 3 Callaway SALP Input Matrix Approach Management to Criteria Involvement Resolution Responsiveness Reporting Enrichment Increase in Spent Fuel Pool 2 1 N/A N/A 01/02/86 Fire Pump Diesel Inspection 2 2 1 N/A 12/10/85 RTS Reliability -
N/A 1 1 1 10/03/85 Extension of Surveillance Interval N/A 1 N/A N/A 08/22/85 Deletion of Fuse Testing N/A 1 N/A N/A 08/21/85 Detailed Control Room Design Review 2 2 1 N/A 08/21/85 Post Trip Review Data 2 N/A 2 N/A 03/26/86 Low Temperature Over Pressure Protection 1 1 1 N/A 07/26/85 Quality Systems Dept.
Organization Change 1 N/A N/A N/A 02/11/86 Reload 2(P3jorEffort) 1 1 1 N/A 03/17/86 Delete Hydrogen Mixing Fans 2 2 N/A N/A 02/19/86 Safety Parameter Display System 2 2 2 N/A 11/26/85 -
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Table 4 RECORD OF MEETINGS AND OFFICIAL DOCUMENTS
- 1. NRR/ Licensee Meetings To Discuss Reload 2 12/5/85 To Discuss low temperature over pressure protection system 11/07/85
- 2. NRR Site Visits / Meetings Training to obtain unescorted access and meeting with resident inspector 06/24/85 Site Tour with regional personnel to discuss SALP report 08/28/85 and meeting with resident inspector 04/29/86
- 3. Comission Meetings NONE
- 4. Schedular Exemptions Granted NONE
- 5. Reliefs Granted NONE
- 6. Exemptions Granted NONE
- 7. License Amendments Issued NONE Amendment 8 - Extension of initial 18 month surveillance 10/03/85 interval Amendment 9 - Deletion of resistance testing of certain 11/19/85 fuses Amendment 10 - Revision to unit organizational chart 11/19/85 Amendment 11 - Revision to fire pump diesel engine 01/22/86 surveillance requirement Amendment 12 - Spent fuel pool enrichment limit 01/24/86 Amendment 13 - Revised value of Pa 03/04/86 Amendment 14 - Quality Systems Department organizational 03/04/86 Amendment 15 - Reload 2 04/04/86
- 8. Emergency Technical Specification Changes NONE
- 9. Orders Issued NONE
- 10. NRR/ Licensee Management Conferences NONE
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