ML20214K175

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Submits Final Response to Generic Ltr 83-28, Required Actions Based on Generic Implications of Salem ATWS Events. No post-maint Tests Identified Which Could Degrade Safety.Changes Per Generic Ltr 84-15 Will Be Sent
ML20214K175
Person / Time
Site: Callaway Ameren icon.png
Issue date: 08/12/1986
From: Schnell D
UNION ELECTRIC CO.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
GL-83-28, GL-84-15, ULKNRC-1356, ULNRC-1356, NUDOCS 8608180199
Download: ML20214K175 (4)


Text

Umou ELECTRIC Essa 1901 Gratiot Street. St. Lcuis Donald F. Schnell August 12, 1986 Vce President Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Wachington, D. C.

20555

Dear Mr. Denton:

ULNRC-1356 DOCKET NUMBER 50-483 UNION ELECTRIC COMPANY CALLAWAY PLANT GENERIC LETTER 83-28, " REQUIRED ACTIONS BASED ON GENERIC IMPLICATIONS OF SALEM ATWS EVENTS"

References:

1.

ULNRC-687 dated 11/18/83, Response to Generic Letter 83-28 2.

ULNRC-ll74 dated 10/16/85, Revision to Technical Specification 3/4.3.1 Reactor Trip System Instrumentation 3.

ULNRC-962 dated 10/30/84, Response to Generic Letter 84-15, Diesel Generator Reliability Recent discussions with NRC staff have indicated that additional information was required for our response to Items 3.1.3 and 3.2.3 of Generic Letter 83-28.

These items relate to the identification of post-maintenance testing required by the Callaway Technical Specifications which could degrade rather than enhance safety.

Reference 1 provided an interim response to Generic Letter 83-28.

This letter constitutes our final response.

Union Electric has not identified any post-maintenance test requirements in the Callaway Technical Specifications which could degrade safety.

However, there are numerous surveillance e_

interval requirements, out-of-service times, and action statements in the Callaway Technical Specifications which we believe do not enhance safety and may negatively affect overall n

plant reliability.

As a result of our participation in the mg Westinghouse Owners Group-Technical Specification Optimization g-oa Program (WOG-TOP), changes to reactor trip system surveillance intervals and allowed out-of-service times have been proposed in gg Reference 2.

These proposed changes a ' based on WCAP-10271.

Reference 3 provided our response to Gs eric Letter 84-15

$d regarding diesel generator (DG) reliability.

Reduction of the gg number of DG starts required as a result of re-defined action m<

statements, allowed outage times based on manufacturer y

recommendations, and test frequencies based on fewer valid tests

]0(jI og are regarded as safety enhancements.

A license amendment request maa on DG Technical Specifications will be submitted under separate g,8 cover.

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

2

' O

-In addition to participation in the WOG-TOP program, Union Electric is also active in the WOG's Methodically Engineered, Restructured and Improved Technical Specifications (MERITS) program.

This program is based on the AIF and NRC technical specification improvement recommendations.

Future changes resulting from our participation in the WOG-TOP and MERITS programs will be submitted via the normal license amendment process.

We look forward to working with the staff to realize the technical specification improvements discussed above.

Very truly yours, 4%

i

/

Do

. Schnell GGY/plh 4

1 t

e STATE OF MISSOURI.)

)

SS

. CITY OF ST. LOUIS )

Robert'J. Schukai, of lawful age, being first duly sworn upon oath says that he is General Manager-Engineering (Nuclear) 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 behalf of said company with full power and authority to do so; and

'that the facts therein stated are true and correct to the best of his knowledge, information and belief.

/

By Robe t J.

Schukai Genera anager-Engineering Nuclear SUBSCRIBED and sworn to before me this /8(Nday of u f, 1988.

AW BARBARA J. PFAFF( yy v %

NOTARY PUBLIC, STATE OF MISSOURI MY COMMISSION EXPlRES APRIL 22, 1983 ST. LOUIS COUNTY.

a e

cc:

Gerald Charnoff, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M. Street, N.W.

Washington, D.C.

20036 Nicholas A. Petrick Executive Director SNUPPS 5 Choke Cherry Road Rockville, Maryland 20850 C. W. Hehl Division of Projects and Resident Programs, Chief, Section lA U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, Illinois 60137 Bruce Little Callaway Resident Office U.S. Nuclear Regulatory Commission RRil Steedman, Missouri 65077 Paul O'Connor Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 316 7920 Norfolk Avenue Bethesda, MD 20014 Manager, Electric Department Missouri Public Service Commission P.O. Box 360 Jefferson City, MO 65102

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