ML20217Q872
| ML20217Q872 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/08/1998 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Randolph G UNION ELECTRIC CO. |
| References | |
| 50-483-97-11, EA-97-469, NUDOCS 9804130212 | |
| Download: ML20217Q872 (5) | |
See also: IR 05000483/1997011
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611 RYAN PLAZA DRIVE. SulTE 400
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April 8,1998
EA 97-469
Garry L. Randolph, Vice President and
Chief Nuclear Officer
Union Electric Company
P.O. Box 620
,
Fulton, Missouri 65251
SUBJECT:
RESPONSE TO NRC INSPECTION REPORT 50-483/97-11 AND NOTICE OF
VIOLATION
Dear Mr. Randolph:
Thank you for your letter of February 6,1998, in response to our December 24,1997, letter and
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Notice of Violation conceming the findings of the Maintenance Rule baseline inspection at the
Callaway Plant. We have reviewed your reply, and require additional information for each of the
three violations.
Violation A
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In regard to your response to Example 1, additional information regarding the planned change to
the performance criteria for the containment isolation function is needed in order to evaluate the
effectiveness of the corrective actions. Specifically, we request that you provide the definition of
" failure" which is referred to in item 2 of the planned changes to the performance criteria on
page 5 of your response. As presently stated, simultaneous failures of both valves in a
penetration could be interpreted to mean: both valves of a penetration exceeding their individual-
administrative leakage limits; both valves, as well as, eight other valves exceeding their
administrative leakage limits; or both valves exceeding 0.4 l . Please explain simultaneous
failure of both valves in a penetration with regard to test program leakage.
In regard to your response to Example 2, you did not agree that a violation had occyrred in your
monitoring of feedwater heaters. We agree with your position that the feedwater heaters are not
classified as run-to-failure and are presently being monitored at the plant level. We also
recognize that a design change to replace the feedwater heater tube bundles with an improved
' design is in progress. However, additional information is needed before we can further consider
you denial of this portion of Violation A, Example 2. Specifically, have there been, or could there
be, occasions where tube failures have been repaired without incurring a power loss?. In --
addition, how will your plant-level performance criteria recognize and capture degraded heater
performance using unplanned capacity loss when there is an existing reduced power level for
core axial offset, or any other reason?
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E-Mail report to T. Frye (TJF)
E-Mail report to D. Lange (DJL)
E-Mail report to NRR Event Tracking System (IPAS)
E-Mail report to Document Control Desk (DOCDESK)
E-Mail report to Richard Correia (RPC)
E-Mail report to Frank Talbot (FXT)
bec to DCD (IE01)
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Regional Administrator
Resident inspector
DRS Director
DRS Deputy Director
DRP Director
DRS-PSB
Branch Chief (DRP/B)
MIS System
Project Engineer (DRP/B)
RIV File
Branch Chief (DRP/TSS)
C. Goines (RIV Al 98-0058)
C. Gordon (RIV Al 98-0058)
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In regar' to your response to Example 2 that addressed heater drain pump seals, the planned
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- corrective action to evaluate the heater drain pump seals for monitoring in a run-to-failure mode
is satisfactory. We will verify the implementation of your planned corrective action during future
inspection activities at the Callaway site.
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Violation B
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In regard to your response to Violation B, we note that you intend to review all suggestion
occurrence solution reports that have been initiated since July 10,1993, in order to verify that all'
structures, systems, or components (SSCs) within the program secpe have been properly
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evaluated and classified as Category (a)(1) or.(a)(2). This corrective action is satisfactory and
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will be reviewed during a future inspection. However, we request clarification on your completed -
corrective action. In particular, the team noted in the inspection report that a failure would not be
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classified as a functional failure on the basis that an equipment operator was available at the -
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valve to open it and that personnel errors during the performance of maintenance activities were
not considered for functional failure evaluations. As a result of your response to Violation C,
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please discuss your current position relative to taking credit for operator intervention for -
functional failure evaluation. Also, please describe how your program evaluates personnel
errors in determining whether functional failures have occurred.
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Violation _Q
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. In regard to your response that provides train unavailability criteria for monitoring the reactor.
protection trip system, we find the planned corrective action to be acceptable. We will review the
implementation of the corrective action during a future inspection.
Your planned program change concoming the evaluation of unavailability does not take into
consideration the unavailability of risk-significant SSCs during surveillance if there is a minimal
restoration time for those SSCs and is, therefore, not acceptable because this action would not
necessarily preclude future violations. Your reference to INPO performance indicator reporting
guidelines for taking credit for operator action to quickly restore SSCs undergoing surveillance is
not endorsed by NRC. NUMARC 93-01 guidance, which is endorsed by NRC, is clear with
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respect to availability determination in that SSCs, which respond automatically, must be subject
to direct control or function automatically without human action to be considered available. Your.
approach does not take into consideration that maintenance / surveillance time be counted as
- unavailable for the purpose of determining the effectiveness of the maintenance and
. surveillance performed on SSCs.' Furthermore, your stated tr.tention to take exception to the
guidance of NUMARC 93-01 for availability determination, by allowing a " minimal * intervention
- time, was not accompanied by an acceptable alternative for NRC review,
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You are required to respond to our concems relating to your response to Violations A, B,'and C
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within 30 days of receipt of this letter. If you have questions about this letter, please contact
Dr. Dale A. Powers at 817/860-8195. For your completed and planned corrective actions that
are considered to be appropriate, we will review the implementation of those corrective actions '
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during a future inspection to determine that full compliance has been achieved and will be
maintained.
As discussed in our letter of December 24,1997, we wish to hold a management meeting with
. Union Electric to discuss your plans to improve your Maintenance Rule program. At this
meeting, we want to include, as agenda items, the results of your continuing corrective action -
evaluations that were targeted for completion by April 30,1998, and your response'to the
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- questions in this letter. As discussed between Messrs. Mark Reid.meyer and Dale Powers on
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February 17,1998, we understand that your proposed time for this meeting is near the end of
May _1998. Dr. Powers will be contacting your representative to obtain details for the meeting
and to establish the meeting date.
Sincerely,
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ArthurT. H
eli lli,' Director
Division of
ctor Safety -
Docket No.:
50 483
License No.: NPF-30
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Professional Nuclear Consulting, Inc.
19041 Raines Drive
Derwood, Maryland 20855-
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Gerald Chamoff, Esq.
Thomas A. Baxter, Esq.
L Shaw, Pittman, Potts & Trowbridge
2300 N. Street, N.W.
Washington, D.C.- 20037
H. D. Bono, Supervising Engineer
Quality Assurance Regulatory Support
Union Electric Company.~
P.O. Box 620
Fulton, Missouri 65251
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Union Electric Company
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Manager- Electric Department
Missouri Public Service Commission
301 W. High .
P.O.' Box 360
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Jefferson City, Missouri 65102
Ronald A. Kucera, Deputy Director
Department of Natural Resources
P.O. Box 176 ,
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, Jefferson City, Missouri 65102
Otto L. Maynard, President and -
Chief Executwe Officer
Wolf Creek Nuclear Operating Corporation
P.O. Box 411
Burlington, Kansas 66839
Dan I. Bolef, President
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= Kay Drey, Representative
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Board of Directors Coalition .
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for the Environment
6267 Delmar Boulevard
University City, Missouri 63130
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- Lee Fritz, Presiding Commissioner
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Callaway County Court House
10 East Fifth Street
Fulton, Missouri 65151
Alan C. Passwater, Manager
Licensing and Fuels
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AmorenUE
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One Ameren Plaza
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1901 Chouteau Avenue
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P.O. Box 66149 '
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St. LoiJis, Missouri 63166-6149_
J. V. Laux, Manager
Quality Assurance
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Union Electric Company.
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P.O. Box 620
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Fulton, Missouri 65251
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