ULNRC-04117, Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.73

Comment Supporting Proposed Rules 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Rev 2, Event Reporting Guidelines 10CFR50.72 & 50.73

ML20212F116
Person / Time
Site:	Callaway
Issue date:	09/22/1999
From:	Witt W UNION ELECTRIC CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR36291, RTR-NUREG-1022, RULE-PR-50, RULE-PR-72 64FR36291-00019, ULNRC-04117, NUDOCS 9909280032
Download: ML20212F116 (4)

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ftien Etetric PO Ilox 620 I9 ca,,,m nr runon,uo casi DOCKET NUMBERn$0 "TSoe PROPOSED RULE r '~ <J72 (L4FR34291)

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/u . September 22,1999 Secretary U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 Attn: Rulemakings and Adjudications Staff

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1. E utNRC-04ii7 Gentlemen:

DOCKET NUM11ER 50-483 CALLAWAY PLANT UNIT 1, UNION ELECTRIC CO.

FACILITY OPERATING LICENSE NPF-30

Reference:

Federal Register Volume 64, No.128, Pages 36291-36307, dated July 6,1999

Subject:

Comments On Proposed Rule 10 CFR Parts 50 And 72," Reporting Requirements For Nuclear Power Reactors," And Draft NUREG-1022, Revision 2, " Event Reporting Guidelines -

10 CFR 50.72 And 50.73" Union Electric (UE) appreciates the effort that the Nuclear Regulatory Commission (NRC) has put into revising 10 CFR 50,72 and 10 CFR 50.73 and allowing for industry involvement. Specifically, the table top exercises, held on November 13, 1998, as discussed in the Reference page 36291 were ofgreat benefit and allowed for an open exchange ofinformation. UE supports the NRC's position to reduce or eliminate the reporting burden associated with events oflittle or no safety significance. The proposed rule has made progress toward this goal. i

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l However, there are specific portions of the rule and associated NUREG-1022,  !

I Revision 2, that detract from this goal and, ifimplemented, may increase the reporting burden of the licensee. Our areas of concern include:

Significantiv Degraded Comnonents Most important is the recent addition of a new reporting criterion for Significantly Degraded Component (s). UE finos the new criterion, as written, to be unclear in focus and subject to widely varying interpretation. The attempt to capture items (components) which are seriously degraded, but not necessarily enough to render a system inoperable, is far below the current reporting threshold and represents an increase in licensee burden. Further, even if an operability statement is added to the criterion, as suggested at the August 3,1999 tabletop, UE feels that a component degradation significant enough to render a system inoperable would be captured by other reporting criteria, making this new criterion redundant and unnecessary.

In addition, the new criterion as discussed by the stafrat the table top exercise on August 3,1999, appeared to have been added primarily as a data collection mechanism for motor operated valves. This is contrary to the stated objectives of the proposed rule which focuses on events of risk and safety significance. If component data is needed, there are other resources available to the NRC to obtain the information, such as maintenance rule reports and the Equipment Performance Information Exchange (EPIX).

UE recommends that the new criterion not be added to the rule. As discussed at the table top, held on August 3,1999, significant component degradations that are risk and/or safety significant will be reported under other criteria such as loss of a function, common-mode failure, Part 21, or as a Technical Specification violation.

ESF Actuations The addition of a specific list of systems which must be reponed as Engineered Safety Features will increase reporting by plants whose licensing basis does not include those specific systems. UE recommends a return to the pre-1998 practice of relying on each facility's Final Safety Analysis Report (FSAR) and shift to a risk-informed approach when such criteria are fully

developed. As part of the effort to risk inform Part 50, this section should be l changed to be more risk informed.

Invalid ESF actuations are still included in the proposed rule change reporting requirements for the written LER. UE recommends that the existing clarifications for not reporting certain invalid actuations be retained in the

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ULNRC-04117 Callaway Plant Page 3 guidance. Actuations that need not be reported are those initiated for reasons other than to mitigate the consequences of an event. Specifically, actuations I when the system is already properly removed from service, part of a planned l

evolution, that occur afler the safety function has already been completed, or  !

single component actuations of complex systems, which do not by themselves mitigate the consequences of significant events, should not be reportable.

LER Information The scope ofinformation requested for human performance events has increased by shifling from " personnel error" and the implied " root cause" to

" human performance related problem" and " contributing factors." It is more appropriate to require discussion of personnel error root causes.

UE recommends deletion of the new criterion,10 CFR 50.73(a)(3)(ii), which  !

requires a discussion of emergency or operating procedures, that could have been used to recover from an event, be included in a LER. The proposed rule change would result in a large amount of additional information that would be of minimal use. The safety consequences discussion would be cluttered with hypothetical failures and speculated plant responses. l Historical Limitalions UE supports the new historical reporting limitation for operations prohibited j by the plant's Technical Specification and conditions that could have i prevented fulfillment of a safety function. UE recommends this limitation be applied to the active rule.

In addition to the generai comments above, UE endorses the. comments submitted to the NRC by the Nuclear Energy Institute (NEI).

Sincerely, Nw 4.a#

Warren A. Witt Assistant Plant Manager l

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ULNRC-04117 l Callaway Plant Page 4 l cc: U. S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop PI-137 Washington, DC 20555-0001 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 Steedman, MO 65077 Mr. Jack N. Donohew (2 copies) i Licensing Project Manager, Callaway Plant i Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission l Mail Stop OWFN-4D3 Washington, DC 20555-2738 Manager, Electric Department Missouri Public Service Commission PO Box 360 JefTerson City, MO 65102 Superintendent, Licensing Wolf Creek Nuclear Operating Corporation PO Box 411 Burlington, KS 66839 l'

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