|
---|
Category:Report
MONTHYEARML24122C6372024-05-0101 May 2024 CFR 50.59 and 10 CFR 72.48 Summary Report November 24, 2022 to May 1 2024 ML24115A0992024-04-0101 April 2024 EIP-ZZ-A0066, Rev 30, RERP Training Program ML24086A5142024-03-26026 March 2024 Changes to the Westinghouse and Framatome ECCS Evaluation Models and PCT Penalty Assessments ULNRC-06861, Westinghouse and Framatome, ECCS Evaluation Model Margin Assessments2024-03-26026 March 2024 Westinghouse and Framatome, ECCS Evaluation Model Margin Assessments ML24065A2992024-03-0505 March 2024 Enclosure - Callaway Nuclear Plant: Form Oar-1 Owners Activity Report ML23354A2462023-12-20020 December 2023 Cracking Assessment for Framatome RSG Channel Head Assembly ML23215A1992023-08-31031 August 2023 ANP-4012NP, Callaway, Unit 1, Rod Ejection Accident Analysis Revision 2, August 2023 ML23299A1982023-06-16016 June 2023 Enclosure 2: Callaway RR Tech Report Containment Post-Tensioning System Inservice Inspection Technical Report Basis for Proposed Extension of Examination Interval, Revision 0 ML23156A6712023-06-0505 June 2023 Description and Justification for Changes ML23150A1832023-05-30030 May 2023 EIP-ZZ-00240 Addendum E, Revision 027, Health Physics Coordinator (Hpc) Checklist Administrative Correction ML23150A1842023-05-18018 May 2023 EIP-ZZ-00240 Addendum E, Revision 027, Health Physics Coordinator (Hpc) Checklist ML23150A1892023-05-18018 May 2023 EIP-ZZ-00245 Addendum H, Revision 004, Security Coordinator Checklist for the Alternate Tsc/Osa Assembly Area ML23131A3882023-04-26026 April 2023 EIP-ZZ-PRO2O Minor Revision 54, Activation and Operation of the Joint Information Center - Procedure Review Form and 50.54(q) Screening Form ML23110A0712023-04-0606 April 2023 Procedure Review Form (PRF) for EIP-ZZ-A0066, Revision 28, RERP Training Program ML24115A1002023-03-26026 March 2023 EIP-ZZ-PRO2O, Rev. 55, Activation and Operation of the Joint Information Center ML23068A0992023-03-0909 March 2023 Special Report 2023-01 PAM Report ML23052A0492023-02-14014 February 2023 Enclosure 7 - Holtec International Report HI-2230125, Revision 0, Supplemental Criticality Safety Analysis of SFP for Callaway Nuclear Generating Station, Revision 0, Dated February 14, 2023 ML22349A6272022-12-15015 December 2022 Enclosure 3 - 2022 Proxy Statement of Ameren Corporation ML22349A6322022-12-15015 December 2022 Enclosure 8 - 10-K Filed 02/23/2022 ML22349A6342022-12-15015 December 2022 Enclosure 9 - 10-Q Filed 03/31/2022 ML22349A6352022-12-15015 December 2022 Enclosure 10 - 10-Q Filed 06/30/2022 ML22349A6362022-12-15015 December 2022 Enclosure 11 - 10-Q Filed 09/30/2022 ML22349A6402022-12-15015 December 2022 Enclosure 14 - Schedule 14C Information for Union Electric Company March 2022 ML22327A2242022-11-23023 November 2022 Enclosure 1: Callaway Plant - Report Period: 10 CFR 50.59 and 10 CFR 72.48 Summary Report June 16, 2021 to November 23, 2022 ML22335A5012022-11-16016 November 2022 Enclosure 3: ANP-4012NP, Revision 1, Callaway Rod Ejection Accident Analysis ML22318A1902022-11-14014 November 2022 Enclosure 2 - Pressurized Water Reactor Owners Group Letter, OG-22-187, Subject: PWR Owners Group Mode 4 LOCA Analysis for Westinghouse NSSS Plants ML22299A2352022-10-21021 October 2022 HI-2220020, Revision 2, Non Proprietary Version of Criticality Safety Analysis of SFP for Callaway Nuclear Generating Station ML22285A1252022-10-12012 October 2022 Attachment 8 to Enclosure 1: ANP-3969NP, Callaway Non-LOCA Summary Report, Revision 2, Dated October 2022 ML22285A1222022-10-12012 October 2022 Attachment 5 to Enclosure 1: ANP-3947NP, Callaway Unit 1 License Amendment Request Inputs for Use of Framatome Fuel, Revision 3, Dated October 2022 ML22285A1232022-10-12012 October 2022 Attachment 6 to Enclosure 1: ANP-3944NP, Callaway Realistic Large Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 ML22285A1242022-10-12012 October 2022 Attachment 7 to Enclosure 1: ANP-3943NP, Callaway Small Break LOCA Analysis with Gaia Fuel Design, Revision 1, Dated October 2022 ML22181B1362022-06-30030 June 2022 Attachment 6 - Replacement for Attachment 6, Description and Assessment Specific to TSTF-439, of ULNRC-06688 ML22181B1402022-06-30030 June 2022 Enclosure 1 - Replacement for Enclosure 1, List of Revised Required Actions to Corresponding PRA Functions, of ULNRC-06688 ML22181B1412022-06-30030 June 2022 Enclosure 4 - Replacement for Enclosure 4, Information Supporting Justification of Excluding Sources of Risk Not Addressed by the PRA Models, of ULNRC-06688 ML22153A1822022-06-0202 June 2022 Attachment 6 - Non-Proprietary Version of Rlbloca Summary Report ML22153A1832022-06-0202 June 2022 Attachment 7 - Non-Proprietary Version of SBLOCA Summary Report ML22153A1852022-06-0202 June 2022 Attachment 8 - Non-Proprietary Version of Non-LOCA Summary Report ULNRC-06715, Enclosure 3: Attachment a to the NPDES Permit Modification Application2022-03-0101 March 2022 Enclosure 3: Attachment a to the NPDES Permit Modification Application ML22027A8082022-01-27027 January 2022 Enclosure 3: Callaway, Unit 1, Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02 ML22027A8092022-01-27027 January 2022 Enclosure 4: Callaway, Unit 1, Acronyms and Definitions ML22027A8062022-01-27027 January 2022 Enclosure 1: Request for Exemptions for Risk-Informed Approach to Resolution for Generic Letter 2004-02 ML21356B5072021-12-22022 December 2021 Enclosure 1: Mark-up of Operating License (OL) ML21356B5082021-12-22022 December 2021 Enclosure 2: Clean Copy of Affected OL Pages (Reflecting Proposed Change) ML21343A0952021-12-0909 December 2021 Attachment 1: Description and Assessment ML21335A1602021-12-0101 December 2021 Special Report 2021-02: Accident Monitoring Instrumentation Non-Functional for Greater than 7 Days ML21280A3802021-10-0707 October 2021 Cumulative Summary of Changes to Enclosure 2, License Amendment Request, and Enclosure 3, Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526 ML21280A3812021-10-0707 October 2021 License Amendment Request for Risk-Informed Approach to Resolution of Generic Letter 2004-02 ML21272A1702021-09-28028 September 2021 Enclosure 2 - Full Scope Implementation of Alternative Source Term Evaluation of Proposed Changes (Redacted) ULNRC-06683, Enclosure 3: Callaway, Unit 1, Amendment Request Regarding Risk-Informed Approach to Closure of Generic Safety Issue 191 - CAL Roverd Results Baseline (Non-Isolable Breaks)2021-08-23023 August 2021 Enclosure 3: Callaway, Unit 1, Amendment Request Regarding Risk-Informed Approach to Closure of Generic Safety Issue 191 - CAL Roverd Results Baseline (Non-Isolable Breaks) ML21237A1372021-08-23023 August 2021 Enclosure 1: Callaway, Unit 1, Amendment Request Regarding Risk-Informed Approach to Closure of Generic Safety Issue 191 - Baseline Weld Input 2024-05-01
[Table view] Category:Miscellaneous
MONTHYEARML24115A0992024-04-0101 April 2024 EIP-ZZ-A0066, Rev 30, RERP Training Program ML24086A5142024-03-26026 March 2024 Changes to the Westinghouse and Framatome ECCS Evaluation Models and PCT Penalty Assessments ULNRC-06861, Westinghouse and Framatome, ECCS Evaluation Model Margin Assessments2024-03-26026 March 2024 Westinghouse and Framatome, ECCS Evaluation Model Margin Assessments ML23156A6712023-06-0505 June 2023 Description and Justification for Changes ML23131A3882023-04-26026 April 2023 EIP-ZZ-PRO2O Minor Revision 54, Activation and Operation of the Joint Information Center - Procedure Review Form and 50.54(q) Screening Form ML24115A1002023-03-26026 March 2023 EIP-ZZ-PRO2O, Rev. 55, Activation and Operation of the Joint Information Center ML23068A0992023-03-0909 March 2023 Special Report 2023-01 PAM Report ULNRC-06715, Enclosure 3: Attachment a to the NPDES Permit Modification Application2022-03-0101 March 2022 Enclosure 3: Attachment a to the NPDES Permit Modification Application ML22027A8092022-01-27027 January 2022 Enclosure 4: Callaway, Unit 1, Acronyms and Definitions ML22027A8062022-01-27027 January 2022 Enclosure 1: Request for Exemptions for Risk-Informed Approach to Resolution for Generic Letter 2004-02 ML21356B5072021-12-22022 December 2021 Enclosure 1: Mark-up of Operating License (OL) ML21356B5082021-12-22022 December 2021 Enclosure 2: Clean Copy of Affected OL Pages (Reflecting Proposed Change) ML21343A0952021-12-0909 December 2021 Attachment 1: Description and Assessment ML21335A1602021-12-0101 December 2021 Special Report 2021-02: Accident Monitoring Instrumentation Non-Functional for Greater than 7 Days ML21280A3812021-10-0707 October 2021 License Amendment Request for Risk-Informed Approach to Resolution of Generic Letter 2004-02 ML21280A3802021-10-0707 October 2021 Cumulative Summary of Changes to Enclosure 2, License Amendment Request, and Enclosure 3, Callaway Methodology for a Risk-Informed Approach to Address Generic Letter 2004-02, of ULNRC-06526 ML21173A3412021-06-22022 June 2021 CFR 50.59 and 10 CFR 72.48 Summary Report - May 16, 2019 to June 15, 2021 ULNRC-06437, Cycle 22 Commitment Change Summary Report2018-06-0707 June 2018 Cycle 22 Commitment Change Summary Report ML17097A5582017-03-30030 March 2017 Enclosure 2 to ULNRC-06349 - Minimum Decommissioning Cost - Per 10 CFR 50.75 Formula Process ULNRC-06349, Callaway, Unit 1 - Enclosure 2 to ULNRC-06349 - Minimum Decommissioning Cost - Per 10 CFR 50.75 Formula Process2017-03-30030 March 2017 Callaway, Unit 1 - Enclosure 2 to ULNRC-06349 - Minimum Decommissioning Cost - Per 10 CFR 50.75 Formula Process ML16160A0952016-06-0808 June 2016 ASP ANALYSIS-REJECT- Callaway Unit 1 Auxiliary Feedwater Control Valves in Motor Driven Pump Train Inoperable due to Faulty Electric positioner Cards (LER 483-2015-003 and 483-2015-004) ULNRC-06292, Transmittal of 10 CFR50.46 Annual Report ECCS Evaluation Model Revisions2016-03-30030 March 2016 Transmittal of 10 CFR50.46 Annual Report ECCS Evaluation Model Revisions ULNRC-06199, Nuclear Property Insurance Reporting2015-03-18018 March 2015 Nuclear Property Insurance Reporting ULNRC-06173, Submits Owner'S Activity Reports (OAR-1 Forms) for Cycle 20 and Refuel 202015-02-19019 February 2015 Submits Owner'S Activity Reports (OAR-1 Forms) for Cycle 20 and Refuel 20 ML14310A8362015-02-0909 February 2015 NRC Staff Evaluation of Final Rule for Continued Storage of Spent Nuclear Fuel for the License Renewal Environmental Review for Callaway, Unit 1 ULNRC-06168, Enclosure 5 - 10-K Filed Period 12/31/2013 - Ameren2014-12-18018 December 2014 Enclosure 5 - 10-K Filed Period 12/31/2013 - Ameren ULNRC-06168, Enclosure 7 - 10-Q Filed Period 6/30/2014 Ameren2014-12-18018 December 2014 Enclosure 7 - 10-Q Filed Period 6/30/2014 Ameren ULNRC-06168, Enclosure 10 - Articles of Incorporation Ameren Corporation Restated 10/17/19952014-12-18018 December 2014 Enclosure 10 - Articles of Incorporation Ameren Corporation Restated 10/17/1995 ULNRC-06168, Enclosure 8 - 10-Q Filed Period 9/30/2014 Ameren2014-12-18018 December 2014 Enclosure 8 - 10-Q Filed Period 9/30/2014 Ameren ULNRC-06168, Enclosure 9 - Articles of Incorporation Ameren Corporation Dated 08/07/19952014-12-18018 December 2014 Enclosure 9 - Articles of Incorporation Ameren Corporation Dated 08/07/1995 ULNRC-06168, Enclosure 14 - Defc 14c Filed Period 3/11/2014 - Union Electric2014-12-18018 December 2014 Enclosure 14 - Defc 14c Filed Period 3/11/2014 - Union Electric ULNRC-06168, Enclosure 6 - 10-Q Filed Period 3/31/2014 - Ameren2014-12-18018 December 2014 Enclosure 6 - 10-Q Filed Period 3/31/2014 - Ameren ULNRC-06168, Enclosure 11 - Ameren Corporation By-Laws Effective 12/14/20122014-12-18018 December 2014 Enclosure 11 - Ameren Corporation By-Laws Effective 12/14/2012 ULNRC-06168, Enclosure 4 - 2013 Annual Report (Includes 2013 Form 10-K) - Ameren2014-12-18018 December 2014 Enclosure 4 - 2013 Annual Report (Includes 2013 Form 10-K) - Ameren ULNRC-06168, Enclosure 16 - Articles of Incorporation - Union Electric Company Restated 04/12/19942014-12-18018 December 2014 Enclosure 16 - Articles of Incorporation - Union Electric Company Restated 04/12/1994 ML14352A4342014-12-18018 December 2014 Enclosure 11 - Ameren Corporation By-Laws Effective 12/14/2012 ML14352A4472014-12-18018 December 2014 Enclosure 3 - 2014 Proxy Statement of Ameren Corporation - Ameren ML14352A4432014-12-18018 December 2014 Enclosure 10 - Articles of Incorporation Ameren Corporation Restated 10/17/1995 ML14352A4412014-12-18018 December 2014 Enclosure 7 - 10-Q Filed Period 6/30/2014 Ameren ML14352A4402014-12-18018 December 2014 Enclosure 5 - 10-K Filed Period 12/31/2013 - Ameren ML14352A4392014-12-18018 December 2014 Enclosure 8 - 10-Q Filed Period 9/30/2014 Ameren ML14352A4382014-12-18018 December 2014 Enclosure 9 - Articles of Incorporation Ameren Corporation Dated 08/07/1995 ML14352A4362014-12-18018 December 2014 Enclosure 14 - Defc 14c Filed Period 3/11/2014 - Union Electric ML14352A4352014-12-18018 December 2014 Enclosure 6 - 10-Q Filed Period 3/31/2014 - Ameren ML14352A4332014-12-18018 December 2014 Enclosure 4 - 2013 Annual Report (Includes 2013 Form 10-K) - Ameren ML14352A4322014-12-18018 December 2014 Enclosure 16 - Articles of Incorporation - Union Electric Company Restated 04/12/1994 ML14352A4302014-12-18018 December 2014 Enclosure 17 - By-Laws of Union Electric Company as Amended to 12/10/2010 ML14352A4292014-12-18018 December 2014 Enclosure 15 - Articles of Incorporation - Missouri Electric Light and Power Company Dated 11/20/1922 ULNRC-06168, Enclosure 17 - By-Laws of Union Electric Company as Amended to 12/10/20102014-12-18018 December 2014 Enclosure 17 - By-Laws of Union Electric Company as Amended to 12/10/2010 ULNRC-06168, Enclosure 15 - Articles of Incorporation - Missouri Electric Light and Power Company Dated 11/20/19222014-12-18018 December 2014 Enclosure 15 - Articles of Incorporation - Missouri Electric Light and Power Company Dated 11/20/1922 2024-04-01
[Table view] |
Text
ARB
SUMMARY
Responsible RPBB RIV-2007-A-0048 Branch Facility Name Callaway ARB Date: April 17, 2007 Docket Number 050-483 01 Case No.: ARB DECISION Purpose of ARB Initial Previous N/A Decisions Today's Decision RPBB to inspect all 3 concerns.Basis for Another ARB REFERRAL Refer to: Criteria Reviewed?Referral Rationale 01 INVESTIGATION Priority Rationale DOL Deferral Rationale ARB PARTICIPANTS
(' denotes.ARB Chairman Approval)JWalker HFreeman KFuller DWhite AHowell*DChamberiain W MVasquez VGaddy MBloodgood I Information in this record was deleted in accordance with the Freedom of Informatiorn Act, exemptions
')C S"0fA- o___ ,_o_-____se-G Iv -3cu.rift lestod InforM-8tirin CONCERNS LIST RIv-2007-A-0048 Concern (Brief Statement)
Reulatory Requirement Branch Action (Inspect, Refer, Planned..
Significance 01 Prority Investigate, No Action) Completion
((High, (H, N, L)* ' Normal)1 The licensee decided, due to economic reasons, to not 10 CFR 50 App. B correct a long standing design deficiency on the RHR Criterion XVI suction relief valves' discharge piping during the spring 2007 (, refueling outage but wait until the next refueling outage. p_ _ _ _ _ _ _RPBB Inspect 5/17/07 Normal L 2 The licensee changed the RHR suction relief valve 10 CFR 50 App. B surveillance from a staggered test basis to reduce the Criterion XI probability of identifying a failed valve while the valve is in the system. This again was an economic decision.RPBB Inspect 5/17/07 Normal L 3 The licensee delayed testing RHR suction relief valve that 10 CFR 50 App. B had been previously removed. A mid-cycle outage would Criterion Xl have been required to replace the other valve if the valve had failed its test.RPBB Inspect 5/17/07 Normal L 4 5 6 Revised 5/22/02 Indirect Charaes Al 0304 Support for Allegations (Reactors)
Al 0191 Support for Allegations (Materials)
Direct Inspection Activities AF BJ2 AFT Allegation Followup Allegation Prep/Doc Allegation Travel ALLEGATION RECEIPT FORM Page 24 Received By: Michael Peck Receipt Date: April 6, 2007 Receipt Method (meeting, phone call, letter, Plant Mail -Letter etc.)FACILITY Facility Name Callaway Plant Location Fulton, Missouri Docket(s)50-483 CONCERN Summary the of Concerns (be brief)* AmerenUE deferred corrective action for a potentially significant design deficiency from the current refueling outage until the next refueling outage.This design deficiency has been a long standing problem (please see attached letter).Delay in testing RHR relief valves (removed October 2005, not tested until August 2006).*AmerenUE changed RHR relief valve surveillance from a staggered test bases to reduce the probability of identifying a failed valve.,Obtain concern specifics.
What Is the concern, when did It occur, who was Involved, oft. t the conoern Involves dtrimlrnation.'fll In the last section o1 the torm.The Callaway RHR suction relief and PORV discharge are routed through a common discharge line into the PRT. During operating cycle 14, the PORV lifted several times during a plant transient.
The PRT pressurized, lifting a column of water up the common discharge line. This water collected on the backside of the RHR relief valve. A subsequent PORV lift caused a significant water hammer against the back side of the RHR relief valve, damaging the valve internals.
The licensee's interim corrective action was to declare the RHR relief valves inoperable if the PORV should lift. AmerenUE had scheduled modification to correct the design problem this outage, but deferred the modification until the following refueling outage.What Is the potential safety impact? Is this an ongolna concern?1. Unavailability of the RHR suction relief valves for cold pressure over protection (Technical Specification 3.4.12).2. Potential loss of RHR pressure boundary -RWST drains to PRT (loss of both cold leg injection and cold leg recirculation modes of ECCS).What requlrement/reauiation governs this concern?50.50.a, ASME Code (relief valve discharge must have a drain path), 50, App B, Criteria 16, prompt corrective actions What records should the NRC review?CARS 200703254, 200609805, 200607188, Mod MP 07-0007, LER 05000483/2006-008-00 NRC Component Design Bases Inspection Report 05000483/2006009 What other Individuals could the NRC contact for Information?
n/a How did the Individual find out about the concern?
ALLEGATION RECEIPT FORM Page 25 Served on as Root Cause Team Member Was the concern brought to management's attention?
If so. what actions have been taken, If not, why not?Why was the concern brmuaht to the NRCs attention?
ALLEGATION RECEIPT FORM Page 26 ALLEGER INFORMATION Full Name "Redacted]
Employer AmerenUE Mailing Address (Home) [Redacted]
Occupation Engineer Telephone (Daytime) odace Relationship to facility Employee (Other)Preference for method and time n/a Was the Individual advised of no of contact identity protection Referral Explain that If the concerns are referred to the licensee, that alleger's Identity will not be revealed and that the NRC will review and evaluate the thoroughness and adequacy of the licensee's response.
Nf the concerns are an agreement state issue or the )urlsdiction of another agency, explain that we will rater the concern to the appropriate agency, and If the alleger agrees, we will provide the alleger's Identity for followup.Does the Individual object to the n/a Does the Individual object to n/a referral?
releasing their identity?Regulations prohibit NRC licensees (including contractors and subcontractors) from discriminating against Individuals who engage In protected activities (alleging violations of regulatory requirements, refusing to engage in practices made unlawful by statues, etc.).Does the concern involve n/a Was the Individual advised of the No discrimination?
DOL process?What was the protected activity?Yes What adverse actions have been taken? When?n/a Why does the individual believe the actions were taken as a result of en-,aging in a protected activit?Revised 9/3/0.
April 5, 2007 Michael Peck Nuclear Regulatory Commission Senior Resident Inspector Callaway Plant Mr. Peck The Primary Relief Tank Common Relief Valve Discharge Header at Callaway Plant is not properly designed:
the arrangement of the piping permits the RHR Suction Relief Valves to be damaged by a water slug propelled down the pipe when a Pressurizer PORV is actuated at Normal Operating Pressure.Callaway Plant management has known about this liability since September 22, 2006.The liability was formally documente Cause doio-CAR-z206071 88 in October 2006. 1 was the b)(7)c b)(7)c I 1ln October 2006 b)(7)c e anager of Desig ngineenng (then Fadi Diya) that the piping arrangement was inadequate and needed to be corrected at the next opportunity (Refueling Outage 15).After questioning the Root Cause Team's findings for three months, Callaway Plant approved Modification Package MP 07-0007 on January 26, 2007. 1 learned late in the evening on April 3 that MP 07-0007 has been removed from RF15.Ogb)(7)C the Manager of Design Engineering (now Mark McLathlan) b)(7 .. ecision to not modify the PRT Common Relief Valve Discharge eader dumrig RF15 might not be viewed favorably by the NRC. Mr. McLachlan's response was that it was not the NRC's decision as to whether or not we performed the modification.
Callaway Plant had evaluaed the Operability of the system with an Operability Determination and could decide to defer the modification based on a Probabilistic Risk Assessment.
If the NRC disagreed with our decisions, they could challenge our decisions during their routine or special inspections.
I was directed to CARS 200609805, Action 13 for the justification.
CARS 200609805, Action 13 states: There were no instances where the set pressure of a relief was lowered, so loss of inventory from low pressure actuation is not considered credible.I'am not satisfied that a low pressure actuation is not considered credible.
The-events of February 11, 2004 caused the assembly pins of these valves to break into many pieces.With assembly pin fragments (FME) present as the bellows assembly is moving up and/V -AW-4 0 q9 1 down due to the water hammer transient on the PRT Common Relief Discharge Header, I believe it is credible that an assembly pin fragment might lodge in such a manner that the full spring for'ce is no longer applied to the center of the disk. With metal FME present along wi'tAl movement, many things are credible."b)(7)c o neeIms were documented in CARS 200703254, Inadequate LTs 0 1 ction to Safety Related System one cycle. CARS 200703254 was screened a Sig 4 (Corrective Action Only) meaning no investigation of the inadequacy of the CARS 200609805, Action 13 response nor any investigation of the inadequacy of our PI&R and modification processes is necessary.
Note that Callaway Plant has had many opportunities to discover and corrept the. design deficiencies of the PRT Common Relief Valve Discharge Header: In 1993, while pressurizing the RCS to start Reactor Coolant Pumps fbr the RF6 heatup, a RHR Suction Relief Valve lifted at 350 psig (more than 100 psi below its setpoint), causing RCS pressure to blowdown to approximately 100 psig. This valve was installed in the system during the February 13, 1989: Safety Injection and had not passed a surveillance lift since that time ýevery time it was tested it needed to be adjusted).
When the valve was disassembled in 1994, the assembly pin was found broken in five pieces. An inadequate PI&R failed to determine the cause of the valve failure and closed the issue stating: "Based on past history and the design of the valve, this incident is considered an isolated case."* Contrary to good engineering practice, the RHR Suction Relief valve surveillances are not performed on a staggered test basis. Performing these surveillances on a staggered test basis would have, resulted in the removal and testing of one of the valves damaged in the 2004 Safety Injection an entire cycle earlier., The valves removed in October 2005 were not tested until August 2006. It is not understood why this 10 month delay was necessary.
Instead of suffering for having an inadequate PI&R process, Callaway Plant benefits from it. Had one~of the damaged valves been removed in RF13 and failed its bench test during cycle 14, Callaway Plant may have been forced into a mid-cycle outage to replace the other valve. Had the valves removed in RFI 4 been bench tested earlier in the cyclei Callaway Plant may have been expected to makemore of an effort to correct the design deficiencies of the PRT Common Relief Valve Discharge Header during RFI 5, incurring unbudgeted expenditures.
It appears Callaway Plant has made a sound business decision.
Delaying exit from RF1 5 potentially costs Ameren $1 million/day in lost generation.
Due to our procrastination mad inadequate decision making, MP 07-0007 could delay our exit from RF1 5 were we to attempt to perform itJduring this outage. We have once again decided that it is worth the regulatory risk to not do the right thing (correct known deficiencies with safety related equipment).
This is a sound business decision because if the NRC were: to challenge our response to CARS 200609805, Action 13, and if the NRC were to issue a finding and fine 2 due tO inadequate technical rigor in our response, it is extremely unlikely the amount of the fine the NRC could level would -be any comparison to the loss generation the company could suffer by delaying its exit from RFI5.Another item of note is the response to CARS 200607188, Action. 11.4. This action requested the surveillance frequency for testing the RHR Suction Relief Valves be performed on a staggered test basis. The response clearly indicates the reason the company does not wish to perform the surveillance on a staggered test basis is because we would be better off not knowing of a potential problem with the other train's valve until the valve is no longer in the system and current (vice past) operability is no longer an issue. Again, based on the limited regulatory fallout from having no opemble.RHR Suction Relief Valves and no operable (for COMS) PORVs for morelthan anmentire fuel cycle, theyrefusal to perform these surveillances on a staggered test basis appears to be a sound business decision.I have attempted to address the inadequacy of the PRT Common i .ar with my management through sever m hods: b)(7)c or AR b)()L in.Z o er2006, b)(7)- NIr. ...er an esi en ineer: for MP .07-0007 ou nter mo b)(7)c b)() r. McLachlan b)(7)c ARS 254. allaway Plant. managment
.e *eves it is doing e n t thing in-delaying MP 07-0007 until R-F16. I would like verification freim the NRC that they agree with Callaway's actions. I recognize the'NRC has 30 days to respond to me. If possible, I would like an answer before the plant is next in MODE 5 -ascending (currently scheduled for April 20,2007).Please contact me a f you have any questions regarding this issue.Thank you,.3