ML042610123
| ML042610123 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/23/2003 |
| From: | Marschall C NRC/RGN-IV/DRS/EMB |
| To: | Randolph G Union Electric Co |
| References | |
| FOIA/PA-2004-0277, IR-03-007 | |
| Download: ML042610123 (4) | |
See also: IR 05000483/2003007
Text
Staceqy L. Munroe -NRR
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EFHV052
Essential Service Water Train B To Component Cooling Water Heat Exchanger B
EGHVOI16
Component Cooling Water Train B Supply/Return Isotation
EGHV054
Component Cooling Water Train 6 Supply Isolation
EGHIV102
Component Cooling Water To Residual Heat Removal Heat Exchanger B Isolation
EJFCV611
Residual Heat Removal Pump B Miniflow Control Valve
EJHV8701B
Residual Heat Removal Pump B Suction Isolation
EJHV8716A
Residual Heat Removal Train A Safety Injection System Hot Leg Recirculation Isolation
EJHW8716B
Residual Heat Removal Train B Safety Injection System Hot Leg Recirculation Isolation
EJHV8804B
Residual Heat Removal Train B Safety Injection Pump Supply Isolation
EJHV8811lA
Containment Recirculation Sump A To Residual Heat Removal Pump A Suction Isolation
EJHV881 1B
Containment Recirculation Sump B To Residual Heat Removal Pump B Suction Isolation
EMHV8801 B
Boron Injection Tank Outlet To Cold Legs Isolation B
EMWV8803B
Boron Injection Tank Supply From Centrifugal Charging Pump B Isolation
EMHV8814A
Safety Injection Pump A Recirculation To Refueling Water Storage Tank Isolation
EMHV881 46
Safety Injection Pump B Recirculation To Refueling Water Storage Tank Isolation
EMHV8821A
Safety Injection Pump A Discharge To Cold Leg Injection Isolation
EMHV8a2I B
Safety Injection Pump B Discharge To Cold Leg Injection Isolation
EMHV8923A
Refueling Water Storage Tank To Safety Injection Pump A Suction Isolation
EMHV8923B
Refueling Water Storage Tank To Safety Injection Pump 6 Suction Isolation
The inspectors considered this item to be unresolved, pending a determination of whether any of
the remaining 42 potentially affected valves would be damaged if they were to spuriously actuate
from a hot short during a control room fire, If any of the valves were incapable of being manually.
re-positioned during the post-control room evacuation steps of Procedure OTO-ZZ-00001, then
the licensee's alternative 'shutdown capability would not be In compliance with the Operating
License. This was identified as an unresolved item (50-483/9904-02). During the supplemental
exit meeting conducted by telephone conference call on April 13, 1999, the licensee committed to
develop a plan to'evaluate the 42 subject valves.
July 23, 2003
Garry L. Randolph, Senior Vice
President and Chief Nuclear Officer
Union Electric Company
P.O. Box 620
Fulton, Missouri 65251
SUBJECT:
CALLAWAY -NOTIFICATION OFAN NRC TRIENNIAL FIRE PROTECTION BASELINE
INSPECTION 05000483/2003007
Dear Mr. Randolph:
The purpose of this letter is to notify you that the U.S. Nuclear Regulatory Commission (NRC), Region IV
staff, will conduct a triennial fire protection baseline Inspection at your Callaway Plant in September of
2003. The inspection team will be comprised of a team of reactor inspectors from the NRC Region IV
office and a contractor. The Inspection will be conducted In accordance with Inspection
Procedure 71111.05, "Fire Protection," the NRC's baseline fire protection Inspection procedure.
StcyL. Munroe - NRR open items~j tbewpd
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The schedule for the inspection is as follows:
- Information
gathering Visit - September 9 - 11, 2003
- Onsite
inspection - September 22 - October 2, 2003
Members of the inspection team will Visit the Callaway Plant from September 9 to 1 1, 2003, to gather
Informnation and documents needed to support the Inspection, obtain unescorted access, and to become
familiar with your fire protection program. The enclosure to this letter provides a list of the types of
documents the team will want to review. After review the team leader will request that you transmit
copies of some of the documents to the NRC, Region IV office for team use in preparation for the
inspection. We would appreciate it if you could send this information so that it will arrive in our office in
Arlington, Texas, no later than noon on September 15, 2003.
We request that during the onsite Inspection week, you ensure that copies of analyses, evaluations, or
documentation regarding the Implementation and maintenance of the fire protection program, Including
post-fire safe shutdown capability, be readily accessible to the team for their review. Of specific Interest
are those documents that establish that your fire protection program satisfies N RC regulatory
requirements and conforms to applicable NRC and industry fire protection guidance. Also, appropriate
personnel knowledgeable of:' (1) those plant systems required to achieve and maintain safe shutdown
conditions from inside and outside the control room, (2) the electrical aspects of the post-fire safe
shutdown analyses, (3) reactor plant fire protection systems, and (4) the fire protection program and its
implementation should be available to support the team at the site during the inspection.
Your cooperation and support during this Inspection will be appreciated. If you have questions
concerning this inspection or the inspection team's information or logistical needs, please contact
Rebecca L. Nease at 817-860-8154.
Sincerely,
/RAN RLN for
Charles S. Marschall, Chief
Engineering and Maintenance Branch
Division of Reactor Safety
Enclosure:
Triennial Fire Protection Inspection Supporting Documentation
Docket: 50-483
License: NPF-30
3tacey L. Munroe - NRR openI items table.w~pd
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.2
Fire Protection of Safe Shutdown Capability and Post-fire Safe Shutdown Circuit Analysis
a.
Inspection Scope
The team reviewed licensee documentation to verify that at least one post-fire safe shutdown
success path was free of fire damage In the event of a fire in the selected fire areas. Specifically,
the team examined the separation of safe shutdown cables, equipment, and components within
the same fire areas. The team reviewed, on a sample basis, the analysis of electrical protective
devices (e.g., circuit breakers, fuses, relays), coordination, and adequacy of electrical protection
provided for nonessential cables, which share a common enclosure (e.g., cable trays) with cables
of equipment required to achieve and maintain safe shutdown conditions. Additionally, the team
reviewed the protection of diagnostic instrumentation required for safe shutdown for fires in the
selected areas. The team reviewed the licensee's methodology for meeting the requirements of
10 CFR 50.48, and the bases for the NRC's acceptance of this methodology as documented in
NRC safety evaluation reports. In addition, the team reviewed license documentation, such as,
the Updated Final Safety Evaluation Report, submittals made to the NRC by the licensee In
support of the NRC's review of their fire protection program, and deviations from NRC regulations
to verify that the licensee met license commitments.
b.
Findings
Introduction. The scope of Inspection Procedure 71111.05 has been temporarily reduced to stop
requiring inspectors to address fire-induced circuit failure of associated circuits as a direct line of
inquiry, nor to require developing associated circuit inspection findings. This was being done in
order to allow the industry to develop an approach acceptable to the NRC for resolving this issue.
However, during the course of this inspection, a number of associated circuit vulnerabilities were
incidentally identified. These circuit vulnerabilities could, under certain postulated fire scenarios,
adversely affect the ability to achieve and maintain safe shutdown of the facility.
Description. Appendix R, Section lll.G.1 of 10 CFR Part 50, requires that one train of systems
needed to achieve and maintain hot shutdown conditions must be free of fire damage. Section
Ill.G.2 states that cables or equipment, including associated non-safety-related circuits that could
prevent operation or cause mal-operation due to fire damage of redundant trains of systems
necessary to achieve and maintain hot shutdown conditions, must be protected. The Callaway
Updated Final Safety Analysis Report allows either "free of fire damage, or a diverse means will
be provided." The team identified some associated circuit issues that are neither-protected from
fire damage nor provided with a diverse means of providing the function. Specific examples of
equipment or associated cables located within the fire areas reviewed by the team that could
affect the safe shutdown process included:
Fire Area A-21 - possible loss-of-seal water Injection capability to any one of the four
reactor coolant pumps, which could lead to seal failure; and inability to isolate any one of
the four main steam Isolation valves or main feedwater isolation valves, which cool lead to
overcooling of the reactor coolant system.
Fire Area A-1 8 - loss of thermal barrier cooling to any one of four reactor coolant pumps,
which could lead to seal failure; spurious opening of a pressurizer spray valve or the
pressurizer auxiliary spray valve, which could lead to uncontrolled depressurization and
overfilling the reactor coolant system; spurious opening of a containment emergency
recirculation sump isolation valve that could divert water from the refueling water storage
tank to the containment sump and make It unavailable for coolant inventory control;
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spurious opening of a reactor head vent flow path, causing a loss-of-coolant and
uncontrolled depressurization; and spurious closing of either steam admission valves to
the turbine driven auxiliary feedwater pump, making it unavailable for decay heat removal.
Fire Area 0-9 - spurious closure of a volume control tank outlet valve, causing a loss of
charging, affecting reactor coolant inventory control and reactor coolant pump seal
cooling.
Analysis. This finding is unresolved pending additional action by the NRC. See below.
Enforcement. Failure to either protect these associated circuits from spurious operation or
otherwise prevent them from affecting safe shutdown is an apparent violation of Appendix R,
Section lll.G.2. In accordance with the NRC Enforcement Manual, Section 8.1 .7.1 .a, this
apparent violation will be treated as an unresolved item pending development of an industry
method to resolve these types of issues; Unresolved Item 05000483/2003007-01, Failure to
Protect Associated Circuits. The determination of the safety significance and disposition of this
apparent violation will be performed after the NRC develops additional guidance for addressing
associated circuit issues. This issue Is In the licensee's corrective action program under Callaway
Action Request 200307232. This Callaway action request Included an action to evaluate whether
any specific compensatory actions were needed.