ML050830208

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Response to Generic Letter 2004-02: Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized-Water Reactors
ML050830208
Person / Time
Site: Callaway Ameren icon.png
Issue date: 03/07/2005
From: Moser T
AmerenUE
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, ULNRC-05124
Download: ML050830208 (8)


Text

I AmerenUE Calla way Plant PO Box 620 Fulton, MO 65251 March 7, 2005 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P I-137 Washington, DC 20555-0001 WAmerea UE ULNRC-05124 Ladies and Gentlemen:

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

FACILITY OPERATING LICENSE NPF-30 RESPONSE TO GENERIC LETTER 2004-02: "POTENTIAL IMPACT OF DEBRIS BLOCKAGE ON EMERGENCY RECIRCULATION DURING DESIGN BASIS ACCIDENTS AT PRESSURIZED-WATER REACTORS" Enclosed is the Union Electric Company (AmerenUE) response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors." Within 90 days of the date of the NRC safety evaluation report providing the guidance for performing the requested evaluation, the generic letter requires licensees to provide information regarding their planned actions and schedule to complete the requested evaluation.

Attachment I to this letter provides AmerenUE's 90-day response to the requested information. Attachment II lists AmerenUE's commitments contained in this letter.

AmerenUE will also provide the information requested by Part 2 of the generic letter by September 1, 2005.

a subsidiary of Ameren Corporation

ULNRC-05 124 March 7, 2005 Page 2 If you have any questions concerning this matter, please contact Mr. Keith Young at (573) 676-8659, or Mr. Dave Shafer at (314) 554-3104.

Sincerely, Tod A. Moser Manager, Plant Engineering Attachments: I - 90 day Responses II - List of Commitments

ULNRC-05124 March 7, 2005 Page 3 Mr. Bruce S. Mallett Regional Administrator U.S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-4005 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Jack N. Donohew (2 copies)

Licensing Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 7E1 Washington, DC 20555-2738 Missouri Public Service Commission Governor Office Building 200 Madison Street PO Box 360 Jefferson City, MO 65102-0360 Mr. Jerry B. Uhlmann Director Missouri State Emergency Management Agency P.O. Box 116 Jefferson City, MO 65102

ULNRC-05124 March 7. 2005 Page 4 bcc:

C. D. Naslund C. R. Younie K. D. Young G. A. Hughes D. E. Shafer (470) (2 copies)

S. L. Gallagher (100)

S. L. Klang (NSRB)

M. A. Reidmeyer E. W. Henson A160.0761 Ms. Diane M. Hooper Supervisor, Licensing WCNOC P.O. Box 411 Burlington. KS 66839 Mr. Scott Bauer Regulatory Affairs Palo Verde NGS P.O. Box 52034, Mail Station 7636 Phoenix, AZ 85072-2034 Mr. Scott Head Supervisor, Licensing SouthTexas Project NOC Mail Code N5014 P.O. Box 289 Wadsworth. TX 77483 Mr. Dennis Buschbaum TXU Power Comanche Peak SES P.O. Box 1002 Glen Rose, TX 76043 Mr. Stan Ketelsen Manager, Regulatory Services Pacific Gas & Electric Mail Stop 104/5/536 P.O. Box 56 Avila Beach, CA 93424 Certrec Corporation 4200 South H-lulen, Suite 630 Fort Worth, TX 76109 (Certrec receives ALL attnachmzents)

Mr. John O'Neill Shaw, Pittman 2300 N. Street N.W.

Washington, DC 20037

ULNRC-05124 March 7, 2005 Page 5 STATE OF MISSOURI

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SS COUNTY OF CALLAWAY)

Tod A. Moser, of lawful age, being first duly sworn upon oath says that he is Manager, Plant Engineering 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 y

Tod A. Moser Manager, Plant Engineering SUBSCRIBED and sworn to before me this '7 day of PIA Out-h 2005.

TERRA E. GUITTAR Notary Public-Notary Seal

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State of Missouri. Caloaway County My Commission Expires May 13, 2006

ULNRC-05124 Attachment I Page 1 of 2 90-Day Response to NRC Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors Below is AmerenUE's response to NRC issued Generic Letter 2004-02, Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors. The generic letter's "Requested Information" is shown in bold followed by AmerenUE's response.

NRC Requested Information 1 Within 90 days of the date of the safety evaluation report providing the guidance for performing the requested evaluation, addressees are requested to provide information regarding their planned actions and schedule to complete the requested evaluation. The information should include the following:

NRC Requested Information 1(a):

[Providel A description of the methodology that is used or will be used to analyze the susceptibility of the ECCS and CSS recirculation functions for your reactor to the adverse effects identified in this generic letter of post-accident debris blockage and operation with debris-laden fluids identified in this generic letter. Provide the completion date of the analysis that will be performed.

AmerenUE Response 1(a):

AmerenUE plans to analyze the susceptibility of the emergency core cooling system (ECCS) and containment spray system (CSS) recirculation functions for the Callaway plant to the adverse effects of post-accident debris blockage and operation with debris-laden fluids identified in the Generic Letter 2004-02 using the guidance of Nuclear Energy Institute (NEI) document titled "Pressurized-JMater Reactor (PTYR) Sump Performance Methodology, " dated May 28, 2004 which was approved and supplemented by the NRC in SER dated December 6, 2004. The sump performance methodology and the associated NRC SER have been issued collectively as Nuclear Energy Institute Report NEI 04-07 (Reference 1).

The current licensing basis for Callaway as well as plant-specific features may identify exceptions and/or refinements to be taken to the guidance given in NEI 04-07. There are no exceptions or refinements identified at this time. Additional data from ongoing research on specific issues such as downstream effects, chemical effects, and coatings may also impact the methodology and guidance described in NEI 04-07. All exceptions or refinements to the guidance given in NEI 04-07, should they be taken, will be identified and a basis for them documented in the completed analysis. This analysis is scheduled to be completed by September 1, 2005.

ULNRC-05124 Attachment I Page 2 of 2 NRC Requested Information 1(b):

IProvide] A statement of whether you plan to perform a containnment walkdown surveillance in support of the analysis of the susceptibility of the ECCS and CSS recirculation functions to the adverse effects of debris blockage identified in this generic letter. Provide justification if no containment walkdown surveillance will be performed. If a containment walkdown surveillance will be performed, state the planned methodology to be used and the planned completion date.

AmerenUE Response 1(b):

AmerenUE performed a containment walkdown surveillance in November 2002. The walkdown performed was consistent with the intent of the guidance given in Nuclear Energy Institute Report NEI 02-01 (Reference 2). However, AmerenUE recognizes the benefit of performing supplemental walkdowns to collect additional information that could be useful to support the analysis of the ECCS and CSS recirculation functions.

A containment coatings walkdown assessment will be performed using NEI 02-01 guidance to provide a current assessment of Callaway's comprehensive coatings program to support the analysis of the ECCS and CSS recirculation functions. This walkdown will be completed prior to restart from Callaway's fall 2005 refueling outage currently scheduled in November 2005.

A containment walkdownv assessment will be performed using NEI 02-01 guidance to provide a current assessment of dirt, dust and lint to support the 'analysis of the impact of this debris source on post-accident sump performance. This walkdown will be completed prior to restart from Callaway's fall 2005 refueling outage currently scheduled in November 2005.

References

1.

Pressurized Water Reactor Sump Performance Evaluation Methodology, NEI 04-07, Revision 0, Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C., December 2004

2.

Condition Assessment Guidelines: Debris Sources Inside PWR Containments, NEI 02-01, Revision 1, Nuclear Energy Institute, 1776 I Street N. W., Suite 400, Washington D.C., September 2002

ULNRC-05124 1 Page lof 1 LIST OF COMMITMENTS The following table identifies those actions committed to by AmerenUE in this document. Any other statements in this document are provided for information purposes and are not considered commitments. Please direct questions regarding these commitments to Mr. David E. Shafer at (314) 554-3104.

COMMITMENT Due Date/Event

1. AmerenUE will provide Part 2 of the information September 01, 2005.

requested in Generic Letter 2004-02 to the NRC.

2. AmerenUE will perform an analysis of the susceptibility of September 01, 2005.

the Emergency Core Cooling System and Containment Spray System recirculation functions to the adverse effects of post-accident debris blockage and operation with debris-laden fluids.

3. AmerenUE will perform a containment coatings walkdown Prior to restart from assessment using NEI 02-01 guidance to provide a current Callaway's fall 2005 assessment of Callaway's comprehensive coatings refueling outage program to support the analysis of the ECCS and CSS currently scheduled in recirculation functions.

November 2005.

4. AmerenUE will perform a containment walkdown Prior to restart from assessment using NEI 02-01 guidance to collect Callaway's fall 2005 information on dirt, dust and lint to support the analysis of refueling outage the impact of this debris source on post-accident sump currently scheduled in performance.

November 2005.